Our Privacy Policy

People First -Total Solutions takes very seriously your right to privacy. This document sets out our current Privacy Policy:

1.0 Collection of Personal Information
1.1 People First -Total Solutions will only collect Personal Information where the information is necessary for People First -Total Solutions to perform one or more of its functions or activities. In this context, by “collect” we mean to gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 People First -Total Solutions collects Personal Information primarily to supply clients with the products and services ordered from us. People First -Total Solutions also collects and uses Personal Information for secondary purposes including:

• billing and account management
• business planning and product development; and
• to provide individuals with information about promotions, as well as the products and services of OzVPM and other organisations.

1.3 People First -Total Solutions will notify individuals (including, but not limited to, our clients) of the matters listed below before collecting any Personal Information:
the main reason that we are collecting Personal Information (this reason will be the Primary Purpose; other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes):

• our identity and how individuals, organisations or companies can contact us
• that individuals can access the Personal Information that People First -Total Solutions holds about them
• that individuals should contact our privacy officer (even if they are not a client) if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information
• the organisations or types of organisations to whom we usually Disclose the Personal Information including Related bodies, partner organisations and contractors;
• where applicable, any law that requires Personal Information to be collected
• consequences (if any) for the individual if all or part of the Personal Information is not provided to People First Total Solutions.

1.4 Where it is not practicable for People First -Total Solutions to notify individuals of all of the Collection Information before the collection of Personal Information, People First -Total Solutions will ensure that individuals are notified of the Collection Information as soon as possible after collection. People First -Total Solutions will only engage in “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.5 When collecting Personal Information over the telephone, it may not always be practicable to provide all the Collection Information at that time. In such circumstances, we will provide the individual with People First Total Solutions contact details, and then provide the balance of the Collection Information in a confirming letter.
1.6 People First -Total Solutions will not collect Sensitive Information from individuals except with consent and only where it is necessary for People First -Total Solutions to collect such information for an activity or function.
1.7 People First -Total Solutions will not collect Personal Information secretly or in an underhanded way.
1.8 People First -Total Solutions will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.

2.0 Use of Personal Information
2.1 People First -Total Solutions will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose that would be within the relevant individual’s Reasonable Expectations.
2.2 People First -Total Solutions Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 In circumstances where we utilise direct marketing, People First -Total Solutions will ensure that:

• the individual is clearly notified of their right to opt out from any further direct marketing
• there is only one use of the information before the opt out right is provided
• the individual is given an opt out in all further instances of Direct Marketing if they have not previously chosen to opt out; and
• if the individual opts out of all Direct Marketing the opt out will be respected by People First -Total Solutions and all of its partners and related bodies.

2.4 People First -Total Solutions will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.5 People First -Total Solutions will not use Sensitive Information for Direct Marketing.
2.6 People First -Total Solutions may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities
2.7 People First -Total Solutions will not attempt to match de-identified or anonymous data collected through surveys or such on-line devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.

3.0 Disclosure of Personal Information
3.1 People First -Total Solutions may disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual’s consent for Disclosures made under the credit reporting requirements of the Privacy Act 1988. If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or up-front consent has not been obtained, People First -Total Solutions will not disclose Personal Information otherwise than in accordance with the exceptions set out at 3.2 to 3.6 below.
3.2 People First -Total Solutions may disclose Personal Information between partners and related bodies. In such cases, the related body Corporate or partner is bound by the original Primary Purpose for which the information was collected.
3.3 People First -Total Solutions may disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as accounting and billing), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations. Individuals will be notified of People First -Total Solutions usual disclosures via the Collection Information, as outlined in 1.3.
3.4 People First -Total Solutions will take all reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act 1988.
3.5 People First -Total Solutions may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 People First -Total Solutions may disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.7 People First -Total Solutions does not sell or share its client lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, People First -Total Solutions will take steps to ensure (by contract) that the use of its client list by third parties does not exceed the scope of the consent.


4.0 Quality of Collected Information
4.1 People First -Total Solutions will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 People First -Total Solutions will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires us to do otherwise.

