POLICY STATEMENT
TotalFusion is committed to managing personal information in accordance with the Australian Privacy
Principles, Privacy Act 1998 and Privacy Amendment (Enhancing Privacy Protection) Act 2012 .
POLICY APPLICATION
The Privacy Act is the national legislation which ensures that organisations protect people’s personal
information and are transparent about how they handle this information. It was amended in the Privacy
Amendment (Enhancing Privacy Protection) Act 2012 and these changes came into force 12 March
2014.
The legislation incorporates 13 Australian Privacy Principles that regulate the handling of personal
information:
Part 1- Consideration of personal information privacy
Australian Privacy Principle 1- open and transparent management of personal information
Australian Privacy Principle 2 – anonymity and pseudonymity
Part 2- Collection of personal information
Australian Privacy Principle 3 – collection of solicited personal information
Australian Privacy Principle 4 – dealing with unsolicited personal information
Australian Privacy Principle 5 – notification of the collection of personal information
Part 3- Dealing with personal information
Australian Privacy Principle 6 – use or disclosure of personal information
Australian Privacy Principle 7- direct marketing
Australian Privacy Principle 8 – cross-border disclosure of personal information
Australian Privacy Principle 9 – adoption, use or disclosure of government related identifiers
Part 4 – Integrity of personal information
Australian Privacy Principle 10 – quality of personal information
Australian Privacy Principle 11- security of personal information
Part 5- Access to, and correction of, personal information
Australian Privacy Principle 12 – access to personal information
Australian Privacy Principle 13 – correction of personal information
The following information specifies how TotalFusion manages personal information across its business
undertakings:
Personal information privacy
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Personal Information is information TotalFusion holds which is identifiable as being about an individual
or could reasonably identify an individual. TotalFusion has implemented practices so that its
management of Personal Information is open and transparent.
TotalFusion is not practicably able to provide anonymity and pseudonymity options for its clients due to
the requirement to provide payment information (bank account/credit card details).
Collection of personal information
Collection of solicited personal information: Generally TotalFusion collects personal information directly
i.e. face to face, over the phone, email correspondence or membership application forms. The types of
people include employees, contractors, suppliers and members.
The types of personal information collected are as follows:
● names, job titles, contact address details;
● information in identification documents (i.e. drivers license, passport);
● tax file numbers and other government-issued identification numbers;
● date of birth and gender;
● bank account details;
● details of superannuation and insurance arrangements;
● educational qualifications, employment history and salary;
● visa or work permit status.
In some cases it may be necessary for TotalFusion to collect sensitive information such as professional
memberships, ethnic origin, criminal record and health information.
There may be times when information is collected from a third party via a reference check. This
information is collected only from a source that is nominated by the person the information is about.
TotalFusion may also collect personal information via Social Media, SMS mobile marketing or from a
person’s use of its website via contact mailboxes or registration processes.
Dealing with unsolicited personal information: A person may also provide TotalFusion with someone
else’s personal information. When this occurs TotalFusion will, as bets it can, ascertain if permission
has been given that allows an individual to provide this information on behalf of someone else.
Notification of the collection of personal information: TotalFusion will, as soon as practicable, notify an
individual that it has collected the information, where it was collected from and the purpose for which it
was collected.
Information Storage: There are a number of secure ways TotalFusion stores information depending on
the purpose it was collected for. It can be stored electronically via club computer hard drives, a club
smart phone and/or in hard copy.
Privacy on TotalFusion Websites
Cookies: Cookies are used for a variety of reasons. TotalFusion uses cookies to obtain information
about the preferences of visitors and the services they select. Cookies are also used for security
purposes to protect authorized customers. For example, if an authorized customer is logged on and the
site is unused for more than 20 minutes, it will automatically log off the authorized customer.
Cookies are a common part of many commercial websites that allow small text files to be sent by a
Website, accepted by a Web browser and then placed on a hard drive as recognition for repeat visits to
the Site. Every time a person visits the Site, TotalFusion servers, through cookies, pixels and/or GIF
files, collect basic technical information such as domain names, the address of the last URL visited prior
to clicking through to the Site, and the browser and operating system. Cookies do not need to be
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enabled to visit the TotalFusion site, however, some parts of the site and some services may be more
difficult or impossible to use if cookies are disabled.
