The Independent Liquor Group Distribution Co-Operative Limited
The Independent Liquor Group (Suppliers) Co-Operative Limited

Privacy Policy

1.1  Protecting your Privacy

We take seriously our responsibility for protecting your privacy and the confidentiality of your personal information.

As part of our business we are committed to providing a number of different services to our members. To provide these services it is necessary for us to collect, store and use your personal information. We have been recording such information for over 25 years of operation and we believe we have earned our members trust in doing so. We are continuing to improve and revise the security and accessibility of this information in line with new technology.

We will only deal with your personal information in the ways we describe to you in this policy.

1.2  Personal Information Collected

We collect most personal information from you directly. For example, we may collect personal information when you apply for membership, open an account, deal with us over the telephone, send us a letter, visit our web site, or when you contact us in person.

The type of information we collect will include your name and may include: contact details, tax file number, Australian Business Number (ABN) date of birth, financial details, business transaction details, credit record and transaction history.

We do not generally collect information that is sensitive personal information as defined by the Privacy Act 1988 (Cth). However we may on occasion collect information relating to your business and financial affairs. Such information will only be collected from you and will only be used for the purpose for which it was collected. We do not disclose sensitive personal information to third parties without your permission or instruction.

We will use this information for the purposes that you have provided it.

 Where you provide information in an application for membership, we will use this information:

• For our register of members and shareholders
• For the provision and offer of membership services.

Where you provide information in an application for a financial product or service, we will use this information:

• To create and maintain a financial service relationship

If you cannot provide us with the information we require to provide and maintain these services we may be unable to accept or continue your membership or to provide you with financial services.

We may need to source information about you from a third party; for example, a credit reporting agency. Wherever possible this will be done with your authorisation or where this is not possible we will inform you when such information is collected.

1.3  Use and Disclosure

Personal Information is treated as confidential within the co-operative and is used by us for the purpose for which it was collected or for a related purpose.

Personal Information is information about and which identifies individuals. It includes information obtained from any source and it will include anything about credit worthiness, standing history and capacity, which under and in accordance with the Privacy Act 1988, may lawfully be exchanged.

You agree that personal information about you, which may at anytime be provided to us in connection with a facility for which application is made, may be held and used by us to assess and process the application, to establish, provide and administer and improve the facility and to execute your instructions.

You agree if you make application for credit to us or if you act as a guarantor in respect of credit, we may provide, that in assessing the application (or if relevant in assessing whether to accept you as a guarantor), we may seek and obtain personal information about you from a credit reporting agency, financial institution and may give personal information about you to a credit reporting agency or a financial institution.

You also agree that we may hold and use personal information about you, which may at any time be provided to us in connection with your application for membership or a facility for which you make application to us, for the purposes (as relevant) of:  

• Considering any other application you may make to us

• Complying with legislative and regulatory requirements

• Performing administrative functions, including accounting, risk management, record keeping, archiving, systems development, credit scoring and staff training

• Managing our rights and obligations in relation to external payment systems

• Conducting market or customer satisfaction research

• Developing, establishing and administering alliances and other arrangements with other organisations in relation to the promotion, administration and use of our respective products and services

• Developing and identifying products and services that may interest you

• Providing you with information about other products and services.

Where personal information, which we collect about you is sensitive information (such as information about business health status, membership of a professional or trade association), you nevertheless consent to its collection by us.

Wherever our business is outsourced to third party contractors such as mailing houses and information technology professionals. Information provided to these parties remains the property of the co-operative and is only used for the specific purpose for which it is supplied.?Wherever possible, the co-operative will elect to deal with agents who are bound by the provisions of the Privacy Act. Where this is not possible we will make every effort to verify that they otherwise comply with the National Privacy Principles as provided by the Office of the Federal Privacy Commissioner.

You agree that we may collect personal information about you from, and disclose it to the following, even if the disclosure is to an organisation overseas and that organisation is not subject to the same privacy obligations, which apply to us:  

• Credit reporting agencies

• Financial institutions

• Our agents, suppliers, contractors and external advisers whom we engage from time to time to carry out, or advise on, our functions and activities

• Regulatory bodies, government agencies, law enforcement bodies and courts

• Any person who introduces you to us

• Other organisations with whom we have alliances or arrangements for the purpose of promoting our respective products and services, and any agents used by us and our business partners in administering such an arrangement or alliance

• Anyone supplying goods or services to you in connection with a facility you have applied for

• Debt collecting agencies

• External payment systems operators

• An organisation proposing to fund the acquisition of or acquire, any interest in any obligation you may owe us (whether under a loan, guarantee or security), that organisation?s agents, persons involved in assessing the risks and funding of the acquisition and, after acquisition, the purchaser and any manager

• Any person to the extent necessary, in our view, in order to carry out any instruction you give to us

• Our related bodies corporate for the marketing of their products and services

• Your agents and contractors, including your legal adviser and your financial adviser.

