Privacy Charter

Part A — Intelematics’ Personal Information Handling Practices

The following words have the meaning as listed beside them

  • We, us, our – means Intelematics Australia Pty Ltd.
  • You, your, yourself, individual, customer, consumer – means an individual but not a company or commercial organisation.
  • Third party means an authorised organisation we may deal with from time to time.
  • Employee – means an individual directly employed by Intelematics Australia.
  • Applicant Files – records on candidates for employment with Intelematics Australia.

Our obligations under the Privacy Act

This privacy policy sets out how we comply with our obligations under the Privacy Act (Privacy Act). We are bound by the Australian Privacy Principles (APPs) in the Privacy Act which regulate how we may collect, use, disclose and store personal information, and how you may access and correct personal information held about you.

In this privacy policy, ‘personal information’ has the same meaning as defined in the Privacy Act, which is –‘ Information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion’.

Collection

It is our usual practice to collect personal information directly from the individual or their authorised representative.

We also collect personal information on behalf of a third party where we are providing products or services for that third party, for example where we manage and operate a telematics program on behalf of a car company or motoring club.  In this case your agreement/contract will be with the provider of the product or service and you will be covered under their privacy policy.  While we hold your data as an agent for your provider we will always abide by the Australian Privacy Principles with regard to your data.  In the first instance the responsibility for this data, and any enquiries relating to that data or its use should be referred to your product or service provider.

Sometimes we collect personal information from a third party, but only if the individual has consented to such collection or would reasonably expect us to collect their personal information in this way, or if it is necessary for a specific purpose.

In limited circumstances we may receive personal information about individuals from third parties who contact us and supply us with the personal information of others in the documents they provide to us.

Intelematics collects many kinds of information in order to operate effectively and provide you the best products, services and experiences we can.

We collect information when you activate, sign in and use our web or online sites, products and services. We may also be supplied with information from other companies we work with in delivering services to you.

We collect this information in a variety of ways, including from web forms, technologies like cookies, web logging and software on your computer or other device including from products and services we provide to you or are provided to you via a third party.

We only collect personal information for purposes which are directly related to our functions or activities as defined in the Service Subscription Agreement or Terms and Conditions agreed to by you, and only when it is necessary for or directly related to such purposes. We also collect personal information related to employment services, human resource management, and other corporate service functions.

These purposes are listed below.

Administrative activities:

  • when we process customer and consumer enquiries
  • when we manage the personnel and corporate service functions of Intelematics.

 

For more detailed information about these purposes and the information handling practices that apply to them, see Part B – Files.

We also collect personal information (including contact details) as part of our normal communication processes directly related to those purposes, including:

  • when you email us
  • when you telephone us
  • when you provide us with your business card or other material that contains your personal details.

Use and disclosure

We only use your personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities, and we do not give it to other government agencies, organisations or anyone else unless one of the following applies:

  • you have consented
  • you would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies
  • it is otherwise required or authorised by law

 

In the rare event that Intelematics is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors Intelematics will only do so in accordance with the Privacy Act or any other relevant Australian legislation.

Disclosing your personal information overseas

We do not disclose your personal information to third parties overseas.

Sharing non-personal information

We may share non-personal, aggregate, or summary information about you with our business partners or other third parties.

Location – Based Services

To provide location based services through the Connected Mobility Service and App as well as other Intelelmatics products and services, Intelematics and its partners and licensees may collect, monitor, store, use and share location data, including the real-time geographic location of your Smartphone and/or your vehicle. This location data is used by us, our partners and licensees to provide and improve location based features and services.

Data quality

We take steps to ensure that the personal information we collect is accurate, up to date and complete. These steps include maintaining and updating personal information when we are advised by individuals that their personal information has changed, and at other times as necessary.

Data security

We take steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure, and against other misuse. These steps include password protection for accessing our electronic IT systems, paper files in locked cabinets and physical access restrictions.

When no longer required, personal information is destroyed in a secure manner, or deleted according to the Intelematics Records Disposal Policy.

Access and correction

If you request access to your personal information that we hold about you, or request that we change your personal information, we will allow access or make the changes unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make the changes.

If we do not agree to provide access to your personal information or to amend or annotate the information we hold about you, you may seek a review of our decision.

If we do not agree to make requested changes to your personal information you may make a statement about the requested changes and we will attach this to your record.

You can obtain further information about how to request access or changes to the information we hold about you by contacting us (see details below).

How to complain about a possible breach of privacy

If you believe that we have breached your privacy or if you have any questions or concerns in relation to this privacy policy, you can contact us using the details below:

Telephone

03 8415 9000 (or from outside Australia +61 3 8415 9000)

Post

250 Swan Street, Richmond, VIC, 3121

Facsimile

+61 3 8415 9001

Email

privacymanager@intelematics.com

We will promptly acknowledge your complaint and provide a complaint form for you to complete and return to us. We will then investigate your complaint and determine the steps we will undertake to resolve your complaint within a reasonable time. We will contact you if we require any further information and will provide you with our determination once it is made. If you are unhappy with our determination you can take the matter to the Information Commissioner. Further information about the complaints to the Information Commission can be found here: http://www.oaic.gov.au/privacy/privacy-complaints.

