Our policy for dealing with any personal information that you disclose to us is explained below.
What personal information does TWG collect?
The type of personal information we collect depends on the nature of your dealings with us and the reason for collecting it. We may collect personal information if you:
- purchase a new or used motor vehicle from us;
- are one of our suppliers;
- are a subscriber to our mailing list or newsletter; or
- submit a job application.
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). If you are one of our suppliers or contractors, or one of their employees, we may collect your name, contact details and position in the organisation.
If you apply for a job with us, you may provide us with certain information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.
If you are a subscriber to our mailing list or newsletter, or attended an event organised by TWG, we may collect your name, contact details, job title, areas of interest and details of your dealings with us. Generally TWG does not collect sensitive information about you, such as health records, unless it is reasonably necessary for the purpose of providing you with a specific product or service or is otherwise permitted by law.
How does TWG collect personal information?
TWG may collect personal information from you in a variety of ways including, without limitation:
- on vehicle purchase contracts,
- 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 being collected is outlined in the collection statement.
If the information we request for the provision of products or services is not provided to us, then this may affect our ability to provide those products or services to you.
Why does TWG collect personal information?
TWG will only collect personal information in connection with the provision of products and services provided by TWG or business activities.
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 relevant licensing authorities and motor registries;
- 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 that we offer; and
- to satisfy any legal requirements.
Generally, the purpose for which TWG collects personal information will be apparent from the way in which we collect it, or will be disclosed at the time of collection. If at any time the purpose for which we are collecting your personal information is unclear, please raise your concerns with the person you are dealing with or contact us using the contact details below.
How does TWG use personal information?
TWG will only use your personal information in the following ways:
- for the purpose(s) you have provided the information;
- for a purpose you have consented to; or
- for a purpose otherwise permitted by law.
Personal Information will only be used for any other purpose than you have consented to where that purpose is related to the primary purpose and a reasonable person would expect TWG to use or disclose the personal information for that other purpose.
TWG may use your personal information for research and development of our products and services or to send you information about other products or services offered by us which may be of interest to you. If you would prefer not to receive promotional or other material from us, please let us know by sending an email to the contact details below and we will respect your request. Alternatively, simply select the "unsubscribe" option in any of the emails that you receive from us. If you apply for a job with us, we will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, we will disclose only such information as is necessary in the circumstances. In considering your application, we may also collect personal information about you from any third parties that you nominate as your referees in your application.
We may also use your contact information to keep you updated on offers and specials and upcoming events that TWG may be having that may be of interest to you.
When does TWG disclose your personal information?
TWG discloses your personal information to related TWG entities or third party service providers and contractors who assist in our internal business and administrative operations. When we engage the services of a third party, we take reasonable steps to ensure they comply with the Privacy Act and maintain the confidentiality of any personal information to which they have access.
TWG may disclose your personal information to organisations offering you insurance, finance and extended warranties.
We may disclose your personal information to fulfil legal requirements, such as disclosure to law enforcement agencies or the courts.
With your consent, we do allow your personal 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.
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.
Will TWG disclose your personal information to anyone overseas?
TWG does not ordinarily disclose your personal information overseas. However there may be circumstances where we need to disclose your personal information to a third party and this third party may disclose your personal information overseas. This may occur, for example where we:
- have to send your personal information to the manufacturers, distributors and or financiers and they will on-send that information to their overseas headquarters or related companies; or
- where we have a database or server hosted outside Australia.
APP 8.1 requires that we will take all reasonable steps to ensure that the third party recipient of your information complies with the APPs (other than APP 1) in relation to your personal information, or that the third party recipient is bound by laws that offer you at least as much protection as the APPs and that you are able to enforce your rights under those international laws in the event of any breach. TWG will obtain your consent before it discloses your personal information to overseas third parties.
How does TWG ensure your personal information is correct?
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. To assist, please contact us at firstname.lastname@example.org if any of the details you have provided are incorrect or have changed.
How does TWG keep personal information secure?
TWG is committed to keeping your personal information secure. We take reasonable steps to protect the personal information that we hold from misuse or loss and from unauthorised access, modification or 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. TWG does not accept responsibility for the security of information transmitted to us over the Internet. Passwords, firewalls and virus protection are used to protect TWG systems holding personal information from unauthorised access. Our website may contain links or plug-ins to other sites. We are not responsible for the content of or the practices or policies of, those sites.
We will destroy or permanently de-identify personal information no longer needed for any purpose in accordance with the APPs.
How can you access and correct your personal information?
You have the right to access your personal information held by TWG. You can also make a request for us to correct any inaccurate, incomplete or out-of-date personal information. For security reasons, a written request may be required to access your information as well as providing proof of your identity.
We are committed to granting you access to your personal information within a reasonable time frame. We will not refuse you access unless there are legal reasons for doing so. In such circumstances, we will explain those reasons to you. This may be necessary so that TWG can ensure that your personal information is not disclosed to any other person.
If you consider that the personal information that we hold about you is not accurate, complete or up to date then we ask that you provide to us in writing with the correct information so the personal information held about you is accurate, complete and up-to-date.
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 any costs incurred by TWG.
Does the TWG website collect personal information?
We do not collect personal information from casual visitors to our web site, unless you have voluntarily supplied us with personal information via one of our web forms or via email.
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
TWG will not use identifiers assigned by government agencies as its own identifier. An ABN is not an identifier.
Our Employees and Training
How does TWG deal with privacy complaints?
Your privacy is important to TWG and we will make every effort to resolve your concerns. To assist us in helping you, we ask you to:
- 1. Gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
- 2. Submit your complaint in writing by email to email@example.com with your contact details or via mail to:
The Privacy Officer
Tony White Group
Po Box 63
Chermside South, Qld 4032
We will then investigate your complaint and endeavour to respond to you in writing within 30 days of receipt of your written complaint.
If at this stage the matter has not been resolved to your satisfaction, you can telephone the Australian Information Commissioner's hotline on 1300 363 992 or, if calling from outside Australia, + 61 2 9284 9749.
Further information about privacy
Further information may be obtained on privacy issues in Australia by visiting the Australian Information Commissioner’s website at www.privacy.gov.au
Date last revised: March 2014