In handling personal information, PFA complies with the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and all other relevant Australian privacy laws.
This policy may be updated from time to time.
The kinds of personal information PFA collects:
‘Personal information’ is deﬁned in the Privacy Act to mean any information or opinion about an identiﬁed individual, or an individual who is reasonably identiﬁable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
We collect and hold a range of personal information in carrying out our business and functions as an association representing the unlisted property funds sector. The kinds of personal information that we collect and hold about you will depend upon the nature of our relationship with you.
Generally, the kinds of personal information PFA collects are:
- contact and identification information such as your name, address, telephone number, email address;
- where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;
- banking details and financial information as required for PFA’s functions and activities;
- information about your areas of property interest or specialisation; and
- other information required for PFA’s functions and activities.
In some circumstances PFA may also hold other personal information provided by you.
Contractors, service providers, suppliers and job candidates:
In addition to the information above, the PFA may collect and hold the following kinds of personal information, particularly for job candidates:
- driver’s license, passport number, bank statement or other types of verification details; and
- sensitive information, including health information, where you are applying for a position with PFA and the information is relevant to the recruitment process through which you must progress or where you are an employee and the health information is relevant to your employment with PFA.
How personal information is collected:
In most instances, PFA collects your personal information directly from you, through the completion of a manual or online form, an interaction or exchange in person or by way of telephone, facsimile, email or post, or through the use of the PFA or any other related entity’s website.
There may be occasions when PFA collects your personal information from other sources such as from:
- an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for PFA to provide its products or services to that entity through you or where necessary for that entity to supply products or services to PFA;
- an information services provider;
- if for recruitment purposes, an external recruitment, labour hire, or background screening services provider or third parties with whom you have previously worked;
- a publicly maintained record or other publicly available sources of information including social media and similar websites (such as LinkedIn and Facebook); and
- a government agency.
When we obtain personal information from third parties to whom you refer us, we will assume and you must ensure that you have made that third party aware that you have referred us to them and of the purposes involved in the collection, use and disclosure of the relevant personal information.
How personal information is held:
Personal information is held in hardcopy ﬁles and in electronic form, and all reasonable steps are taken to protect personal information from misuse, interference, loss, and unauthorised access, modiﬁcation or disclosure.
Hardcopy ﬁles are stored in oﬃces, cupboards and compactuses within access-controlled premises. Under our records management system, access to ﬁles is appropriately limited. We may apply additional security measures limiting access to information about ﬁles or store ﬁles in locked cupboards or access restricted rooms as necessary or desirable based on our clients’ needs.
We store electronic records within our own secure network and through third party data storage providers. Personal information within our network is password protected and access is appropriately limited.
Our third-party data storage providers are required to protect personal information in accordance with applicable laws and take appropriate technical and organisation measures against unauthorised or unlawful use of personal information or its accidental loss, destruction or damage.
PFA will destroy or de-identify personal information in circumstances where it is no longer required, unless PFA is otherwise required by law to retain the information.
The purpose for which we collect, hold and disclose personal information:
PFA collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
- providing PFA’s services and products to you (or the organisation you represent) and all associated purposes including:
- to verify your identity and contact details;
- for invoicing and/or administrative purposes;
- to respond to any inquiries, feedback or complaints made by you;
- enabling PFA to promote its products and services to you;
- assisting PFA to improve its products and services;
- managing PFA’s internal business operations and processes;
- processing and assessing employment applications for current and future positions;
- your employment with PFA;
- accounting, billing and other internal administrative purposes;
- complying with our legal and regulatory obligations; and
- to otherwise carry out our functions as a professional service
PFA may also use your personal information for purposes related to the above purposes and for which you would reasonably expect PFA to do so in the circumstances, or where you have consented, or the use is otherwise in accordance with law.
Where personal information is used or disclosed, PFA takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to PFA. However, without certain information from you, PFA may not be able to provide its products and/or services to you.
To whom PFA discloses personal information
PFA discloses your personal information for the purpose for which PFA collects it. That is, generally, PFA will only disclose your personal information for a purpose set out above. This may include disclosing your personal information to:
- third parties engaged to perform administrative or other business management functions;
- people or entities considering acquiring an interest in PFA’s enterprise or assets;
- PFA’s professional advisors, agents, contractors, consultants and related bodies corporate;
- insurance providers;
- recruitment and labour hire agencies (as required); and
- regulatory bodies if and as necessary, including during audit processes.
PFA’s disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. PFA may also disclose your personal information with your consent or if disclosure is required or authorised by law.
PFA is not likely to disclose personal information to overseas recipients. However, in the event PFA does disclose personal information to overseas recipients, PFA will, before disclosing any personal information to an overseas recipient, take steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
If you are a current member or prospective member or have otherwise expressed interest and provided us with your contact details, we may send emails to you about our research and our services.
We use an “email management system” to automate the management and dispatch of these emails. The system operates by inserting tracking codes in the emails that we send to you. The tracking code allows us to collect personal information about you, such as whether you received and opened an email, and whether you clicked through to any links to our website. The personal information that the email management system collects and holds about you is used by us to:
- ensure that you only receive correspondence that you have informed us that you wish to receive;
- insert your personal information into our communications with you;
- determine whether the information that we send to you is suitable for your interests, information needs and proﬁle;
- ensure that the email address that you have provided us is still operational;
- determine whether emails that we send to you are received by you;
- update a request that you make to us to unsubscribe from a publication that we send to you; and
- review the eﬀectiveness and relevance of our emails to you by collecting other statistical
If you do not wish for us to send you such emails, please let us know by contacting our Privacy Oﬃcer at the details below. You can also unsubscribe from our email notiﬁcations by clicking on the ‘Unsubscribe’ button at the bottom of our email notiﬁcations and following the prompts or by emailing us by clicking the ‘Contact Us’ button for details or emailing firstname.lastname@example.org.
When accessing PFA’s or a related entity’s website, PFA uses ‘cookies’ which are small pieces of information sent from the website and stored by your browser on your computer’s hard drive. Cookies that PFA use enable our systems to provide features of our services and allow you to visit our website without re-entering your username and/or password, personalise and improve your experience, and improve the functionality and user-friendliness of our services and monitor how our website is used through your computer.
This information is used by PFA to improve and tailor our website functionality and better understand how you interact with PFA’s products and services and to monitor aggregate usage and web traffic routing on our website. You can modify your browser setting by editing your browser options to reject PFA’s cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of PFA’s online services may not function properly.
Access to your personal information:
PFA takes steps reasonable in the circumstances to ensure personal information we hold is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to request access to personal information that we hold about you and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. If at any time you would like to access or correct the personal information PFA holds about you, or you would like more information on PFA’s approach to privacy, please contact PFA’s Privacy Oﬃcer at the details below.
PFA will grant access to the extent required or authorised by the Privacy Act and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- PFA requests that you be reasonably specific about the information you require; and
- PFA may charge you a reasonable administration fee, which reflects the cost to PFA for providing access in accordance with your request.
PFA will endeavor to respond to your request to access or correct your personal information within 30 days from your request.
If you would like to complain about a breach of the Australian Privacy Principles, you may contact our Privacy Oﬃcer at the details below.
At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and PFA.
If you disagree with our decision, you may refer your complaint to the Oﬃce of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing email@example.com.
If you would like more information about the way we manage personal information, would like to request access to or correction of personal information that we hold about you, or wish to make a complaint, please contact our Privacy Oﬃcer: