This policy covers Smartgroup Corporation Ltd and its related bodies corporate ("Smartgroup", "we" or "us"), including Smartgroup Benefits Pty Ltd, Smartfleet Management Pty Ltd, Smartsalary Pty Limited (including Smartleasing and Autogenie, which are registered trade marks of Smartsalary Pty Ltd), Smartequity Pty Ltd, PBI Benefit Solutions Pty Ltd, Smartsalary Software Solutions Pty Ltd, Health-e Workforce Solutions Pty Ltd, Salary Packaging Solutions Pty Ltd, Advantage AccessPay Pty Ltd, AccessPay Payroll Pty Ltd, AccessPay Pty Ltd, Smartsalary Payroll Solutions Pty Ltd, Salary Packaging Solutions Pty Ltd, Autopia Management Pty Ltd, Selectus Pty Ltd and ABM Corporation Pty Ltd (as updated from time to time).
We understand how important it is to protect your personal information. This policy sets out how Smartgroup collects, uses, discloses and holds personal information.
1. Collection of personal information
When we refer to personal information, we mean information about reasonably identifiable individuals. This may include information or an opinion about individuals, whether true or not.
The kinds of personal information we may collect about you include:
We may also collect additional information about you depending on the products and services provided:
We may collect your sensitive information only to the extent it is necessary to administer our products or services to you, to assess your application for employment or for employment purposes, and only with your consent. Sensitive information includes membership of professional or trade associations or unions, membership of a political association, or health information or and, in an employment context, your criminal history, racial or ethnic origin, religious beliefs and sexual orientation.
Where reasonable and practical we will collect your personal information directly from you, such as via application or enquiry forms or other documents that you submit to us; when you contact us via phone, email or our websites or social media accounts; when you attend one of our events; or when you submit a CV or application for employment to us. If you do not provide the information requested by us, we may not be able to provide you with our products or services or respond to your enquiry.
Depending on the product or service provided or your relationship with us, we may also collect your personal information from third parties, for example, from your employer, your employer's outgoing salary packaging service provider or your financial planner. If you are applying to work for us, we may collect personal information through recruitment companies, websites, other organisations and referees with your consent. We may also collect your personal information from our related bodies corporate, where we are permitted under law to do so or have otherwise obtained your consent.
2. Use of personal information
We use your personal information for the purpose for which it has been provided, reasonably related secondary purposes which are within the contemplation of the parties (and are directly related if the information is sensitive information), any other purpose you have consented to and any other purpose permitted under the Privacy Act 1988 (Cth). This may include using your personal information for the following purposes:
and for any other purpose related to or ancillary to any of the above.
3. Disclosure of personal information
We disclose your personal information for the purpose for which it has been provided, reasonably related secondary purposes which are within the contemplation of the parties (and are directly related if the information is sensitive information), any other purpose you have consented to and any other purpose permitted under the Privacy Act. Depending on the product or service we are providing to you, or your relationship with us, we may disclose your personal information:
and for any other purpose related to or ancillary to any of the above.
One of the ways we store and manage information (including personal information) is by using cloud computing, where servers are based overseas including in Japan and the USA. We take reasonable steps to maintain the security of your information and to ensure your information is treated in accordance with the standards that apply in Australia.
4. Direct marketing
We may from time to time use your personal information to provide you with current information about loans, insurance products, special offers you may find of interest, changes to our organisation, or new products or services being offered by us, our related bodies corporate or any other company we are associated with. By providing us with your information, you consent to receiving such information, including by phone, email, SMS and social media, on an ongoing basis until you unsubscribe. We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us. Contact details are set out at section 11 of this policy. If the direct marketing is by email you may also use the unsubscribe function and if the direct marketing is by SMS you may reply 'STOP' to opt out. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
5. Cookies, advertising and tracking
Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.
6. Accessing, updating and correcting your personal information
You can request to access your personal information we hold at any time. Depending on the volume or difficulty in obtaining the information, we may charge a fee that covers our costs.
An initial response will be provided to you within 7 days from your request, and the outcome of the investigation given in 30 days. There may be situations where we are not required to provide you with access to your personal information, and we will set out the reasons for this. An example of this would be where the information related to existing or anticipated legal proceedings, or if your request was vexatious.
You may also request to correct any of your personal information we hold if it is incorrect, inaccurate or out of date. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
Depending on the request we may update your personal information immediately, or we may provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days from your initial request. We may have to consult with external entities as part of your request to access or correct your personal information.
7. Using government related identifiers
If we collect government related identifiers, such as your drivers licence number or tax file number, we do not use or disclose this information other than to the extent required or authorised by law. For instance, we will never adopt your tax file number as your account number to identify you.
