Our privacy commitment
At NewSky Consulting, we respect your privacy and are committed to handling your personal information in a way that is consistent with the Privacy Act 1998 (Cth) and the Australian Privacy Principles.
About this policy
- the kinds of personal information that we collect and hold;
- how we collect and hold personal information;
- the purposes for which we collect, hold, use and disclose personal information;
- how you can access the personal information that we hold about you and seek to have it corrected; and
- how you can complain about the way that we have handled personal information.
NewSky Consulting offers consulting and coaching in the areas of leadership, team and system dynamics.
You can find out more information about us and services by visiting our website at www.newskyconsulting.com.au.
Changes to this policy
Key terms used in this policy
In this policy:
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
Sensitive information is a subset of personal information and means:
- information or an opinion about an individual’s:
- racial or ethnic origin;
- political opinions;
- membership of a political association;
- religious beliefs or affiliations;
- philosophical beliefs;
- membership of a professional or trade association;
- membership of a trade union;
- sexual orientation or practices; or
- criminal record;
that is also personal information;
- health information about an individual;
- genetic information about an individual that is not otherwise health information;
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- biometric templates.
We, us, and our means Katrina Johnson t/a NewSky Consulting ABN 93 717 134 132.
You and your means any individual about whom we collect personal information.
The kinds of personal information that we collect and hold
We may collect and hold information about a range of persons that we encounter, including:
- clients, prospective clients and their employees and related parties;
- suppliers, prospective suppliers and their employees and related parties;
- contractors, prospective contractors and their employees and related parties;
- prospective employees, volunteers and other workers; and
- individuals that visit our website.
We will only collect and hold personal information that is reasonably necessary for our functions or activities as a consultancy and coaching business.
We will only collect and hold sensitive information if you consent to the collection of the information and the information is reasonably necessary for our functions or activities.
The kinds of personal information that we may collect depends on the nature of your interaction with us and may include:
- your name;
- your contact details, including email address, street address, mailing address and/or telephone number;
- your organisation, occupation and job title;
- your signature;
- your age and/or date of birth;
- your preferences and/or opinions;
- your credit card or payment details (through our third-party payment processor);
- photographs, video or audio recordings of you;
- information you give us in the course of your relationship with us as a client, prospective client, employee of a client, supplier, prospective supplier, contractor, prospective contractor, prospective employee, volunteer or other worker, or visitor to our website;
- information we obtain from you or any third party in the course of us performing our functions or activities;
- de-identified information about your access and use of our website, including the date and time of your visit, which pages you visit, the internet protocol address assigned to your device, your internet services provider, the documents downloaded, links from other sites that you visit to reach our website and the type of browser you use; and
- de-identified information about your access and use of electronic publications that we may send to you, including if and when you opened the publication and if and when you click on a link in the publication.
The kinds of sensitive information that we may collect includes:
- health information (for example, in the context of providing individual coaching or mentoring to you or if you register for an event, function or activity and we ask you for information about your health, any disabilities and special dietary needs); and
- philosophical beliefs in the context of providing individual coaching or mentoring to you.
If you choose not to provide this information to us:
- we may not be able to provide you with goods or services or it may affect the goods or services that we are able to provide to you;
- it may affect your use of our website and associated applications; and
- we may not be able to otherwise interact with you.
How we collect personal information
Generally we will collect personal information directly from you.
This may include:
- when you interact with us in person or via telephone, SMS, online chat services, our website or other electronic means;
- when you write to us (including via email);
- when you complete a form, survey or questionnaire;
- when you subscribe to one of our publications; or
- when you register for or attend one of our events, functions or activities.
We may also collect personal information:
- from our related entities;
- from publicly available records;
- from marketing mailing lists and other public information;
- from third parties, such as suppliers and contractors who assist us to operate our business, regulatory or credit reporting agencies, your employer or contracting organisation, referees, and referrers;
- from social media or networking sites where that information is public;
- via cookies, web beacons and other tracking technologies used on our website and through email;
- via analytics tools such as Google Analytics; and
- via social media widgets and applications.
A bit more about cookies, web beacons and other tracking technologies
Cookies are text files placed in your device’s browser to store your preferences. They can be used to manage your internet sessions, personalise offerings and track your online activities. Web beacons are small pieces of code placed on a web page or through email to monitor the user’s behaviour and collect data about the user’s viewing of a web page or email.
You can tailor your experience with these technologies via the privacy and browser settings on your device or by rejecting the associated cookies.
A bit more about analytics tools
We may use analytics tools such as Google Analytics to collect data about how users use our site. We may also use analytics tools built into applications such as Dubsado, Mailchimp and bitly to collect data about how you interact with our documents and email communications.
