Privacy Act

Our business, BPM Bloodstock Pty Ltd, (“we”, “us” and “our”) is bound by the Privacy Act 1988 (the Act) and the Australian Privacy Principles (APP). Our business is an APP entity as defined in s 6(1) of the Act.

We collect and hold personal information relating to our clients/customers and to other people and entities associated with our clients/customers as may be provided or disclosed to us in the course of business (including via access to any system maintained by us or your conduct on any website maintained by us or through third parties). Such personal information may include, but is not limited to, names, addresses, telephone numbers, social media details, email addresses and bank account details.

Personal information is collected from our clients/customers in the following ways:

• by providing it to us directly;
• by authorising third parties to provide it to us;
• by other parties providing it to us either voluntarily or pursuant to compulsory processes we conduct on our client’s behalf.

How is personal information received and held?

Personal information may be received and held either as a hard copy, paper, or a soft copy being electronic data, in any available form. In either case, we take the security of personal information very seriously. We secure hard copy documents carefully in and out of our office. We use cyber-security systems to protect soft copy documents. We never ask for bank details or other sensitive information by email.

For what purpose is personal information collected, held, used and disclosed?

All data processed by the business is done on a lawful basis. The purposes for which we collect, hold, use and disclose personal information are:

• to offer our products and services to our clients/customers. In doing so we may disclose personal information to other people or entities involved in the provision of the product or service, such as government departments and individuals. Unless compelled by law, we will never disclose personal information without our client’s knowledge and consent;
• to facilitate our internal and external administrative processes including financial and business operations and reporting requirements;
• to obtain, maintain and comply with the terms of our professional indemnity and other insurance policies; and
• to comply with applicable laws.

How can personal information be accessed or corrected?

Clients/customers may access their personal information and seek correction of it at any time by applying to our office in person or in writing.

Clients/customers will be formally identified before releasing or amending any personal information.

What is the complaints process relating to personal information?

If there is a breach of this privacy policy (Privacy Policy), either of the Act or the Australian Privacy Principles (APP), a complaint may be made by the client to our Privacy Officer at bpm.bloodstock@gmail.com.

You can choose to deal with us anonymously. We will do our best to action any request or complaint that you supply to us anonymously. However, without providing your identity, we may be limited in the action that we can take in relation to your enquiry or complaint.

If you believe that we have not adequately addressed your complaint, you may complain to the Office of the Australian Information Commissioner.

Data breaches

All staff are responsible for protecting the confidentiality of client information and business information. In accordance with this Privacy Policy our staff will refer any data breaches, or suspected data breaches, to the Privacy Officer as soon as possible.

What is an eligible data breach?

An eligible data breach, defined in s 26WE(2) of the Act, is when:

(a) both of the following conditions are satisfied:

(i) there is unauthorised access to, or unauthorised disclosure of, the information;

(ii) a reasonable person would conclude that the access or disclosure would be likely to result in serious harm to any of the individuals to whom the information relates; or

(b) the information is lost in circumstances where:

(i) unauthorised access to, or unauthorised disclosure of, the information is likely to occur; and

(j) assuming that unauthorised access to, or unauthorised disclosure of, the information were to occur, a reasonable person would conclude that the access or disclosure would be likely to result in serious harm to any of the individuals to whom the information relates.…

If there is a suspicion of a breach

If we suspect that there has been an eligible data breach, a reasonable and expeditious assessment will be conducted within 30 days.  

If we believe or have reasonable grounds to believe there has been a breach then a statement will be prepared setting out:

• the business’s details;
• a description of the breach;
• the kind or kinds of information concerned; and
• recommendations about the steps that we will take in response to it.

If practicable, we will advise the contents of the statement to each of the affected clients/customers who may be at risk from the breach. If this is not practicable we will publish the statement on our website and take other reasonable steps to publicise its contents. Communications with individuals will be via their preferred communication method.

The statement will be submitted to the Privacy Commissioner.

Exception to reporting

Mandatory notification requirements are waived if remedial action can be taken that results in a reasonable person concluding that the access or disclosure is not likely to result in serious harm to any of those individuals.

Transborder data flows

Where necessary we will disclose personal information to overseas recipients, including a related body corporate. The likely countries that information might be sent to includes New Zealand. 

There may be other occasions when personal information is transferred outside of Australia within our network, or such as where we engage a third party to provide services or an element of the services to you. Generally, this will occur in the provision of services to you and the transfer of this information outside of Australia will have been disclosed to, and authorised by, you as part of the terms of our engagement. When transferring personal information outside Australia within our network, we will comply with the requirements of the Act that relate to transborder data flows. Where the international transfer of personal information is to countries whose privacy laws may be considered not to provide the same level of protection as Australia, our commitment to safeguard your privacy will not change and remains subject to existing obligations and this Privacy Policy.

As part of provision of the services to you we may store your personal information using online or cloud software. The personal information that you provide to us may be transferred to the servers of our software providers as a function of transmission across the internet. By providing your personal information you are consenting to that personal information being transferred to and stored on the servers as set out in this Privacy Policy. However, as the third parties who host our servers do not control, and are not permitted to access or use your personal information (except for the limited purpose of storing the information), we do not “disclose” personal information to those server hosts, whether or not they are located overseas.

Notwithstanding the above, for the purpose of transparency we advise that the servers of our software providers are currently located in Australia. However, this location may change without prior notice to you. Your personal information may be routed through, and stored on, those servers. If the location of those servers changes in the future, we will update this Privacy Policy. We recommend that you familiarise yourself with our Privacy Policy regularly.

We will use reasonable endeavours to ensure that our server hosts do not have access to, and use the necessary level of protection to safeguard, your personal information and otherwise comply with the APPs. If you do not want your personal information to be transferred to a server in the location listed in the previous paragraph or to any other international locations, you should not provide us with your personal information or use our services.

Updating privacy policy

We may review our Privacy Policy from time to time to ensure that it is in line with best practice and remains current with any legislative requirements. Any changes to our Privacy Policy will be incorporated into a new version of this Privacy Policy stating the date from which it will operate and can be obtained on our website or by telephoning our office. Our commitment to protection of your personal information will be governed by the most recent and up-to-date Privacy Policy in place.

Contacting us

We welcome your comments regarding this Privacy Policy and/or our treatment of your personal information. If you have any questions about this Privacy Policy and would like further information, please contact our Privacy Officer on bpm.bloodstock@gmail.com or by calling our office during business hours.