ACFS Port Logistics

Privacy Policy

1. Document Information

2. Classification

This document is classified as public.

 

3. Purpose of this Policy

This policy describes how Australian Container Freight Services Pty Ltd ABN 95 603 120 047 (ACFS) collects, holds, uses, and discloses your personal information (including sensitive information) consistent with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and, where applicable, the European Union General Data Protection Regulation (GDPR).

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a)  whether the information or opinion is true or not; and

(b)  whether the information or opinion is recorded in a material form or not.

Common examples are an individual’s name, signature, address, telephone number, date of birth, bank account details and commentary or opinion about a person.

Sensitive information includes any personal information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics, biometrics, or biometric templates.

ACFS appreciates the importance of protecting your personal information. Our Privacy Policy explains how your personal information will be managed when dealing with ACFS.

We understand that your privacy is important to you, and we value your trust. That’s why we protect your information and aim to be clear and open about what we do with it.

By engaging ACFS to provide you with any goods or services, communicating with ACFS through email, by telephone, in writing or by using any of ACFS’ (and its subsidiaries) services, including any of ACFS’ websites, face-to-face conversation or meetings, products and services, you agree with the terms of this policy and consent to the collection, use, holding and disclosure of your personal information in the manner described in this policy and in accordance with the Privacy Act (including the Australian Privacy Principles).

This Privacy Policy also explains how we process ‘personal data’ about people in the European Union (EU), as required under the General Data Protection Regulation (GDPR).

In some situations, users may provide us personal information over platforms that are outside our control, for example, through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.

This website may contain links or references to other websites to which this Privacy Policy may not apply.  You should check their own privacy policies before providing your personal information.

 

4. Types of Personal Information we collect and hold

ACFS collects personal information, such as:

• • name, address, and contact details
  • credit or debit account details
  • user IDs and passwords
  • details of any goods or services provided to you
  • records of your communications with ACFS
  • website usage information
  • information for reference.

ACFS may collect your personal information:

• • directly from you, when you provide it to us or our agents or contractors;
  • from publicly available resources;
  • by analysing our own records of your use of our services and website; and with cookies.

As you navigate through this website, certain information can be passively collected (that is, gathered without you actively providing the information) through various technologies, such as cookies, internet tags or web beacons and navigational data collection.

This website may use and combine such passively collected anonymous information to provide better services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends and otherwise administer and improve the website for your use.  Such information is not combined with personally identifiable information collected elsewhere on the website unless you have consented.

 

5. The purpose of collecting, holding, using, and disclosing your Personal Information

We collect personal information that is necessary for our business activities and to provide and develop our services.

The primary purpose of collecting your personal information is for ACFS’ business operation, which includes providing you with ACFS’ goods and services, communicating with you, and improving and developing our business relationship with you. ACFS also collects personal information for marketing purposes.

ACFS discloses personal information:

• • for the primary purpose for which it was collected;
  • where the individual would reasonably expect this;
  • where the individual has consented;
  • for direct marketing by ACFS.

 

6. During Employment

As a business, ACFS is required to ensure that all employees are suitable for their nominated role and comply with all legal, local and federal employment regulations (such as the right to work in Australia). We are required by law to provide each employee’s Tax File Number to government agencies (such as ATO). Without limitation to any other rights that we may have in relation to your employment records, if you are an employee of ACFS (or its subsidiaries) or a contractor (with full-time, part-time or casual status) ACFS may:

• • disclose personal information to the government and/or government agencies as required by law;
  • keep records of your time worked and whereabouts (for payroll and security purposes and as part of ACFS’ internal operational requirements);
  • use CCTV and surveillance equipment as part of the security requirements of our business
  • disclose personal information for reference;
  • use personal and psychological assessments to establish job suitability and training requirements;
  • utilise background and security checks (this may require a cross border personal information exchange with authorised agencies);
  • keep all your employment records on file for legal purposes after you have ceased your engagement with ACFS (or its subsidiaries). Any such information on file is treated as confidential with limited access. This includes (but is not limited to) records such as biometric personal records, medical records and other personal information which is received, communicated and/or provided to ACFS in a solicited manner and with your knowledge.

 

7. Accurate and Up-to-date Information

ACFS takes reasonable steps to ensure personal information is accurate, complete and up to date by updating its records whenever changes to the data come to its attention. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information and we will take appropriate steps to update or correct such information in our possession.

 

8. Security and Storage of your Personal Information

ACFS protects personal information from loss, misuse, unauthorised access, modification, disclosure or destruction by restricting access to the information in electronic format, and by appropriate physical and communications security.

