The Morgan Family's ESP members list, both "snail mail"
and e-mail is never sold, rented or loaned to outside parties. On occasions, members
may receive mailings from third parties, however the mailing function will always
be internally processed & managed by our ESP Member Benefits Manager.
Morgan's Privacy Policy Statement
1.Morgan's IGA Supermarkets is an organisation that is bound by law to comply with the National Privacy Principles contained in the federal The Privacy Act 1988 (“the Act”). Morgan’s IGA undertakes, as a policy, not to interfere with an individual’s Privacy rights in the way we collect, use or disclose the personal information of any persons who provide the Organization with such information in the course of carrying out our functions as a retail operator and in accordance with the National Privacy Principles, as contained in the Act.
Morgan’s IGA Supermarkets will at all times handle the personal information they collect, use or disclose in a responsible way, that ensures individuals a degree of control over their own personal information.
A Privacy Statement summarising the way Morgan's Supermarkets collect, hold, use and disclose personal information can be found in all store level policy manuals or is available at our Support Office.
2.What is personal information?
Personal information is information or an opinion about an individual whose identity is apparent or can reasonably be ascertained. An individual is a natural person and therefore our policy does not extend to information about non-natural persons such as a business or a company, unless that information also constitutes personal information.
Information is still regarded as personal information, even if it not true or correct and whether or not it is recorded in a material form or not.
3. What is sensitive information?
Personal information is sometimes not only personal but also personal and sensitive information.
Sensitive information is information or an opinion about an individual’s
- (i) racial or ethnic origin; or
- (ii) political opinions; or
- (iii) member of a political association; or
- (iv) religious beliefs or affiliations; or
- (v) philosophical beliefs; or
- (vi) member of a professional or trade association; or
- (vii) member of a trade union; or
- (viii) sexual preferences or practices; or
- (ix) criminal record;
- that is also personal information; or
- health information about an individual.
4. What is health information?
Health information is information or an opinion about:
- (i) the health or a disability (at any time) of an individual; or
- (ii) an individual’s expressed wishes about the future provision of health services to him or her; or
- (iii) a health service provided, or to be provided, to an individual;
- that is also personal information; or
Health information is also other personal information collected to provide, or in providing, a health service; or other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances.
5. Employee records exemption
An employee record, in relation to an employee, means a record of personal information relating to the employment of the employee. Examples of personal information relating to the employment of the employee are health information about the employee and personal information about all or any of the following:
- (a) the engagement, training, disciplining or resignation of the employee;
- (b) the termination of the employment of the employee;
- (c) the terms and conditions of employment of the employee;
- (d) the employee’s personal and emergency contact details;
- (e) the employee’s performance or conduct;
- (f) the employee’s hours of employment;
- (g) the employee’s salary or wages;
- (h) the employee’s customer of a professional or trade association;
- (i) the employee’s trade union customer;
- (j) the employee’s recreation, long service, sick, personal, maternity, paternity or other leave;
- (k) the employee’s taxation, banking or superannuation affairs.
Acts done or practices engaged in by Morgan's Supermarkets where Morgan's Supermarkets is or was an employer of an individual are exempt from the application the Act and this policy, if the act or practice is directly related to :
- (a) a current or former employment relationship between Morgan's Supermarkets and the individual; and
- (b) an employee record held by the Morgan’s and relating to the individual.
This exemption does not apply to prospective employees, contractors, subcontractors or temporary staff who are employees of a recruitment agency of the Morgan’s.
6. Types of personal information the Morgan’s collect and hold for the purposes of collecting and holding such information.
The Morgan’s provide goods and services to the general public. As part of this function we collect some personal information -
- · Customer data base - Contact details, names and addresses of specific customers (club members).
- · A record of the utilisation of services by various customers and the means by which they pay for these services, shopping habits and frequency etc.
- · Personal information about a range of contract businesses and suppliers we deal with in the provision of our services, such as name, position and contact details.
- · A record of the applications made for job seekers
- · A record of both internal and external e-mails as outlined in our e-mail policy; Some of these e-mails may contain personal information
- · A record of the personal details of our contractors and external consultants, including contract and payment details
7. Morgan's Supermarkets application of the National Privacy Principles
7.10 Collection of personal information
The Morgan’s only collect personal information that is necessary for one or more of our activities or functions as a retailer, and in providing assistance to our customers and team members.
The collection of such information is only done by fair and lawful means in a way that is not unreasonably obtrusive.
Where it is practical, personal information will only be collected from the individual directly, although this is not always practical.
Morgan's Supermarkets undertaking on the collection of personal information
At or before the time (or if that is not practical, as soon as practicable after), the Morgan’s collect personal information about an individual from the individual, the Morgan’s will take reasonable steps to ensure that the individual is aware of
- (a) Our identity and how to contact us; and
- (b) the fact that he or she is able to gain access to the information; and
- (c) the purposes for which the information is collected; and
- (d) the organizations (or the types of organizations) that the Morgan’s usually discloses information of that kind to; and
- (e) any law that requires the particular information to be collected; and
- (f) the main consequences (if any) for the individual if all or part of the information is not provided to Morgan's Supermarkets.
