What is your personal information?
What personal information do we collect and hold?
We may collect the following types of personal information:
Mailing or street address;
Email address, telephone and facsimile numbers;
Mobile phone number;
Age or birth date;
Profession, occupation or job title;
ACN or ABN numbers;
Web site address;
Details of the products and services you have purchased from us or our customers (on whose behalf we may provide products or services) or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
Credit card details;
In the case of Forrest Marketing Group’s website, how you use the website, and information regarding your browsing activity when you visit the website;
Any additional information relating to you that you provide to us directly through our website or indirectly through use of our website or online presence, through our representatives or otherwise; and
Information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.
It is important to appreciate that much of the personal information we collect and hold is done so by us when we are acting as the “agent” or service provider of our customer. For example, we operate call centres on behalf of many Australian companies, from retailers to banks and other institutions. When you contact one of our operators at a call centre, or are contacted by one of our operators at a call centre, you may not necessarily be aware that the call centre is operated by Forrest Marketing Group on behalf of our customer. We have set out in the Annexure to this policy some more detail around the information we may collect and hold in respect of each of our key businesses. Please read this carefully.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous data or aggregated information about how users use our websites. We do not re-identify this information to turn it into personal information.
How do we collect your personal information?
Personal information is only collected by lawful and fair means in accordance with the Act. We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
Directly from you via business cards, details provided in correspondence, over the telephone or when submitted by a form on one of our web sites;
Through your access and use of our website;
From third parties such as our related companies;
From your representatives;
During conversations between you and our representatives;
During correspondence between you and our representatives, including electronic correspondence;
Through your use of telephone and mobile communication (including but not limited to fixed line IVR services, SMS and MMS);
When you complete an application, contract or purchase order;
From publicly available sources of information; or
When legally required to do so.
Some of the personal information Forrest Marketing Group holds or deals with is not actually collected by Forrest Marketing Group. Because Forrest Marketing Group is an outsourced service provider, much of the data and personal information it deals with is provided to it by its clients, and has not actually been directly collected by Forrest Marketing Group from the individual concerned.
It is impracticable for us to collect information directly from you when we are acting as the “agent” or service provider of our client, our client has already collected the relevant information from you (or another third party), and our client has provided it to us for our use in providing services to or on behalf of our client.
For example, we act on behalf of customers in sending email and SMS communications. To enable us to do so we may use our customer’s database of personal information which our customer has supplied to us. It is impracticable for us to “recollect” this information from you directly before use and as requested by our client.
In respect of personal information which is provided to us by our clients, we do seek client assurances that all such personal information has been collected lawfully and in compliance with the Privacy Act and that all required consents have been obtained for, and disclosure statements made in respect of, the intended use of that personal information. Forrest Marketing Group however will not be responsible for, and accepts no liability in respect of, any failure by a client to do so.
We may also collect personal information from third parties who are not our clients including for example, from third party companies such as data providers and brokers, credit reporting agencies, law enforcement agencies and other government entities.
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information. Additionally, although not strictly cookies, we do have code on our website that uses data gathered from URL changes. This gives us the name of the company who has visited our site, the physical address as well as what pages they have visited and how long they have stayed.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
We may not be able to provide the requested products or services to you, either to the same standard or at all, or we may not be able to supply services to our clients which will enable our clients to do the same; or
We may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions, or we may not be able to supply services to our clients which will enable our clients to do the same; or
We may be unable to tailor the content of our websites to your preferences, or we may not be able to supply services to our clients which will enable our clients to do the same; or
If you are a client of ours, we may not be able to provide you with the products and services you require; or
If you are a contractor to us, you may not be able to provide your services to us.
For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service to you and to enable us to provide products and services to our clients. We collect, hold, use and disclose your personal information for the following purposes, in each case, either on our own behalf or when acting on behalf of a client:
Verify your identity;
Assist you with our products and services;
Provide or improve our service delivery through a range of media;
Administer and manage our services provided to you including charging, billing and collection of debts;
Inform you of ways the products and services provided to you can be improved;
Research and develop our products and services;
Improve our understanding of your business to provide you with better products and services;
Maintain and improve our business systems for improved services and product delivery.
To provide products and services to you and our clients and to send communications requested by you and/or our clients;
To answer enquiries and provide information or advice about existing and new products or services;
To provide you with access to protected areas of our websites;
To assess the performance of our websites and to improve the operation of our websites;
For the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of Forrest Marketing Group, its related business entities, clients, contractors or service providers;
To provide your updated personal information to our related business entities, clients, contractors or service providers;
To update our records and keep your contact details up to date;
To process and respond to any complaint made by you; and
To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).
We may also use your personal information for the other purposes related to those described above which would be reasonably expected by you.
To whom may we disclose your information?
We may disclose your personal information to:
Our employees, related business entities, clients, contractors or service providers for the purposes of operation of our websites or our businesses, fulfilling requests by you, and to otherwise providing products and services to you and our clients including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
Suppliers, clients and other third parties with whom we have commercial relationships, for business, marketing and related purposes; and
Any organisation for any authorised purpose with your express consent.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate. Our clients may do likewise.
Direct marketing materials
We may send you direct marketing communications and information about our products and services that we, or our clients, consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).
At any time you may opt-out of receiving marketing communications from us by contacting us (see details below) or by using the opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list (or where we are using a mailing list provided by our client or other third party, we will pass your request on to that party).
How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be $30 per hour of time spent. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will, where possible and practicable, add a note to the personal information stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.
Our procedure for investigating and dealing with privacy breaches is to ascertain all relevant facts and correspond with those involved (including where relevant our clients), reach a view as to the existence, scope and cause of the issue, and where relevant and appropriate, implement corrective or rectification measures.
A request for access to the personal information held by Forrest Marketing Group concerning an individual can be made by that individual to Forrest Marketing Group’s Privacy Officer on the number or address mentioned below or, in cases where Forrest Marketing Group is acting on behalf of a client, to Forrest Marketing Group’s client. A fee may apply, the amount of which will be advised at the time of application.
Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above.
Except where specific individual consent has been obtained under APP 8.2(b), we take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to entities located outside of Australia, including the following:
Our clients and their related entities located in foreign countries, to the extent that we are acting on their behalf or at their direction in using, storing, or collecting your personal information. Applicable foreign countries include United States of America, Canada, New Zealand, Great Britain and France.
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Please contact our Privacy Officer at:
Forrest Marketing Group Pty Ltd, Suite 2, 277-283 Condamine Street, Manly Vale NSW 2093.
Phone: (02) 9939 6888
Fax: (02) 9949 5548
Specific examples of Personal Information held by Forrest Marketing Group Pty Ltd
|Business Activity||Types of Personal Information held and/or collected|
|Email marketing services, data analysis and management services||Name, address, date of birth, email addresses, other contact information, purchase information, websites visited, purchasing trends, interests, profile information, census data, and other information supplied to us by our clients or data providers and brokers.|
|Call centre services||Name, address, contact details, payment details including bank account details, credit card information, purchase history, purchase trends, enquiries, problems experienced, customer service issues, insurance policy details, referral advisor details, claim information, subscription details, email information, invoices, survey information.|
Where we are given access directly to our clients systems, we have access to the personal information held in those systems. For example, we may operate a call centre for a health provider, retailer, bank etc.
|BPO – back office services||Name, address, contact details, payment details including bank account details, credit card information, purchase history, purchase trends, enquiries, problems experienced, customer service issues.|
Where we are given access directly to our clients systems, we have access to the personal information held in those systems.
Help desk and other customer issues support as required.