8.1 Physical Security

• • • Secured access to facilities where personal information is stored.
    • Use of locks, alarms, and surveillance systems to protect physical storage locations.
    • Restricted access to authorized personnel only.
    • Secure storage devices, such as locked cabinets or safes.

8.2 Communications Security

• • • Use of encryption technologies to protect data during transmission.
    • Secure protocols (e.g., HTTPS, TLS) for data exchange over the internet.
    • Secure communication channels, such as virtual private networks (VPNs) for remote access.
    • Firewalls and intrusion detection systems to protect against unauthorised access.

 

9. Data Storage and Disposal

Secure methods for storing electronic files, such as encrypted storage.

Regular audits and reviews of data storage practices to ensure compliance with security policies.

Secure and compliant disposal of data, including shredding physical documents and secure wiping of electronic storage devices.

ACFS stores personal information in a secure manner, employing various methods for both electronic and hard copy formats:

9.1 Electronic Storage

Personal information is stored in encrypted format on secure servers. Access to this information is restricted to authorised personnel only, and regular audits are conducted to ensure compliance with security policies.

9.2 Hard Copy Storage

For hard copy formats, personal information is stored in lockable cabinets in secure premises. Access to these cabinets is restricted, and regular audits are conducted to ensure compliance with security policies.

9.3 Data Disposal

When personal information is no longer needed or requested to be destroyed, it is disposed of securely. For physical documents, this involves shredding them using a secure shredding service. For electronic storage devices, data is securely wiped to prevent any retrieval.

These measures are in place to protect the privacy and security of personal information. However, it’s important to note that no internet transmission is entirely secure or error-free, and users should be aware of the inherent risks, particularly regarding email communication.

Any data that is being destroyed is disposed of in a manner that protects the privacy of information in an appropriate manner.

 

10. Dealing with Unsolicited Information

ACFS takes all reasonable steps to ensure that all unsolicited information is destroyed immediately. Any unsolicited PII or information received will be addressed and affected entities will be notified.

 

11. Access to your Personal Information

ACFS acknowledges that individuals have a general right of access to information concerning them, and to have inaccurate information corrected.

You may request access to any of the personal information we hold about you by contacting us as specified below.  We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.

 

12. Anonymity when dealing with ACFS

ACFS allows individuals the option not to identify themselves when dealing with it, where practicable.

 

13. Collecting Sensitive Information

ACFS does not collect sensitive information, unless it is specifically relevant and necessary for the purpose of ACFS’ business operation. All sensitive information that is collected is used in accordance with this Privacy Policy. ACFS does not use government identifiers (e.g. tax file numbers) to identify individuals.

 

14. Automated Decision Making and Profiling

We sometimes use systems to make automated decisions (including profiling) based on personal information we have collected from you or obtained from other sources.

 

15. Who should you contact for further information?

To contact our Privacy Officers (Data Protection Officer) if you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officers:

Name:  Jason Spiteri

Address: 2 Simblist Road, Port Botany, NSW 2036

Phone:  02 8484 6200

Email: [email protected]

 

Name:  Anthony Tzaneros

Address:  2 Simblist Road, Port Botany, NSW 2036

Phone: 02 8484 6200

Email: [email protected]

 

16. Notifiable Data Breaches (NDB) Scheme

ACFS has established internal procedures which ensure an effective management of NDB scheme requirements. All personal information security breaches are reported following ACFS’ internal Incident Management & Reporting procedure.

In the event of any loss or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will:

• • investigate; and
  • notify you and the Australian Information Commissioner as soon as practicable,

in accordance with the Act.

 

17. Complaints

If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy or the Act, please contact us as set out above. Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.

ACFS will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):

Office of the Australian Information Commissioner (OAIC)

Complaints must be made in writing

1300 363 992

Director of Compliance 

Office of the Australian

Information Commissioner

GPO Box 5218

Sydney NSW 2001

www.oaic.gov.au

 

18. Changes to this Policy

Our Privacy Policy may change from time to time as updated on https://acfs.com.au/ . Before providing us with personal information, please check this Policy on our website for any changes.

This Privacy Policy was last updated 29/05/2024.

 

19. Reference

• • ACFS Port Logistics – Privacy Policy Plan
  • ACFS Port Logistics – Code of Conduct
  • ACFS Port Logistics – HRPOL7 – Workplace Monitoring and Surveillance Policy
  • ACFS Port Logistics – POL001 – Information Security Policy