Privacy Policy

PRIVACY PRINCIPLE 1 - COLLECTION OF PERSONAL INFORMATION

CELTIC HOLDINGS PTY LTD will

(a) not collect personal information unless the information is necessary for one or more of our business functions or activities;

(b) only collect personal information by lawful and fair means, and not in an unreasonably intrusive way;

(c) ensure that at or before the time (or, if that is not practicable, as soon as practicable after) we collect personal information about an individual from the individual, we will take reasonable steps to ensure that the individual is aware of:

(i) our identity and how to contact us; and

(ii) the fact that he or she is able to gain access to the information; and

(iii) the purposes for which the information is collected; and

(iv) the organisations (or the types of organisations) to which we usually disclose information of that kind; and

(v) any law that requires the particular information to be collected; and

(vi) the main consequences (if any) for the individual if all or part of the information is not provided.

In most instances this will be achieved by ensuring that the form the individual completes clearly states our name and contact details, why the information is being collected and includes such other information as may be required;

(d) only collect personal information about an individual from that individual providing that this is reasonable and practicable to do so. At times however, we will use rented mailing lists subject always to the NPP's;

(e) ensure that the individual is or has been made aware of the matters listed in subclause

(c) if we collect personal information about an individual from someone other than that person unless, by making the individual aware of the matters would pose a serious threat to the life or health of any individual.

2. PRIVACY PRINCIPLE 2 - USE AND DISCLOSURE

2.1 CELTIC HOLDINGS PTY LTD will not use or disclose personal information about an individual for a purpose (the secondary purpose) other than the primary purpose of collection unless:

(a) both of the following apply:

(i) the secondary purpose is related to the primary purpose of collection and, if the personal information is sensitive information, directly related to the primary purpose of collection;

(ii) the individual would reasonably expect us to use or disclose the information for the secondary purpose; or

(b) the individual has provided us with written consent to the use or disclosure; or

(c) if the information is not sensitive information and the use of the information is for the secondary purpose of direct marketing:

(i) it is impracticable for us to seek the individual's consent before that particular use; and

(ii) we will not charge the individual for giving effect to a request by the individual to CELTIC HOLDINGS PTY LTD not to receive direct marketing communications; and

(iii) the individual has not made a request to CELTIC HOLDINGS PTY LTD not to receive direct marketing communications; and

(iv) in each direct marketing communication with the individual, CELTIC HOLDINGS PTY LTD draws to the attention of the individual, or prominently displays a notice, that he or she may express a wish not to receive any further direct marketing communications; and

(v) each written direct marketing communication by CELTIC HOLDINGS PTY LTD with the individual (up to and including the communication that involves the use) sets out CELTIC HOLDINGS PTY LTD's business address and telephone number and, if the communication with the individual is made by fax, telex or other electronic means, a number or address at which we can be directly contacted electronically; or

(d) if the information is health information and the use or disclosure is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety:

(i) it is impracticable for us to seek the individual's consent before the use or disclosure; and

(ii) the use or disclosure is conducted in accordance with guidelines approved by the Commissioner under section 95A of the Privacy Act for the purposes of this subparagraph; and

(iii) in the case of disclosure - we reasonably believe that the recipient of the health information will not disclose the health information, or personal information derived from the health information; or

(e) we reasonably believes that the use or disclosure is necessary to lessen or prevent:

(i) a serious and imminent threat to an individual's life, health or safety; or

(ii) a serious threat to public health or public safety; or

(f) we have reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or

(g) the use or disclosure is required or authorised by or under law; or

(h) we reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body:

(i) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;

(ii) the enforcement of laws relating to the confiscation of the proceeds of crime;

(iii) the protection of the public revenue;

(iv) the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;

(v) the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

2.2 If CELTIC HOLDINGS PTY LTD uses or discloses personal information under paragraph 2.1(h), we will make a written note of the use or disclosure.

