PRIVACY POLICY

YOUR PRIVACY IS IMPORTANT TO US

ChangeTrack Research Pty Limited respects your privacy. All our staff are required to read this policy and understand their responsibilities when dealing with personal information.

In this policy:

• sensitive information refers to information about a person’s racial or ethnic origin, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, trade and professional memberships, sexual preferences or practices, criminal record or health information;
  
• CTRE, we, us and our refer to ChangeTrack Research Pty Limited ABN 87 005 368 387;
  
• you and your refer to you, an individual whose personal information we may deal with; and
  
• personal information refers to any information or an opinion whether true or not, from which an individual’s identity is apparent, or can reasonably be ascertained

CTRE works alongside senior management teams to successfully implement change and to build an environment that sustains high levels of innovation. We are recognised internationally for our abilities to assist managers to 'architect-change' and build the capabilities needed to lead their people. CTRE provides a range of consulting and research services to our clients and business associates. Find out more about us at www.changetracking.com.

CTRE has undertaken to be bound by the National Privacy Principles (NPPs) in the Privacy Act 1988 (the Act). We have adopted internal policies and procedures to ensure that your personal information is dealt with in accordance with the NPPs. You can see the full text of the NPPs online at www.privacy.gov.au.

COLLECTION

We need to collect personal information for a number of reasons but primarily to provide you or your employer with CTRE products or services.

Management Competency Assessment (MCA)

One of our services, MCA requires us to obtain data from individuals in order to prepare reports for assess management competency and provide feedback to individuals. To do this, we receive some personal information that might, for example, include name, work contact details, position, or date of birth and gender. We retain this data for future use, for example to assist us with furture assessments and to generate reports with summary or detailed aggregated data and participant lists.

ChangeTracking® and PerformanceTracking™

CTRE’s prime service offerings, ChangeTracking® and PerformanceTracking™ involve collection of data, and this includes some personal information. We process the data and provide reports to assist clients who wish to achieve higher performance or better manage change processes.

We also add the data to our master database for benchmarking purposes, which helps to continually improve the rigour of our analytical model, however individual responses are not disclosed to third parties outside CTRE.

In addition, CTRE does not provide group results where comparison of different reports would allow identification of individual responses.

Other Information

We may need to collect personal information from you such as your name, address, phone numbers and other contact details. We may also collect other personal information, for example the geographical region in which you are located, your title, the name of the business that you represent, or details of your age, sex, hobbies and other interests.

We need to collect personal information so we are able to:

• identify our customers and potential customers, and their authorised representatives;
• inform individuals of information or marketing initiatives we think may be of interest;
• provide goods, services or other benefits to be offered to customers;
• conduct our business in a professional and efficient manner; and
• develop and implement initiatives to improve our products and services.

If you do not provide us with some of the personal information we request from you, we may be unable to do business with you.

Where possible we will collect your personal information directly from you. However, your representatives or other third parties may hold personal information (eg, financial or bank account details or a credit reference) that we may need to access for particular business transactions or other purposes. Where we are at liberty to do so, we will use our best endeavours to seek your consent before obtaining your personal information from third parties.

Your personal information will be collected by us when you:

• contact us about our products and services, in person or over the telephone or internet;
• enter into a business transaction with CTRE;
• contact our support desk; or
• make an inquiry, where your personal details are required to fulfil the query.

Your personal information will usually be recorded or up-dated in our records, each time we have contact with or from you.

Any additional purpose for the collection (not included in this policy) will be identified when we collect your personal information, or as soon as practicable afterwards.

SENSITIVE INFORMATION

We generally do not need to collect "sensitive information" (as defined in the Act) about you. However, where we are at liberty to do so, and it is practicable to do so, we will seek your consent before collecting your sensitive information and inform you of the purpose at the same time.

USE

We may use your personal information:

• to identify you;
• to minimise risk of unauthorised access to your personal information in our records, or accounts or services in our control;
• to improve our services to you or any of our customers;
• to provide prospective customers with case studies of past projects we have been involved in, customer references, employee resumes or supplier details for reference purposes;
• to keep you informed of our service offerings, up-coming seminars, or relevant news;
• to derive or aggregate anonymous information from which you cannot be identified as an individual;
• to prevent or lessen a threat to a person’s life or health;
• where disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim;
• for the purpose for which it was collected, or for a related purpose (or a directly related purpose in the case of "sensitive information" as defined in the Act) that you would reasonably expect from us;
• for other purposes permitted, required or authorised by or under law; and
• for any other purpose, where you have consented to its use for that purpose.

DISCLOSURE

Except where indicated above, we will not disclose your personal information to a third party unless:

• the disclosure is for a primary purpose for which the information was collected;
• you have consented to the disclosure;
• the third party is our agent or contractor, in which case we will require them to use your personal information only for the purpose for which it was disclosed;
• there are reasonable grounds to believe that disclosure is necessary to prevent or lessen a threat to your life or health or that of another person;
• the disclosure is to a subsidiary or holding company, or a company in the CTRE group of companies;
• the disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim;
• the disclosure is permitted, required or authorised by or under law.

OUR WEBSITE

To ensure we are meeting the needs and wants of our website users, and to develop our online services, we may collect aggregated information by using cookies.

Cookies are unique numbered identification numbers like tags that are placed on your browser. They do not in themselves identify you personally, but may be linked back to a database record about you.