• Your executor, administrator, trustee, guardian or attorney

• Your referees

• Your insurers or prospective insurers and their underwriters and

• Your sureties and guarantors and prospective sureties and guarantors

1.4  Confidentiality

We have a duty to keep confidential all personal information we hold about you, including:

• Your name, address and financial information
• The balance in your account and

1.5  Disclosure to Third Parties

Except where required by law, we only disclose personal information to third parties with your express or implied consent.

1.6  Your Consent

Your consent to us may be express or implied.

We obtain your express consent by you writing to notify us of your consent by signing a statement of consent. Your implied consent includes your consent, by taking up membership, or continuing to trade with us in the normal manner, to allow us to disclose your identifying information to our service providers to enable us to operate and provide services and products to you. Confidentiality of the information will at all times be maintained.

Without such consent we may not be able to maintain your membership and accounts with the co-operative.

1.7  Direct Marketing and your Privacy

From time to time we will use the personal information we collect from you to inform you of products and services that we consider may be of interest to you.

If you do not wish to receive direct marketing information you can tell us at any time by contacting our Privacy Officer.

1.8  Tax File Number and ABN

We use and disclose these numbers only for the purposes required by law.

1.9  If you think the information we hold about you is incorrect or you want to update it.

We rely on the accuracy of the information you provide to us. If you believe or know that information we hold about you is incorrect, out of date or incomplete, please contact us and we will make all reasonable efforts to correct the information.

1.10          Security of your Personal Information

We take all reasonable precautions to protect your personal information from loss, unauthorised access, modification and unauthorised disclosure. Personal information about your accounts and membership is only accessible by you and by those who are authorised to access it. Only authorised persons have access to your personal information and only for approved purposes. Your personal information can only be amended and deleted by authorised means.

Records that we hold containing your personal information may be in hardcopy documents or electronic data.

Hardcopy documents are secured on our premises and at archive sites by locks and security systems. Electronic data stored on our computers is protected by computer and network security products, including firewalls, encryption, virus software, as well as user identities and passwords.

Our website uses the highest level of technology to ensure maximum security however, no data transmission over the Internet can be guaranteed to be totally secure.

1.11          Access to your Personal Information

You may request access to the personal information we hold about you. We will provide you with such access wherever possible and within reasonable time. We may apply a fee for such access, to cover our costs. If we deny your request for access, we will provide you with reasons for that denial.

We would ask that any such request is stated as clearly as possible and adequately identifies the information you are seeking.

1.12          Changes to our Privacy Policy

We may vary this policy from time to time. Changes to our policy will be published from time to time.

1.13          Resolving Privacy Issues

If you believe that the co-operative has failed to observe the privacy of your personal information, you can register your concern or complaint with our Privacy Officer. We will respond as soon as possible and usually within 2 working days, to let you know the person in our organisation who will be responsible for investigating the matter. If we are unable to resolve the matter within 10 working days we will contact you to let you know its progress and status and when we expect the matter to be resolved.

1.14          How to Make a Complaint or Enquiry

You can contact our Privacy Officer on 96758400 to register a complaint or concern or to answer your questions relating to this Privacy Policy.

2.0  Organisation Identity

We are The Independent Liquor Group Distribution Co-Operative Limited.

• Our address is Locked Bag 8013 Penrith NSW 2751
• Our Contact Officer for Privacy Issues is our Privacy Officer.
• Our Privacy telephone number is 96758400
• Our Privacy e-mail address is privacyofficer@ilg.com.au

2.1                            Personal Information about Third Parties

You represent that, if at any time you supply us with personal information about another person (for example, a referee), you are authorised to do so and you agree to inform that person who we are, that we will use and disclose their personal information for the purposes set out above, and that they can gain access to that information.

Where you supply us with personal information about another person you acknowledge that we may send that person a notice that we have collected and will hold that person?s personal information.

2.2                            Access to your Personal Information and Contacting Us

• Subject to provisions of the Privacy Act 1988, you may access personal information, which we may hold about you at any time by asking us.?You should write to or telephone our Privacy Officer who is contactable as detailed at 2.0.

• We are not obliged to provide you access to personal information where:

• Providing access would pose a serious and imminent threat to the life or health of any individual.

• Providing access would have unreasonable impact on the privacy of other individuals.

• The request for access is frivolous or vexatious.

• The information sought relates to existing or anticipated legal proceedings between you and us and that information would not be accessible by the process of discovery in those proceedings.

• Providing access would be unlawful.

• Denying access is required or authorised by or under law.

• Providing access would be likely to prejudice an investigation of possible unlawful activity.