2.3 Subclause 2.1 operates in relation to personal information that CELTIC HOLDINGS PTY LTD that is a body corporate has collected from a related body corporate as if CELTIC HOLDINGS PTY LTD's primary purpose of collection of the information were the primary purpose for which the related body corporate collected the information.

3. PRIVACY PRINCIPLE 3 - DATA QUALITY

3.1 CELTIC HOLDINGS PTY LTD will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date.

4. PRIVACY PRINCIPLE 4 - DATA SECURITY

4.1 CELTIC HOLDINGS PTY LTD will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorized access, modification or disclosure.

4.2 CELTIC HOLDINGS PTY LTD will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed under National Privacy Principle 2.

5. PRIVACY PRINCIPLE 5 - OPENNESS

5.1 CELTIC HOLDINGS PTY LTD will set out in a document clearly expressed policies on our management of personal information. This Management of Personal Information is to be readily available to anyone who asks for it.

5.2 On request by a person, we will take reasonable steps to let the person know, generally, what sort of personal information it holds, for what purposes, and how it collects, holds, uses and discloses that information.

6. PRIVACY PRINCIPLE 6 - ACCESS AND CORRECTION

6.1 Personal information held by CELTIC HOLDINGS PTY LTD about an individual, must be provided to the individual on receipt of a written request by the individual, except to the extent that:

(a) in the case of personal information other than health information - providing access would pose a serious and imminent threat to the life or health of any individual; or

(b) in the case of health information - providing access would pose a serious threat to the life or health of any individual; or

(d) the request for access is frivolous or vexatious; or

(e) the information relates to existing or anticipated legal proceedings between CELTIC HOLDINGS PTY LTD and the individual, and the information would not be accessible by the process of discovery in those proceedings; or

(f) providing access would reveal the intentions of CELTIC HOLDINGS PTY LTD in relation to negotiations with the individual in such a way as to prejudice those negotiations; or

(g) providing access would be unlawful; or

(h) denying access is required or authorised by or under law; or

(i) providing access would be likely to prejudice an investigation of possible unlawful activity; or

(j) providing access would be likely to prejudice:

(a) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or

(b) the enforcement of laws relating to the confiscation of the proceeds of crime; or

(d) the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or

(e) the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders; by or on behalf of an enforcement body; or

(k) an enforcement body performing a lawful security function asks CELTIC HOLDINGS PTY LTD not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia.

6.2 However, where providing access would reveal evaluative information generated within CELTIC HOLDINGS PTY LTD in connection with a commercially sensitive decision-making process, CELTIC HOLDINGS PTY LTD may give the customer an explanation for the commercially sensitive decision rather than direct access to the information.

6.3 If CELTIC HOLDINGS PTY LTD is not required to provide the individual with access to the information because of one or more of paragraphs 6.1(a) to (k) (inclusive), we must, if reasonable, consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties.

6.4 CELTIC HOLDINGS PTY LTD may charge an individual for providing access to personal information, however those charges:

(a) are not to be excessive; and

(b) must not apply to an individual lodging a request for access.

6.5 If CELTIC HOLDINGS PTY LTD holds personal information about an individual and the individual is able to establish that the information is not accurate, complete and up-to-date, we will take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

6.6 If the individual and CELTIC HOLDINGS PTY LTD disagree about whether the information is accurate, complete and up-to-date, and the individual asks us to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, we will take reasonable steps to do so.

6.7 CELTIC HOLDINGS PTY LTD will provide an individual with written reasons for a denial of access or a refusal to correct personal information.

7. PRIVACY PRINCIPLE 7 - IDENTIFIERS OF CUSTOMERS

7.1 In this Privacy Principle identifier includes a number assigned by CELTIC HOLDINGS PTY LTD to one of our customers to uniquely identify that person for the purposes of our business operations. However, an individual's name or ABN (as defined in the A New Tax System (Australian Business Number) Act 1999) is not an identifier.