We may use cookies to track your use of our web site, and to compile statistics on visits to the site in an aggregated form and log anonymous information such as:

• the address of your server,
• your top level domain (such as .com. or .au),
• the date and time of your visit,
• the pages you accessed and downloaded,
• the search engine you used, or
• what type of browser was used.

When you visit our site a cookie may be placed on your machine. Where you have visited us before the cookie may be read each time you re-visit the site.

If you choose not to have your browser accept cookies from our site, you will still be able to view the text on the screens, however you will not be able to complete or submit online forms.

MARKETING

We may use your personal information to advise you of new services and marketing initiatives that we think may be of interest to you. This may include newsletters and general information about CTRE.

If you would prefer not to receive information about our products and services, please contact our Privacy Officer on +61-2-9247 6988 or privacy@ctreconsulting.com to be removed from the relevant circulation list. We may require written confirmation of your request, for example where legislation requires us to provide particular communications to you.

We do not disclose your personal information to a party outside CTRE for the purposes of allowing them to direct market their products or service on you.

CTRE does not sell mailing lists.

CORRECTION OF RECORDS

During the course of our relationship with you we will ask you to tell us of any changes to your personal information. We ask you to notify us of any changes, incompleteness or inaccuracy from time to time so we can update your personal information. Once we receive your notification, we will take reasonable steps to correct the information in the manner that you have requested.

If we consider that the personal information we retain does not require amendment, we will note your request to correct your personal information on our files.

SECURITY

The protection of your personal information is a priority for CTRE.

We are committed to maintaining:

• safeguards to protect personal information against unauthorised use, disclosure, access, alteration, destruction and accidental loss. All personal information we hold is dealt with in accordance with the NPPs;
• industry standards for the security and protection of information. Your personal information is stored securely and access is restricted to authorised personnel only. Our computer systems require access passwords, and these are kept secure; and
• internal policies on management of personal information and staff training to ensure compliance with these policies. All our staff are required to read this policy and understand their responsibilities in relation to your personal information.

ACCESS TO YOUR PERSONAL INFORMATION

Under the National Privacy Principles you are generally entitled to access the information we hold about you. Where you are entitled to access, the time we require to give you access will depend on the type of information requested. If we can, we will answer your question immediately. We will also try to answer you in the same way that you ask, for example, if you telephone to ask for the information we will, if practicable, give you that information over the telephone. We will generally respond to a written request in writing.

Sometimes, we will ask that you put your request in writing, for example, where you want copies of material or access to older information or files which are not current or it is necessary for us to retain a record of your request.

We may also ask you to identify yourself to our satisfaction.

RESTRICTIONS ON ACCESS

You may not be allowed access to the personal information we hold about you where access would reveal evaluative information generated by CTRE in connection with a commercially sensitive decision-making process. Instead, CTRE may give you an explanation for the decision, rather than direct access to the information.

If we have given you such an explanation and you believe that direct access to the evaluative information is necessary to provide a reasonable explanation of the reasons for the decision, we will, at your request, review the decision. Personnel other than the original decision-maker will conduct the review.

Wherever direct access by you is impractical or inappropriate, we should consider together whether the use of a mutually agreed intermediary would allow sufficient access to meet both our needs and concerns.

Other instances where it may not be appropriate to provide you with access to the personal information we hold about you, include where:

• providing access would pose a serious and imminent threat to the life or health of any individual;
• providing access would have an unreasonable impact upon the privacy of other individuals;
• the request for access is frivolous or vexatious;
• the information relates to an anticipated or existing legal dispute us and disclosure would compromise our position.

CHARGES FOR ACCESS

You will incur no charges for lodging a request to access your personal information. However, we may levy a reasonable charge for providing the access. We will provide an estimate of any charge to you on request or if it appears to us that the work will be onerous or otherwise warrants a charge.

OVERSEAS TRANSFER

We may transfer your personal information overseas for the purposes of data storage and to integrate your personal information with information obtained from other people or organisations.

We will not otherwise transfer your personal information outside Australia unless:

• we reasonably believe that the recipient of the information is subject to legal obligations that uphold principles for the protection and fair handling of personal information that are substantially similar to the principles contained in the NPPs and this policy; or
• you give us your consent to do so, expressly or by implication; or
• we are contractually required to do so; or
• the transfer is for your benefit, and it is not practicable for CTRE to obtain your consent (and if you were able to grant consent, you would be likely to give it) - in this instance we will advise you to whom your information has been disclosed as soon as practicable.

Changes to this Privacy Policy

We reserve the right to review and amend this Privacy Policy from time to time and to notify you by posting an updated version on our web site (www.ctreconsulting.com).

COMPLAINT RESOLUTIONWe are committed to constantly improving our procedures so that your personal information is treated appropriately.

If you feel that we have failed to deal with your personal information in accordance with the NPPs or this policy, please speak to us so that we have an opportunity to resolve the issue to your satisfaction.

The person to contact is our Privacy Officer, whose contact details are shown below.

Our Privacy Officer will manage the following process for us to:

• listen to your concerns and grievances regarding our handling of your personal information;
• discuss with you the ways in which we can remedy the situation; and
• put in place an action plan to resolve your complaint and improve our information handling procedures if appropriate.

If this process does not result in an outcome that is satisfactory to you, you may contact the Privacy Commissioner’s Office. We will work together with the Privacy Commissioner’s Office to resolve the issues between us.

The contact details for the Privacy Commissioner’s Office are as follows:

CONTACT INFORMATION

If you wish to access any personal information of yours that we are storing, or have a query about this policy, please contact us: