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Privacy Policy / Terms and Conditions

 

PRIVACY POLICY

Grange Workplace Initiatives Pty Ltd

 

1. Purpose

Grange Workplace Initiatives Pty Ltd ("Grange", "we", "our", or "us") is committed to protecting the privacy, confidentiality and security of personal information.

This Privacy Policy explains how Grange collects, holds, uses, discloses, stores, secures and manages personal information in accordance with the Privacy Act 1988 (Cth), the

Australian Privacy Principles (APPs) and other applicable Australian laws.

By engaging our services, visiting our website, communicating with us, or otherwise providing personal information to us, you acknowledge that your information may be handled in accordance with this Privacy Policy.

2. About Our Services

Grange provides professional services including:

  • Workplace advisory services

  • Leadership development

  • Executive coaching

  • Mentoring

  • Training and workshops

  • Workplace support services

  • Return to work support

  • Workplace injury management support

  • Administrative support services

  • Project coordination

  • Workforce and organisational support services

In many circumstances, Grange provides services to organisations in relation to their employees, workers and workplaces.

Grange generally becomes aware of an employee, worker, workplace issue, injury management matter or other employment-related matter because a client organisation has engaged Grange and referred the matter to us.

The client organisation determines the purpose for which personal information is collected and disclosed to Grange and is responsible for ensuring that:

  • personal information has been lawfully collected;

  • any required privacy notices have been provided;

  • any required consents, authorities, permissions or approvals have been obtained;

  • disclosure to Grange is lawful and authorised; and

  • applicable legal obligations have been satisfied.

Grange relies upon the authority of its client organisations and authorised representatives when information is provided to us for the purpose of delivering services.

To the maximum extent permitted by law, Grange is entitled to rely upon the accuracy, completeness and authority of information supplied by a client organisation or persons acting on its behalf.

3. Personal Information We Collect

The personal information we collect depends on the nature of our relationship with you and the services being provided.

We may collect:

  • Full name

  • Residential or postal address

  • Telephone number

  • Email address

  • Date of birth

  • Occupation

  • Employer details

  • Position title

  • Professional qualifications

  • Professional registrations

  • Training records

  • Correspondence and communications

  • Service records

  • Website interaction information

  • Other information reasonably required to provide our services

4. Sensitive Information

Where reasonably necessary and permitted by law, Grange may collect sensitive information, including:

  • Health information

  • Workplace injury information

  • Medical certificates

  • Medical restrictions and capacities

  • Return to work information

  • Professional association memberships

  • Information relating to workplace support services

  • Other sensitive information as defined under the Privacy Act

Sensitive information will only be collected, used or disclosed where:

  • required for the provision of services;

  • authorised by the relevant client organisation;

  • consent has been obtained where required by law;

  • required or authorised by law; or

  • another exception under the Privacy Act applies.

5. How We Collect Information

We may collect personal information directly or indirectly through:

  • Client organisations

  • Individuals

  • Meetings and interviews

  • Coaching and mentoring sessions

  • Workshops and training programs

  • Telephone communications

  • Email correspondence

  • Website enquiries and online forms

  • Insurers

  • Rehabilitation providers

  • Medical practitioners

  • Allied health professionals

  • Legal representatives

  • Service providers

  • Publicly available sources whereby lawful

  • Other authorised third parties

Where permitted by law, telephone calls may be monitored or recorded for quality assurance, training, risk management, security and dispute resolution purposes.

6. Employee and Worker Information

Grange may receive personal information relating to:

  • Employees

  • Workers

  • Contractors

  • Volunteers

  • Candidates

  • Labour hire personnel

  • Other individuals connected with a client organisation

Such information may include:

  • Employment records

  • Position details

  • Attendance records

  • Leave information

  • Workplace support information

  • Workplace injury information

  • Return to work information

  • Medical capacity information

  • Training records

  • Workplace investigation information

  • Workplace conduct information

  • Other information reasonably necessary to perform contracted services

Personal information relating to employees or workers may be obtained directly from the individual, the client organisation, insurers, rehabilitation providers, medical practitioners, legal representatives or other authorised parties.

