Watson Holden PRIVACY POLICY
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We appreciate the importance of protecting your personal information and recognize the trust placed in us when you supply your personal information to us. We value your privacy and are bound by the National Privacy Principles ("NPP's") under the Privacy Act 1988 (as amended) in the way that we collect, use, disclose, secure and provide access to personal information. To comply with the NPP's and in recognition of your trust in us, we have implemented a privacy charter. This charter explains how we handle personal information relating to individuals, whether or not they are customers. Nothing in this charter limits any of our obligations at law.
The Privacy Officer
Watson Holden
PO Box 117
Bundoora 3083
Information Collection:
We collect personal information only to the extent that this is necessary for one or more of our following activities, relevant to our business relationship with you: Selling you a new or used motor vehicle and registering that vehicle in the name provided by you. We are required by law to provide certain information to the licensing authorities (VIC Roads); Completing an application for the provision of Financing facilities relating to the purchase of a New or Used motor vehicle.
The information requested is the minimum required by the finance providers; Completing an application for the provision of Insurance cover; Providing after-sales service for your vehicle; To offer you new products and services that we believe may interest you; Market research in relation to the products and services referred to in the preceding paragraphs; and to satisfy any legal requirements.
The types of personal information that we may collect and hold for our activities includes, without limitation, an individual's name, date of birth, physical or postal addresses, e-mail address, telephone and fax numbers, driver's license details, vehicle details, credit card details, occupation, salary and personal finances (for loan applications), health information (for life or disability insurance) and details of current or previous insurance (for motor insurance). We will not collect any sensitive information unless this is necessary to provide you with a specific product or service.
We may collect personal information from you in a variety of ways including, without limitation, on vehicle purchase contracts, questionnaires, through our website, over the telephone or during person-to-person contact. The collection will be done by lawful and fair means and not in an unreasonably intrusive way. We will collect information directly from an individual wherever possible. If this is not possible, we will take reasonable steps to ensure that the individual is made aware of the information outlined in the collection statement.
If the information we request for the provision of goods or services is not provided to us, we may not provide the goods or services to the person requesting them.
Information Use and Disclosure:
We will only use or disclose your personal information for the primary purpose of collection or a related purpose or where we are required or permitted to do so by law or where you have provided consent. We will not seek a broader consent than is necessary for the circumstances.
Information will only be disclosed for a secondary purpose where the secondary purpose is related to the primary purpose and the individual would reasonably expect the organisation to use or disclose the information for the secondary purpose.
We may disclose your personal information to the vehicle manufacturer for the purposes of supplying goods and services that you request and contacting you for promotional, safety, market research purposes and other matters relating to the motor vehicle and you. The manufacturer may disclose your personal information to certain organisations, such as marketing and research companies and other contractors for the purposes outlined above.
We may disclose your personal information to organisations offering you insurance, finance and extended warranties.
We may disclose your personal information to fulfill legal requirements, such as disclosure to law enforcement agencies or the courts.
With your consent, we do allow your information to be provided to select organisations that perform certain functions or operations for us. We bind these companies to the same standard of care as we do ourselves. All information disclosed remains the property of Watson Holden.
In addition, we use your information when advising you about our products and services or upcoming events at Watson Holden.
We will not provide your personal information to any other organisation for marketing purposes without your consent and will not share, sell or trade your personal information to non-related companies or persons.
Data Quality and Security
We will endeavour to ensure that the personal information we collect and hold about you is complete, accurate and up to date. We use technology, documented procedures and internal review processes to assist in this process.
We will also take reasonable steps to protect the personal information that we hold from misuse or loss and from unauthorised access, modification or disclosure.
We will destroy or permanently de-identify personal information no longer needed for any purpose under NPP2 ("Use and Disclosure").
When using our website, you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you transmit to us over the Internet and you do so at your own risk.
Passwords, firewalls and virus protection are used to protect Watson Holden systems holding personal information from unauthorized access.
Access, Correction and Further Information
We will, in appropriate circumstances, provide you with access to your personal information held by us unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us if you:
- Wish to have access to the personal information that we hold about you; Consider that the personal information that we hold about you is not accurate, complete or up to date; or Require further information on our personal information handling practices.
- To obtain access you will have to provide proof of your identity. This is necessary so that Watson Holden can ensure that your personal information is not disclosed to any other person.
There will generally be no charge for access to and supply of personal information. However, in cases where information has to be retrieved from archives or where large volumes of information has been requested, a reasonable fee might be charged to cover costs incurred.
Policy on Information Retention
We will retain information for as long as it is necessary to service your account or to continue to provide products and services you have requested or purchased from us. We will retain information for a reasonable period if you cease to be our customer unless the law requires us to keep it for longer.
Policy on Identifiers
Watson Holden will not use identifiers assigned by government agencies as its own identifier. An ABN is not an identifier.
Our Employees and Training
We will provide training and communications programs designed to educate employees about the meaning and requirements of our Privacy Policy. Employees who intentionally or negligently breach the Privacy Policy will be subject to disciplinary action.
