Proactiv is committed to complying with the requirements of the Privacy Act 1988 (‘Act’) as it is amended from time to time. The core requirements of the Act are set out in the Australian Privacy Principles (APPs). The APPs set out how an organisation such as Proactiv should collect, hold, use, and disclose personal information. The APPs also give individuals a right to know what information an organisation holds about him or her, and the right to correct it if it is wrong.
This document sets out our policy in relation to the protection of the privacy of personal information. This policy document is intended to enable our clients and others who interact with the Proactiv to understand what types of personal information we collect, and what we do with such information to provide our products and services and in light of our privacy obligations.
From time to time, as Proactiv updates and improves its service Proactiv may change this Privacy Statement. Proactiv will publish these changes on its website at proactivpayroll.com.au/privacy
Proactiv is a registered Australian propriety company that operates out of Perth, Western Australia. All client processing and services are provided by our capable team located in this office.
- What is personal information?
Personal information is defined in the Act as;
‘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.’
- What personal information does Proactiv collect and hold?
Proactiv collects and holds personal information that is reasonably necessary to provide its services. Proactiv may collect information from or about individuals, including:
- Employees of Proactiv Clients: Proactiv generally collects personal information such as the individual’s name, address, e-mail address, user ID, banking details, date of birth, payroll details, and employment-related information such as salary details, superannuation contributions, Tax File Number, relevant awards and PAYG withholding tax.
- Client contacts: Proactiv collects contact information from or about clients or prospective clients, including individuals working for clients or prospective clients, and records details of interactions with clients and prospective clients. This could include:
- Contact information – information that allows Proactiv to communicate with the client, such as their name, username, mailing address, telephone numbers, email address or other addresses that allow Proactiv to send messages.
- Relationship information – information that helps Proactiv do business with the client, such as the types of products and services that may interest the client, information on the organisation’s size, geographic locations, creditworthiness and demographics.
- Transaction information – information about how the client interacts with Proactiv, including purchases, inquiries, customer account information, and information about how the client uses the Proactiv websites and applications.
- Employees of Proactiv: Proactiv collects personal information from its employees as described in its Privacy Notice to Associates.
- Applicants for jobs at Proactiv: Proactiv collects contact details, employment history and other background information as required and as permitted by law.
Some personal information collected by Proactiv may be sensitive information as defined in the Act; for instance, membership of a trade union (where Proactiv pays trade union membership fees on behalf of an employee).
- How does Proactiv collect and hold personal information?
In most cases, when providing payroll services, Proactiv collects personal information about a client’s employees and payment recipients directly from the Proactiv client that employs the relevant employee.
As Proactiv does not normally deal directly with clients’ employees, it asks its clients to obtain the consent of the individual for the collection, use, and disclosure of the individual’s personal information to and by Proactiv. It also asks its clients to have regard to the information in this privacy statement in making its own disclosures to employees under the Privacy Act.
Proactiv will ask for personal information (including contact information and relationship information) when a client or prospective client interacts with Proactiv, such as when filling in the contact form on our website, signing up to receive a newsletter, or making a purchase. Proactiv may collect additional relationship information from third party data suppliers who enhance Proactiv’s files and help Proactiv better understand its customers. When products or services are purchased from Proactiv, Proactiv collects transaction information. Proactiv collects transaction information when a person visits the Proactiv website, uses Proactiv applications or contacts Proactiv Payroll, such as for customer service purposes.
Proactiv collects information from a job applicant directly from the applicant or publicly available information. With the consent of the applicant Proactiv may conduct reference, background and criminal record checks.
- The purposes for which we collect, hold, use and disclose personal information
Proactiv deals with personal information for a number of purposes, such as:
- Providing payroll services
- Billing and account management
- Internal business operations such as planning, product development, research, and reporting to Proactiv related bodies corporate
- Fulfilling requests for products or services and for related activities, such as product and service delivery, customer service, account management, support and training and to provide other services related to the relationship with Proactiv;
- Providing marketing communications and offers for products and services from Proactiv and, in some cases, Proactiv partners, including offers targeted based on interests, business characteristics and location;
- Administering surveys and other promotional events;
- Determining eligibility for certain products, services or offers;
- Providing additional information that may be of interest, such as Proactiv news and announcements and technical service bulletins; and
- Managing Proactiv’s everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, fulfilment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, and business continuity.