8. Doing business without identifying you
In most circumstances it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without you providing us with personal information, for example where you make general enquiries about our products or services, or any special offers.
9. How safe and secure is your personal information that we hold?
We may store your personal information in paper or electronic form. We take reasonable steps to protect any personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Some of the steps that we take to protect personal information include, but are not limited to, the following:
When the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
If you are dissatisfied with how we have dealt with your personal information, or have a complaint about our compliance with the Privacy Act, you may contact us using the details in clause 11. We will acknowledge your complaint within seven days and provide you with a decision on your complaint within 30 days. If you feel your complaint is still not resolved adequately after discussion with us, you may then contact the Office of the Australian Information Commissioner on http://www.oaic.gov.au/privacy/privacy-complaints.
11. Further information
If you have any questions about how we handle your personal information, contact our Privacy Officer by phone on 1300 476 278, via email at email@example.com, or at:
Smartgroup Corporation Ltd
GPO Box 4244, Sydney NSW 2001
Last updated: 9 November 2017
Information on the Website
You must take your own precautions to ensure that the process which you employ for accessing this Website does not expose you to the risk of viruses, malicious computer code or other forms of interference which may damage your own computer system. Except as required by law, we do not accept responsibility for any interference or damage to your own computer system which arises in connection with your use of this Website or any Third Party websites.
The information provided on this Website is of a general nature only, and does not constitute financial advice. You should make your own enquiries before acting or relying on any information or material which is made available to you pursuant to the Website.
Information from third parties
The Website also contains links to the websites of third party providers of goods and services ('Third Party websites'). Those links are provided for convenience only and may not remain current or be maintained. We are not responsible for the content or privacy practices associated with Third Party websites.
Our links with Third Party websites should not be construed as an endorsement, approval, affiliation with or recommendation by us of the owners or operators of those websites, or of any information, products or services referred to or contained on those websites, unless and to the extent stipulated to the contrary.
If you have accessed Third Party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.
Where you access a Third Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
Advertising and tracking
When you view our advertisements on a Third Party website, the advertising company uses 'cookies' and in some cases 'web beacons' to collect information such as:
When you access our Website after viewing one of our advertisements on a Third Party website, the advertising company collects information on how you utilise our Website (e.g. which pages you view and whether you proceed to obtain services from us).
You are not obliged to accept a cookie and you can modify your browser so that it will not accept cookies. However, if you do so this may affect your browsing experience and certain functions within the Website may not work.
Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our Website.
When you send a completed online form or provide information through our Website to us, we retain the information you have sent us. We are able to then use that information to provide any services that you require.
You can also suspend and save the online form, so you can complete and send the form at a later time. If you suspend or save your form, the information that you have entered will be retained in our systems so that you may recover the information when you resume your form. Online forms that have been suspended or saved may be viewed by us.
Security of information
The security of your information is very important to us. We regularly review developments in security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as totally secure.
This Website includes trade marks owned by us (or our licensors). You must not use any of our trade marks in or as the whole or part of your own trade marks or business name or company name; in connection with activities, products or services which are not ours; in a manner which may be confusing, misleading or deceptive; or in a manner that disparages us or our information or services (including this Website).
Last updated: 20 November 2017
As a customer of a Smartgroup company, you can expect a simple and rewarding experience that is easy to understand and even easier to manage.
We continually look for ways to innovate and simplify the products and services we offer, and ask you, our customer, to let us know how we're going so that we may learn from your experience dealing with us - both good and otherwise.
Our commitment to you
Our mission is to make the services we offer easy to understand, and for them to be simple and seamless so that you may take full advantage of your benefits.
We value your feedback - it's what drives us to improve the way we serve - so if you feel we're not meeting this commitment to you, we'd like to know about it. To lodge a complaint and understand how your complaint will be handled, see our Complaints Charter.
So that we can provide the service you've come to expect from us, we ask that you:
Get in touch with us whenever and however it suits
We're here to assist when you need us. To find the communication channel that suits you, see Contact Us.
We respect and protect your personal information
For your peace of mind, we:
We welcome your feedback
The feedback we receive from our customers is as at the heart of the improvements we make to our service delivery. So we welcome your feedback, good and otherwise.
If you would like to let us know about an experience you've had, email us at firstname.lastname@example.org or call 1800 555 582 to speak with a member of our service team.
How to make a complaint
When things don't go as they should, and you feel we're not meeting our commitment to you, we appreciate you letting us know.
To ensure a satisfactory resolution, contact the team handling your benefits on 1800 555 582, or email email@example.com.
How we handle your complaint
What to do it you are not satisfied with the outcome