Disclosure
If you have any concerns about the way your personal information has been managed by Watson Holden, kindly advise us in writing and address the complaint to:
The Privacy Officer
Watson Holden
PO Box 117
Bundoora 3083
HOLDEN PRIVACY POLICY
GM Holden Ltd (Holden) recognises the importance of protecting an individual's privacy. We appreciate that individuals are concerned about the security of their personal information and we are committed to protecting any personal information we hold.
Personal information is information or an opinion about an individual who is reasonably identifiable.
In accordance with the 13 Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act), this Privacy Policy details how Holden will manage and protect personal information, including information that Holden collects and uses for the purpose of providing better customer service by striving to meet our customers' needs and expectations about our cars and other products.
This Privacy Policy generally does not apply in relation to current or former Holden employees.
Holden dealers are independent of Holden and have privacy policies which differ from ours. Holden dealers are responsible for their own privacy policies and privacy practices. Please contact your Holden dealer directly for further information.
Holden may amend this Privacy Policy at any time. The updated version will be available by following the "Privacy Policy" link on Holden's website homepage, at www.holden.com.au. Holden may highlight changes to this Privacy Policy on its homepage, but you should check the Privacy Policy regularly for changes.
COLLECTING PERSONAL INFORMATION
Holden will be fair and open about the way we collect information about you and what we intend to do with the information.
Holden may collect and hold personal information about you such as your name, address, telephone number, driver's license, date of birth, your vehicle's vehicle identification number, registration date, registration number, change of address and telephone information, amount of your GM Holden MasterCard rebate and the expiry date of your rebate points, and any other information you may voluntarily provide to us.
Holden collects most personal information directly from you, for example when you provide information through market surveys, product focus groups, the websites operated by Holden, Holden's customer assistance service (Customer Care) via mail, email and telephone enquiries, and during the recruitment process. Third parties may also share information with us, including our Dealers (such as vehicle purchasing, servicing and warranty information), related companies and Westpac (if you have a GM Holden MasterCard, Westpac provides Holden with some information for the purposes of ensuring that card holders are able to claim their GM Holden MasterCard rebate when purchasing an eligible Holden vehicle). We may also collect your personal information if you enter a competition or promotion we run (either directly or through our marketing agents), or through a recruitment or employment agency.
We may collect information about Dealer staff directly from those staff or from our Dealers, and about staff of our suppliers directly from those staff or from other staff of those suppliers. The information we collect about Dealer staff may include your name, position, contact details and training records. The information we collect about staff of our suppliers may include your name, position and contact details.
Other than the personal information set out in this policy, Holden does not collect any credit information about you. If we receive information about you from a third party, wherever practical we will make sure they undertake to comply with the Privacy Act.
Holden vehicles, like other modern motor vehicles, have a number of sophisticated computer systems that monitor and control several aspects of the vehicle's performance. Holden vehicles use on-board vehicle computers to monitor emission control components to optimize fuel economy, to monitor conditions for air bag deployment and, if so equipped, to provide anti-lock braking and to help the driver control the vehicle in difficult driving situations. Some information may be stored during regular operations to facilitate repair of detected malfunctions; other information is stored only in certain collision events by computer systems, such as those commonly called event data recorders (EDR). The information from EDR's, if available, is used to improve customer and driver safety, better understand what happens to our vehicles in the event of a collision and shall be provided to the police on request.
USING PERSONAL INFORMATION
Holden only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by an Australian law or court or tribunal order.
We may use personal information we collect about you for a number of purposes including:
- to tell you about other products and services that may be of interest to you;
- to learn more about your level of satisfaction, your expectations of us and our Dealers and how we can meet them (for example, in relation to Holden's products and services, and the products and services provided by Dealers and contracted service providers such as Roadside Assistance);
- to ensure that any warranty claim is properly administered;
- to run a competition or promotion you have entered;
- to consider you for a position at Holden for which you have applied;
- to acquire goods or services from you or from your employer;
- to ensure that you are contacted as soon as possible in the event of a safety-related product recall;
- to improve driver safety and to better understand what happens to Holden vehicles in the event of a collision;
- for other purposes to which you have consented; and
- as required or permitted by relevant laws and regulations.
Generally, we may use your personal information for the purposes for which we collected it and for related purposes which would be reasonably expected by you.
If you do not provide your personal information, Holden is less able to perform the above functions.
DISCLOSING PERSONAL INFORMATION
Holden may need to disclose personal information outside of the jurisdiction from which it was collected. When we disclose your personal information overseas, Holden is generally required to take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia. In relation to health information about an individual, we will generally only disclose the information outside of the state or territory where we collected it if we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which upholds principles for fair handling of the information that are substantially similar to the principles that apply in the state or territory of collection.
We may disclose personal information we collect about you for different purposes including:
- to assist our related companies (such as General Motors and Holden New Zealand) and other service providers (such as information technology service providers, payroll service providers, recruitment service providers, third parties that provide services in relation to Holden's internal feedback and reporting programs i.e. Awareline program, service providers who assist us with "onboarding" new staff, mailing houses, Holden Assist, Holden Roadside Assistance) so that they can provide the services that we have contracted out to them;
- to provide information to our Dealers so that they can provide goods or services to you or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you;
- to your nominated referees so that we may check your references if you are applying for a position with Holden; and;
- as required by relevant laws and regulations.
