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 the following:

• 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 "Travel Club" page 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:

1. we will expressly ask you for that personal information;
2. 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:
   1. personalise and tailor our information, services or products for you;
   2. to identify who we are communicating with; or
   3. to inform you of further information relating to our services or products, or to this website;
3. 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) 64217305 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) 64217305 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 materials 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 sales and 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.

Online Travel Club

TT-Line's online Travel Club 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) 64217305 or email on privacy@spiritoftasmania.com.au.