Benefit Capital takes our privacy obligations seriously and protecting your personal information from misuse, interference and loss; and from unauthorised access, modification or disclosure is held in high regard.
This Policy is a legal requirement under the Privacy Act 1988 (Privacy Act). By signing the Benefit Capital Letter of Engagement, you accept and agree to the collection, use, holding and disclosure of your personal information for the purposes described in this policy.
Scope & Policy Awareness
- Management team;
- All employees;
- Associates (a person or entity formally engaged to perform certain functions and will involve the use or disclosure of protected information)
Benefit Capital will commit to:
- Communicate the policy to managers, particularly managers with responsibility for training;
- Communicate the policy to all employees; and
- Ensure that the policy is consistently applied across the organisation.
What is personal information?
‘Personal Information’ is information that can be used to personally identify you. If the information we collect personally identifies you, or can reasonably identify you, Benefit Capital will consider that information to be personal information.
We will only collect information where:
- You have consented to it; or
- The collection is required by law.
We may collect the following types of personal information:
- Basic personal information such as your name, profession, occupation or job title;
- Contact information such as your mailing address, email address, telephone number;
- Demographic information such as your street address;
- Any client information necessary to deliver products and services and to respond to your enquiries.
Why do we collect personal information?
We collect personal information about you so that we can provide the best possible quality of service.
We will only collect personal information which is relevant for the purpose for which it is sought.
We agree to keep confidential all information that is not publicly available and relates to or concerns you, your business affairs, your clients, know-how, intellectual property, or that may, by its nature or content, be considered confidential. We will not disclose your confidential information to any third parties without your permission unless we are legally compelled to do so and will only disclose it to our officers and employees to the extent that it is necessary for providing our services to you.
We may engage third-party contractors to perform services for us which involve the contractor handling personal information we hold (for example, Benefit Capital preferred graphic designer). Where we engage third-party contractors to perform services for us, we prohibit the third-party contractor from using personal information about you except for the specific purpose for which we supply it.
How do we collect personal information?
The personal information we require to deliver our products and services will be obtained directly from you, except where you have consented to us collecting the personal information from a third party or the law permits us to do so. We may collect personal information in ways including:
- during conversations between you and our representatives;
- during conversations with your stakeholders, as instructed by you;
- when you enter into a contract for services with us; or
- through various methods of communication such as verbally, in writing, by telephone or by e-mail.
Benefit Capital accepts the personal information you supply to us is true and accurate to the best of your knowledge.
Security of personal information
Benefit Capital will protect any personal information that we hold from misuse and loss. We also protect it from unauthorised access, modification and disclosure.
Personal information may be stored either in electronic copy documents or as electronic data in Benefit Capital software or systems (e.g. Microsoft Office applications). Benefit Capital will maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers, strong passwords and multi-factor authentication to control access to computer systems.
Benefit Capital cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Therefore, any personal information or other information which you transmit to us online is transmitted at your own risk.
“Cookies” are a standard method for storing small pieces of data on a web client (i.e. the web browser on your computer). Any web server (including Benefit Capital’s) may:
- Store one or more cookies in your browser; or
- Request your browser to transmit the data to the web server.
Benefit Capital may send cookies to your computer while you are accessing the Benefit Capital Internet site.
By using cookies, websites can track information about visitors’ usage of the site, provide customised content, or even the use of password protection. Note that some browsers can be configured to allow cookies to be accessed by servers other than the originating server.
Please note that most web browsers can also be configured to notify the user when a cookie is received, allowing you to either accept or reject it.
Reporting a Breach of Privacy
If you believe that your privacy has been breached, please contact the Practice Manager (firstname.lastname@example.org) and provide details of the incident so that Benefit Capital can investigate it.
We will treat your complaint confidentially, investigate it, and aim to ensure that we contact you and resolve the complaint within a reasonable time frame (or at least within the time required by the Act, if applicable).
Reporting & Document Management
Benefit Capital commits to monitoring and reviewing any complaints or reported breaches and will ensure they are recorded in the Benefit Capital Incident Register and appropriate action taken. Further, these reports will provide learning and highlight improvements that will inform Benefit Capital’s policy documents. If a breach of this policy has occurred, Benefit Capital will investigate and continually enhance our systems and processes to meet our governance commitments.
Benefit Capital will review this policy every 5 years, or earlier as warranted.
Any reports made in accordance with this policy will be monitored, outcomes recorded, and an incident review will follow to ensure learnings are documented and reflected when reviewing Benefit Capital policy and procedures.