The collection, use and disclosure of personal information may be required or authorised under various Commonwealth and State laws, including:
- The Income Tax Assessment Acts
- Superannuation Guarantee (Administration) Act 1992 (Cth)
- Fair Work Act 2009 (Cth)
- Payroll Tax Acts
- Long Service Leave Acts
- Occupational Health & Safety Acts
- Workers Compensation Acts
- Tax Agent Services Act 2009 and Tax Agent Services Regulations 2009
- Privacy Act 1988 (Cth)
- Corporations Act 2001 (Cth)
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
- Any secondary legislation pursuant to primary legislation referred to above.
- Disclosure of personal information to third parties
Proactiv understands that individuals do not want Proactiv to provide their personal information to third parties for their own marketing purposes. Under Proactiv’s policy, personal information may be disclosed to the following third parties where appropriate for the purposes set out under section 4 above:
- Australian Taxation Office and other governmental agencies as required by law;
- Banks/financial institutions;
- Superannuation funds;
- Health funds;
- Contracted service providers who are bound by law or contract to protect the personal information and only use the personal information in accordance with Proactiv’s instructions; and
- Business partners, and related bodies corporate of Proactiv
Proactiv may share personal information with business partners, but only to the extent a product or service has been purchased from such partner, interacted with such partner, or otherwise authorised the sharing. For example, if a person is referred to Proactiv from a business partner website, Proactiv may provide that partner with the person’s contact information and certain transactional information to validate the referral. Proactiv may also provide the person’s contact information to companies that offer complementary products and services if the person requests information about these solutions.
Proactiv may disclose personal information where needed to affect the sale or transfer of business assets, to enforce Proactiv’s rights, protect Proactiv property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. Proactiv may also disclose personal information when required or authorised to do so by law.
Please note that Proactiv may use and disclose information about individuals that is not personally identifiable. For example, Proactiv may publish reports that contain aggregated and statistical data about Proactiv’s clients. These reports do not contain any information that would enable the recipient to contact, locate or identify an individual. These reports also do not contain any identifiable company information.
Where an individual has applied for employment with Proactiv, the personal information submitted with their job application will be added to Proactiv’s job opportunities database and may be used for recruitment and other customary human resources purposes. For example, Proactiv may send the applicant information about new job opportunities within Proactiv as well as other career development resources.
- How can individuals access, correct or update their information?
Proactiv respects the right of an individual to access and correct their personal information. Where an individual has access to an online account they can log into their account at any time to access and update the information they have provided to Proactiv.
Proactiv will give individuals access to their personal information on request, subject to the Act. Proactiv may impose a charge for giving access to personal information.
If any information is incorrect, Proactiv will correct it on request. If the individual has a direct relationship with Proactiv, the person or department at Proactiv the individual normally deals with should be contacted initially. The request may also be made to Proactiv’s Privacy Officer (using the details below).
An individual who is an employee or other payment recipient of a Proactiv client is encouraged in the first instance to contact the client so that the client can ask Proactiv to correct its records.
Proactiv may require substantiation of any request to correct personal information.
Individuals may request not to receive marketing communications from Proactiv. Proactiv aims to ensure such requests are complied with within five business days.
- What can an individual do if they have a complaint?
Any complaint regarding a possible breach of Proactiv’s privacy obligations may be directed to:
- the person or department at Proactiv the individual normally deals with, if the individual has a direct relationship with Proactiv Payroll; and/or
- Proactiv Payroll’s Privacy Officer (using the details below).
The Privacy Officer will investigate any complaint and notify the individual within a reasonable timeframe of the outcome of the investigation.
- Does Proactiv disclose personal information to overseas recipients?
Proactiv Payroll operates its business from Australia and all technologies and data storage is within Australia.
- How does Proactiv protect the security of personal information?
Proactiv exercises great care to protect personal information that it holds. This includes, among other things, using industry standard techniques such as firewalls, encryption, intrusion detection, and site monitoring.
Internally, Proactiv restricts access to personal information to employees or parties who need access to the information in order to do their jobs. These employees or parties are limited in number, and are committed to maintaining confidentiality.
Proactiv reviews its security arrangements from time to time, as it deems appropriate.
- Further information
Please contact Proactiv if you have any queries about the personal information that Proactiv holds about you or the way we handle that personal information. Our contact details for privacy queries and complaints are set out below:
Proactiv Payroll Australia Pty Ltd
PO Box 854, West Perth, 6872
Phone: +61 6163 4400
- Changes to this policy