Australian Payments Plus
Australian Payments Plus is bound by the private sector provisions (other than the credit reporting provisions) of the Privacy Act 1988 (Cth) (Privacy Act). Our policy is to comply with those provisions of the Privacy Act. This policy is made in accordance with Australian Privacy Principle 1, and describes Australian Payments Plus’ policies for handling personal information that we may collect, hold, use or disclose for the purposes of our functions and activities.
What personal information does Australian Payments Plus collect and hold?
As a holding company, Australian Payments Plus does not collect and hold large volumes of personal information.
The personal information we collect and hold may include your name, title, business address, other contact details and other information that we consider is reasonably necessary (such as information about your opinions, policies, statements and writings) so we can perform our legitimate functions and activities.
We will not collect sensitive personal information about you unless we have your express or implied consent or if the law otherwise permits it.
Personal information that we collect is stored or held securely by Australian Payments Plus or in archives maintained by a third party information storage provider.
How is personal information collected?
As well as collecting personal information from you directly or from our members, we collect personal information from oral sources, from correspondence and other written material either sent to us or from publicly available sources of personal information such as newspapers, electronic media, records of proceedings and public registers. Our subsidiaries may also provide us with personal information in connection with our role as an owner of the companies in providing oversight of their activities.
Australian Payments Plus also collects personal information from this website through receiving subscription applications and emails.
When you visit our website, your domain name is recorded in our logs. This information is not likely to identify any individual (in other words, it is not likely to be personal information), and is used for statistical and web development purposes only. Australian Payments Plus may use external service providers to analyse traffic on this website. Generally, information collected through such analysis is anonymous.
Where we consider that you may not be aware or would not have expected that we had collected personal information about you we will take such steps as are reasonable in the circumstances to let you know that we have collected the personal information, our purpose in collecting it, to whom we would usually disclose the information and whether it is likely that we would disclose the information to overseas recipients including the countries in which those recipients are located if it is practicable for us to specify those countries.
Purposes of collecting, holding, using and disclosing personal information
In general, Australian Payments Plus will use and disclose your personal information for the following purposes:
- to perform Australian Payments Plus’ functions as a holding company;
- to communicate with you and to facilitate communication between members;
- to help Australian Payments Plus manage and enhance its services; and
- to comply with Australian Payments Plus’ legal obligations.
Disclosure of personal information
We may disclose personal information to:
- our members;
- our subsidiaries
- organisations as required or authorised by law;
- external parties such as: your representatives, including your legal advisers;
- our representatives, such as our legal advisers;
- service providers such as printers and posting services and organisations involved in the provision and maintenance of our business systems and infrastructure; and
- those organisations where you have consented.
Australian Payments Plus works closely with other payments industry representative organisations and associations in other countries. Disclosures may occur outside Australia to overseas recipients in which case we will observe the applicable Australian Privacy Principles. Otherwise, in connection with any specific occasion on which such a disclosure may occur, at or before the time we collected your personal information, it would not be practicable for us to specify the countries in which these recipients are likely to be located.
Where your personal information is disclosed, we will seek to ensure that the information is held, used or disclosed consistently with the applicable Australian Privacy Principles and other applicable privacy laws and codes.
Management of personal information
We will take reasonable steps to keep your personal information secure, having regard to its nature and source. Arrangements are in place to safeguard the information against unauthorised access, modification, disclosure and interference and from loss and misuse.
We will destroy or permanently de-identify your personal information we are holding when it is no longer needed for the purpose for which we collected it. When we destroy your personal information we will ensure that this is carried out properly and securely.
If you would like more information about how we manage your personal information please contact us (see “Contact details” below).
Access to personal information
You may request access to your personal information that we are holding (see “Contact details” below). Before giving you access we may need to establish your identity by sighting some form of identification or asking you some questions.
You may ask us to correct your personal information that we are holding if you believe it is incomplete, inaccurate, irrelevant, out-of-date or misleading. This access is subject to some exceptions allowed by law. For example, we can deny you access where access would:
- be unlawful;
- pose a serious threat to the life, safety or health of an individual or to public health or safety;
- have an unreasonable impact on the privacy of others;
- involve disclosure of a commercially sensitive decision making process;
- prejudice enforcement activities such as criminal proceedings or negotiations with you; or
- reveal certain information relevant to legal dispute resolution proceedings.
We may also deny your request for access if it is frivolous or vexatious.
We will give you reasons if we deny your request.
Complaints about privacy
If you believe Australian Payments Plus has breached its obligations under the Privacy Act you can contact us directly (see “Contact details” below) and we will try to satisfy any questions that you have or correct any errors on our part.
If you are not satisfied with our response, you are entitled to make a complaint to the Office of Australian Information Commissioner who can be contacted on 1300 363 992 or by email at firstname.lastname@example.org.
We are unable to handle or assist you with a privacy complaint involving a financial institution which is an Australian Payments Plus member.
If you have a privacy complaint about an Australian Payments Plus member, you should make your complaint directly to the organisation or financial institution concerned.
Need more information?
If you would like more information about privacy and the Privacy Act (including the Australian Privacy Principles), you can access the Privacy Commissioner’s website at https://www.oaic.gov.au/privacy/.