Charter Keck Cramer is committed to respecting your privacy. This Policy describes the types of personal information we collect about you, and how we may use or disclose that information. It applies to Charter Keck Cramer, our related companies, wholly owned subsidiaries, agents, and contractors (together “Charter”, “we”, “our” or “us”) in relation to our clients, prospective clients, suppliers, and other individuals who we deal with in the course of our business.
We will generally take steps to notify you of this Policy whenever we collect personal information from you. It is important that you read this Policy in full, so that you understand how your personal information may be collected, used, and disclosed by us.
From time to time, we may need to make changes to this Policy to reflect changes to our services, how we do business, or because of changes to the law. We will endeavour to notify you of any material changes to this Policy by notice on our website.
1 What is personal information?
Throughout this Policy, we refer to your “personal information”. This means any information or opinion about you from which you can be reasonably identified. Your name, home address, and home telephone number are examples of your personal information.
We may also collect and handle information that is not about you, or that cannot reasonably identify you. This information is not “personal information” and is therefore not the subject of this Policy. Examples of this information can include information about a corporate client (where this does not identify any individual) or aggregated statistical information (such as research data about market trends or demographics where the data does not relate to any specific individual).
2 What personal information does Charter collect?
2.1 General information
The main types of personal information that we collect include:
- names and contact details for clients, potential clients, business partners,contractors, service providers, newsletter subscribers, attendees at eventsand seminars provided by Charter etc;
- information you provide during meetings or calls with us (e.g. businesscards);
- financial and transactional information, such as bank account details, payment details, or tax file numbers for clients, contractors, service providers etc;
- property sales and valuation data, which may identify a specific individual (e.g. the property owner or purchaser);
- marketing information such as a your investment preferences, services you may be interested in, your communications preferences etc.;
- information we may ordinarily collect about you if you apply for a position at Charter, such as your CV, covering letter, police check report, references, right to work (visa) documentation, proof of identity documents, academic qualifications and transcripts etc;
- call records and logs if you call our offices, such as call metadata, call recordings (where we have notified you that a call will be recorded) or voice messages;
- CCTV footage if you enter the Charter premises; and
- network security logs (such as IP addresses and time of access) if you use our network.
2.2 Cookies and other metadata
The data we collect using cookies may include:
- your device type and operating system;
- the parts of our website or online services you have accessed;
- when you have accessed our website or online services;
- your general location (we do not track your precise location); and
- your browsing settings or preferences.
Most web browsers will allow you to delete or disable cookies at any time and without charge. However, some of our online services may no longer function correctly if you disable all cookies.
2.3 Sensitive information
Occasionally, we may need to collect sensitive information about you.
Sensitive information means 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.
The main types of sensitive information we collect are:
- information about your professional memberships or affiliations;
- health information such as dietary requirements or allergies, for example, where you register to attend one of our events; and
- information about your criminal history if you apply for a position with Charter.
If we need to collect your sensitive information, then we will generally seek your express consent before doing so, unless the law requires us to collect this information.
3. How does Charter collect my personal information?
We may collect your personal information when you interact with us in the following ways:
- if you seek or receive consulting, advisory, valuation, or other services from us;
- if you participate in market research activities we conduct;
- if you register for or attend an event, seminar, or workshop we provide;
- if you sign-up to receive our newsletter or other subscription services;
- if you contact us through our website or other communication channels (including email, telephone, or social media);
- if you apply for a position with Charter;
- if you visit and browse our website or other online services;
- if you access our premises, connect to our network, or access our cloud sharing applications (such as OneDrive); and
- if you are engaged by us as a contractor or sub-contractor.
There may be other specific circumstances where we will collect your personal information. We will generally take steps to notify you when we collect your personal information, or ensure you are made aware of this, at or before the time of collection (or as soon as practicable after we collect your personal information).
4 How will Charter use my personal information?
4.1 General purposes for which we use your personal information
Depending on the services you receive from us, and how you interact with us, we may collect, hold, and use your personal information for the following general purposes:
- to provide services that we have been engaged to provide;
- to communicate with clients, prospective clients, contractors, service providers, and other third parties that we work with;
- to conduct market research and perform data analytics;
- to prepare for and conduct industry events, workshops, and seminars;
- to assess market trends and to identify new business opportunities;
- to develop and market new products or services;
- or compliance purposes such as meeting qualification, license and professional membership requirements;
- for tender submissions or valuation panel applications (professional memberships only); and
- for security review purposes.
