Introduction

WSP Services Pty Ltd (“Company”) recognises our reputation is built largely on the ethical behaviours of our People. The Company expects its People to always display the highest standards of professional and personal conduct. We strive to be the best at what we do, meet and exceed our targets, our customer expectations and the expectations of our People.

 

Purpose

The Company is committed to ensuring it’s obligations at law as to the privacy of any personal information that it may collect, hold, use or disclose in conducting business activities.

 

Scope

This policy applies to all individuals who are employed or engaged by the Company, including directors, employees, contractors, and consultants, and those engaged as part of the Company’s supply chain, including suppliers and third-party labour hire providers. (“People”).

 

1. Policy Statement

The Company has implemented this Privacy Policy to provide information about what kinds of Personal Information the Company may collect or hold, how the Company collect, hold, use and disclose that Personal Information, choices People have regarding the Company’s use of that Personal Information, and employee’s ability to access or correct that Personal Information.

From time to time, the Company may be related to other companies and entities (related entities). This Privacy Policy applies to the use of Personal Information by the Company and by:

• any related entity which refers to this Privacy Policy in collecting Personal Information; and
• any other related entity to the extent they handle Personal Information that the Company disclose to them, unless otherwise specified by those related entities.

A reference in this Privacy Policy to the Company is also a reference to those related entities.

 

2. What is Personal Information?

The Company’s "Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

 

3. What Personal Information Do We Collect and Hold?

The types of Personal Information the Company may collect about an individual will depend upon the nature of the interaction. Personal Information that the Company collects may include (but is not limited to) the following:

• name;
• age and/or date of birth;
• contact details including telephone numbers (landline and/or mobile);
• address (including postal address);
• email address;
• identification information such as driving licence details;
• payment and account details, such as credit card or bank account details (for payments to or from us);
• occupation and employment details including employment status and any previous work experience;
• information from or in connection with resumes or job applications if People apply for a position with us;
• geographical location;
• Australian Business Number (ABN);
• trade references, credit references or reports from a third-party;
• credit information;
• commercial credit reports;
• photographs and/or images of People from camera footage; and
• information from social media accounts and profiles.

We collect and record Personal Information about individuals such as:

• the Company’s portfolio companies, potential portfolio companies and their representatives;
• the Company’s investors and shareholders;
• the Company’s suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders;
• contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to the Company;
• the Company’s tenants to manage leases we provide;
• the Company’s employees past and present, including applicants; and
• any other person who comes into contact with the Company.

 

4. How and When Do We Collect Personal Information?

The Company collects Personal Information to allow the Company to conduct the Company’s business functions, to provide, market and sell the Company’s products and services and for the specified purposes set out in herein. In some circumstances the collection of Personal Information may be required by law.

The Company may collect Personal Information in the course of providing goods or services, or:

• when People receive or use the Company’s services;
• when People provide the Company, or People offer or apply to supply the Company, with goods or services;
• when People provide information to the Company in any way (including by completing a form, disclosing information over the phone or via email, or providing the Company a business card);
• when People request information about the Company or the Company’s services;
• when People visit or fill in a form on the Company’s Website;
• when People visit premises from which the Company operates;
• when People (or an employer) provide that information to the Company in the course of conducting or administering the Company’s relationship with People, or when People are carrying out activities in connection with the Company’s business operations;
• when People apply for or enter into a lease with the Company;
• when People submit a job application to the Company;
• when People otherwise contact the Company by telephone, fax, email, social media, post or in person; or
• where the Company is otherwise required or authorised by law to do so.

Generally, when providing the Company’s products and services, dealing with the Company’s employees, or obtaining goods and services from the Company’s service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

The Company may also collect Personal Information about People from third parties and other sources such as:

• nominated representatives (e.g. spouse accountant, power of attorney, brokers and other professional advisors);
• publicly available sources of information;
• related entities, companies and businesses of the Company; or
• credit reporting bodies who provide information about commercial credit worthiness,

but the Company will only collect Personal Information in this way if it is unreasonable or impracticable to collect this information directly from People or if the Company is otherwise permitted to do so.

