Privacy and disclaimer

Systems Planning and Analysis, Australia
Privacy Policy

This Privacy Policy details how Systems Planning and Analysis, Australia (SPA Australia), and its related bodies corporate and affiliates handle personal information.

SPA Australia has privacy practices and systems in place to  manage personal information in accordance with the Privacy Act 1988 (Cth) (the Act), including the Australian Privacy Principles.  

As an incorporated legal practice, SPA Australia also has professional obligations to our clients, including confidentiality obligations. For details of these, please see our terms of engagement.

PERSONAL INFORMATION 

Under the Act, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable: 

• whether the information or opinion is true or not; and 
• whether the information or opinion is recorded in a material form or not. 

This includes information such as your name, date of birth or contact details, and may include any recorded communication we may have had in our dealings with you. 

SENSITIVE INFORMATION 

Sensitive information is a subset of personal information and includes information or opinions about your racial or ethnic origin, political opinions, memberships (including trade unions or associations), religious beliefs, sexual orientation, health or criminal record. For the full list, please refer to the Act. 

We only collect, use or disclose sensitive information about you if you have provided us with consent or if the law permits or requires us to do so without consent. We note that we may sometimes be obliged to collect sensitive information in order to meet our legal obligations.

The types of sensitive information that we collect includes professional memberships (e.g. your local Law Society), if you are an employee or you provide it to us as a prospective employee, and may in certain circumstances also include other sensitive information required to be collected under applicable laws.

PERSONAL INFORMATION WE COLLECT & WHAT WE DO WITH IT 

The following table explains the types of personal information we collect, and the purposes for which we use and disclose it. If we need to use your personal information for anything else, we will seek additional consent from you to do this.

For…	We collect this personal information about them…	And use and disclose it for…
People who work for our client organisations	Name, business address, title, organisation and contact information  Interests in specific service lines and capabilities Interests in events  Information about client relationships or meetings – clients usually provide this information to us at the commencement of a business relationship. However, we may collect information about client personnel from other public or non-public sources.	Providing services to our clients    Business development and marketing    Managing relationships with our clients
People who work for our prospective client organisations
People who attend our events
People who subscribe to our electronic communications
People who work for our business partner and supplier organisations	Name, business address, title, organisation and contact information	Building and managing our commercial relationships with our partners and suppliers
Individual suppliers
Prospective employees	Information provided by the person (e.g. a job application, including a referee report), or on behalf of the person (e.g. by a recruitment agency)  Information provided by other people, e.g. current SPA Australia staff  We may sometimes be required to ask for and retain sensitive information about prospective employees to comply with applicable laws.	Selecting people who would be right to join our team
Referees for prospective employees	Written or oral referee reports
Current and past employees	Personnel records  Information from applications for security clearance, criminal history checks or other checks required by our clients, and the high-level results.	Managing the employment relationship
People who browse our website	see section Using Our Website below

RECIPIENTS OF PERSONAL INFORMATION

The types of APP entity to which we may disclose personal information include:

• service providers, including information technology, accounting, and legal services engaged by us in connection with our business.  Such disclosures are on a confidential basis for the purpose of receiving those services or for another purpose permitted under the Act; and
• clients, for the purpose of providing services to them or managing our relationship with them.

DATA SECURITY 

SPA Australia has information and data protection processes in place to keep personal information secure. We use secure cloud-based ICT systems, primarily based on Microsoft Azure and Office 365 platforms. Most systems have data hosted in Australia or the US. Some Microsoft services are hosted in the Asia-Pacific region, with a migration path to Australian or US hosting. The SPA Inc. Privacy Policy may apply to externally hosted systems, such as recruitment platforms, accessed through the Careers page.

All SPA Australia employees and contractors are required to comply with our strict guidelines in the secure handling of all information. This is to ensure that client confidential information is kept confidential in line with each client’s requirements. 

USING OUR WEBSITE (www.au.spa.com) 

When you visit our website, we receive information from your browser and information knowingly and voluntarily submitted by you. To improve your experience on our website, we may use ‘cookies’. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser. 

We collect and use the following kinds of information when you use our website: 

• information about your use of the website, including which pages you visit and the length of time you remain on those pages; 
• information that you provide for the purpose of using the website (e.g. an enquiry); and 
• information about transactions carried out over the website. 

We may use your personal information to: 

• administer the website; or
• personalise the website for you.

Our website uses Google Analytics, a service that sends website traffic data to Google servers in the US. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. 

If you use our website, then Google may process data in relation to that use in the manner described in Google’s Privacy Policy  and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google. 

Our website may contain links to other websites that we do not control. When you follow such a link, you should satisfy yourself about the privacy practices of that other website. 

Our website uses interfaces with social media sites such as Facebook, LinkedIn and Twitter. If you choose to ‘like’ or ‘share’ information from this website through one of these services, you should review the privacy policy of that service. 

CORRECTION OF INFORMATION 

We do our best to ensure all personal and client data we hold is up to date, complete, relevant and appropriate in the case of disclosure.  

If we believe information to be wrong, misleading or out of date, we will take reasonable steps to correct this information and notify third parties (if you notify us and it is reasonable and practicable for us to do so). 

You can request a change of information by contacting us on our details below. However, we are under no obligation to change this information if it is found to be correct. If we do not agree with changes you have requested, we will advise you in writing (unless the law allows us to not specify a reason). You may request that we associate a statement from you about the information. 

ACCESS TO YOUR PERSONAL INFORMATION 

You may ask for access to the personal information we hold about you at any time using our contact details below. We will respond to your request within three business days.  

If we refuse to provide this information to you, we will advise in writing (unless the law allows us to not specify a reason) and tell you how to lodge a complaint about our refusal. 

MARKETING 

From time to time, we send out marketing communications in the form of email communications, postal mail-outs or SMS text messages. SPA Australia includes an unsubscribe facility in every electronic marketing communication in line with the Spam Act 2003 (Cth).  To unsubscribe from other marketing communications, please contact us using the contact details below.

ENQUIRIES & COMPLAINTS 

If you wish to make an enquiry or complaint in relation to this privacy policy or our handling of personal information, please contact us using the following details: : 

Phone:            1800 959 885 
Email:              enquiries@au.spa.com 
Write:              SPA Australia, Level 2, 55 Blackall Street Barton ACT 2600  

We will do our best to respond within three business days of receipt of the request.