If the Morgan’s collect personal information about an individual from someone other than the individual, the Morgan’s will take reasonable steps to ensure the individual is or has been made aware of the above matters (a) to (f).
7.2 Use and disclosure of personal information
Morgan's Supermarkets will not use or disclose personal information about an individual for any secondary purpose, other than the primary purpose of the collection unless that secondary purpose is related (directly related in the case of sensitive information) to the secondary purpose and the individual would reasonably expect the disclosure in the circumstances or unless CONSENT has been given.
Marketing of our products & services
Morgan’s Supermarkets may use collected personal information to market its products and services. In these circumstances the personal information of such individuals will be used for the sole purpose of providing the service for which the individual provided the information.
Morgan's Supermarkets will in each direct marketing communication with an individual make individuals aware that they can express a wish not to receive any further communications. Such a wish may be expressed at any time, even if the individual has previously consented to the receipt of such material.
Morgan's Supermarkets reserves the right to keep a record of such requests for the sole purpose of ensuring we are able to comply with any such request.
All direct marketing communications by Morgan’s Supermarkets will contain the Companies postal address, telephone number, fax number and e-mail address.
On occasion, the Morgan’s in providing services to its customers may make available the service in conjunction with other organisations. Any personal information collected in these circumstances will only be disclosed to any third party organisation with the express consent of the individual.
Any other disclosure of personal information will only be where required or authorised by or under law.
7.3 Data quality
The Morgan’s will take all necessary steps to ensure that any personal data we collect, use or disclose is up to date and accurate.
Members can update their contact details at any time by faxing a request to the Support office.
7.10 Data security
The Morgan’s take all necessary steps to protect the personal information we hold from any misuse, unauthorised access, modification or disclosure. Personal information is held in both our computerised databases and in hard-copy files
Morgan’s databases are secured by passwords, as is our team member and customer database.
The Morgan’s Information Technology team and/or contractors ensure all systems are protected from unauthorised access and all systems have virus protection.
Only employees who require access have access to these databases. Where only limited access is necessary then only limited access is provided.
Personal information held in hard copy is limited only to those individuals who need access to such information to perform their duties
Security classification system
The Morgan’s classifies information for the purposes of implementing our Privacy Policy according to whether it is -
Sensitive and personal information
- Level 1 Personal information Level 2 Not personal nor sensitive information
- Level 3Information that has either a Level 1 or 2 classification attracts the operation of this policy. Level 1 information attracts strict collection, access, use, storage and disclosure procedures.
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7.5 Openness
This Privacy Policy is available to anyone who requests a copy, as is the Privacy Statement, which is a summary of this Policy.
Further upon request the Morgan’s will make available to any person or organisation the sort of personal information we hold and the purpose of collecting, holding, using and disclosing such information.
7.6 Access to personal information
Where the Morgan’s hold personal information about individuals those individuals will be able to access that personal information upon request, unless the request is frivolous or vexatious, would have an unreasonable impact on the privacy of others or access is otherwise not required by the Act.
Requests for access must be made to the Morgan’s Privacy Officer and must be made in writing.
The Privacy Officer will acknowledge your request within 14 days and will provide you with the information requested as soon as practicable. If the Morgan’s denies access or part access to personal information that has been requested the Morgan’s will provide reasons to the individual why the access or part access has been denied.
In most circumstances, the Morgan’s expect that we would be able to provide you with the information requested or reasons for denial to access within 30 days of receipt of the access request form.
All individuals requesting access must positively identify themselves; a customer number is not sufficient for this purpose.
At the time of acknowledging your request for access, the Privacy Officer will endeavour to let you know the approximate cost of your access request at which point you will be required to confirm your request and positively identify yourself.
The Morgan’s reserve the right to hold all documents lodged or arising out of or in connection with any request for access to personal information for the purpose of obtaining legal advice or for demonstrating compliance with the Act, the National Privacy Principles and this Policy.
Fees for access
The Morgan’s do not charge any fee for the lodging of a request for access and access can be requested by completing an access request form.
However the Morgan’s do charge a fee for providing access for all time spent in processing such a request at $25.00 per hour and $1.00 per photocopied page and any associated postage costs. In addition these charges attract the GST.
Requests made for the same information to which an individual has already granted access will attract additional fees.
The Morgan’s reserves the right to increase these fees at our discretion.
Correction of personal information
Where the Morgan’s hold personal information about an individual and that individual is able to demonstrate that the information is inaccurate, incomplete or not up to date, the Morgan’s will take steps to correct, complete or up date the personal information.
If there is a disagreement about the accurateness, up to date ness or completeness of the personal information and the Morgan’s has been asked to associate the in-dispute information with a statement by the individual that acknowledges their disagreement, the Morgan’s will do so upon request.
A request for correction must be made in writing and any personal information will only be changed after the individual has positively identified himself or herself.
