JK Williams Group (JKW) is committed to protecting the privacy of personal information. The purpose of this policy is to outline how and what kind of personal information JKW will collect, use, store, share and dispose of in line with the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).
This Policy will commence from 25th March 2021. It replaces all other Privacy policies of JKW (whether written or not).
This Policy applies to all JKW clients, transferees and prospective employees.
JKW: JK Williams Group is comprised of JK Williams Contracting Pty Ltd, JK Williams Constructions Pty Ltd and Hombu Holdings Pty Ltd (each a ‘company’).
This policy does not apply to the personal information of JKW employees, however JKW is committed to applying the same level of protection to information relating to these individuals.
JKW reserves the right to vary, replace or terminate this policy from time to time.
Personal information means 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.
Sensitive information means:
Kinds of personal and sensitive information collected & held
Through conducting our business, we may need to collect personal and sensitive information from those that we interact with. The type of information that we may collect from individuals will depend upon the particular service being provided. Examples of information collected include, but are not limited to:
How and why we collect and use personal identifiable information
JKW does not collect personally identifiable information about individuals except when such individuals specifically provide such information on a voluntary basis which is reasonably necessary for, or directly related to, one or more of JKW’ functions or activities. For example, an on-line service request requires the collection of personal data in order for us to be able to respond promptly and correctly to the service request.
If JKW is not able to collect all or some of the personal information required, we may not be able to provide our services to you.
Personal information is collected in a number of ways including:
Personal information is collected for a variety of reasons, some examples include:
All personal information is stored electronically on the JKW secure network and / or in hardcopy stored in secure cupboards and cabinets.
JKW does not disclose your personal information for any secondary purposes unless your consent has been given or as required by law.
JKW will not sell any personal information that it collects from an individual.
Means of collection of information
JKW only collects information by lawful and fair means. JKW only collects personal information about an individual from that individual unless it is unreasonable or impractical to do so.
Unsolicited personal information
If JKW receives unsolicited personal information about an individual that it could have collected upon requesting it from the individual, it may be used, stored or shared if it is reasonably necessary for, or directly related to, one or more of JKW functions or activities.
JKW takes reasonable steps to ensure unsolicited personal information that is not needed is destroyed immediately or de-identified (all identifying features are removed).
Disclosure of personal information to external bodies
To provide our services, JKW may be legally required to disclose your personal information to Government agencies, such as Roads & Maritime Services.
JKW may also need to disclose your personal information to our contractual service partners to complete your service. All contractual service partners are required to sign a Code of Conduct and Non-Disclosure Agreement which includes an obligation to protect the private and confidential information of JKW and its customers.
By signing the JKW Service Agreement, you consent to JKW disclosing your personal information where it is reasonably necessary for the sole purpose of facilitating our services.
We may disclose Personal Information to external service providers located overseas so that they can provide us with services in connection with the operation of our business, such as marketing services, business support services (including the facilitation of correspondence), and data storage.
JKW does not adopt, use or disclose government related identifiers (such as a passport number or tax file number) of an individual unless it is reasonably necessary to verify the identity of an individual or fulfil our obligations to a Government agency.
Security of personal information
JKW will take reasonable steps to ensure that any personal information held is protected from:
Destruction of personal information
When personal information about an individual is no longer needed for the purpose for which it was collected (taking into account legal requirements for retaining certain information), JKW will ensure the secure destruction or de-identification of such information.
Anonymity & Pseudonymity
An individual has the option of not identifying themselves, or of using a pseudonym when dealing with JKW.
However, individuals should be aware that there will be limitations to the services that JKW is able to provide unless some identifying information is provided (the level of information depends on the service being provided).
From time to time, JKW may contact you regarding our services using the personal information (not sensitive information) you have supplied to us.
If you do not want to receive marketing information, please advise your point of contact at JKW. If you are not sure who this is, you can contact the Privacy Officer (contact details outlined at the end of this policy) who will assist you or direct you to the most appropriate person.
We will not provide your information to any third party for the purpose of direct marketing.
Accessing personal information
An individual can access personal information held by JKW about themselves by making contact with their point of contact at JKW, except where an exception applies (please see exceptions listed below). If they are unsure who to contact, they should contact the JKW Privacy Officer (contact details outlined at the end of this policy) who will assist them or redirect their enquiry to a more appropriate person.
JKW will respond to the request for access to the personal information within a reasonable period after the request is made. JKW will give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.
Circumstances under which an individual would not be given access to their information include:
If JKW elects not to give access to the information for one or more reasons outlined above, we will take reasonable steps to give access in a way that meets the needs of JKW and the individual. The individual will be provided with a written notice that sets out:
Correcting personal information
An individual can correct personal information held by JKW about themselves by making contact with their point of contact at JKW. If they are unsure who to contact, they should contact the JKW Office and speak to the Privacy Officer (contact details outlined at the end of this policy) who will assist them or redirect their enquiry to a more appropriate person. JKW will respond to the request for correction to the personal information within a reasonable period after the request is made.
If JKW has corrected personal information about an individual that we have previously disclosed to a third party, and the individual requests that JKW notifies the third party of the correction, we will take reasonable steps to give that notification unless it is impracticable or unlawful to do so.
If JKW refuses to correct the personal information as requested by the individual, we will provide a notice to the individual which sets out:
If JKW refuses to correct the personal information as requested by the individual, the individual may request JKW to associate a statement outlining that the information is inaccurate, out of date, incomplete, irrelevant or misleading. JKW will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.
Using our website
Visitors can access our website home page and browse our site without disclosing personal data by disabling the cookie settings on our website.
We do not collect information about our visitors from other sources, such as public records, public bodies or private organizations.
To give you the very best browsing experience, the cookie settings on the website are set to allow all cookies. If you continue to browse the site without changing these settings, you consent to this.
JKW will conduct a privacy audit at least to ensure that the requirements of this policy are being adhered to.
More information / Complaints
If you would like to make a complaint related to JKW breaching the Australian Privacy Principles (APPs) or would like further information on the way that JKW collects, uses, stores shares and disposes of your information, please contact the Privacy Officer (contact details outlined at the end of this policy).
The nature of your complaint will determine how it is dealt with, however steps may include an investigation, escalation, review of internal policy or process and / or apology to those affected.
JK Williams Group
39 – 53 Jack Williams Drive, Penrith NSW 2750
(02) 4725 3427
(m) 0414 315 199
Availability of the Policy
This policy is available on the JKW Company website (http://www.jkw.com.au).
Alternatively, you can request a copy in person, by phone or email to your JKW, and we will provide a hard copy or send it to you by your preferred method (facsimile, email or physical mail).
Dated: 25th March 2021 Next Review: 3rd September 2021
Original Issue Date: 1st September 2018