The relevant client organisation remains responsible for ensuring that any required employee notices, consents, authorities or approvals have been obtained before information is provided to Grange.

Grange generally uses such information only for purposes connected with the services we have been engaged to provide and for purposes otherwise permitted or required by law.

Requests relating to employment records may be referred to the relevant employer.

7. Information Provided by Clients

Grange may receive information from:

  • Client organisations

  • Authorised representatives

  • Insurers

  • Rehabilitation providers

  • Medical practitioners

  • Allied health providers

  • Legal practitioners

  • Consultants

  • Contractors

  • Other authorised third parties

Grange relies upon the organisation or person providing information to ensure that:

  • the information has been lawfully collected;

  • disclosure to Grange is lawful;

  • required privacy notifications have been provided;

  • any necessary consents, authorities or permissions have been obtained; and

  • disclosure complies with applicable legislation.

To the extent permitted by law, Grange is not responsible for any failure by a client organisation or third party to satisfy these obligations before information is provided to Grange.

8. Website Information

When you visit our website, certain information may be automatically collected, including:

  • IP address

  • Device information

  • Browser type

  • Operating system

  • Pages visited

  • Documents downloaded

  • Dates and times of access

  • Referring websites

This information assists us to:

  • Improve website functionality

  • Enhance user experience

  • Monitor website performance

  • Maintain website security

  • Analyse website usage trends

Where website information can reasonably identify an individual, it will be treated as personal information.

9. Cookies and Analytics

Our website may utilise:

  • Cookies

  • Website analytics platforms

  • Security monitoring technologies

  • Website performance tools

These technologies help us:

  • Improve website functionality

  • Understand website usage trends

  • Improve user experience

  • Maintain website security

You may choose to disable cookies through your browser settings; however, some website features may not function correctly.

We may use third-party analytics services such as Google Analytics or similar providers. Information processed through these systems may be stored or processed outside Australia.

Our website may contain links to external websites. Grange is not responsible for the privacy, security or content practices of third-party websites.

10. How We Use Personal Information

We may use personal information to:

  • Deliver our services

  • Support client organisations

  • Provide coaching and mentoring

  • Conduct training and workshops

  • Facilitate workplace support services

  • Assist with workplace injury management support

  • Assist with return to work support

  • Communicate with clients and stakeholders

  • Respond to enquiries

  • Manage administrative functions

  • Improve our services

  • Conduct quality assurance activities

  • Protect our legal rights and interests

  • Satisfy legal and regulatory obligations

  • Manage business operations

We will not use personal information for purposes unrelated to those for which it was collected unless authorised by law, reasonably expected, or consent has been obtained.

11. Disclosure of Personal Information

We may disclose personal information to:

  • Client organisations

  • Authorised client representatives

  • Contractors

  • Consultants

  • Insurers

  • Accountants

  • Auditors

  • Legal advisers

  • Technology providers

  • Cloud service providers

  • Training providers

  • Government agencies

  • Regulators

  • Law enforcement agencies

  • Other persons where permitted or required by law

We take reasonable steps to ensure third parties handling personal information maintain appropriate privacy, confidentiality and security standards.

12. Artificial Intelligence and Technology

Grange may utilise approved technology platforms, automation tools, document management systems and artificial intelligence-assisted technologies to support service delivery and business operations.

Where such technologies are used:

  • Appropriate safeguards will be implemented;

  • Access controls will be maintained;

  • Confidentiality obligations will apply;

  • Security measures will be adopted; and

  • Personal information will not knowingly be used to train publicly available artificial intelligence models without appropriate authorisation.

Grange takes reasonable steps to assess technology providers and service providers before engagement.

13. Overseas Disclosure

Some service providers engaged by Grange may store, process, host or back up information outside Australia.

Where overseas disclosure occurs, Grange will take reasonable steps to ensure recipients maintain privacy and security protections appropriate to the circumstances and consistent with applicable legal requirements.

