Privacy Policy
This Privacy Policy sets out the approach which Pharos Coaching will take in relation to the treatment of Personal Information. It includes information on how Pharos Coaching collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how Pharos Coaching makes the Personal Information it holds available for access to and correction by the individual.
This policy has been prepared having regard to Pharos Coaching' obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act).
'Individual' includes persons and organisations.
1. Collection
1.1 Pharos Coaching will only collect Personal Information where the information is necessary for Pharos
Coaching to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 Pharos Coaching collects Personal Information primarily to advise potential clients of our services or to supply clients with services. Pharos Coaching also collects and uses Personal Information for secondary purposes including:
(i) billing and account management;
(ii) business planning and product development; and
(iii) to provide individuals with information about the services of organisations with which Pharos Coaching has close commercial ties and which supply services related to those of Pharos Coaching or which supply services to Pharos Coaching, and which have privacy policies similar to these.
1.3 Pharos Coaching will sign non-disclosure agreements with potential or actual clients prior to collecting information beyond basic contact and organisational structure information, excepting where the potential or actual client waivers the need for a non-disclosure agreement.
2. Use
2.1 Pharos Coaching uses Personal Information primarily for the purposes listed in 1.2 above..
2.2 Pharos Coaching will not use Sensitive Information for Direct Marketing.
2.3 Pharos Coaching may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.4 Pharos Coaching will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3. Disclosure
3.1 Pharos Coaching may disclose Personal Information to related or unrelated third parties for secondary purposes. Pharos Coaching will not disclose Sensitive Information for secondary purposes
3.2 Pharos Coaching may disclose Personal Information between Related Bodies Corporate. Where information is disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
3.3 Pharos Coaching may disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing), where that is disclosure or use for a related Secondary Purpose disclosed under 1.3 above.
3.4 Pharos Coaching will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the use and disclosure requirements of the Privacy Act.
3.5 Pharos Coaching may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 Pharos Coaching may disclose Personal Information to avoid an imminent threat to a person's life or to public safety.
3.7 If a disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Pharos Coaching will not disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
4. Information security
4.1 Pharos Coaching requires employees and contractors to perform their duties in a manner that is consistent with Pharos Coaching's legal responsibilities in relation to privacy.
4.2 Pharos Coaching will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Pharos Coaching who have a genuine "need to know" as well as "right to know".
5. Access and correction
5.1 Pharos Coaching will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
5.2 Pharos Coaching will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
5.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting their primary Pharos Coaching contact.
5.4 Pharos Coaching will not charge a fee for processing an access request unless the request is complex or is resource intensive.
6. Openness
6.1 Pharos Coaching websites will contain a prominently displayed privacy statement and will include a copy of this Pharos Coaching Privacy Policy.
7. Glossary
Pharos Coaching means Pharos Coaching Pty Limited, ABN 37 120 374 889
Direct Marketing means the marketing of services through means of communication including written, verbal or electronic means. The services which are marketed may be those of Pharos Coaching or an organisation with which Pharos Coaching has close commercial ties or those of an independent third party organisation.
Disclosure generally means the release of information outside Pharos Coaching, including under a contract to carry out an "outsourced function".
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual's expectation that their personal information might be used or disclosed for the particular purpose.
Related Body Corporate means that where a body corporate is:
a holding company of another body corporate;
a subsidiary of another body corporate; or
a subsidiary of a holding company of another body corporate,
the first mentioned body corporate and the other body corporate are deemed to be related to each other.
Sensitive Information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record; that is also personal information
(b) information about an organsiation's:
(i) strategies and commercial activities that are not public knowledge
(ii) financial information that is not subject to disclosure under company laws and regulations
(iii) business and product development concepts and activities
(iv) market and competitive information that has been acquired at a cost or through privileged channels and is not in the public domain
(v) internal policies, processes, information systems, competencies, programs and projects that create or are intended to create competitive or commercial advantage to the organisation
(vi) personnel policies, individual remuneration packages, or related plans and contracts
(vii) contributions to political and charity organisations
Use means the handling of Personal Information within Pharos Coaching.
Contacting Pharos Coaching:
If you require further information regarding Pharos Coaching' Privacy Policy, you can contact Pharos Coaching on:
Telephone: 1300 778 878
Fax: 1300 778 868
