Privacy policy
TT-Line Company Pty Ltd ("TT-Line") is legally bound by the
Personal Information Protection Act 2004 (Tas) ("PIP Act") and the
National Privacy Principles set out in the Privacy Act 1988 (Cth)
(the "Privacy Act").
In order to fulfil our obligations under the PIP Act and the
Privacy Act, TT-Line expects all management and staff to read and
abide by our Privacy Policy, which sets out how TT-Line will manage
and secure personal information.
TT-Line is committed to developing a culture that respects the
privacy of individuals through ensuring the security of personal
information about them. We will protect personal information from
misuse, loss, corruption or disclosure.
TT-Line has appointed a Privacy Officer who is responsible for
ensuring TT-Line's Privacy Policy and procedures are fully
implemented and working effectively and promoting TT-Line's Privacy
Policy to all staff.
The Company appointed Privacy Officer will also be the first point
of contact for all privacy concerns raised by customers or
staff.
In order to comply with the privacy provisions in the PIP Act
and the Privacy Act, TT-Line has developed this prominent and
easily accessible Privacy Policy. The Privacy Policy will be placed
online and will be available in hard copy form. TT-Line's online
Privacy Policy will be placed on a link that is clearly visible on
our home page. People will be advised to read the statement (as
well as the terms of carriage) before they commit to an online
booking or enter their details on the e-news sign up
form and/or brochure requests.
1 Collection
TT-Line only collects personal information that is necessary for
our functions and activities as a passenger, vehicle and freight
service and agent of travel insurance providers. This means that
the Company need to collect customers name and contact details and
billing information.
TT-Line will also collect information for sales and marketing
and market research purposes. TT-Line will not include customer's
personal details on any of our sales or marketing databases if the
customer has requested not to receive direct marketing
communications.
Generally, TT-Line does not need to collect any personal
information when users visit our website - generally you can visit
our website without telling us who you are or revealing other
personal information.
If TT-Line wish to collect personal information about users
(such as name, contact information or other registration
information) via the internet, then the Company will operate by
these principles: TT-Line will expressly ask you for that personal
information; when the Company asks you for that personal
information, TT-Line will tell you how the Company intend to use
that personal information if you choose to give it to TT-Line. For
instance, the Company may wish to use that personal information to:
personalise and tailor TT-Line's information, services or products
for you; to identify who the Company is communicating with; or to
inform you of further information relating to the Company's
services or products, or to this website; TT-Line intend to keep
track of the domains from which people visit us. TT-Line analyses
this data for trends and statistics.
2 Disclosure
TT-Line does not sell or disclose any information held by it to
third parties or contractors except for market research purposes
and the provision of travel insurance.TT-Line does not transfer
personal information overseas or out of Tasmania unless satisfied
that the information will be afforded similar protection as TT-Line
is required to provide, or where it is necessary to complete
insurance arrangements for the customer's benefit.
TT-Line does not sell or disclose personal information to any
third parties for the purposes of direct marketing.
If clients tell TT-Line that they do not wish to have this
personal information used for a particular purpose, the Company
will respect their wishes and they can e-mail TT-Line at privacy@spiritoftasmania.com.au
to do this. TT-Line will make customers aware of the implications
this may have on the service TT-Line can provide.
TT-Line will co-operate with all law enforcement bodies in
providing information when requested.
3 Access and Correction
All clients have a legal right to access the information TT-Line
hold about them unless restriction of access is permitted by law,
including under the Right to Information Act 2009 (Tas). They can
request an electronic printout of this information by contacting
our Privacy Officer on (03) 6421 7305 or email on privacy@spiritoftasmania.com.au.
Clients may request amendment of that information if it is
incorrect, incomplete, out of date or misleading.
Individuals do not have to give a reason when asking for access
to personal information. A printout of information held on all
databases as well as a copy of the reservation details should be
sent to the individual on request.
