Privacy Policy

About this policy

Purpose

The purpose of this privacy policy is to:

  • clearly communicate the personal information handling practices of R&W Noosa
  • enhance the transparency of R&W Noosa’s operations, and
  • give individuals a better and more complete understanding of the sort of personal information that R&W Noosa holds, and the way we handle that information.

Outline of this policy

‘Part A — Personal Information Handling Practices’ explains our general information handling practices across R&W Noosa including information about how we collect, use, disclose and store your personal information.

‘Part B — Files’ offers further detail by explaining our personal information handling practices in relation to specific R&W Noosa functions or activities. Here you can find out what sort of records we keep and why. You may find this section helpful if, for example, you have made an enquiry to R&W Noosa and wish to know how we manage our enquiries files.

‘Part C — Online’ explains our personal information handling practices when you visit our websites.

Part A — Our Personal Information Handling Practices

Noosa Resort Management Pty Ltd ACN 059 862 467 t/a Richardson & Wrench Noosa (‘R&W NOOSA’) treats any information received by you confidentially.

This privacy policy sets out how we comply with our obligations under the Privacy Act 1988 (Privacy Act). We are bound by the National Privacy Principles in the Privacy Act which regulate how we may collect, use, disclose and store personal information, and how individuals may access and correct personal information held about them.

In this privacy policy, ‘personal information’ has the same meaning as defined by section 6 of the Privacy Act:

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.

Sometimes we collect personal information from a third party or a publicly available source, 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 such as the investigation of a privacy complaint.

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

We only collect personal information for purposes which are directly related to our functions or activities under the Privacy Act, Freedom of Information Act 1982 (FOI Act) or the Australian Information Commissioner Act 2010 (AIC Act), 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.

Enquiries made by you to us:

When an individual contacts us asking for information or use of our services.

  • Property sales enquiry
  • Holiday booking enquiry
  • When an individual emails staff members
  • When an individual telephones us
  • When an individual text messages us
  • Contacts us via social media websites
  • When an individual hands us their business card.
  • To help us develop and identify products and services that may interest you;

Property inspections:

  • Open for inspections register.
  • Property maintenance.
  • To comply with legislative or regulatory requirements.

Administrative activities:

  • To process bookings and travel arrangements
  • To process deposits, accommodation and sundry charges
  • To collect deposit money under sale contracts;
  • To perform our internal administration and operations (including accounting, reporting, risk management, record keeping, systems development and testing and staff training);
  • To comply with legislative or regulatory requirements.

Complaint handling:

  • In a rare instance a complaint needs to be reviewed.

Contact list:

  • To inform of related functions or activities
  • When people ask to be on an email or mailing list so that the R&W Noosa can send them information about its activities, functions and publications

Use and disclosure

We only use 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 businesses, organisations or anyone else unless one of the following applies:

  • the individual has consented
  • the individual would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies
  • it is otherwise required or authorised by law
  • it will prevent or lessen a serious and imminent threat to somebody’s life or health
  • it is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.

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 systemecuring paper files in locked cabinets and physical access restrictions.

When no longer required, personal information is destroyed in a secure manner.
Personal information records will be shredded and electronic records will be securely deleted so that they can’t be retrieved.

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

 

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

Enquiries made by you to us:

Purpose

We collect personal information to enable us to:

  • respond to enquiries

We collect personal information from telephone and written enquiries we receive about our services to enable us to respond to those enquiries.

We collect personal information to help us develop and identify products and services that may interested you now or in the future.

Collection

We collect personal information from contact forms on our websites, emails, telephone enquiries, Open For Inspection (OFI) sheets and face to face directly from individuals or their agencies or organisations, or from publicly available sources such as websites or telephone directories.

Use and disclosure

We only use the personal information we collect to carry out our enquiries.

We may use the personal information we hold to make contact with the enquirer and any other relevant individual, agency or organisation.

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 individuals that their 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:

  • Sales agents
  • Sales assistants
  • Directors
  • IT staff
  • Records management staff
  • Property managers and assistants
  • Property maintenance staff
  • Bookings and reservations staff

When no longer required, personal information is destroyed in a secure manner.
Personal information records will be shredded and electronic records will be securely deleted so that they can’t be retrieved.

