Privacy Policy
CPM Reviews undertakes reviews and investigations of workplace behaviour, ethics, administrative actions and employment decisions for the public sector and other organisations. The CPM Reviews team has experience across a wide range of employment areas, with many reviewers having previously occupied senior management, legal and human resource positions.
CPM Reviews Pty Ltd (ABN: 93 151 808 374) is registered and wholly based in Australia.
CPM Reviews attaches high priority and importance to the privacy and confidentiality of its clients, including that of persons involved in its reviews and investigations.
CPM Reviews is bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). The APPs are designed to protect the confidentiality of information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and managed. Personal information is, generally, information relating to an identified, or reasonably identifiable, individual. This policy explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about this information.
Why do we collect personal information?
We collect personal information about our clients, stakeholders, persons involved in reviews or workplace investigations conducted by us, to conduct our business activities and meet legal obligations.
What personal information do we collect?
"Personal information" is information we hold which is identifiable as being about you. The types of personal information we may collect include contact information (such as your name, address, email address, fax and telephone number), information about you provided by your employer or the organisation that has oversight for workplace conduct or matters complained about, information that you provide to us (orally, in writing or electronically) in the course of our business, or information provided by another party involved in a contracted matter we are lawfully involved in. Sometimes our activities require us to collect sensitive information.
Personal information may be collected by CPM Reviews in the course of conducting our business where information is relevant to or contained in material provided to us as part of conducting our contracted activities. Personal information may be provided to us and collected by way of forms filled out by individuals, surveys, emails, telephone conversations, face-to-face meetings and interviews and other discussions that may be recorded in writing or electronically.
We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.
You may in some circumstances have the option of not identifying yourself or using a pseudonym when you deal with us if there are lawful reasons for you to do so.
How might CPM Reviews use and disclose your personal information?
CPM Reviews may use and disclose your personal information for the primary purpose of conducting our contracted business. We may disclose your personal information to enable us and our reviewers to comply with our contracted functions.
We may disclose your personal information to our employees, officers, insurers, professional advisers or a subcontractor, insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services or for other legally required purposes. We do use the services of a professional transcription provider to transcribe some of the interviews we conduct with individuals. Our provider is Australian based and complies with the Privacy Principles.
We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
Information that we collect may from time to time be stored, processed in or transferred between parties located in Australia as part of conducting our contracted activities.
By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, the third party will be either already be contractually obligated to deal lawfully with that information or we will request that the third party follow this Policy regarding handling your personal information.
We do not sell or license your personal information to third parties.
Generally, CPM Reviews will retain your personal information within Australia and not use or disclose it overseas. However, on some occasions the personal information may need to be transferred overseas in order to perform one of our functions or activities – for example, where your employer is part of an overseas owned company it may be that we are required to provide some information to the parent entity.
Some of the information we collect in the course of our contracted business activity may be ‘sensitive information’ - including information or an opinion about an individual's health, racial or ethnic origin, political opinions, membership an association, religious beliefs or affiliations, membership of a professional or trade association or membership of a trade union that is also personal information, among other things.
CPM Reviews may use and disclose your sensitive information for the primary purpose of collection as part of a review or investigation, or for reasonably expected secondary purposes which are directly related to the primary purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Act (eg where required or authorised by law to be disclosed, or where disclosure is necessary to prevent a threat to life, health or safety).
Security and management of personal information
CPM Reviews takes reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure.
The ways we do this include:
- limiting physical access to our premises;
- limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access);
- requiring any third-party providers to have acceptable security measures to keep personal information secure; and
- putting in place physical, electronic, and procedural safeguards.
If we no longer require your personal information and are not legally required to retain it, CPM Reviews will take reasonable steps to destroy or permanently de-identify the personal information.
Additional Privacy Obligations
When CPM Reviews performs services under contract for Commonwealth and State government and some other entities, we are often contractually obligated to meet privacy provisions specified by those clients. When requested in writing, and where permitted by law, we will endeavor to provide you with a copy of those provisions.
Accessing the information we hold about you
Under the APPs, you may be able to obtain a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard. A small administrative fee may be payable for the provision of information.
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete or irrelevant, please write to our Privacy Officer at CPM Reviews Pty Ltd, PO Box 201, Deakin West, ACT 2600 or email us at enquiries@cpmreviews.com.au.
Complaints
If you have any complaints about our privacy practices, please feel free to bring your complaints to our attention by contacting our Privacy Officer (see below for contact details).
Contact us
Any complaints or correspondence in relation to this Privacy Policy should be sent to our Privacy Officer at:
CPM Reviews Pty Ltd,
PO Box 201, Deakin West, ACT 2600
or email to the Privacy Officer via enquiries@cpmreviews.com.au.
We take complaints very seriously and we will endeavour to respond to all complaints and correspondence promptly after receiving written notice of your complaint.