TT-Line Company Pty Ltd ("TT-Line") is legally bound by the
National Privacy Principles set out in the new provisions of the
Privacy Act 1988 (Cth) (the "Privacy Act"), which will come into
effect on 21 December 2001.
In order to fulfil our obligations under the Privacy Act,
TT-Line expects all management and staff to read and abide by our
privacy policy, which sets out how we 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 will appoint a privacy officer who will be 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 privacy officer (Kevin Maynard) will also be the first point
of contact for all privacy concerns raised by customers or
staff.
In order to comply with the new privacy provisions in 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. Our 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.
Collection
TT-Line only collects personal information that is necessary for
our functions and activities as a passenger, vehicle and freight
service. This means that we need to collect customers name and
contact details.
We also collect information for sales and marketing purposes. We
will not include customer's personal details on any of our sales or
marketing databases unless they authorise us to do so.
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 we wish to collect personal information about users (such as
name, contact information or other registration information) via
the internet, then we will operate by these principles: we will
expressly ask you for that personal information; when we ask you
for that personal information, we will tell you how we intend to
use that personal information if you choose to give it to us. For
instance, we may wish to use that personal information to:
personalise and tailor our information, services or products for
you; to identify who we are communicating with; or to inform you of
further information relating to our services or products, or to
this website; we intend to keep track of the domains from which
people visit us. We analyse this data for trends and
statistics.
Disclosure
TT-Line does not sell or disclose any information held by it to
third parties or contractors, and does not transfer personal
information overseas.
We do not sell or disclose personal information to any third
parties for the purposes of direct marketing.
If clients tell us that they do not wish to have this personal
information used for a particular purpose, we will respect their
wishes and can e-mail TT-Line at privacy@spiritoftasmania.com.au
to do this.
TT-Line will co-operate with all law enforcement bodies in
providing information when requested.
Data security
TT-Line treats all personal information as confidential. We have
a secure Internet transmission and take all reasonable steps to
ensure that your personal information is protected from
unauthorised access, modification or disclosure.
Access
All clients have a legal right to access the information we hold
about them. They can obtain an electronic printout of this
information by contacting our Privacy Officer on (03) 6421 7305 or
email on privacy@spiritoftasmania.com.au.
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 have a right to access telephone operator comments
about them. Please be aware of this right to access information and
take care not to write insensitive comments about passengers when
taking telephone bookings.
Queries or complaints
If you have any queries or complaints about the way we handle
your personal information please do not hesitate to contact our
Privacy Officer on (03) 6421 7305 or email on privacy@spiritoftasmania.com.au.
Telephone statement
For individuals making a new booking using our telephone booking
service, TT-Line will provide the following information.
"TT-Line is legally bound by the National Privacy Principles. We
collect personal information such as your name and contact details,
which is necessary for our functions and activities. We do not
disclose this information to third parties. nor will we use this
information for direct marketing if you instruct us not to do so.
Do you require any further information on the privacy
principles."
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.
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. This is because it is usually difficult
to conclude that a message has been read. It is also commonly
considered that there may be adverse consequences to an individual
from opening and replying to an unsolicited e-mail, for example,
confirming that the individual's address exists.
Law enforcement
The Privacy Act is 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.
Written note of the disclosure is required, including the date
of the disclosure, the personal information disclosed, the relevant
law enforcement body and how the information was used, or to whom
the information was disclosed.
Data quality
There is a legal requirement to ensure that all data collected is
accurate, complete and up-to-date.
Staff are required to confirm accuracy of information at the
time of collection. If at any time after the collection of personal
information a staff member considers that the information is
inaccurate then that staff member should confirm the information
either with the individual concerned or through other means to
ensure the accuracy of information kept by TT-Line.
Data security
All staff must take reasonable steps to protect the personal
information we hold from misuse and loss and from unauthorised
access, modification or disclosure.
In general, treat all personal information as confidential.
Personal information should be handled with care and only used for
authorised purposes.
TT-Line will continue to develop and monitor security measures
in order to decrease the risk of unauthorised access to personal
information.
We 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 staff must check facsimile numbers before sending personal
information and confirm receipt. Staff should also check the
identity of callers before giving personal information over the
telephone.
All information no longer required for any purpose will be
destroyed or permanently de-identified. We cannot legally retain
personal information unless we have a proper purpose for continuing
to hold it.
Permanent de-identification means that we are not able to match
the de-identified information with other records to re-establish
the identity of individuals.
Destruction of data must occur by a secure means. Paper based
records should be shredded or disposed of securely by an authorised
disposal company. Electronic records should be overwritten before
being deleted.
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, we do collect health information for the purposes of
our Passenger Monthly Accident/Illness Reports.
Health information is regarded as sensitive and as such, must be
treated as highly confidential. Health information should only be
accessible to authorised persons and should not be entered on any
reservations, sales or marketing databases.
Individuals must be told of the purpose of collection by the
relevant officer at the point of collection. This health
information must not be disclosed to any other person without the
individual's consent. Consent may be implied, depending on the
circumstances. Such circumstances would usually only be in an
emergency or when the person had lost consciousness.
Breach of privacy
The Privacy Commissioner has 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.
If the Commissioner receives a complaint, the individual will in
most cases be referred back to TT-Line's privacy officer to resolve
the complaint directly. As a last resort, the Commissioner can make
a final determination which may be enforced by the Federal
Court.
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