Part B — Files: how we handle specific types of files that contain personal information

Telematics – Safety and Security Services

Purpose

We collect personal information to enable us to deliver the services outlined in the Service Subscription Agreement and we are bound by the Terms and Conditions accepted by you (the Services).

We collect personal information from telephone and written enquiries we receive relating to the Services. We also collect personal information from third parties where the individual would reasonably expect, or has been told, that information of that kind is usually passed on by those individuals, bodies or agencies.

We collect personal information from customer feedback and complaints to enable us to assess, make preliminary enquiries, investigate, conciliate or determine these complaints. We use that personal information to ensure that we are accountable for the way we handle those matters.

Collection

We collect personal information directly from you as our customer, or your authorised representatives.

We may also collect personal information about you from third parties, when it is relevant to the delivery of the Services.

Information held

Your personal information held by us includes your name, authorised driver name(s), addresses and telephone numbers provided by you when you activate the Services and when you request that your personal information be updated.

Your telematics-enabled vehicle will provide us with the vehicle location, vehicle alarm monitoring status and some vehicle diagnostic information as and when the Services are delivered.  This information received from the vehicle is directly associated with you, whilst you maintain your subscription for the Services.

Other information volunteered by you that specifically relates to delivery of the Services is also recorded in your service history.

Use and disclosure

We only use the personal information we collect to carry out delivery of the Services or customer enquiries.

We may use your personal information to make contact with you and any other relevant third party.

We will only provide your personal information to other organisations that are directly associated with providing the Intelematics services and that we consider you would reasonably expect would be provided in allowing the service to be delivered. We will not disclose any further information unless we are required by law to do so or if the disclosure will prevent or lessen a serious and imminent threat to somebody’s life or health.

Data quality

We maintain and update your personal information that we hold as necessary or when we are advised by you that your personal information has changed.

Data security

The personal information collected is held in electronic databases. Some personal information is also held in paper files.

The following staff members have access to the electronic databases and paper files on a need to know basis:

  • Finance Staff
  • Operational Staff
  • IT Staff
  • Call Centre Agents

 

When no longer required, your personal information in paper files is destroyed, in a secure manner, in accordance with Intelematics Records Disposal Policy.

Personal information stored in our electronic databases, when no longer required, is deleted in a secure manner. The databases maintain audit trails whenever personal information is accessed, included, amended or deleted on the database.

Access and correction

For information about how to access or correct your personal information held in your files see ‘Access and correction’ in Part A of this document.

Telematics – Connected Vehicle

Purpose

We collect personal information to enable us to:

Deliver the services outlined in and bound by the Terms and Conditions accepted by you (the Services).

Collection

It is our usual practice to collect personal information directly from you or from the companies for which we act as an authorised service provider.

Information held

Your personal information held by us includes your name and email address provided by you when you activate the Services and when you request that your personal information be updated.

Your connected vehicle or Smartphone may provide us with your location, trip logs and some vehicle diagnostic information as and when the Services are delivered.  This information received from the vehicle is directly associated with you, whilst you maintain your subscription for the Services.

Use and disclosure

We only use your personal information for the purposes of delivering the Services.

The personal information is not disclosed to other agencies, organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to those agencies, organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data quality

We maintain and update the personal information we hold as necessary or when we are advised by you that your personal information has changed.

Data security

Personal information stored in our electronic databases, when no longer required, is deleted in a secure manner. The databases maintain audit trails whenever personal information is accessed, included, amended or deleted on the database.

The following staff members have access to personal information on a need to know basis:

  • Finance Staff
  • Operational Staff
  • IT Staff

Access and correction

For information about how to access or correct your personal information in  our files see ‘Access and correction’ in Part A of this document.

General Enquiries Database

Purpose

The purpose of our general enquiries database is to store the details of enquiries from consumers and the general public that relate to our functions to:

  • provide information as requested
  • identify trends relating to enquiries

 

The limited personal information in our general enquiries database relates to correspondence and requests from people with an enquiry concerning the services provided by Intelematics.

Collection

We collect personal information in our general enquiries database directly from individuals using our websites or contacting Intelematics by e-mail, telephone or other means.

Use and disclosure

Your personal information in general enquiries database is only used for the purpose of responding to general enquiries and analysing enquiry trends.

The personal information in the general enquiries database is not disclosed to other agencies, organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to those agencies, organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data quality

We maintain and update personal information in our general enquiries database as necessary or when we are advised by you that your personal information has changed.

Data security

Your personal information stored in our electronic databases, when no longer required, is deleted in a secure manner. The databases maintain audit trails whenever personal information is accessed, included, amended or deleted on the database.

The following staff members have access to policy files on a need to know basis:

  • All Intelematics Staff

Access and correction

For information about how to access or correct personal information in our general enquiries database see ‘Access and correction’ in Part A of this document.

