Privacy Policy
1. INTRODUCTION
1.1 Kubic Transport Pty Ltd (ACN 613 309 489) (Kubic Transport) recognises that the privacy of personal information is important and is committed to protecting personal information that it collects and holds. The Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles set out the applicable legal requirements with respect to the management of personal information, with the exception of certain employee records.
1.2 This policy sets out how Kubic Transport collects, uses, discloses and otherwise manages personal information. ‘Personal information’ is information or opinions relating to an identifiable individual. Information is not personal information where it cannot be linked to an identified individual.
1.3 Nothing in this policy prevents Kubic Transport from collecting or disclosing personal information that comprises employee records of current or former employees, provided such collection or disclosure does not breach the Privacy Act.
1.4 The policy is effective from 09/09/2024.
2. TYPES OF PERSONAL INFORMATION KUBIC TRANSPORT COLLECTS
2.1 The types of personal information that Kubic Transport may collect and hold in relation to subcontractors, employees and prospective subcontractors and employees includes:
(a) contact information including date of birth, ID documents and emergency contact information;
(b) recruitment information including application form/s, interview documentation, reference checks or screening information;
(c) employment history including any promotions or demotions, performance reviews and disciplinary records;
(d) medical information including medical testing, details of leave of absences or workplace accidents or injuries;
(e) GPS data and other telemetry from in-vehicle management systems (IVMS) and other logistics technology solutions including Verizon Connect;
(f) video footage from cameras in vehicles and in Kubic Transport’s depots;
(g) financial information;
(h) licensing information; and
(i) information that Kubic Transport is legally required to collect.
2.2 The types of personal information that Kubic Transport may collect and hold in relation to customers and suppliers (other than subcontractors) includes:
(a) contact information;
(b) recruitment information including application form/s, interview documentation, reference checks or screening information;
(c) video footage from cameras in Kubic Transport’s business premises;
(d) billing and financial information;
(e) licensing information;
(f) details of any enquiries or complaints;
(g) information that Kubic Transport is legally required to collect; and
(h) in the case of customers, credit information, the management of which is explained in clause 3.
2.3 ‘Sensitive information’ is a special category of personal information and includes information that could have serious consequences for the individual if it is used inappropriately. Kubic Transport may, with the consent of the individual, collect sensitive information about subcontractors and employees and prospective subcontractors and employees including:
(a) medical history;
(b) drug and alcohol test results;
(c) criminal history; and
(d) membership of unions and professional associations.
2.4 Kubic Transport will not collect sensitive information without the consent of the individual to whom the information relates unless it is permitted to do so under the Privacy Act.
2.5 Kubic Transport collects video recordings and photographs from in-vehicle cameras and closed-circuit television cameras at its business premises.
3. TYPES OF CREDIT INFORMATION KUBIC TRANSPORT COLLECTS
3.1 In providing services to a customer, Kubic Transport may collect and hold the following types of credit information:
(a) information about any credit that has been provided;
(b) repayment history information and information about overdue payments; and
(c) information in relation to court proceedings that are initiated in relation to customer credit activities and any relevant bankruptcy or insolvency arrangements.
3.2 Sources from which Kubic Transport may collect credit information include:
(a) ASIC;
(b) banks;
(c) suppliers; and
(d) Kubic Transport’s subcontractors and agents.
3.3 Kubic Transport also uses CreditorWatch which provides Kubic Transport with credit risk information on customers and guarantors for corporate customers. Kubic Transport may disclose to CreditorWatch any serious failures by customers or guarantors in meeting payment obligations.
3.4 Kubic Transport may also collect personal information which may affect a customer’s creditworthiness from other credit providers, such as trade referees, who may collect that information from credit reporting bodies. The types of personal information Kubic Transport collects may include any of those types of personal information outlined in clause 3.1 of this policy.
4. COLLECTION OF PERSONAL INFORMATION THROUGH OUR WEBSITE
4.1 Kubic Transport’s website provider may make and maintain records of Kubic Transport’s official website and the pages you visit so that Kubic Transport can:
(a) monitor website traffic;
(b) determine which of our services are popular; and
(c) deliver customised content or advertising.
4.2 Kubic Transport website may also set cookies. A cookie is a text file that is placed on your hard disk by a webpage server. Cookies are uniquely assigned to you, and can only be read by a webserver in the domain that issued the cookie to you. A cookie notifies the webserver that you have returned to a specific page. For example, if you personalise Kubic Transport’s webpage or register with Kubic Transport’s site, a cookie:
(a) helps Kubic Transport to recall your specific information on subsequent visits; and
(b) simplifies the process of recording your personal information, such as your billing address and delivery address.
