“Walker”, “we” or “us” means Walker Corporation Pty Ltd (ACN 001 176 263) as well as each of its related entities incorporated in Australia and all trusts for which any of those related entities acts as trustee.
Your Privacy is Important to Us
Walker has always valued the privacy of personal information. We are bound by the Privacy Act 1988 (as amended from time to time) (the “Privacy Act”), the Australian Privacy Principles (the “APPs”) and the privacy provisions of other applicable legislation. The Privacy Act and the APPs set out standards to be met in the collection, use, disclosure and handling of personal information. It is designed to protect the privacy of individuals by regulating the way personal information is managed.
The Privacy Act defines “personal information” as information or an opinion about an identifiable individual, or an individual who is reasonably identifiable:
- a) whether that information or opinion is true or not; and
- b) whether the information or opinion is recorded in a material form or not.
This policy outlines how we manage the personal information we collect, hold, use and disclose. Any personal information collected by us is covered by this policy and it applies to all of our divisions and organisations, including our trading and business entities.
What Kind of Personal Information Do We Collect?
We may collect and hold personal information about:
- respective and prospective customers, clients, tenants and suppliers;
- job applicants, employees, and contractors; and
- other people who may come into contact with Walker Corporation or one of its associated companies within the group.
The type of personal information we may collect and hold includes (but is not limited to):
- your name;
- your address;
- your telephone number;
- your email address; and
- how you heard about a Walker project.
This information may be obtained by way of telephone, Internet enquiries or forms filled out by such individuals, face to face meetings, interviews, and telephone conversations, either from the relevant individual or from a third party (providing that the third party has permission to disclose the information to us in this way).
We may ask for other information voluntarily from time to time (for example, through market research or surveys) to enable us to improve our service or consider the wider needs of our customers or potential customers.
How Do We Hold and Use Personal Information?
We hold personal information in a combination of secure computer storage facilities (including online) and paper based files and other records.
The purposes for which we collect, hold, use and disclose personal information are:
- to understand and meet your needs and provide the services and products our group of companies may offer;
- to be able to develop and identify projects and services that may interest people;
- to conduct market or customer satisfaction research;
- to develop, establish and administer alliances and other arrangements with other organisations in relation to promotion, administration and use of our respective products and services;
- to market our property developments to existing and potential clients;
- to provide products or services that have been requested;
- to help us manage and enhance our products and services, including by analysing future customer needs;
- to communicate with clients and potential customers;
- to assess the suitability of prospective tenants and buyers of property;
- to provide ongoing information about our products and services to people that we believe may be interested;
- to comply with legal obligations; and
- to recruit employees and contractors.
To Whom May Personal Information Be Disclosed?
We may disclose your personal information with your consent, for the purposes for which that information was collected or related purposes which are reasonable to expect, or where compelled by law.
Additionally, in the course of our business, we may disclose your personal information to:
- real estate agents who assist in us in providing services to you;
- other divisions or organisations within our company group;
- joint venture/alliance partners who may wish to communicate with you about their services, products or promotional opportunities which may be of advantage to you, unless you tell us not to;
- service providers and specialist advisers who have been contracted to provide administrative, financial, research or other services to us;
- insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
- credit reporting, reference agencies or insurance investigators; or
- anyone authorised by you.
We require that organisations outside Walker that handle or obtain your personal information as service providers to us comply with the APPs and this policy. We also require that these organisations use your personal information only for our purposes and otherwise follow our reasonable directions with respect to that information.
You do not need to provide us with your personal information if you do not want to, and you can choose to interact with us on an anonymous basis. However, in some cases, if you do not provide the personal information requested, we or those involved with the provision of the service or product may not be able to provide the appropriate type or level of service or product you require.
Sensitive Information is Subject to Greater Restrictions
Some personal information that we collect may be ‘sensitive’. Sensitive information includes a person’s racial or ethnic origin, religion, membership of political bodies or trade unions, sexual preferences or activities, criminal record and health information.
The way we use tax file numbers and information received from a credit reporting agency about an individual is also restricted by law.
Sensitive information, specifically health information, may be relevant to applications by prospective employees and while consent will be sought before this is obtained, we may not be able to adequately assess candidates’ suitability for some positions without this information.
The APPs require that sensitive information is used and disclosed only for the purposes for which it is provided, or directly related secondary purpose, unless the relevant individual agrees otherwise or for other specific reasons such as if the use of disclosure of this information is required by law (for example, to prevent a crime or serious injury).
Management of Personal Information
We have appointed a National Privacy Compliance Officer to oversee our management of personal information in accordance with this policy and the Privacy Act.
Security and Storage of Your Personal Information
Safeguarding the privacy of your personal information is important to us and we endeavour to protect any personal information whether people interact with us personally, by telephone, mail, over the Internet or other electronic media. We take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. Some of the ways we achieve this are:
- confidentiality requirements on our employees;
- policies on document storage security;
- security measures for access to our systems;
- only providing access once proper identification has been given;
- controlling access to our premises; and
- website protection measures.
The APPs also require us not to store personal information longer than necessary. Where we no longer require any personal information that we hold, that personal information is destroyed or details which may identify individuals to be removed.
What We Expect of You
When you provide us with personal information about other individuals, we rely on you to make them aware that you will or may provide their information to us, the types of third parties we may disclose to it, the relevant purposes we and the third parties we disclose it to will use it for, and how they can access it (as described in this document). If it is sensitive information we rely on you to have obtained consent to the above. If you have not done either of these things, you must tell us before you provide the relevant information.
If you collect, use disclose or handle personal information on our behalf or receive it from us, you and your representatives must meet the relevant requirements of the APPs and the Privacy Act and only use and disclose it for the purposes we agree to.
How Do We Keep Personal Information Accurate and Up-To-Date?
We will take reasonable steps to ensure that your personal information is accurate, complete and up to date whenever we collect, disclose or use it. However, we encourage you to contact us as soon as possible when there are changes in your contact details and personal circumstances. Our contact details are set out below.
Even if you do not contact us to correct your personal information, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.
You Have the Right to Access the Personal Information About You Held By Us
Under the APPs, you have the right to access any personal information which we hold about you and to advise us of any perceived inaccuracy. The exceptions under the APPs which affect your right to access your personal information we hold about you include:
- access would pose a serious threat to the life or health of any individual;
- access would have an unreasonable impact on the privacy of others;
- a frivolous or vexatious request;
- the information relates to commercially sensitive decision making process;
- access would be unlawful or denying access is required or authorised by law;
- access would be prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function, or negotiations with the individual; and
- the information relates to legal dispute resolution proceedings.
If we refuse you access to your personal information, we will let you know the reasons for our refusal in writing.
To make a request to access personal information we hold about you, please contact us in writing using the contact details below. We will require you to verify your identity and to specify what information you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
What If You Have a Complaint?
How to Contact Us
To contact us about a privacy related issue by e-mail, phone, facsimile or post:
Attention: National Privacy Compliance Officer
Phone: (02) 8273 9600
Facsimile: (02) 9252 7400
Postal Address: GPO Box 4073, Sydney, NSW, 2001
Updates to this Policy