The Herron Todd White Group (HTW, we, us, and our) value your privacy and take the protection of your personal information seriously.
We appreciate that you have trusted us with your personal information, and we are committed to honouring your trust through appropriate management of your personal data. This Privacy Policy explains the types of personal information that we usually collect, the purposes for which we collect it, to whom we routinely disclose it, how we hold and keep it secure and your rights in relation to your personal information, including how you may access and seek correction of your personal information, how to make a complaint and how we deal with complaints.
In this Privacy Policy:
Personal information
- means any information or opinion about an identified individual or an individual who can be reasonably identified from that information, whether true or not. It does not include information that is de-identified or information about our current or former employees that is part of an employee record.
“Sensitive information”
- is a special category of Personal Information and includes health information and information about an individual’s race or ethnic origin, political opinion, membership of a political association, professional or trade association, religious or philosophical beliefs, sexual preferences or practices, or criminal history.
The Herron Todd White Group includes:
- Herron Todd White (Australia) Pty Ltd
- Herron Todd White (Consolidated) Pty Ltd
- Herron Todd White (Brisbane) Pty Ltd ACN 605 787 200;
- Herron Todd White Plant and Equipment (Brisbane) Pty Ltd ACN 605 154 774;
- Herron Todd White (RQ) Pty Ltd ACN 608 235 507;
- Herron Todd White (Darling Downs) Pty Ltd ACN 101 855 412;
- Herron Todd White (Gold Coast & NSW Far North Coast) Pty Ltd ACN 052 339 358;
- Herron Todd White (Northern Territory) Pty Ltd ACN 159 442 574;
- Herron Todd White (NSW & ACT) Pty Ltd ACN 630 251 919;
- Herron Todd White (NAT Operations) Pty Ltd ACN 632 595 692;
- Herron Todd White (South East Regional Australia) Pty Ltd
- Herron Todd White (South Australia) Pty Ltd
- Herron Todd White (Sunshine Coast) Pty Ltd
- Herron Todd White (VicTas) Pty Ltd
- Herron Todd White (WANT) Pty Ltd; and
- any other company which may become a shareholder of Herron Todd White (Australia) Pty Ltd or Herron Todd White (Consolidated) Pty Ltd or operates with the agreement or consent of Herron Todd White (Australia) Pty Ltd or Herron Todd White (Consolidated) Pty Ltd under the Herron Todd White name and brand.
We will handle your personal information in accordance with this Privacy Policy and applicable legislation, including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
What personal information do we collect?
The types or personal information we collect about you depends on the dealings you have with us and for different parts of our business operations, and includes personal information about our customers, contractors and job applicants.
Customers
The personal information that we collect about our current and prospective customers includes: contact information (including name, address, email address and phone number); bank details and other payment related information; your interests and preferences; feedback from customer satisfaction surveys; and other records of your communications with us.
Job applicants and contractors
The personal information that we collect about job applicants and contractors includes: information concerning your employment history, qualifications, certifications and academic records, skill, character and experience; screening checks (including references, criminal history and background checks); medical information; emergency contact details; information about race or ethnic origin where that information is relevant to the HTW Group’s Reconciliation Action Plan; and payroll matters, including leave and taxation, banking or superannuation affairs.
Why do we collect your personal information?
We collect, hold, use and disclose your personal information for our business purposes including:
- where you are a customer:
- to verify your identity and information;
- to understand your requirements and preferences to provide you with our products and services;
- to set up, administer, and manage our products and services, including to process payments;
- respond to your comments or questions, including advice on any of our products or services;
- to fulfil requests for products and services and information for internal operations;
- to assess and investigate any complaints made about our products or services;
- for product and service research and development and business strategy; and
- for marketing purposes;
- where you are a job applicant or contractor, to manage our human resources; and
- more generally:
- to manage, train and develop our potential employees, contractors and representatives;
- to manage complaints and disputes and report to dispute resolution bodies;
- to manage security, health and safety; and
- to comply with applicable laws and regulations, respond to complaints and claims, and investigate and protect ourselves and third parties against any activity that we reasonably suspect to be fraudulent.