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

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

Property inspections:

Purpose

To maintain contact information about individuals who enter a property to comply with legislative or regulatory requirements.

Collection

We collect and maintain personal information from individuals who enter a property we open for inspection via registration forms.  Individuals are required to enter their personal details such as; Name, Address, Email and Telephone Number. We will also collect this personal information from individuals performing maintenance or similar reasons that require an individual to enter a property.

Use and disclosure

We only use the personal information we collect to inform individuals of R&W Noosa activities and functions.

We may use the personal information we hold to make contact with the enquirer and any other relevant individual, agency or organisation.

If the individual has given consent we will use their contact information to inform them of R&W Noosa activities and functions.

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 individuals that their 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:

  • Sales agents
  • Sales assistants
  • Directors
  • IT staff
  • Records management staff
  • Property managers and assistants
  • Property maintenance staff
  • Bookings and reservations staff

When no longer required, personal information is destroyed in a secure manner.
Personal information records will be shredded and electronic records will be securely deleted so that they can’t be retrieved.

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

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

Administrative Activities:

Purpose

To maintain contact information for the following purposes:

  • To process bookings and travel arrangements
  • To process deposits, accommodation and sundry charges
  • To collect deposit money under sale contracts;
  • To process funds from vendors for maintenance and marketing
  • To perform our internal administration and operations (including accounting, reporting, risk management, record keeping, systems development and testing and staff training);
  • To comply with legislative or regulatory requirements.

Collection

We collect personal information from contact forms on our websites, emails, telephone enquiries and face to face directly from individuals or their agencies or organisations, or from publicly available sources such as websites or telephone directories.

Credit card:
R&W NOOSA will take reasonable steps to protect credit card details it holds from misuse and loss and from unauthorized access, modification or disclosure. R&W NOOSA will ensure that where credit card details are collected via facsimile, in person or manual imprint, they are stored in a secure location. Credit card details will be destroyed in a secure manner when they are no longer needed by R&W Noosa. See ‘data security’ below.

Use and disclosure

We use this personal information we collect for the administrative purposes listed above.

We may use the personal information we hold to make contact with the client and any other relevant individual, agency or organisation.

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 individuals that their 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:

  • Sales agents
  • Sales assistants
  • Directors
  • IT staff
  • Records management staff
  • Property managers and assistants
  • Property maintenance staff
  • Bookings and reservations staff

When no longer required, personal information is destroyed in a secure manner.
Personal information records will be shredded and electronic records will be securely deleted so that they can’t be retrieved.

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

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

Complaint Handling:

Purpose

We collect personal information to enable us to:

  • respond to enquiries
  • assess, make preliminary enquiries, investigate and conciliate privacy and FOI complaints
  • make privacy determinations
  • conduct privacy and FOI own motion investigations
  • respond to FOI requests made to R&W Noosa about information it holds.

We collect personal information from telephone, text messages, email and written enquiries we receive about FOI , privacy, and information policy matters to enable us to respond to those enquiries. We also collect personal information to enable us to respond to FOI applications made to us.

We collect personal information in privacy and FOI 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.

We collect personal information to enable us to make determinations in some privacy complaints and in conducting investigations at the initiative of one of the Commissioners (own motion investigations)…

The personal information held is about applicants/complainants, respondents (including employees and contractors of respondents), witnesses, third parties and individuals reporting matters for investigation. The database or paper files may include personal information about individuals who are authorised to represent complainants or respondents, and about third parties who provide information in the course of our investigations. We may also collect the personal information of third parties to privacy complaints or merit review applications.

Collection

We collect personal information directly from applicants/complainants and respondents, or their authorised representatives.

We may also collect personal information about applicants/complainants and respondents from third parties, when it is relevant to auditing, complaint handling, and investigative work.

Use and disclosure

We only use the personal information we collect to carry out our enquiries, dispute resolution and regulatory work.

We may use the personal information we hold to make contact with the applicant/complainant, the respondent and any other relevant individual, agency or organisation.

For privacy complaints we will usually provide the complainant’s name and details about the complaint to the respondent, as we consider the complainant would be reasonably likely to be aware that this would happen. However, we give the complainant the opportunity to tell us if there are any parts of their complaint that they do not want us to disclose to the respondent. We will not disclose any such parts of the complaint to the respondent 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.

