Sales Marketing and Real Technologies – SMART Pty Ltd and subsidiary companies (The SMART Group) operates as a sales and marketing company that collects personal information on behalf of various organisations (SMART’s clients) to promote and sell their products and services.
The SMART Group recognises personal information as a key asset of the organisation and is committed to the safeguard of personal information to ensure its privacy, integrity and confidentiality is secure and managed at all times. The protection and security of personal information forms an integral part of the way The Smart Group does business.
The SMART Group is required to comply with the Privacy Act and the Australian Privacy Principles (APPs).
The SMART Group identifies its personal information management requirements and implements the required policies, processes, management procedures, systems and infrastructure to ensure the privacy, integrity and security of personal information.
The SMART Group only collects and retains personal information that is necessary for the performance of SMART’s business activities to fulfil its obligations.
The SMART Group officers, employees, agents and all other representatives must at all times, strictly comply with all personal information privacy requirements when collecting, using, disclosing, storing and accessing personal information.
Types of Personal Information Collected and Retained
Personal information includes but is not limited to:
- Personal identification information: eg. name, address, date of birth, email, telephone and facsimile number
- Profession, occupation or job title
- Details of products and services purchased from SMART or its clients and or information previously provided to SMART
- Credit card and bank account details
- Details of credit worthiness and credit history
Information may also be collected that is not personal information as it does not identify an individual.
How Personal Information is Collected and Retained
The SMART Group collects personal information only through lawful and consensual means. Personal information is collected directly from the individual unless the individual consents to collection from another individual, it is unreasonable or impracticable to do so or required by Australian law.
The SMART Group collects personal information through a number of means including:
- During face to face or telephone conversations between the individual and SMART’s representatives
- During correspondence between the individual and SMART’s representatives including electronic correspondence
- When the individual completes an application or contract
As SMART operates as an outsource service provider, a large amount of the personal information SMART collects and retains is performed when SMART is acting as the agent or service provider on behalf of SMART’s clients. Personal information may also be provided to SMART by SMART’s clients to promote and sell their products and services.
Personal information is collected by SMART contact centre sales agents and field sales agents.
The SMART Group does not hold or store credit card and bank account information. When collected, the information is passed directly through to SMART’s clients systems. Stop/start processes are in place to ensure any credit or bank account information collected as part of telephone conversations is not recorded.
The SMART Group operates a formalised quality assurance system and feedback process to ensure all personal information directly collected by SMART has been obtained lawfully, fairly, with consent and with the required disclosure statements regarding the intended use of the personal information collected.
The SMART Group collects personal information from third parties that are not clients of SMART including data providers, brokers, credit reporting bodies, law enforcement agencies and other government entities.
Personal Information Is Not Provided
If the individual does not provide the personal information necessary for SMART to perform its business activities, this may cause:
- SMART may not be able to provide the requested products and services, either to the same standard or at all
- SMART may not be able to provide the individual with information about products and services that the individual requests including information regarding discounts, sales or special promotions
- Contractors may not be able to provide services to SMART
Personal Information Security
The SMART Group’s Information Security Policy defines SMART’s commitment and approach to ensure personal information is protected from misuse, interference, loss and from unauthorised access, modification and disclosure.
SMART retains personal information in both electronic and hard copy form. SMARTs Information Security Policy, Information Management Policy and SMART’s information security and management activities includes information asset disposal processes to ensure personal information is disposed securely and safely when no longer required. SMART securely archives or destroys personal information when services are ceased and no longer provided to the client. Personal information is stored in accordance with regulatory requirements.
Disclosure of Personal Information
The SMART Group does not disclosure personal information other than for the primary purpose of performing the organisations business activities of fulfilling its marketing and service obligations to its clients and to administer the sale or complete the application process.
Personal information is not disclosed for activities outside SMART’s business activities without the individuals consent unless required by law or exception to disclose conditions as defined in the APPs.
An individual’s personal information is disclosed to the individual on request unless prevented by law or exception to disclosure conditions as defined in the APPs.
Integrity of Personal Information
The SMART Group’s Information Security Policy, Information Management Policy and information management process provide reasonable assurance personal information collected and stored by SMART is accurate, up-to-date, complete and relevant.
Individuals are able to submit requests to SMART for changes to their personal information. The SMART Group assesses correction for personal information requests and responds in accordance with the requirements of the Privacy Act and the APPs.
The SMART Group maintains a formalised Complaints Management Policy and complaints management process to enable its ongoing commitment to the protection and security of personal information.
Complaints regarding breaches to the Privacy Act or APPs are required to be made in writing to The SMART Group by the individual impacted by the privacy breach. The SMART Group complaints management process requires the investigation and response to breach of privacy complaints in the manner and format described in the complaints management process.
Escalation processes are in place to ensure appropriate SMART management attention and response to breach of privacy complaints.
The SMART Group’s Compliance Officer is the assigned company officer responsible for the oversight and management of personal information privacy across the organisation.
The Compliance Officers contact details are:
Telephone: 1300 654 261
Postal Address: The Compliance Officer
Level 6, 324 St Kilda Road
Southbank, Vic 3006