PRIVACY POLICY

Use of Cookies

Most commercial websites, including this website, use cookies. Cookies are pieces of information that websites send to the browser and are stored in the computer hard-drive. Cookies are designed to make using the website easier by storing information about your preferences on the website. Cookies will not identify you personally.

If you would prefer not to receive cookies, you can alter your security settings on your web browser to disable cookies or to warn you when cookies are being used. However, by disabling the ‘cookie’ function in your web browser you may impede your ability to use parts of the website.

What is your personal information?

“Personal information” is information or an opinion relating to an individual that can be utilised to identify that person.

Your personal information

• Contact information
• Job position or title
• Membership of associations, industry groups, boards or networking groups
• If required, financial information
• If required, health information

The type of personal information we collect and hold about you will vary depending on the nature and purpose of our relationship.

If the personal information you provide to us is inaccurate, or if you choose not to provide us with certain personal information, we may not be able to contact you, give you access to information you have requested or otherwise provide you with the outcome you require from us.

How we collect personal information

Your personal information will be collected by HGS through the website or otherwise through our dealings with you. We will only collect personally identifiable information that you voluntarily provide. You may choose to provide us with personally identifiable information if, for example, you contact us with an enquiry, register on the website, subscribe to our articles, webinars or newsletters, fill out a survey or other form with your personal information included or request us to provide you with information or services. If you are a client, you will be required to provide us with your personal information to allow us to comply with our obligations to you. Some examples of how we collect personal information includes:

• Directly from the source to whom the personal information relates
• From organisations about their employees and contractors
• From organisations about their customers and suppliers
• Marketing purposes, from events, seminars, business associates, potential new clients and other third party sources.
• Contact forms and subscription forms completed by visitors to the HGS website *

Email addresses of HGS staff are not provided as a means for prospective clients contacting or submitting information to us. By clicking the “submit” checkbox and reading this privacy policy, you acknowledge that we have no obligation to maintain the confidentiality of any information you submit to us.

We collect certain information from visitors who access our website, including dates and time of access, IP addresses, browser type, operating system and domain names.

We also collect information via analytics software that can track use of the website. This analytic information can include navigation through the website, number of visits, duration of the visit and the areas of the website commonly used. This analytic information does not identify or disclose any personal information about the visitor and is utilised to improve performance of the website.

This information can also assist us in preventing or detecting fraud or abuses of the website. By visiting the HGS website, you are accepting and consenting to the collection of this information. The information we collect in this way will not personally identify you.

Use and disclosure of personal information

We use personal information collected for a number of reasons. You consent for us to collect, use, disclose and store your personal information for the following purposes, which are related to the purpose for which you provided the information:

• to conduct our business (including through the provision of our services);
• to provide information or market our services that may be of interest to you;
• to communicate with you and manage our relationship with you;
• to purchase from you;
• to facilitate our internal business operations, such as for internal marketing analysis;
• to comply with our legal obligations; and
• to help us manage and enhance our services.

We will disclose your personal information for the purposes for which it was collected and related purposes. You consent that HGS may also disclose your personal information (subject to our professional obligations) to:

• other members of HGS;
• any third parties who assist us in providing services or who perform functions on our behalf (such as mailing houses, specialist consultants and barristers);
• to our external service providers, who assist us in operating our business (subject to the compliance with the NPPs);
• courts, tribunals and regulatory authorities; and
• anyone else who you authorise us to disclose it to.

We do not rent, share or trade personal information.

Cross border disclosure

We will not transfer any personal information to recipients that are not located in Australia, unless:

• We have the consent from the individual to whom the personal information relates
• It complies with the NPP’s.

Consent

It is up to you whether you submit any other personal information regarding your identity when you use our website or other services. By providing your personal information you are deemed to have consented to the collection, use, disclosure and storage of that information as outlined in this privacy notice.

Security

We may hold your personal information in different ways, including in hard copy or electronic form. We have measures in place to ensure that any personal information we hold is secure and protected from misuse, loss, fraudulent activity and unauthorised disclosure.

All information is held in a secure, electronic or physical manner. Information storage methods include access controlled premises or via electronic databases and customer relationship management databases that require logins and passwords.

We take all reasonable steps to protect all personal information that we hold from misuse or unauthorised access.

Access and Accuracy Information

HGS endeavours to ensure that the personal information it holds about you is accurate and up-to-date.

You have a right to view and have a copy of, personal information about you that we hold at any time, unless we are permitted under the Privacy Amendment (Enhancing Privacy Protection) Act 2012 to refuse access. If you are able to establish that personal information we are holding about you is not accurate, complete and up-to-date, please let us know and we will take reasonable steps to correct it so that it is accurate, complete and up-to-date.

If you wish to exercise your right of access and correction, please contact HGS using the details provided below. We may charge you a reasonable fee for processing your request to access your information. Identification will also be required to access personal information.

At any time you may opt out of receiving any communications from HGS

Grievance procedure

If you wish to make a complaint about the way we have managed your Personal Information you may make that complaint verbally or in writing by setting out the details of your complaint to any of the following:

Our Privacy Officer:

Hesper Flores
Dpo.oss@teamhgs.com

Alternatively, complaints may also be referred to a number of services as set out below:

Australian Information Commissioner

The Australian Information Commissioner receives complaints under the Act. Complaints can be made:

Online: https://www.oaic.gov.au/privacy/making-a-privacy-complaint
By phone: on 1300 363 992
By fax: on +61 2 9284 9666

In writing:

Address your letter to the Australian Information Commissioner at the:
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 NSW 2001

How we will deal with your complaint

The complaint will be investigated by us in accordance with our internal procedures and processes.

The complainant may be invited to participate in a conference by the staff member conducting the investigation. At the discretion of the [insert title as applicable ie facility manager] other interested parties may also be invited to participate in the conference to discuss the nature of the complaint and attempt to resolve it. This may include the presence or participation of a support person or advocate for the complainant.

The complainant will be provided with a response to their complaint within a reasonable timeframe after completion of any investigation. This response will be in writing and will include the outcome of the investigation, any proposed action

How to Contact Us

If you wish to contact us about your personal information, to obtain further information about privacy or to lodge a complaint, you should contact our Privacy Officer at the following email address: Dpo.oss@teamhgs.com

For further information, please visit the Federal Privacy Commissioner’s website at www.privacy.gov.au.