Google has developed the Google Analytics Opt-out Browser Add-On which enables website visitors to prevent their data from being used by Google Analytics. More information can be found here: https://tools.google.com/dlpage/gaoptout
A bit more about social media widgets and applications
Some of our websites and services may include functionality to enable information sharing via third party social media applications, such as the Facebook, LinkedIn and Twitter widgets. These social media applications may collect and use information regarding your use of our website. Any personal information that you provide via such social media applications may be collected and used by members of that social media application separate to us and are subject to the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.
Information from third parties
If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
How we hold personal information
We hold personal information in both hard copy and electronic formats and use reasonable physical and electronic security measures to keep your personal information secure from misuse, interference, loss or unauthorised use or disclosure.
We cannot however guarantee the security of your personal information. The internet is not a secure environment. The transmission and exchange of personal information via the internet is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. You are encouraged to exercise care in sending personal information via the internet.
We also have policies and processes in place which govern document retention and destruction. We endeavour to ensure that personal information is kept as current as possible and that irrelevant or excessive information is deleted, destroyed or de-identified where and when it is no longer required by us. However, some personal information may be retained by us for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.
The purposes for which we collect, hold, use and disclose personal information
We may collect, hold, use or disclose personal information for the following purposes:
- to contact and communicate with you;
- to provide you or someone you know with goods or services;
- to arrange third party goods or services on your behalf or to refer you to a third party;
- to verify your identity;
- to process and respond to requests, queries, complaints and feedback;
- to invite you to events, functions and activities that we may hold;
- to provide you with information, updates, alerts, newsletters and articles that may be of interest to you
- to conduct surveys or to seek your feedback;
- to market our products and services to you;
- for record-keeping, invoicing, accounting and related administration purposes;
- to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
- to improve our products and services;
- for purposes related to our recruitment, employment or engagement of personnel, including employees, contractors, volunteers and other workers
- for training employees, contractors, volunteers and other workers;
- to enable you to access and use our website, associated applications and associated social media platforms;
- to prevent and detect security threats, fraud or other malicious activity;
- to conduct data analysis and audits;
- for market research and business development purposes;
- to comply with applicable laws and our other regulatory, accounting, reporting or professional obligations;
- to protect, exercise or defend our legal rights;
- for business purposes such as part of an actual (or proposed) acquisition, disposition, merger or de-merger of our business or entering into an alliance, joint venture or referral arrangement; and
- for any other purpose considered necessary or desirable by us (acting reasonably) in relation to the operation of our business.
If you do not want to receive invitations, updates, alerts, newsletters, articles or marketing correspondence from us you can opt out at any time using the contact details set out below or by using the opt-out facilities provided in the communication.
Who we may disclose personal information to
We may also disclose personal information to:
- specific third parties authorised by you to receive information held by us;
- third parties to collect and process data, such as Google Analytics or other relevant businesses;
- a purchaser of the assets and operations of our business providing those assets and operations are purchased as a going concern;
- courts, tribunals, government agencies, regulatory bodies and law enforcement agencies as required by law, in connection with any actual or prospective legal proceedings or in order to establish, exercise or defend our legal rights; and
- law enforcement agencies where your activities suggest possible illegal activity or harm to others.
Some of these third parties to whom we have disclosed personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies. They may also receive or store your information in overseas locations.
In some cases we engage third parties to host electronic data (which may include personal information) on our behalf. These third parties may host the data in Australia or overseas.
By providing us with personal information you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act 1998 (Cth) and the Australian Privacy Principles. You acknowledge that some overseas recipients may not be regulated by the Privacy Act 1998 (Cth) and the Australian Privacy Principles and that you may not be able seek redress against them for any acts or omissions that contravene these laws.
How you may access and seek correction of personal information that we hold about you
In most cases, you may have access to personal information that we hold about you.
We will handle requests for access to your personal information in accordance with the Privacy Act 1998 (Cth) and the Australian Privacy Principles.
All requests for access to your personal information must be directed to us by email using the email address provided below or by writing to us at our postal address provided below. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us to retrieve your information, but in no case will we charge you a fee for your application for access.
In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:
- be unlawful;
- have an unreasonable impact on another person’s privacy; or
- prejudice an investigation of unlawful activity.
We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.
If we refuse to give you access, we will provide you with reasons for our refusal.
We will correct any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.
How you may complain about a breach of this Policy and how we will deal with such a complaint
If you have a complaint about how we have managed your personal information you must submit your complaint in writing to the email or postal address below. We will respond to you within a reasonable time of receiving your written complaint (usually 30 days). If we fail to resolve your complaint, you may raise your complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).
A warning about third party websites
20 December 2021