Privacy Policy

INTRODUCTION:
Nuplex Industries (Nuplex) sees the importance of privacy to the organisation, its customers and other stakeholders. As such, Nuplex is committed to protecting the privacy of the personal information that we hold. This is part of our organisation.
(a) Legal obligations under the Privacy Act 1988 FOR Australia and the Privacy Act 1993 in New Zealand.
(b) Ethical and business obligations
(c) Service to you.
Nuplex places high priority on effectively dealing with any complaints dealing with privacy that you may have.

OVERRIDING PRINCIPLES:
At all times the conduct under this procedure will be governed by the following principles:
(a) All complaints will be treated seriously
(b) All complaints will be dealt with promptly
(c) All complaints shall be dealt with in a confidential manner
(d) The privacy complaint will not affect your existing obligations or the commercial arrangements that exist between Nuplex and you.

WHO MAY COMPLAIN UNDER THIS PROCEDURE?
If you have provided us with personal information you have a right to make a complaint, have it investigated and dealt with under this procedure.

WHAT IS A PRIVACY COMPLAINT?
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
(a) How personal information is collected
(b) How personal information is stored
(c) How this information is used or disclosed
(d) How access is provided.

WHAT DO I DO IF I HAVE A COMPLAINT ABOUT PRIVACY PRACTICES?
Nuplex resolves grievances at the local level if possible. If you have a complaint about privacy please contact the Privacy Officer.
All complaints will be logged on a complaints register.
You may complain orally or in writing. Usually your contact with the organisation will be the proper person to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter will then be referred to the next level of management.

GRIEVANCE PROCEDURE:
The goal of this procedure is to achieve an effective resolution of your complaint within a reasonable set timeframe (28 days).
Once the complaint has been made, the point of contact can then resolve the matter in a number of ways:
1. Request further information:
Your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential.
2. Discuss options:
We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.
3. Investigation:
The complaint may be investigated. The organisation will try to do so within 72 hours. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.
4. Escalate internally:
If your complaint can’t be resolved it will be referred to senior management. This will be discussed with you before the referral.
5. Discussion with any other parties:
If your complaint deals with the conduct of our employees we will raise the matter with the employee concerned and seek their comment and input in the resolution of the complaint and investigation stage.
6. The complaint is resolved:
If your complaint is found to be substantiated, you will be informed of the reason for the decision. Nuplex will then take appropriate steps to resolve the complaint and prevent the problem from recurring.
7. If the complaint is not substantiated, or cannot be resolved to your satisfaction, but this procedure has been followed, Nuplex’s decision will be final. Your contact will discuss with you the reasons for the decision.
8. If there is still disagreement your complaint will be dealt with by a mutually agreed independent intermediary.
9. If after all the above steps have been followed your complaint is unresolved you are free to take your complaint formally to the federal Office of the Privacy Commissioner.

RECORDS:
The organisation will keep a record of your complaint and the outcome.

ANONYMOUS COMPLAINTS:
Nuplex is unable to deal with anonymous complaints as we are unable to investigate properly and follow-up such complaints.
However, in the event that an anonymous complaint is received Nuplex will note the issues raised and try and resolve them appropriately. For example, Nuplex may wish to conduct further training or provide assistance in a given area.

INFORMATION:
For any further information about this procedure please contact the Privacy Officer.

PURPOSE:
To set out guidelines to ensure the Company complies with the various Privacy acts, in particular the Privacy Principles as set out in the relevant Australian and New Zealand legislation, currently the Privacy Act 1988 (as amended by the Privacy Amendment (Private Sector) Act 2000) in Australia and the Privacy Act 1993 in New Zealand.
To assist in this regard, the Company has appointed Peter Ware to the position of Privacy Officer for the Australia Group and Sylvia Langton as Privacy Officer for the New Zealand Group.

SCOPE:
Applies to all work sites within the Nuplex group of companies in Australia and New Zealand and covers collection, use, disclosure, transfer, security and destruction, but does not apply to employee records.

POLICY:
Personal information concerning individuals is confidential and will only be used for purposes for which the information was collected.

STORAGE:
The safety and security of such information is a prime responsibility, and Nuplex will take all steps necessary to protect such information.

COLLECTION OF PERSONAL INFORMATION:
The collection of personal information is restricted to the purpose for which it is required, for example:
(a) Job applicants – such information as is required to assess a person’s suitability for a position.
(b) Individual personal customers – such information as is required to establish a credit rating if required.

COMPLAINTS:
If anyone has a complaint about the Company’s handling of personal information they have access to the Company’s Complaints Procedure, a copy of which is available from the relevant Privacy Officer.

ACCESS:
You have access to the personal information held by Nuplex about you. You may also make corrections and additions to personal information to make sure that the information is accurate, up to date and complete. To do this, please contact the Human Resources Manager.

EXCEPTIONS:
Personal information may not be used for purposes other than that for which it was collected unless it is:
• with the consent of the person concerned;
• to prevent a serious threat to a person’s health or life;
• as required or authorised by law;
• where reasonably necessary for the enforcement of criminal or revenue law.