If the Personal Information the Company collects includes sensitive information, including health information, the Company will seek consent to collect such sensitive information, unless the law allows the Company to collect it without consent.

Where the Company engages with People multiple times over a short period in relation to the same matter, the Company may not provide a separate notice about privacy each time the Company engages with People.

If People choose not to provide Personal Information to the Company for the purposes set out in this Privacy Policy, or if the Company is unable to collect the Personal Information the Company requires, the Company may not be able to provide People with requested information, products or services, or to effectively conduct a relationship with People.

 

5. Information Collected via Company Website

Personal information may be collected by the Company and by our third-party service providers who assist us in operating the Company’s website at www.wspservices.com.au including its subdomains and any other website the Company operates from time to time (collectively the Website).

The Company may use various technological methods from time to time to track the visiting patterns of individuals accessing the Website, including but not limited to the methods set out herein.

 

6. Click Stream Data

When People read, browse or download information from the Website, the Company or the Company’s internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address a computer, and any information downloaded. This information is used for statistical, reporting and website administration, maintenance and improvement purposes.

 

7. Cookies

The Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. The Company uses this information to enhance the content and services offered on the Website.

Cookies may also be used for other purposes on the Website.

If People disable the use of cookies on a web browser or remove or reject specific cookies from the Website or linked sites then People may not be able to gain access to all of the content and facilities in those websites.

 

8. Third-Party Content (e.g. Social Media Links)

Some of the content on the Website may include applications made available by third parties, such as social media buttons or links that allow People to share content or links to the Website through relevant third-party platforms.

These third-party applications themselves may facilitate collection of information by those third parties. The Company is not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third-party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

 

9. How Do We Use Personal Information?

The Company uses the Personal Information the Company collects about People for the Company’s business functions and activities, in order to operate the Company’s business efficiently, and to promote the Company’s services. The Company may collect, hold and use Personal Information:

• to identify and communicate with People;
• to enable the Company to provide People with requested information or services;
• to manage leases;
• to enable the Company to manage portfolio companies including trustees/trusts and companies;
• to otherwise assist portfolio companies by providing them with information and support;
• to collect and process payments;
• to help the Company to manage and enhance products or services the Company;
• to help the Company to manage and enhance goods and services the Company procures from suppliers and subcontractors;
• to help the Company manage and respond to a general or specific shareholder enquiry;
• to process share applications and service shareholders' needs;
• to provide facilities and services a shareholder may request;
• to carry out appropriate administration in relation to shareholders and share registry, including to submit listing applications to, or respond to enquiries from, corporate regulators;
• to manage and administer any account or lease People may hold with the Company;
• to carry out credit checks in respect of the Company’s tenants and potential tenants;
• to carry out debt recovery functions;
• to protect People and the Company from fraud;
• to provide for the safety and security of workers and onsite visitors;
• to help the Company manage business operations;
• for business support purposes including maintenance, backup and audit;
• to process any job application submitted;
• to respond to any queries or complaints People may have; or
• to comply with the Company’s statutory and legal obligations.

The Company may aggregate Personal Information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows the Company to better inform ourselves and anticipate portfolio companies' preferences and requirements, and to monitor and improve the effectiveness of the Company’s business, products and services. The Company may also de-identify information for inclusion in such aggregated databases or reports.

The Company reserves the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but the Company has no obligation to monitor the use of the Website or to retain the content of any user session.

People consent to the Company using their Personal Information in the above ways and as set out in this Privacy Policy.

The Company may otherwise collect, use or disclose Personal Information where the collection, use or disclosure is:

• in accordance with this Privacy Policy or any agreement People enter into with the Company; or
• required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

 

10. When does the Company disclose Personal Information?

The Company may disclose or provide access to Personal Information to third parties in connection with the purposes described in paragraph 7. Depending on the circumstances and the nature of engagement with the Company, the Company may disclose Personal Information to our related entities, to third parties that provide products and services to the Company or through the Company, or to other third parties (such as referees) in connection with a job application submitted).

