Updated February 2022
Divergent Insights Pty Ltd (39 657 225 431) (“Divergent Insights”) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au
The personal information we collect includes, but is not limited to:
Personal information for employment, customer and marketing purposes such as full name, postal address, phone and fax numbers and email addresses.
Personal information relating to a person’s business or professional capacities such as ABN/ACN, position, organisation, postal address, phone and fax numbers and email addresses.
Transactional information such as credit card details or bank details.
Personal information for Human Resources, Finance and general entity administration purposes for employees and contractors.
Personal information for the purpose of organising, inviting and holding an event with Divergent Insights or its related entities.
Third parties (we don’t guarantee website links or policy of authorised third parties).
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing. When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
How we collect personal information
Directly from the person and/or the company they represent that we are interacting with to provide advice, services, materials and/or resources, employment opportunities or company information. This information can be collected in hard copy forms, online or by email, post, facsimile, face to face, over the phone or through our reseller channel, including wholesalers and partners.
Enquiries made to external parties in order to provide advice, services, materials and/or resources, employment opportunities or company information, for example, reference checks for employment purposes.
From publicly available information.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
Third parties where you consent to the use or disclosure; and
Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
Divergent Insights will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Divergent Insights may, at its discretion, update or revise this Policy from time to time. Please check our website www.divergentinsights.com.au for the current version of this Policy.
How to access or correct your personal information or make a privacy complaint
Divergent Insights is transparent and accountable for the limited personal information that we collect and aim to maintain the accuracy and quality of this information. Should you wish to access or correct your personal information we hold, please contact Divergent Insights via email@example.com or +61 8 6364 5003. You may also use these contact details to notify us of a privacy complaint if you think we have failed to comply with our obligations under the Australian Privacy Principles. If a complaint is made, it will be thoroughly assessed in a timely manner and any breach will be rectified, where practicable and possible. All complaints will be taken seriously and will feed into continual processes for reviewing and improving privacy.