For FOI complaints we will usually give a copy of the complaint or application to the respondent and, where appropriate, an affected third party to a review.

If the information a complainant or applicant agrees to disclose to the respondent is too limited, we may not be able to proceed with the complaint because procedural fairness requires that we must provide the respondent with sufficient information to respond to the complaint in a meaningful way.

As we are obliged to conduct our investigations in private, we will only give personal information about a complaint to the media if the complainant and the respondent have consented, or if the complainant and the respondent have already made the information public. We may also disclose relevant personal information to the media if the media is the FOI applicant.

We may give information to other regulators or to enforcement bodies in the course of referring a complaint to that body or seeking its advice. We prefer to seek the consent of the individual to such disclosures, but may sometimes disclose without consent if we are authorised or required by law to disclose the information.

We may disclose personal information held in paper files or databases to another review body if a complainant seeks a review of R&W Noosa’s processes or decisions, for example by the Commonwealth Ombudsman, the Administrative Appeals Tribunal or under theAdministrative Decisions (Judicial Review) Act 1977.

Data quality

We maintain and update the personal information we hold as necessary or when we are advised by individuals that their 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:

  • Sales agents
  • Sales assistants
  • Directors
  • IT staff
  • Records management staff
  • Property managers and assistants
  • Property maintenance staff
  • Bookings and reservations staff

When no longer required, personal information is destroyed in a secure manner.
Personal information records will be shredded and electronic records will be securely deleted so that they can’t be retrieved.

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

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

Contacts Lists

Purpose

We maintain contacts lists which include contact information about individuals who may have an interest in our services such as property for sale, rental and holiday accommodation. We use these contacts lists to distribute information about our activities, functions and publications.

Collection

It is our usual practice to collect personal information in contacts lists directly from individuals, for example, where they have asked to be added to a contact list.

Sometimes we collect personal information from a third party or from a publicly available source such as a website or telephone directory. We usually only collect personal information in this way if the individual would reasonably expect us to, or has given their consent. For instance, we might collect this information if we thought that the individual (or the organisation they work for) would like to receive information about a property we offer for sale, permanent rental, holiday rental and property appraisals we are carrying out, or that they might be likely to consider information about our services useful in the work they do. We would only contact this individual in their work capacity.

Use and disclosure

We only use personal information in contacts lists for the purpose of managing public and stakeholder relations.

We do not give personal information about an individual 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.

R&W Noosa uses a number of online channels, including social networking services, to communicate with individuals and organisations with an interest in our services. The use of these services is governed by the online channel’s Terms and Conditions and Privacy Policies. Users may be required to supply some personal information such as name and email address to use these channels to communicate with R&W Noosa. Using these services to communicate with us may make some personal information visible to R&W Noosa and third parties.

Data quality

We maintain and update personal information in our contacts lists when we are advised by individuals that their personal information has changed. We also regularly audit contacts lists to check the currency of the contact information. We will remove contact information of individuals who advise us that they no longer wish to be contacted.

Data security

The personal information in the contacts lists is stored in either password protected electronic media or in locked cabinets in paper form.

When no longer required, personal information is destroyed in a secure manner.
Personal information records will be shredded and electronic records will be securely deleted so that they can’t be retrieved.

Routine access to contacts lists is limited to the database operators who have responsibility for maintaining the contacts lists. Other staff members have access to the personal information in contacts lists on a need to know basis.

Access and correction

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

Part C — Information collected online R&W Noosa

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.

Sometimes we use third party platforms to deliver information. These are sites hosted and managed by organisations other than ourselves. Before deciding if you want to contribute to any third party site you should read their privacy policy.

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. 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 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 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

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

If we do not agree to provide access to personal information or to amend or annotate the information we hold about them, the individual may seek a review of our decision or may appeal our decision under the FOI Act.

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

Individuals can obtain further information about how to request access or changes to the information we hold about them by contacting us via the details noted at the end of this document.

How to contact us:

Ph: 07 5447 4499
Fax: 07 5447 4510

Enquiry form – click here

Post:
PO Box 158
Noosa Heads, QLD 4567

Office Address:
23 Hastings Street
Noosa Heads, QLD

Please provide us with your full name, address and contact number when contacting us.