We may also disclose Personal Information to:

• any of the Company’s internal divisions, business units or departments;
• nominated representatives;
• other organisations or individuals who assist in providing products and services;
• professional service providers and advisors who perform functions on the Company’s behalf, such as lawyers;
• medical providers including medical and rehabilitation practitioners for assessing insurance claims;
• representatives, agents or contractors who are appointed by the Company in the ordinary operation of our business to assist us in providing goods or services or administering the Company’s business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development);
• credit reporting bodies and mercantile reporting agencies in order to assess credit worthiness of our tenants;
• debt collecting agencies;
• banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers; and
• Government, regulatory authorities and other organisations as required or authorised by law.

The Company may also disclose Personal Information to the Company’s Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

As the Company continues to develop the Company’s business, the Company may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of the Company’s business or assets are sold or transferred to a third-party, the Company may also disclose certain information including Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of the Company, the Company’s business or any of the Company’s assets, including in insolvency.

 

11. Overseas Disclosures

Some Personal Information may be disclosed, transferred, stored, processed or used overseas by the Company, or by third-party service providers. This may happen if:

• the Company’s offices or related entities are overseas;
• the Company outsources certain activities overseas;
• transactions, information, services or products have an overseas connection; or
• the Company’s computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

 

12. Other Uses and Disclosures

The Company may collect, use and disclose Personal Information for other purposes not listed herein. If the Company does so, the Company will make it known to People at the time the Company collects or uses their Personal Information.

 

13. Marketing

People consent to the Company using Personal Information for sending them information, including promotional material, about us or our services, as well as the services of our related entities, now and in the future. People also consent to us sending them such information by means of direct mail, email, SMS and MMS messages.

If People do not want to receive marketing information, they can unsubscribe by contacting us using the contact details specified in paragraph 15.

 

14. Storage and Security of Personal Information Held By Us

The Company aims to keep all Personal Information secure. Any Personal Information that is collected via our Website or which is held on the Company’s computer systems is protected by appropriate safeguards.

If the Company finds that the Company no longer requires or have no further need for Personal Information the Company may de-identify it or remove it from the Company’s systems and destroy all record of it.

 

15. Accessing and Updating Personal Information

People are generally entitled to access Personal Information that the Company holds about them. If People request access to their Personal Information, in ordinary circumstances the Company will give full access to their Personal Information. Depending on the nature of the request, the Company may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If the Company refuse a request to access Personal Information, the Company will provide reasons for the refusal where the Company are required by law to give those reasons.

A request for access can be made by contacting our Privacy Officer in any of the ways specified in paragraph 15.

 

16. How We Deal with Complaints About Privacy?

If People feel that the Company has not respected their privacy or that the Company has conducted itself inconsistently with this Privacy Policy, please contact our Privacy Officer in any of the ways specified in paragraph 15 and advise us as soon as possible. We will investigate queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist the Company to respond to complaints promptly if made in writing.

The Company will notify relevant parties of the outcome of any investigation.

 

17. Accessing Information and Contacting Us

Please contact us if you would like to seek access to or correct the personal information we hold:

By Mail:
Privacy Officer
WSP Services Pty Ltd
12/257 Colchester Road,
Kilsyth VIC 3137

By email:
admin@wspservices.com.au

Subject to the Privacy Act, we will, if practicable, generally provide access to personal information and will take reasonable steps to amend any personal information about People which is inaccurate or out of date. We will provide reasons if People cannot access their personal information, or the information cannot be updated.

 

18. Updates to this Policy

The Company may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by the Company will be governed by our most recent Privacy Policy, posted on our website at www.wspservices.com.au where the Privacy Policy will be located. Any changes to this Privacy Policy may be advised by updating this page on our website. The Company encourage People to check this page from time to time for any changes.

 

19. Approval

This policy and any variations must be approved by Managing Director

This policy supersedes all previous versions.

Approved: Will Shields, Managing Director, April 2024

 

20. Version Control