User login information: TotalFusion uses login information, including, but not limited to, IP addresses,
ISPs, and browser types, to analyse trends, administer the site, track a user’s movement and use,
gather broad demographic information and provide personal web page access to authorized customers.
Dealing with personal information
Use or disclosure of personal information: TotalFusion will not disclose personal information to any third
party unless it has the consent of the person to do so. The exception to this is where TotalFusion is
required by law to provide the information.
Direct marketing: TotalFusion will not disclose or use personal or sensitive information for the purposes
of direct marketing unless permission has been given that allows for this to occur. Membership
agreements provide authorisation for personal information to be used for internal marketing purposes.
Cross-border disclosure of personal information: TotalFusion does not share information with any
overseas parties.
Adoption, use or disclosure of government related identifiers: TotalFusion does not use or adopt
government related identifiers. TotalFusion may disclose an identifier (i.e. employee tax file number)
where there is a government statutory requirement for an employer to do so.
Integrity of personal information
Quality of personal information: TotalFusion will take practically reasonable steps to ensure that the
personal information that that it collects is accurate, up-to-date and complete.
Security of personal information: TotalFusion will take practically reasonable steps to ensure that
information it has collected is protected from misuse, interference and loss, unauthorised access,
modification or disclosure.
Where the information is no longer required, TotalFusion will destroy the information or ensure that it is
de-identified.
Access to, and correction of, personal information
Access to personal information: A person is entitled to access their personal information held by TotalFusion. To access personal information, a request should be made in writing to the Club Manager. The
request will be responded to within 7 business days.
TotalFusion may refuse access if:
● it reasonably believes that giving access would pose a serious threat to the life, health or
safety of any individual, or to public health or public safety; or
● giving access would have an unreasonable impact on the privacy of other individuals; or
● the request for access is frivolous or vexatious; or
● the information relates to existing or anticipated legal proceedings between the entity and the
individual, and would not be accessible by the process of discovery in those proceedings; or
● giving access would reveal the intentions of the entity in relation to negotiations with the
individual in such a way as to prejudice those negotiations; or
● giving access would be unlawful; or
● denying access is required or authorised by or under an Australian law or a court/tribunal
order;
or
● both of the following apply:
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o it has reason to suspect that unlawful activity, or misconduct of a serious nature, that
relates to the entity’s functions or activities has been, is being or may be engaged in;
o giving access would be likely to prejudice the taking of appropriate action in relation to
the matter; or
● giving access would be likely to prejudice one or more enforcement related activities
conducted by, or on behalf of, an enforcement body; or
● giving access would reveal evaluative information generated within the entity in connection
with a commercially sensitive decision-making process.
In the event of refusal, TotalFusion will provide a written explanation and provide details of the
associated complaints process.
Correction of personal information: TotalFusion will take all reasonable steps to ensure that information
is accurate, up to date, complete, relevant and not misleading. Where TotalFusion or the person the
information is about believes that this is not the case, all necessary actions will be taken to ensure that
the information is corrected.
Complaints
If a person, or an organisation, wishes to complain about how TotalFusion has handled personal
information, it may do so by contacting the CEO, TotalFusion and providing the complaint in writing.
Contact details:
CEO
TotalFusion
Alliance Wellness Group
PO Box 142
Bulimba Qld 4171
EFFECTIVE DATE
This policy is effective from 1 June 2017.
FURTHER INFORMATION
Should you require any further information or clarification, please contact TotalFusion
[email protected].
DEFINITIONS / GLOSSARY OF TERMS
Personal information – means information or an opinion (including information or an opinion forming
part of a database), whether true or not, and whether recorded in a material form or not, about an
individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Sensitive information – means:
a) information or an opinion about an individual’s:
i. racial or ethnic origin; or
ii. political opinions; or
iii. membership of a political association; or
iv. religious beliefs or affiliations; or
v. philosophical beliefs; or
vi. membership of a professional or trade association; or
vii. membership of a trade union; or
viii. sexual preferences or practices; or
ix. criminal record;
that is also personal information; or
b) health information about an individual; or
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c) genetic information about an individual that is not otherwise health information.