Direct Marketing
From time to time, we may use your personal information to contact you by electronic messages (e.g. email), online (e.g. through our website) and by other means to provide you with information about the state of the market and any other products, promotions and services that you might be interested in. You may withdraw your consent to receiving direct marketing from us at any time by using the unsubscribe function in our communications or by contacting our Privacy Officer using the contact details at the bottom of this Privacy Policy. If you do this, we will stop sending you this type of material.
Sensitive Information
While it is rare for us to collect and handle Sensitive Information, we do, on occasion, collect some forms of Sensitive Information. This may include:
- conducting a national police check as part of our employment processes as some criminal convictions may prevent a person from being able to perform the inherent requirements of a job being applied for, or may give rise or reason to reject an application in order to meet our duty to ensure the safe conduct of our business;
- information about race or ethnic origin where that information is relevant to the HTW Group’s Reconciliation Action Plan; and
- in other circumstances where it is considered reasonably necessary for us to collect such information to perform our functions or provide our services.
We will only collect and handle the sensitive information referred to above with your consent, or where required or authorised by law or by order of a court or tribunal.
HTW acknowledges your right to freedom from discrimination within relevant Australian legislation. HTW does not generally collect information about a person’s political opinion, membership of a political association, professional or trade association, religious or philosophical beliefs, sexual preferences or practices.
How do we collect personal information?
We collect personal information about you in different ways, including:
- from you directly, for example:
-
- if you are a customer, when you complete our forms; subscribe to our newsletter or register with our website; respond to any surveys or marketing materials we send out; or interact with us by telephone, email, online (including through our website) or in person; and
- if you are a job applicant, when you apply for a position with us;
- through third parties with whom we interact with to provide our products and services, for example:
-
- if you are a customer, from instructing financial institutions and other clients who we provide products and services to; and
- if you are a job applicant, from your references and other third parties who provide suitability checks; and
- from publicly available sources including social media (e.g. Facebook, Instagram and LinkedIn) when you post comments, follow or otherwise communicate with us through these social media platforms.
Dealing with us anonymously or using an alias
Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question, we will not record your name unless we need it to respond to your query. However, we will generally need to know who you are in order to provide you with our services. You may receive a better service, in some circumstances if you tell us who you are, e.g. if you have made a complaint about our services, we may be able to deal better with the complaint if we know who you are and know the circumstances of your complaint. If you do not provide us with the personal information we need, some or all of the following may occur:
- if you are a customer, we may not be able to provide you with our products and services;
- if you are a contractor, we may not be able to engage you for your products or services;
- if you are a job applicant, we may not be able to consider your job application; and
- we may not be able to provide services to you where you choose to remain anonymous or use an alias.
Storage of your personal information and technology security practices
Personal information collected by us is generally stored in electronic form (on our cloud-based computing system). We take all reasonable and appropriate steps (including organisational and technology measures) to safeguard your personal information from loss, misuse, unauthorised access, modification or disclosure. Depending on the circumstances, these measures may include:
- external and internal premises security;
- auditing and monitoring of computer systems;
- restricted access to Personal Information;
- confidentiality agreements with contractors and third parties; and
- maintaining technology products to prevent unauthorised computer access.
We have put in place procedures to deal with data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
Information Retention
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods for taking legal action. If HTW no longer requires your personal information, we will take reasonable steps, in the circumstances, to destroy or permanently de-identify that information. These steps may vary depending on the nature of the personal information held, the way it was collected and how it was stored.
You may ask us to delete your personal information if there is no need for us to keep it. You can make this request verbally or in writing. There may be legal or other reasons why we may need to keep your personal information. If so, we will explain why.