Administrative Files

Purpose

The purpose of employee personnel records is to maintain current employee information for business and employment related purposes, or where authorised or required by law. The personal information in these files relates to the employee and may include:

  • Application(s) for employment including the employee’s résumé(s), statement(s) addressing the criteria and referee reports
  • Written tasks undertaken by the employee during the selection process
  • Notes from the selection committee during the selection process
  • The employee’s employment contract, and other records relating to their terms and conditions of employment
  • Details of financial and other personal interests supplied by some employees and their immediate family members for the purpose of managing perceived or potential conflicts of interest
  • a national criminal record check
  • a personal name search of the civil debt databases
  • an Australian Security Investment Commission (ASIC) personal name search
  • Proof of Australian citizenship
  • Certified copies of academic qualifications
  • Records relating to the employee’s salary, benefits and leave
  • Medical certificates or health related information supplied by an employee or their medical practitioner
  • Contact details of employees and their emergency contact
  • Taxation details
  • Superannuation contributions
  • Information relating to the employee’s training and development
  • Information relating to the employee’s Performance Plan and Review process

 

The purpose of keeping records on candidates for employment (“applicant files”) is to allow us to assess the suitability of candidates for employment with Intelematics. Information that we hold may include:

  • Application(s) for employment including the employee’s cover letter(s), résumé(s), statement(s) addressing the criteria and referee reports
  • Written tasks undertaken by the employee during the selection process
  • Notes from the selection panel during the selection process
  • Contact details.

 

Intelematics may also keep applicant files for a period of 6 months to cover situations where the position is not successfully filled initially.  With your consent your application may be held for future vacancies (eligibility lists).

Collection

Intelematics generally collect personal information directly from employees and applicants but may also collect personal information from intermediaries such as recruitment agents and personnel providers.

Intelematics may also collect personal information about employees and applicants from third parties when it is relevant to the selection process.

Use and disclosure

Personal information in personnel files is only used for the purpose of maintaining current employee data and information for business and employment related purposes.

We only use personal information in applicant files for the purpose of assessing and processing applications for employment and other employment related matters such as future promotion or training requirements.

We do not give personal information held in these files to other agencies, organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to those agencies, organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data quality

Intelematics maintain and update personal information in our personnel and applicant files as necessary, or when we are advised by individuals that their personal information has changed.

Data security

Intelematics will take all reasonable steps to ensure that all personnel or application files in its possession or control are protected against loss, unauthorised access, misuse, disclosure or modification and that only authorised employees have access to such material.

Personnel files are stored in locked cabinets in paper form. Previous employee files are archived in boxes and stored in a locked compactus. Personal information relating to payroll is stored in a secure database or in a locked cabinet.

Employee payroll related files are filed and stored on password protected electronic media or in a locked  and secure cabinet. These employee payroll files are stored for 7 years and then destroyed in a secure manner or deleted in accordance with the Australian Taxation Office (ATO).

The following staff members have access to personnel and applicant files on a need to know basis:

  • Office Manager
  • Senior Management Team
  • Payroll, Accounting and HR

Access and correction

For information about how to access or correct personal information in administrative files see ‘Access and correction’ in Part A of this document.

Part C — Information collected online by Intelematics Australia

Collection

It is our usual practice to collect information about all visitors to our online resources. That information is very limited and only used to identify generic behavioural patterns.

There are several methods and packages that we use to collect visitor behaviours on each of our online platforms. We use Google Analytics on our websites. Information and data collected through Google Analytics is stored by Google on servers in the United States of America, Belgium and Finland and other countries as notified by Google from time to time. You can opt out of the collection of information via Google Analytics by downloading the Google Analytics Opt-out browser add on.

When you visit any of our online resources, our metric tools may collect the following information about your visit for statistical purposes:

  • server address
  • top level domain name (for example .com, .gov, .au, .uk etc.)
  • the date and time of your visit to the site
  • the pages you accessed and documents downloaded during your visit
  • the previous site you visited
  • if you’ve visited our site before
  • the type of browser used.

 

We record this data to maintain our server and improve our services. We do not use this information to personally identify anyone.

Cookies

Most of our online platforms use sessions and cookies. The core functionality on these platforms will be largely unaffected if you disable cookies in your browser but you may be unable to access some advanced functions.

Use and disclosure

We do not give personal information collected online to other agencies, organisations or anyone else without consent unless you would reasonably expect, or have been told, that information of that kind is usually passed to those agencies, organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data quality

We will delete or correct any personal information that we hold about you on request.

If you are on one of our automated email lists, you may opt out of further contact from us by clicking the ‘unsubscribe’ link at the bottom of the email.

Data security

There are inherent risks in transmitting information across the internet and we do not have the ability to control the security of information collected and stored on third party platforms. In relation to our own servers, we take all reasonable steps to manage data stored on our servers to ensure data security.

Access and correction

For information about how to access or correct your personal information collected on our website see ‘Access and correction’ in Part A of this document.