4.2 Specific purposes for which we use your personal information
In some cases, we may need to collect, hold, or use your personal information for a more specific purpose not listed in section 4.1 above. In such cases, we will generally take steps to notify you of those specific purposes at or before the time we collect your personal information (or as soon as practicable after we collect your personal information).
We may use your personal information for marketing activities, such as determining the types of products or services you might be interested in, analysing market trends, or developing new products or services.
We will not use your sensitive information for marketing purposes unless you have consented to us doing so.
If you have consented to us doing so, we may from time to time use your non-sensitive personal information (such as your postal address or e-mail address) to send you marketing communications about our products and services (including, for example, invitations to events or seminars we run).
All marketing communications we send will include a simple process to “unsubscribe” if you no longer wish to hear from us. We will process all “unsubscribe” requests within five business days.
5 Who does Charter share my personal information with?
5.1 Sharing internally within Charter
We may share your personal information with our related companies and their wholly owned subsidiaries, our agents, and our contractors. Your personal information will only be shared with these entities on a “needs to know” basis, and for the purposes described in section 4 above.
5.2 Sharing with third parties
In the course of our business, we may need to share your personal information with third parties for one or more of the purposes set out in section 4 above.
The main types of third parties to whom we may share your personal information are:
- our service providers, such as third party payroll providers (e.g. ADP Payroll) or mail service providers (e.g. MailChimp);
- our professional advisers (e.g. accountants, consultants, auditors, lawyers etc.);
- financial institutions such as banks;
- business partners that provide products or services jointly with Charter;
- valuation exchange services such as ValEx;
- entities that provide or receive data under an agreement with Charter;
- industry bodies such as the Australian Property Institute (API) and the Australian Property Institute Valuers Limited (APIV); and
- insurance brokers and insurers.
If we share your personal information with a third party, we will generally take steps to ensure the third party only uses or discloses the personal information for the purposes described in section 4 above, and otherwise handles the personal information in accordance with this Policy.
5.3 Sharing outside of Australia
Some of the third parties we may share your personal information with will be located overseas including, for example, in the United States.
If we share your personal information with a third party located outside Australia, we will generally take steps to ensure the third party handles your personal information in accordance with this Policy and Australian privacy and data protection principles, unless we are required by law to share your personal information with the third party.
6 How can I access my personal information?
You have the right under the Privacy Act 1988 (Cth) to request access to any personal information we hold about you. If you would like to request access to your personal information, please contact firstname.lastname@example.org.
We will generally provide access to your personal information in the manner you have requested, and within a reasonable period after receiving your request, unless we are required or permitted by law to refuse access (for example, where providing access will have an unreasonable impact on the privacy of another person).
We may charge a reasonable fee for the costs of retrieval and supply of any requested personal information.
7 How can I request corrections to my personal information?
You have the right under the Privacy Act 1988 (Cth) to request corrections to any personal information we hold about you if you believe the information is inaccurate, out-of-date, incomplete, irrelevant, or misleading. If you would like to request a correction to your personal information, please contact email@example.com.
We will generally make any requested corrections to your personal information within a reasonable period after receiving your request, unless we are required or permitted by law to refuse the request.
8 How can I contact Charter if I have questions or complaints?
If you have any questions or concerns about our collection, use, or disclosure of your personal information, or if you believe we have not complied with this Policy or the Privacy Act 1988 (Cth), please contact us at firstname.lastname@example.org.
We take all privacy complaints seriously and will aim to resolve any complaints in a timely and efficient manner. Our target response time for responding to questions or complaints is 30 days, although in some cases, it may take us longer to respond if the question or complaint is particularly complex.
If, after receiving our response, you remain dissatisfied, you can also make a complaint to the Officer of the Australian Information Commissioner using the following details:
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing
1300 363 992
Director of Compliance
Office of the Australian
GPO Box 5218
Sydney NSW 2001