Cookies
To help us sell our products and provide services through our website or understand more about visitors to our website, we collect certain information about you, including from your browser. This includes the IP address of your device, browser type, the number of pages viewed, language and access times. Our website also uses cookies and other similar tracking technologies to track pages visited and information accessed within our website. This information is for statistical reference, site analysis and to improve the content we display to you. In many cases, the tools used on our website record information in a way that does not personally identify you. In other cases, the information collected through our website may be personal information (e.g. when you submit an enquiry or subscribe to our newsletter), in which case this Privacy Policy will apply.
Our website may also use third party website tools from time to time, including data analytics and online survey tools such as cookies. A cookie is a small text file on your hard disk that stores information. Below we summarise why we use different types of cookies:
- Necessary cookies: are those that are essential to run our website or enable you to receive a service that you have requested.
- Performance cookies: are those that collect information about how visitors use and interact with our website so that we can improve it.
- Functionality cookies: are those that remember choices you make. Without these cookies you may find that certain features are less convenient and reliable.
- Marketing cookies: are those that help us deliver advertising that is more relevant to you and your interests. They include third-party cookies placed by our partners and other advertisers who share cookie data with us.
Your web browser can be configured to reject cookies. If you set up your web browser to reject cookies, certain functions of our website may become unavailable to you.
When you use a link from our website, or from any other website to which this Privacy Policy applies, to the websites of third parties; those websites are not subject to our privacy standards.
Disclosure of personal information to third parties
We may disclose your information for any of the purposes identified above to:
- various third-party suppliers, which provide products or services and support for our business, including local, state and federal authorities and providers of real estate and financial services;
- our related companies;
- our service providers, including providers of campaigns, promotions, accounting, auditing, legal, banking, payment, debt collection, delivery, data processing, data analysis, document management, research, investigation, technology and IT services, workforce management software services and website analytics services, and training providers;
- third party organisation in the event we sell or transfer all or a portion of our business or assets;
- your organisation and representatives; and
- government agencies for investigations, audit, reporting and regulatory compliance purposes.
Some of these organisations may be based in countries outside of Australia including New Zealand, the EU, India, Philippines and the United States of America. Before HTW discloses your personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient will not breach the APPs in relation to the information.
Access To And Correction Of Your Personal Information
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. You may request access to, and correction of, your personal information that we hold about you at any time by contacting our Privacy Officer on the details below. We will need to verify your identity before responding to your request and you may incur a fee to cover the cost of retrieval and the supply of this information to you.
Subject to any applicable exceptions or requirements, we will provide you with access to the personal information you request within a reasonable time and usually within 28 days. Some requests for access may take longer than 28 days to process depending upon the nature of the personal information being sought. If we decide to refuse your request, we will tell you why in writing.
Amendments to this Policy
HTW regularly reviews all of its policies and procedures to keep up-to-date with changes in the law, technology and market practice. We may change this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we publish the revised Privacy Policy on our website, https://htw.com.au/. This statement replaces all previous HTW Privacy Policies
How to make a complaint
We take your privacy concerns seriously and are committed to resolving any complaint you may have. If you have a complaint regarding our handling of your personal information or concerning our information handling practices, you may file a complaint with our Privacy Officer using the contact details set out at the bottom of this Privacy Policy. Our Privacy Officer will respond to you within a reasonable time to confirm receipt of your complaint and inform you of the next steps. If our Privacy Officer believes an investigation is necessary, we will open an investigation into your complaint. Our Privacy Officer may need to contact you to verify your identity or request further details of your complaint. If an investigation has been opened following a complaint made by you, our Privacy Officer will contact you with the result of that investigation as soon as possible.
If you believe that we have not fulfilled our obligations under the Privacy Act or you do not agree with a decision that we have made in relation to accessing or updating your personal information, you can make a complaint to the Office of the Australian Information Commissioner:
Address: GPO Box 5218 Sydney NSW 1042
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au
Contact details
If you have a question or comment about this Privacy Policy or our information handling practices, or wish to make a complaint or exercise your privacy rights, please contact our Privacy Officer on the following details:
Address: PO Box 61 Chermside South QLD 4032
Email: nationaloffice@htw.com.au
Phone: +61 7 3319 4400
This Privacy Policy was last amended 30 May 2024.
