Privacy Policy

From 12 March 2014, the Australian Privacy Principles (APP’s) replaced the National Privacy Principles and Information Privacy Principles and were inserted into the Privacy Act 1988 (“the Act”) at schedule 1. These principles apply to private sector organisations who deal with information relating to individuals. This legislation is designed to protect personal information about individuals and sets in place a framework and guidelines about how to deal with this information. APP 1.3 requires an APP entity to have a clearly expressed and up-to-date APP privacy policy describing how it manages personal information. Further in February 2018, the Notifiable Data Breaches (“NDB”) Scheme was introduced under Part IIIC of the Act. The NDB establishes requirements and compliance mechanisms for entities in responding to data breaches.

As at 25 May 2018, the EU General Data Protection Regulation (“GDPR”) was introduced providing increased transparency for data protection for all businesses transferring data to the Europe Union. While the GDPR and the APP share some similarities, Sky Free Energy Pty Ltd is providing robust privacy policies and procedures for its staff and clients. This includes ensuring that it conforms to all required APP’s including the provision of a clearly expressed and readily available Privacy Policy. This is completed by the provision of this Privacy Policy Manual.

An APP privacy policy is a key tool for meeting APP 1’s requirements.

To assist with this compliance, Sky Free Energy Pty Ltd ensures that all of its staff members adhere to these policies and procedures. Any breaches of these policies and procedures must be reported to the relevant staff member’s manager or supervisor immediately so that any appropriate measures can be taken to mitigate any issues surrounding an identified breach.

Every staff member of Sky Free Energy Pty Ltd who handles personal information is
required to have an understanding of the Australian Privacy Principles (APP’s), the Act and the GDPR, where necessary. Where a more detailed knowledge of Sky Free Energy Pty Ltd’s rights and responsibilities is required, the Privacy Officer will be able to provide assistance.

All staff are encouraged to discuss privacy issues with the nominated Privacy Officer.

Review

Formal review of this privacy policy shall be undertaken on a 6 monthly basis with the details of this review recorded by the Privacy Officer.

The Privacy Act 1988 and the Credit Reporting Privacy Code 2014 places obligations and responsibilities on employers and employees to ensure that information collected from individuals is collected, retained and used in line with the APP’s. Sky Free Energy Pty Ltd shall abide by the following APP’s at all times:

APP No.
Part 1 – Consideration of personal information privacy
APP 1 Open and transparent management of personal information
APP 2 Anonymity and pseudonymity

Part 2 – Collection of personal information
APP 3 Collection of solicited personal information
APP 4 Dealing with unsolicited personal information
APP 5 Notification of the collection of personal information

Part 3 – Dealing with personal information
APP 6 Use or disclosure of personal information
APP 7 Direct marketing
APP 8 Cross-border disclosure of personal information
APP 9 Adoption, use or disclosure of government related identifiers

Part 4 – Integrity of personal information
APP 10 Quality of personal information
APP 11 Security of personal information

Part 5 – Access to, and correction of, personal information
APP 12 Access to personal information
APP 13 Correction of personal information

Further information regarding the APP’s can be obtained from the office of the Australian Information Commissioner at www.oaic.gov.au.

A copy of the APP’s as produced by the Office of the Australian Information Commissioner is attached as Appendix A. The NDB forms part of the Act as a new implemented scheme for companies to advise its clients, in the event of a potential data breach that is likely to result in serious harm to any individuals whose personal information is involved in the breach. Sky Free Energy Pty Ltd’s Privacy Policy Manual provides a data breach preparation and response to any potential breaches to ensure compliance under the NDB and the Act.

Upon the implementation of the GDPR on 25 May 2018, Sky Free Energy Pty Ltd has updated the way they use and collect personal data from residents in the EU. This involves, identifying Sky Free Energy Pty Ltd’s data protection officer (“Privacy Officer”), how clients can contact the Privacy Officer and identifying the process of transferring client’s personal information. Further, the implementation of cookies notices on Sky Free Energy Pty Ltd’s website has been activated to ensure Sky Free Energy Pty Ltd’s clients have adequate protection in providing consent to Sky Free Energy Pty Ltd in withholding their personal data.

Sky Free Energy Pty Ltd collects personal information for a variety of reasons. This personal information will be collected in the normal course of business and will relate to Goods and/or Services that are provided by Sky Free Energy Pty Ltd to clients. This information collected will be done so in the course of business where the client is a customer of Sky Free Energy Pty Ltd or when the client acts as a guarantor for another person or company that is a client of Sky Free Energy Pty Ltd. Sky Free Energy Pty Ltd will not collect information that is not relevant or sensitive in nature unless it is required in the normal course of business.

The personal information that is collected may include, but will not be limited to the following;

• Full name
• Address
• Date of birth
• Credit references if applicable
• Publicly available information which relate to the clients activities in Australia
• Any information recorded in the National Personal Insolvency Index
• Driver’s licence details
• Medical insurance details (if applicable)
• Electronic contact details including email, Facebook and Twitter details
• Next of kin and other contact information where applicable.

The client acknowledges that provided the correct Privacy Act disclosures have been made that Sky Free Energy Pty Ltd may conduct a credit report on the client for the purposes of evaluating the credit worthiness of the client.

Sky Free Energy Pty Ltd ensures that all personal information is held in a secure manner. Where applicable and to the best of Sky Free Energy Pty Ltd’s knowledge all computers or servers have the required security protections in place to safeguard and protect any personal information that is held by Sky Free Energy Pty Ltd.

We use cookies on our website. Cookies are small files which are stored on your computer. They are designed to hold a modest amount of data (including personal information) specific to a particular client and website and can be accessed either by the web server or the client’s computer. In so far as those cookies are not strictly necessary for the provision of Sky Free Energy Pty Ltd’s services, we will ask you to consent to our use of cookies when you first visit our website.

In the event that you utilise our website for the purpose of purchases/orders, Sky Free Energy Pty Ltd agrees to display reference to cookies and /or similar tracking technologies, such as pixels and web beacons (if applicable), and requests consent for Sky Free Energy Pty Ltd collecting your personal information which may include:

• IP address, browser, email client type and other similar details;
• Tracking website usage and traffic; and
• Reports are available to Sky Free Energy Pty Ltd when Sky Free Energy Pty Ltd sends an email to the client, so Sky Free Energy Pty Ltd may collect and review that information.

If you consent to Sky Free Energy Pty Ltd’s use of cookies on our website and later wish to withdraw your consent, you may manage and control Sky Free Energy Pty Ltd’s privacy controls through your browser, including removing cookies by deleting them from your browser history when you leave the site.

Sky Free Energy Pty Ltd also regularly conducts internal risk management reviews to ensure that its infrastructure (to the best of its knowledge) is secure, and any identifiable risks have been mitigated as much as they can be in the normal course of business.