Our Policies & Procedures

Policy Statement

JPS Audit Specialists (JPS) is committed to protecting the privacy and confidentiality of all information gathered through certification activities. The Privacy Policy sets out how JPS will ensure the confidentiality of both clients and their clients’ information, during and after certification activities.

Our policy is to respect and protect the privacy of all people connected with JPS, including participants, providers, employees, contractors and community partners. This Privacy Policy tells you the kinds of personal information we collect and hold, how and why we collect and hold that information and how we use it. It also tells you how you can make a complaint if you think that we have breached our privacy obligations.

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Purpose

The purpose of the Privacy Policy is to:

• Ensure proprietary client information (including personal information) is managed in an open and transparent way.
• Protect the confidentiality of personal information, including health information of participants and staff.
• Provide for the fair collection and handling of personal information.
• Ensure that personal information we collect is used and disclosed for legally permitted purposes only.
• Regulate the access to and correction of personal information.;
• Ensure the confidentiality of personal information through appropriate storage and security.
  
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Scope

The Privacy Policy ensures that all staff including directors, senior management, staff, contractors and volunteers will be aware of and will adhere to the requirements of JPS management of the privacy and confidentiality of all client information.

This Policy also confirms for clients that their proprietary information, which is collected or created during certification activities, is maintained in a private and confidential way.

Exceptions to maintaining the confidentiality of client information are:

• When a client makes their information publicly available.
• When there is agreement between JPS and the client to make information available that is pertinent to both parties, for example, for the purpose of responding to complaints.
• When JPS is required by law or through contractual arrangements to release confidential information, the client concerned will be notified of the information provided.

Definitions

Confidentiality: The assurance that written and spoken information is protected from access and use by unauthorised persons.

Personal Information: Refers to information or an opinion, whether true or not, about an individual whose identity is apparent or could be reasonably ascertained from that information or opinion.

Privacy: Freedom from intrusion and public attention.

Proprietary: Relating to an owner or ownership.

Sensitive Personal Information: Includes ethnic or racial origin, political opinions, membership of a political association, religious or philosophical beliefs or affiliations, membership of a professional or trade association, health, sexual preferences, practices or activities and criminal record.

Privacy Information

JPS respects the privacy rights of all individuals and is bound to the principles contained within the Privacy Act 1988 (Cth) and with the associated 13 Australian Privacy Principles (APPs) in the Privacy Act.

What information do we collect?

JPS collects and processes personal data about you when you interact with us and when you purchase services from us. During the provision of our services, including if you access our website, we may collect your personal information. The personal data we process includes:

• Personal information provided by you for use in fulfilling the primary purposes intended, including your name, address, telephone number, email address, job title, your payment and delivery details, including billing and delivery addresses and credit card details. This includes information required to provide clients and others with services.
• Information retained on our database in the form of aggregated statistical data which is information relating to your use of our website and our services, such as traffic flow and demographics and the type of browser or device and operating system you use to access our website. Unless we are informed otherwise, we will continue to use the information collected in this manner. Accuracy of information is important to us and changes or corrections to information held will be welcomed at any time.
• Recordings of calls you make to our customer service team.
• Any other information you provide.

All reasonable steps are taken to protect the security of the personal information held, be it stored in electronic or hard copy form. Except for the reasons given in the APPs, access is available to the person whose information is held, subject to the payment of reasonable expenses incurred in extracting such information.

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How do we use this information and what is the legal basis for this use?

We process the personal data listed in the section above for the following purposes:

• As required, to establish and fulfill a contract with you, for example, if you enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of services.
• To comply with applicable laws and regulations.
• In accordance with our legitimate interests in protecting JPS's legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation).
• With your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our services.
• We may use information you provide to personalise:
• our communications to you
• our website; and
• services for you, in accordance with our legitimate interests.

• To monitor the use of our websites and online services. We may use your information to help us check, improve and protect our content, services and websites, both online and offline, in accordance with our legitimate interests.
• If you provide a credit or debit card, we may also use third parties (such as POS payment providers) to check the validity of the sort code, account number and card number you submit in order to prevent fraud, in accordance with our legitimate interests and those of third parties.
• we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests.
• In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests.
• We may use your information to invite you to take part in market research or surveys.

We may also send you direct marketing. Electronic direct marketing will only be sent where you have given your consent to receive it, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.

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Who do we disclose your personal data to?

We may share your personal data with external agencies such as the Australian Government, the NDIS Quality and Safeguards Commission and relevant State authorities as necessary to carry out the purposes for which the information was collected. We may not use or disclose personal data for a purpose other than the primary purpose of collection.

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We may also share your personal data with the below third parties:

• Our professional advisors such as our auditors and external legal and financial advisors.
• Marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice.
• Market research companies.
• Our suppliers, business partners and sub-contractors.
• Search engine and web analytics.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of JPS for the purposes above. Such third parties include, but are not limited to, providers of website hosting, maintenance, call centre operation and identity checking.

In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

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How long will you keep my personal data?

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a client, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 12 months.

Where you are a prospective client and you have expressly consented to us contacting you, we will only retain your data:

• Until you unsubscribe from our communications or, if you have not unsubscribed.
• While you interact with us and our content, or
• For 12 months from when you last interacted with us or our content.

In the case of any contact you may have with our customer services team, we will retain those details for as long as is necessary to resolve your query and for two weeks after the query is closed.

We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require JPS to hold certain information for specific periods other than those listed above.

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Where is my data stored?

We take all reasonable steps to ensure that the personal information we hold is protected against misuse, loss, unauthorised access, modification or disclosure. We hold personal data in both hard copy and electronic forms in secure databases on secure premises, accessible only by our authorised staff.

Non-current information is archived in secure premises in accordance with our Archiving Policy.

However, we cannot guarantee the security of any personal information transmitted to us via the internet.

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What are my rights in relation to my personal data?

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data:

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• By withdrawing your consent for us to use it.
• If it is no longer necessary for us to use your personal data.
• If you object to the use of your personal data and we do not have a good reason to continue to use it; or
• If we haven't handled your personal data in accordance with our obligations.
  

Where can I find more information about JPS’s handling of my data?

Under the Privacy Act, you have a right to access your personal information that is collected and held by us. If at any time you would like to access or change the personal information that we hold about you, or you would like more information on our approach to privacy, please contact our Privacy Officer.

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To obtain access to your personal information, you will have to provide us proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected. We will take all reasonable steps to provide access to your personal information within 30 days from your request.

If providing you with access requires a detailed retrieval of your personal information, a fee may be changed for the cost of retrieval and supply of information.

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How to contact us

For further information or enquiries regarding your personal information, please contact our Privacy Officer.

In writing:

The Privacy Officer
JPS Audit Specialists

7 Wild Oak Avenue

Armstrong Creek, VIC 3217

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By email:
‍admin@jpsaudit.com.au

Complaints concerning our Privacy Policy

Please direct all privacy complaints to our Privacy Officer at admin@jpsaudit.com.au. At all time, privacy complaints will:

• Be treated seriously.
• Be dealt with as promptly as possible.
• Be dealt with in a confidential manner; and
• May not be used to affect your existing obligations or affect the commercial arrangements between you and us.

Our Privacy Officer or their delegate will conduct the investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. Complaints will be recorded in the Complaints Register and reported in the Complaints Report to the Board.

Alternatively, privacy complaints can be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner (OAIC) receives complaints under the Act.

In writing:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney, NSW 2001

or

Office of the Australian Information Commissioner
GPO Box 2999
Canberra, ACT 2601

Online:
‍http://www.oaic.gov.au/privacy/making-a-privacy-complaint

By telephone:
1300 363 992