The written request must be lodged with the Privacy Officer.
The Morgan’s reserves the right to hold all documents lodged or arising out of or in connection with any request for correction to personal information for the purpose of obtaining legal advice or for demonstrating compliance with the Act, the National Privacy Principles and this Policy.
If the Morgan’s refuse to correct personal information upon a request to do so, the Morgan’s will provide reasons for the refusal.
7.7 Identifiers
The Morgan’s may identify customers, by a customer number, this includes customers who are also natural persons, howver we do not identify any individual by any Commonwealth Government identifier such as Medicare or Tax File numbers.
7.8 Anonymity
The Morgan’s are a Food Retail organization providing a range of products and services to its customers. As such our services are available to the general public.
7.9 Transborder data flows
The Morgan’s do not transfer any information about any individual to any foreign country.
7.10 Sensitive information
The Morgan’s do not collect sensitive information about an individual unless they have consented or it is required or authorised by law or the collection is necessary for the establishment, exercise or defence of a legal or equitable claim or the information relates solely to our customers or to individuals who have regular contact with us in connection with our activities and at or before the time of collecting the information the organization undertakes to the individual whom the information concerns that the organization will not disclose the information without the individual’s consent.
8. Morgan’s Services contracted out
The Morgan’s contracts out the following functions of its business:
- Marketing, including handbill & direct mail production.
- Information Technology
- Training development, and delivery.
The Morgan’s on occasion uses external mailing houses and external printers for our publications and postage.
We use contractors for the disposal of paper.
Telstra and others provide communication services to the Morgan’s.
The above organizations and the individuals who work for them have agreed to abide by the Morgan’s Privacy Policy and/or are obliged to apply the National Privacy Principles or a code to the same effect, in the way they handle any personal information collected, held, used, disposed of or disclosed by the Morgan’s for the purpose of any Morgan function or activity they are contracted to perform and not otherwise.
Failure of any contractor or external consultant to abide by the National Privacy Principles, this Policy and their contracted privacy obligations to the Morgan’s Supermarkets may result in their contracts cancelled or not have their contracts renewed with the Morgan’s Supermarkets.
9. Morgan’s IGA Website
The Morgan’s website is at www.morgansiga.com.au. This website is maintained as a service to customers & team members and to allow prospective customers to make enquires about us or purchase from us. Wherever we collect personal information on the website, it is clearly indicated on the website along with our other privacy obligations. The information collected on our website will only be used for the purposes as stated therein.
Some information about the way in which customers use our website is tracked for the sole purpose of developing our website as a user-friendly easily negotiable resource and for no other purpose. This information is not disclosed to any other organization and does not form part of any direct marketing exercise to customers.
10. Morgan’s Supermarkets Privacy Officer
The Morgan’s have nominated a Privacy Officer who can be contacted on 03 9743 4411. All enquires on this policy, requests for access, requests for correction and complaints must be referred to the Privacy Officer.
11. Implementation of the Morgan’s Privacy Policy
All Morgan’s employees, who have access to personal information receive training in the Morgan’s Privacy Policy and procedures and the National Privacy Principles and will collect, use, hold, store and disclose any personal information in accordance with the National Privacy Principles and this Policy.
Failure to abide by this policy of any employee may result in counselling, disciplinary action, and where a serious breach occurs may include the possible termination of their employment.
12. Audits-Ensuring ongoing compliance
The Privacy Officer has ongoing accountability for the compliance of Morgan’s with this Privacy, our procedures and with the Act. This will involve an annual audit of the acts and practices of the Morgan’s in respect of the personal information we collect, use, hold, store and disclose and for ensuring ongoing training to employees to ensure compliance.
The Privacy Officer is also responsible ensuring this policy is appropriately amended to take account of any future amendments to the Act.
13. Complaints of interference with Privacy
Any individual who believes that the Morgan’s may have interfered with their right to privacy as set out in the National Privacy Principles and this Policy can make a complaint to the Privacy Officer.
Complaint process
After receipt of a complaint lodged with the Privacy Officer the Privacy Officer will investigate the allegation.
After the Privacy Officer has conducted an investigation, the Privacy Officer will respond in writing to the individual who has complained with the outcome of the investigation.
Should an interference with an individual’s privacy be acknowledged the Privacy Officer will then take steps to rectify the interference.
The Morgan’s may find that an interference with privacy has not occurred and in these circumstances the complainant will be notified of the reason for this conclusion.
The Privacy Officer will respond in writing as soon as it is practical to do so.
The Morgan’s reserves the right to hold all documents lodged or arising out of or in connection with any complaint of an interference with privacy for the purpose of obtaining legal advice or for demonstrating compliance with the Act, the National Privacy Principles and this Policy
An individual who believes the Morgan’s has interfered with their privacy and who is not satisfied that they have had an appropriate response from the Morgan’s can contact the federal Privacy Commissioner. The website of the Australian Privacy Commissioner is www.privacy.gov.au or telephone 1300 363 992.
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