The rules regarding an individual's access to information means
that people may have a right to access telephone operator comments
about them.
4 Queries or complaints
If you have any queries or complaints about the way the Company
handles your personal information please do not hesitate to contact
our Privacy Officer on (03) 6421 7305 or email on privacy@spiritoftasmania.com.au.
5 Telephone statement
For individuals making a new booking using the Company's
telephone booking service, TT-Line will provide the following
information.
"TT-Line is legally bound by the Tasmanian Personal Information
Protection Principles and the National Privacy Principles. We
collect personal information such as your name, contact and billing
details, which are necessary for our functions and activities. We
do not disclose this information to third parties except for market
research purposes and the provision of travel insurance. Nor will
we use this information for direct marketing if you instruct us not
to do so. You are entitled to request access to copies of your
information held by TT-Line. If you require any further information
on the privacy principles please advise your telephone sales
consultant or email our Privacy Officer on
privacy@spiritoftasmania.com.au."
6 Sales and direct
marketing
Individuals must be told that they can opt out of receiving any
more marketing or promotional literature.
All TT-Line marketing correspondence will display a clearly
visible and user-friendly opt-out tick box. TT-Line may imply
consent to receive marketing material where this opt-out box is not
ticked.
All personal information held on any marketing databases will be
permanently destroyed or de-identified within 45 days of receipt of
an opt-out notice or a request to be removed from the database.
7 Travel Club/Spirit
e-News
TT-Line's Travel Club/Spirit e-News will continue to work
on an opt-in basis. TT-Line will not send online marketing material
without an opt-out clause.
8 Law enforcement
The PIP Act and Privacy Act are not intended to interfere with
legal obligations to disclose information for law enforcement and
regulatory purposes.
TT-Line has a procedure for the purpose of using and disclosing
personal information for investigating and reporting suspected
unlawful activity to the relevant authorities.
9 Emergencies and
disasters
In the event of an emergency or where TT-Line deems it
necessary, passengers' names and addresses will be provided to
authorities and/or agencies assisting in dealing with any such
emergency or disaster. By booking and travelling with TT-Line,
passengers are deemed to consent to the disclosure of this
information to such authorities and/or agencies.
10 Data quality
There is a legal requirement to ensure that all data collected
is accurate, complete, up-to-date and relevant to TT-Line's
functions or activities.
11 Data security
TT-Line treats all personal information as confidential. The
Company has a secure Internet transmission and takes all reasonable
steps to ensure that your personal information is protected from
unauthorised access, use, modification or disclosure.
TT-Line will continue to develop and monitor security measures
in order to decrease the risk of unauthorised access to personal
information.
TT-Line will continue to engage IT support to maintain computer
and network security including access control for authorised users,
data integrity checks, network intrusion systems, host intrusion
detection systems and expert monitoring.
All information no longer required for any purpose for which it
may be used or lawfully disclosed by TT-Line will be destroyed or
permanently de-identified. Permanent de-identification means
that TT-Line is not able to match the de-identified information
with other records to re-establish the identity of individuals.
12 Sensitive information
TT-Line does not usually collect sensitive information, which
includes information about a person's racial or ethnic origin,
political opinions, religious beliefs or health.
However, the Company does collect health information for the
purposes of our Passenger Monthly Accident/Illness Reports and as
required or permitted by health and safety laws.
13 Breach of privacy
The Tasmanian Ombudsman and the Commonwealth Information
Commissioner have the power to investigate complaints made by
individuals about the way organisations manage personal information
or to investigate any act or practice that may be a breach of
privacy, even if no complaint has been made.
14 Conclusion
Compliance with this privacy policy will increase consumer
confidence in our privacy procedures and build a better reputation
for our company.
If you have any concerns about privacy issues after reading this
policy, or if you become aware of a potential breach of privacy,
please contact our privacy officer immediately, on (03) 6421 7305
or email on privacy@spiritoftasmania.com.au