5.0 Security of Personal Information
5.1 People First -Total Solutions requires all staff and contractors to perform their duties in a manner that is consistent with our privacy responsibilities
5.2 People First -Total Solutions will take all reasonable steps to ensure that paper and electronic records containing Personal Information are protected and accessed by staff and contractors who actually “need to know”
5.3 People First -Total Solutions will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved, improved and maintained.

6.0 Access to and Correction of Personal Information
6.1 People First -Total Solutions will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act 1988.
6.2 People First -Total Solutions will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act 1988.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting People First -Total Solutions Privacy Officer, as per the details below.
6.4 People First -Total Solutions will not charge any fees for processing an access request unless the request is complex or is resource intensive.

7.0 Openness
7.1 Individuals wishing to make an inquiry or complaint regarding privacy or requesting a copy of this Privacy Policy, should do so by contacting People First -Total Solutions Privacy Officer as per the details below
7.2 Privacy complaints will be managed according to People First -Total Solutions standard complaint handling procedures which require a response within 21 days
7.3 The People First -Total Solutions website will contain a privacy statement and will include a copy of this People First -Total Solutions Privacy Policy.

8.0 Anonymous Transactions
8.1 People First -Total Solutions will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. People First -Total Solutions may however request visitors to provide Personal Information voluntarily to People First -Total Solutions (for example, as part of a competition, survey or questionnaire).
8.2 People First -Total Solutions will allow its clients to transact with it anonymously wherever that is reasonable and practicable.

9.0 Transborder Dataflows — sending personal information overseas
9.1 People First -Total Solutions will not send personal information to unrelated organisations overseas.
9.2 If Personal Information must be sent by People First -Total Solutions overseas for sound business reasons, People First -Total Solutions will ensure that the overseas organisation receiving the information is equipped to handle that information in accordance with the National Privacy Principles, preferably as part of a services contract People First -Total Solutions will sign with that organisation.

10.0 Glossary of Terms
Collection Information means the information outlined in 1.3 above notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of People First -Total Solutions or partner or related body or those of an independent third party organisation.

Disclosure generally means the release of information outside People First -Total Solutions, including under a contract to carry out a function which may be “outsourced”.

Health Information means:
1. information or an opinion about:

• the health or a disability (at any time) of an individual; or
• an individual’s expressed wishes about the future provision of health services to him or her; or
• a health service provided or to be provided to an individual; that is also personal information; or

2. other personal information collected to provide or in providing a health service; or
3. other personal information about an individual collected in connection with the donation; or intended donation by the individual of his or her body parts or body substances.

Opt out means an individual’s expressed request not to receive further Direct Marketing.


Personal information is information or an opinion that identifies an individual or allows their identity to be readily worked out from the information. It includes information such as a person’s name, address, financial information, marital status or billing details. Some personal information is sensitive information. This includes information about ethnicity, religion and health. Sensitive information is explained further in the Glossary of Terms

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation: means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.

Sensitive Information is a subset of personal information and special rules apply to the handling of sensitive information. It is information or opinion about a person and includes:

• racial or ethnic origin
• political opinions;
• membership of a political association;
• religious beliefs or affiliations;
• philosophical beliefs;
• membership of a professional or trade association;
• membership of a trade union;
• sexual preferences or practices;
• criminal record or
• health information about an individual.
  

Trading in personal information - Trading in personal information happens where businesses collect or disclose an individual’s personal information for a “benefit, service or advantage”(see above), for example they buy or sell a list of personal information for income, concessions or some other return. The Act does not prevent trading in personal information but does set principles that need to be followed.

Use means the handling of Personal Information within People First -Total Solutions.


11.0 Contacting People First -Total Solutions
If you require further information regarding People First -Total Solutions Privacy Policy including wishing to make an inquiry or complaint regarding privacy or requesting a copy of this Privacy Policy, you can contact People First -Total Solutions Privacy Officer at :

email: privacy@pfts.com.au
Mail: People First -Total Solutions, POBox 189, Flemington, Victoria, 3056. Australia

People First -Total Solutions complaints handling procedures require a response within 21 days.