4.3 You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
5. KUBIC TRANSPORT’S PURPOSE OF COLLECTING INFORMATION
5.1 Kubic Transport collects the personal information of subcontractors and employees and prospective subcontractors and employees to allow it to:
(a) manage any employment or engagement relationship, including to assess performance, and for health and safety purposes;
(b) comply with legislative requirements; and
(c) determine whether to offer employment to a prospective employee.
5.2 Kubic Transport collects personal information from in vehicle monitoring systems and closed-circuit television cameras:
(a) to prevent and detect crime;
(b) to assist in providing a safe working environment;
(c) to protect Kubic Transport’s property and the property of Kubic Transport’s customers, subcontractors, agents and visitors; and
(d) for quality and compliance purposes.
5.3 Kubic Transport collects the personal information of customers and potential customers to allow it to:
(a) provide transport and logistics services;
(b) comply with legislative requirements; and
(c) provide information about any additional services Kubic Transport offers.
6. What happens if personal information is not provided?
If a person fails to provide Kubic Transport with personal information that Kubic Transport seeks, or if that information is inaccurate or incomplete, Kubic Transport may be unable to provide that person with transport services or to consider engaging or employing that person.
7. How does Kubic Transport collect personal information?
7.1 Kubic Transport usually collects personal information directly from the person to whom the information relates.
7.2 Kubic Transport may also collect personal information from:
(a) government bodies and agencies;
(b) public records and registers;
(c) courts and tribunals;
(d) current and previous employers;
(e) recruitment agencies and labour hire providers;
(f) doctors or other medical professionals who carry out health screening checks;
(g) in-vehicle cameras and closed-circuit television cameras;
(h) in-vehicle management systems (IVMS) and other logistics technology solutions including Verizon Connect; and
(i) online searches and social media.
8. How does Kubic Transport use and disclose personal information?
8.1 Personal information may be disclosed to:
(a) Kubic Transport’s subcontractors;
(b) entities that conduct licence checks for Kubic Transport;
(c) government bodies such as Australian Taxation Office, Workplace Health and Safety authorities, the National Heavy Vehicle Regulator, and State and Territory road authorities;
(d) customers who require information from Kubic Transport for their compliance procedures or to meet legislative requirements;
(e) third party service providers engaged by Kubic Transport to provide services such as insurers, IT support providers and banks;
(f) entities that provide medical testing and drug and alcohol testing for Kubic Transport;
(g) third party technology providers including Bustle which provide software to allow Kubic Transport to run its transport business.
9. How does Kubic Transport protect personal information?
9.1 Kubic Transport uses various physical and electronic security measures to protect personal information held by Kubic Transport, including using:
(a) security systems and other restrictions to limit access to Kubic Transport’s premises;
(b) secure electronic databases;
(c) unique usernames, passwords and other protections on systems that can access personal information; and
(d) electronic security systems and firewalls.
9.2 Kubic Transport also manages the personal information it collects by:
(a) providing its staff with training on their obligations under the Privacy Act;
(b) supervising staff who regularly handle personal information;
(c) implementing procedures to identify and report privacy breaches and to respond to complaints about privacy breaches; and
(d) designating a privacy officer whose role is to manage compliance with the Privacy Act.
10. Overseas disclosure
Kubic Transport does not generally disclose personal information to overseas recipients. Kubic Transport’s software providers may store or back up data overseas.
11. Accessing and correcting personal information
11.1 Any person may request access to personal information about them held by Kubic Transport or request that their personal information is corrected.
11.2 Requests may be made to Kubic Transport’s Privacy Officer by emailing compliance@kubic.com.au.
11.3 If a request is made in accordance with clause 11.1, Kubic Transport will take reasonable steps to:
(a) provide access to relevant personal information that it holds; and
(b) correct any personal information if the data or information held is incomplete, irrelevant or misleading.
11.4 Kubic Transport will not disclose any personal information under clause 11.1 without proof of identity.
11.5 Kubic Transport may deny access to personal information if:
(a) the request is unreasonable;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person; or
(d) there are other legal grounds to deny the request.
12. COMPLAINTS
12.1 Complaints about a breach of the Australian Privacy Principles may be made to Kubic Transport’s privacy Officer by emailing compliance@kubic.com.au.
12.2 All complaints will be responded to within a reasonable time.
12.3 Complaints may also be referred to the office of the Australian Information Commissioner (see details at www.oaic.gov.au).
13. CHANGES TO THE POLICY
Kubic Transport may update or modify this policy at any time.