Titan Partners is a privacy conscious organisation. This policy demonstrates our commitment to your privacy. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APP) set out in the Privacy Act.

 

From time to time, Titan Partners is required to collect, hold, use and/or disclose personal information relating to individuals (including, but not limited to, its clients, contractors, suppliers and employees) and Titan Partners data and information in the performance of its business activities.

 

"Personal information" means any information or opinion about an individual whose identity is

apparent, or can reasonably be ascertained, from the information or opinion and:

 

• which may be true or untrue;

• which may be recorded in a material form or otherwise; and

• which is received, created, held, or otherwise handled during the course of, or in

connection with, your employment by us.

 

“Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinion, membership of political association, religious beliefs or affiliations, philosophical beliefs, member membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information.

 

Employee Records Exemption

 

This policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record.

 

An employee record is a record of personal information relating to the employment of an employee. The exemption applies if organisations act, or practice is directly related to:

 

• Either a current or former employment relationship between the employer and the individual

• An employee record held by the organisation relating to the individual

 

Please see the Act for examples of employee records.

 

Collection of Personal and/or Sensitive Information

 

Titan Partners only collects information that is reasonably necessary for one or more of its business functions or activities by lawful and fair means.

 

Titan Partners may also collect, hold, use and/or disclose information if consent is obtained, or if required or authorised under law.

 

Titan Partners and its employees will take such measures (if any) as are reasonable in the

circumstances to ensure that the personal information that it collects and has access to is accurate, up-to-date, and complete.

 

The information Titan Partners collects about you depends on the nature of your dealings with the company and what you choose to share with us. The information we collect may include:

 

• Name

• Mailing or residential address

• Date of birth

• Email address

• Phone number

• Bank account details

• Next of kin/ emergency contacts

 

In some circumstances, Titan Partners may need to collect sensitive information about you. If we collect sensitive information we will do so with your consent, and only if it is necessary and relevant to your engagement with us.

 

Security of Information

 

Titan Partners will take all reasonable steps to protect the personal and/or sensitive information it holds from misuse, interference, loss and from unauthorised access, modification, or disclosure. The security of information is of upmost importance, and should not be stored on thumb drives or devices that can be easily misplaced or lost.

 

Reasonable steps will depend on the circumstances, and are relevant to the nature of our business, however these may include both technical and organisational measures such as implementing two factor authentication processes, strong passwords, physical security measures, staff training and security procedures, as appropriate.

 

Where Titan Partners no longer needs personal information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy and information or ensure that it is de-identified.

 

If you have any questions or concerns regarding privacy at Titan Partners, please contact the Privacy Officer using the contact details below.

 

Employee Obligations

 

Under the Corporations Act 2001 (Cth) and Privacy Act 1988 (Cth) obligations are imposed on all employees, these include:

 

• take such steps as are reasonable in the circumstances to notify the individual that information is being collected;

• not to make improper use of information acquired by you by virtue of your position so as to gain personal advantage (or advantage to anyone else) or cause detriment to Titan Partners or the owner of the information; and

• not to allow unauthorised or improper publication of information which may be protected under the Corporations Act 2001 (Cth) or Privacy Act 1988 (Cth).

 

All employees agree that if they collect or handle any personal information, they must do so in a way that complies with:

 

• all laws regulating privacy and confidentiality which apply to us; and

• all of our policies and all of our reasonable directions to you.

 

Automated Decision-Making

 

“Automated decision-making” means any technology that processes personal information and uses computation to make or execute a decision (without a human decision-maker) or substantially and directly assist human staff to make decisions, where the decision could reasonably be expected to significantly affect the rights or interests of an individual. Such technology may include but is not limited to artificial intelligence (AI), machine learning (ML) and/or data analytics.

 

At Titan Partners, these systems may be used in various areas such as recruitment, performance evaluations, payroll and compensation, employee promotions and transfers and/or scheduling and shift management.

 

This policy ensures that the use of automated decision-making is transparent, fair, accountable, and respects the rights and privacy of all individuals involved, including employees, contractors, clients, and third-party vendors associated with Titan Partners. Titan Partners is committed to aligning its automated decision-making systems with the APP, focusing on the following key principles:

 

Transparency: Employees and stakeholders will be clearly informed when automated decision-making processes are in use. This includes a thorough explanation of the system’s purpose, the data involved, and what and/or how decisions based on the information are made.

 

Fairness: Automated decisions will be made impartially, avoiding any discrimination based on age, gender, race, ethnicity, religion, disability, or any other protected characteristic as outlined in Australia’s federal anti-discrimination laws.

 

Accuracy: The data used in decision-making will be accurate, current, and complete. Titan Partners will take all reasonable steps to ensure that information collected is reliable, relevant, and strictly necessary for the company’s functions or activities.

 

Accountability: Automated decisions will be subject to human oversight and review. In the event of disputes or errors, employees will have access to a process for addressing and correcting decisions made by automated systems.

 

Security and Data Protection: Titan Partners is committed to safeguarding the secure collection, processing, and storage of personal data. Regular reviews and security risk assessments of automated systems will ensure that reasonable steps are taken to protect information from misuse, interference, loss, or unauthorized access, modification, or disclosure.

 

The organization will keep up-to-date with evolving laws and regulations surrounding automated decision-making and make adjustments to the policy as needed.

 

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Disclosure

 

Titan Partners may disclose your personal information in accordance with this policy and

circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:

 

• Third party services providers such as IT, HR or payroll providers

• Marketing provides

• Other professional services advisors

 

Breaches

 

A breach is defined as when information held by an organisation is accessed by someone else without authority. Any breaches of this Privacy Policy will be investigated and treated seriously.

 

Any breach or suspected breach must be reported to Titan Partners management. Titan Partners management will then report known or suspected breaches to the Office of the Australian Information Commissioner as required.

 

Unauthorised disclosure of information by an employee may result in termination of employment.

 

One exception to this Policy is where the disclosure is reasonably necessary for the enforcement of the law.

 

Questions and complaints

 

If you have any questions or concerns regarding your privacy, or if you would like to make a complaint about a possible breach of this Privacy Policy or the Australian Privacy Principles, you may direct your correspondence to the General Manager.

 

We take all complaints seriously and will respond to your complaint within a reasonable period.

 

If you believe that we have not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner whose contact details are as follows:

 

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

t: 1300 363 992

e: enquiries@oaic.gov.au

 

Additional information

 

For further information about privacy and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.