When does this policy apply?
This policy sets out the principles that Mulpha Australia Limited and its subsidiaries (Mulpha/we/us/our) adopt in the conduct of our business in order to protect your personal information. A number of our subsidiaries engage in activities under other brands. You can contact the Mulpha Group Privacy Officer to verify the details of the corporate group entity that this policy applies to. You can obtain a copy of this policy from our website at mulpha.com.my or by contacting our Privacy Officer whose details are set out below.
Protecting Your Privacy
Mulpha are committed to providing you with exceptional service, and this includes protecting your privacy and being open and transparent about what we do with your personal information. We aim to maintain a safe and secure system of handling your personal information, whilst still providing access to your personal information when required. For this reason, we aim to ensure that your personal information is handled in strict compliance with the Australian Privacy Principles (APPs) which are part of the Commonwealth Privacy Act 1988.
This policy explains what kind of information we collect and hold; how and why we collect, hold and use it; and how and to whom we disclose that information. It also provides details about how you may access and seek correction of the personal information that we hold about you, and what you can do if you are not satisfied with how we have dealt with your personal information.
What is Personal Information and how do we collect it?
Personal information is information or an opinion (whether true or not and whether recorded in a material form or not) about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from an individual in their capacity as a client, customer, contractor, stakeholder, job applicant or in some other capacity.
In the course of our business and providing products and services we collect and hold:
As part of our recruitment processes for employees and contractors, we may collect and hold:
Generally, we will seek consent from you in writing before we collect your sensitive information.
We only collect personal information about you that is necessary for us to carry on our business functions. The information we collect about you depends upon the nature of our dealings with you. Generally, we only collect personal information from you, unless it is not reasonable or practical to do so in which case we may also collect personal information about you from third parties.
Information we collect from you
We collect personal information from you during your interactions with us, for example if you:
We may collect information based on how you use our website. We use ‘’cookies’’ and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyse and improve our website, marketing campaigns and to record statistics on web traffic.
If you access your account with us online through a secure area of our website, we will collect your personal information using cookies. This is designed to track the use of our website and to allow our customers to effectively access their account information. This information is collected for security purposes and to protect the integrity of account details.
Information we collect from others
We collect personal information about you from third parties such as:
We only collect sensitive information if it is:
Wherever it is lawful and practicable, we will give you the option of not providing information when dealing with us. However, in most cases, if you do not provide the full and complete information requested we will be unable to provide our products or services to you.
Using your information
We only use your personal information for:
We use your personal information so we can, amongst others:
We may also collect, use and exchange your information in other ways where required by law or permitted by Privacy Act 1988.
If you don’t want to receive direct marketing, you can tell us by emailing us and telling us which list you would like to be removed from at firstname.lastname@example.org or write to us at Level 6, 99 Macquarie Street Sydney, NSW 2000 Australia. If we undertake direct marketing we acknowledge that we are bound by the Spam Act 2003 and the Do Not Call Register Act 2006.
Using government identifiers
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
Disclosing your information
The reasons for disclosing your personal information and the parties to whom we might disclose it will be reasonably apparent to you when we collect your information. Our disclosure of your personal information will only be in connection with our business activities or where you have given consent. Where personal information is disclosed to any third party we will take reasonable steps to ensure that the person receiving your personal information keeps it confidential and does not misuse it or improperly disclose it to any other person.
Personal information may be shared between different entities within the Mulpha Group but where this occurs the principles contained in this policy will continue to apply to it.
We may disclosure your personal information to following parties:
We will not sell your personal information to other organisations.
Disclosure of your personal information to overseas recipients
We may disclose your personal information to an overseas organisation in the course of providing our goods or services to you, for example if any of the above named parties are located overseas, or directly to our own offices or agents in an overseas location, or when storing information with a “cloud service provider” which stores data outside of Australia. Where we do this, we make sure as far as reasonably possible that:
Please note that some of these overseas recipients may not operate in countries which have a similar privacy regime to Australia.
Storage and Security of Personal Information
We store personal information in a variety of formats including, but not limited to:
We take all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps include, but are not limited to:
Our public website may contain links to other third-party websites outside of the Mulpha Group. We are not responsible for the information stored, accessed, used or disclosed on such websites and we cannot comment on their privacy policies.
Responding to data breaches
We will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).
If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.
The Quality of Personal Information
We take all reasonable steps to ensure the Personal Information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information.
If we become aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.
How do you access your information?
You may ask us what personal information we hold about you, and you may make a request to access to this information at any time. You may make a request by us by contacting our PRIVACY OFFICER (see below contact details). We may ask you to complete a PERSONAL INFORMATION REQUEST FORM and will process your request within a reasonable time and try to make this information available within 30 days of your request. Before we give you the requested information we will need to confirm your identity.
We generally will not charge you a fee in respect of such access but reasonable administrative costs may be charged in some circumstances. If there is an access charge, we will give you an estimate first and ask you to confirm that you would like us to proceed, if you would like us to we do require payment up front. Generally, the access charge is based on an hourly rate plus any other reasonable costs incurred by us such photocopying and postage. We do not need to provide access to your information in several circumstances; for example, the information is commercially sensitive, the request is frivolous or would unreasonably interfere with another person’s privacy or be in breach of the law, or, where to provide access would pose a threat to health or public safety. If we refuse you access we will advise you of our reasons for doing so.
How do you Correct or update your information?
You may ask us at any time to correct the information we hold about you or that we have provided to others us by contacting our PRIVACY OFFICER (see below contact details). We will process your request within a reasonable time and try to correct the information within 30 days. If it looks like it will take longer, we will let you know the reason for the delay and try to agree to an extended timeframe with you.
If we are able to correct your information because it is indeed inaccurate we will inform you when it is so corrected.
If we disagree with you that the information is inaccurate and should be corrected, we will inform you in writing of our reasons. You may request that we attach a statement to that relevant information noting that you consider it is inaccurate misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps to comply with such a request.
What can you do if you have a complaint?
If you are not happy in respect of how we have dealt with your personal information or in gaining access to it, please contact our PRIVACY OFFICER to discuss your concerns (see below contact details). We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response. If we do not resolve your complaint to your satisfaction or we are unable to resolve your complaint you have the right to refer the matter the Office of the Federal Privacy Commissioner – Privacy Hotline on 1300 363 992 or visit their website at www.oaic.gov.au or writing to GPO Box 5218 Sydney NSW 2001. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.
How to contact us:
Address: Mulpha Group Level 6, 99 Macquarie Street Sydney, NSW 2000 Australia
Phone: +61 2 9270 6186
Changes to our privacy and information handling practices