Holden may disclose personal information to such entities located in the following countries/regions:
- the USA;
- Spain;
- other countries in Europe;
- Africa;
- Oceania;
- South America;
- Asia; and
- the Middle East;
We will not sell, rent or trade your information to/with any other organisation.
CONSENT
We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to Holden collecting, using and/or disclosing your personal information, this may affect Holden's ability to deliver and improve its products and services.
MARKETING AND PRIVACY
Holden sends marketing materials to its customers and other people who have provided Holden with personal information from time to time about products and services offered by Holden, its Dealers and its affiliates.
If you do not wish to receive marketing materials from Holden, its Dealers or its affiliates, please complete the opt-out provision on the marketing information sent to you and return it to Holden (or contact Holden Customer Care on 1800 033 349 or at holdencustomercare@gm.com). Holden will note your request and respect your wish not to receive any marketing materials.
If you choose not to receive any marketing materials from Holden, you may miss out on special product and service offerings and opportunities.
COOKIES
We use cookies and track IP addresses via our websites so we can improve our services provided by our websites and enhance your user experience.
Cookies are pieces of information a website can send to your computer's browser for record-keeping purposes. We use cookies to ascertain which web pages are visited and how often, to make our websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in. For example, cookies allow us to save your password so you do not have to re-enter it every time you visit our site. Most web browsers automatically accept cookies. Cookies can be disabled or purged from your browser if you so choose. You can find information specific to your browser under the "help" menu. We can't guarantee the proper functioning of our websites if you choose to disable cookies.
PROTECTING PERSONAL INFORMATION
Holden will keep your personal information secure by taking reasonable steps to protect it from misuse, loss and unauthorised access, modification and disclosure.
Holden stores personal information in transmission logs and archive systems for a period Holden considers reasonable depending on the primary purpose for which that information was collected. Only properly authorised people who have a need to access personal information to perform their job will be able to see or use that information. The physical and electronic security systems at Holden comply with the guidelines of the Information Commissioner.
Personal information will be de-identified or destroyed when it is no longer required such that it cannot be re-identified at a later date. The de-identification and destruction process will be in accordance with the guidelines of the Information Commissioner.
Holden will ensure that its employees receive training (and refresher training) about the management of personal information relevant to their respective roles and responsibilities.
Holden will take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory rights under any applicable law including the Privacy Act or the Competition and Consumer Act 2010 (Cth). Please notify us immediately if you become aware of any breach of security.
ACCESSING AND REQUESTING CORRECTION OF PERSONAL INFORMATION
We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under the privacy legislation, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your personal information we will tell you why.
If you wish to obtain access to and/or correct your personal information held by Holden, please contact Holden Customer Care on 1800 033 349 or email us at holdencustomercare@gm.com.
Holden will provide written acknowledgement of receiving your request for access within 7 days of receipt. Unless it does not agree to your request for access to personal information, in most cases Holden will provide you with access within 30 days of receipt of your request. If you request corrections to your personal information and Holden agrees with your request, these changes will be made as soon as practicable. If Holden does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you remain dissatisfied you may also complain to the Information Commissioner (at www.oaic.gov.au).
RESOLVING YOUR CONCERNS
If you have a complaint regarding Holden's management of your personal information, please prepare your complaint in writing and email it to us at holdencustomercare@gm.com.
Holden will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.
PRIVACY AND HOLDEN EMPLOYEES
Due to the "employee records exemption" in the Privacy Act, Holden is generally not required to comply with the Privacy Act in relation to personal information held in its employment records concerning current or former Holden employees. Therefore, this Privacy Policy generally does not apply in relation to current or former Holden employees.
However, Holden recognises that employee records should nevertheless be handled carefully, and Holden will comply with any obligations that may apply to employee personal information under other applicable laws.
Holden may disclose personal information held in its employment records for different purposes including: to our related companies (such as General Motors and Holden New Zealand) and to service providers (such as information technology service providers, payroll service providers, recruitment service providers, third parties that provide services in relation to Holden's internal feedback and reporting programs i.e. Awareline program and service providers who assist Holden with "onboarding" new staff) so that they can provide the services that Holden has contracted to them to perform.
Holden employees may seek to access, update or correct the personal information which Holden holds about them by contacting their Human Resources Manager. Such requests will be assessed on a case by case basis.
The employee records exemption does not apply (and this Privacy Policy does apply) to:
(a) independent contractors;
(b) secondees into Holden who remain employees of the seconding client or firm;
(c) voluntary work experience students; or
(d) job applicants.
Health records legislation also applies to health information about employees collected or handled in Victoria and this Privacy Policy will apply to that information.
FURTHER QUESTIONS
If you have any questions about this Privacy Policy or our privacy practices you can contact us on 1800 033 349 or at holdencustomercare@gm.com.
Date of this Privacy Policy: June 2014