14. Data Quality

Grange takes reasonable steps to ensure that personal information collected, used and disclosed is:

  • Accurate

  • Complete

  • Relevant

  • Current

  • Not misleading

Individuals are encouraged to notify us if information requires correction or updating.

15. Storage and Security

Grange takes reasonable steps to protect personal information from:

  • Misuse

  • Interference

  • Loss

  • Unauthorised access

  • Unauthorised disclosure

  • Unauthorised modification

Security measures may include:

  • Restricted access controls

  • Password protections

  • Secure cloud environments

  • Encryption technologies where appropriate

  • Cybersecurity controls

  • Staff confidentiality obligations

  • Secure destruction procedures

  • Staff training and awareness activities

While Grange takes reasonable precautions, no method of transmission or storage can be guaranteed to be completely secure.

16. Data Breach Response

Grange maintains procedures for identifying, assessing and responding to actual or suspected privacy breaches.

Where required by law, Grange may:

  • Investigate the incident;

  • Contain and mitigate risks;

  • Notify affected individuals;

  • Notify client organisations;

  • Notify the Office of the Australian Information Commissioner; and

  • Take any other steps required by applicable law.

17. Data Retention and Destruction

Personal information is retained only for as long as reasonably necessary to:

  • Provide services;

  • Comply with contractual obligations;

  • Satisfy legal requirements;

  • Meet regulatory obligations;

  • Defend legal claims;

  • Maintain insurance records;

  • Manage disputes; and

  • Protect legitimate business interests.

Where information is held as part of services provided to a client organisation, retention periods may also be influenced by contractual obligations, legal requirements and client instructions.

Information no longer required may be securely destroyed, archived or de-identified.

Requests for deletion may not be fulfilled where retention is required or authorised by law.

18. Access and Correction

Individuals may request access to personal information held by Grange and may request correction of inaccurate information.

Requests should be submitted in writing.

Reasonable identification requirements may apply before access or corrections are processed.

Where permitted by law, Grange may refuse access or correction requests.

Where information is primarily held on behalf of a client organisation, Grange may refer the request to the relevant client organisation.

19. Consent

Where consent forms the basis upon which personal information is handled, consent may be withdrawn at any time to the extent permitted by law.

Withdrawal of consent will not affect any collection, use or disclosure that occurred before the consent was withdrawn.

Certain information may continue to be retained, used or disclosed where required or authorised by law.

Where Grange acts on behalf of a client organisation, requests regarding consent may be referred to the relevant client organisation.

20. Reliance on Information Provided

Grange relies upon information supplied by clients, employees, workers, insurers, rehabilitation providers, medical practitioners and other third parties.

While Grange may take reasonable steps to verify information where appropriate, Grange does not warrant the accuracy, completeness or currency of information supplied by third parties.

To the maximum extent permitted by law, Grange accepts no responsibility for inaccuracies, omissions or errors in information provided by third parties.

Grange is not responsible for employment decisions, workplace decisions, disciplinary decisions, workplace investigation outcomes, personnel decisions, return to work decisions or injury management decisions made by client organisations.

21. Complaints

If you believe Grange has mishandled your personal information or breached applicable privacy laws, you may submit a complaint to:

Privacy Officer
Grange Workplace Initiatives Pty Ltd
Email: info@grangeworkplaceinitiatives.com.au

Please provide:

  • Details of the complaint;

  • Relevant dates;

  • Supporting documents; and

  • Any actions already taken.

We will investigate complaints and respond within a reasonable timeframe.

If you are not satisfied with our response, you may contact:

Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au

22. Changes to this Policy

Grange may amend this Privacy Policy at any time.

Any updated version will be published on our website and will take effect from the date of publication.

23. Contact Us

Grange Workplace Initiatives Pty Ltd
Email: info@grangeworkplaceinitiatives.com.au

Important Note: Advice by Grange does not constitute legal, medical, financial, insurance, employment or regulatory advice. Advice is for the consideration of your teams and professional advice should be obtained where appropriate.

©2020 by Grange Workplace Initiatives  acn-645984872

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