7.2 CELTIC HOLDINGS PTY LTD will limit our use of identifiers that Government agencies have assigned to customers and will not adopt as our own identifier, an identifier that has been assigned to a customer by:

(a) a Government agency; or

(b) an agent of a Government agency acting in its capacity as agent; or

(c) a contracted service provider for a Commonwealth contract acting in its capacity as contracted service provider for that contract.

7.3 CELTIC HOLDINGS PTY LTD will not use or disclose an identifier assigned to an individual by a Government agency, or by an agent or contracted service provider mentioned in subclause 7.1, unless:

(a) the use or disclosure is necessary for us to fulfill its obligations to the Government agency; or

(b) one or more of paragraphs 2.1(e) to 2.1(h) (inclusive) of this Policy apply to the use or disclosure.

8. PRIVACY PRINCIPLE 8 - ANONYMITY

8.1 Wherever it is lawful and practicable, individuals must have the option of not identifying themselves when entering transactions with CELTIC HOLDINGS PTY LTD.

9. PRIVACY PRINCIPLE 9 - TRANSBORDER DATA FLOWS

CELTIC HOLDINGS PTY LTD may transfer personal information about an individual to someone (other than the individual) who is in a foreign country only if:

(a) CELTIC HOLDINGS PTY LTD reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of information that are substantially similar to the NPPs; or

(b) the individual consents to the transfer; or

(c) the transfer is necessary for the performance of a contract between the individual and CELTIC HOLDINGS PTY LTD, or for the implementation of pre-contractual measures taken in response to the individual's request; or

(d) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between CELTIC HOLDINGS PTY LTD and a third party; or

(e) all of the following apply:

(i) the transfer is for the benefit of the individual;

(ii) it is impracticable to obtain the consent of the individual to that transfer;

(iii) if it were practicable to obtain such consent, the individual would be likely to give it; or

(iv) CELTIC HOLDINGS PTY LTD have taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the NPPs.

10. PRIVACY PRINCIPLE 10 - SENSITIVE INFORMATION

10.1 For the purposes of this Privacy Principle, sensitive information is defined as personal information a person's:

(a) racial or ethnic origin;

(b) political opinions;

(d) religious beliefs or affiliations;

(e) philosophical beliefs;

(f) membership of a professional or trade association;

(g) membership of a trade union;

(h) sexual preferences or practices; or

(i) criminal record.

10.2 CELTIC HOLDINGS PTY LTD will not collect sensitive information about an individual unless:

(a) the individual has consented to the collection in writing; or

(b) the collection is required by law; or

(c) the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of an individual, where the individual whom the information concerns:

(i) is physically or legally incapable of giving consent to the collection; or

(ii) physically cannot communicate consent to the collection; or

(d) if the information is collected in the course of the activities of a non-profit organization - the following conditions are satisfied:

(i) the information relates solely to the members of CELTIC HOLDINGS PTY LTD or to individuals who have regular contact with it in connection with its activities;

(ii) at or before the time of collecting the information, CELTIC HOLDINGS PTY LTD undertakes to the individual whom the information concerns that we will not disclose the information without the individual's consent; or

(e) the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.

(f) CELTIC HOLDINGS PTY LTD will not collect health information about an individual.

11. POLICIES

Many aspects of how we do our respective jobs in a working day, are covered by State/Territory and Federal legislation as well as Industry Codes of Practice. Privacy is governed by the Privacy Act 1988 (Commonwealth). Yes, we are all governed by red tape whether we like it or not! Both management and employees.

It is essential that we treat each other and others (particularly our customers) in a manner that not only complies with the law, but gives each of us the confidence we need to do our jobs efficiently and professionally.

Individual policies concerning specific aspects of our business practices need to be read and understood. Most importantly they need to be followed. We want to foster a safe, pleasant and professional work environment. The policies we have, assist us to do this.

QUESTIONS

If you have any questions or comments about this Privacy Policy, please contact Craig G. Stevens, +61 8 9485 0133, craig@ccasa.com.au. If you do not have any questions CELTIC HOLDINGS PTY LTD presumes that you understand and are aware of the rules and guidelines in this Privacy Policy and will adhere to them.