Our Privacy Policy – Container Exchange (Qld) Limited (COEX)

Privacy Policy for Business Partners, partner organisations, suppliers and their personnel

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Container Exchange (QLD) Limited (ACN 622 570 209), the operator of the Queensland beverage container refund scheme, Containers for Change. We are committed to respecting your privacy.

We are bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). This legislation regulates how we manage and protect personal information.

This Privacy Policy sets out how we collect, use, store and disclose personal information of our Business Partners, partner organisations, suppliers and their personnel, and describes how you can request to access or correct the personal information we hold about you and how you can raise privacy related concerns with us.

In this Privacy Policy:

• ‘Business Partners’ refers to refund point operators, equipment services providers, logistics services providers, processing services providers, material recovery facility operators, recycling panel members or other independent organisations COEX contracts with for services to deliver the Queensland beverage container scheme; and
• ‘partner organisation’ refers to third party organisations we are working with to harness the benefits of the Queensland beverage container refund scheme to contribute to their sustainability goals. It also refers to organisations that we sponsor.

Generally, this Privacy Policy focusses on the personal information of personnel of the businesses we deal with. However, if the business we deal with is an individual (not another kind of legal entity like a corporation), the information in this Privacy Policy also applies to personal information about you that we handle.

We have a separate Privacy Policy that describes how we handle the personal information of our Containers for Change customers and members of the public. This separate Privacy Policy also applies to partner organisations who are also Containers for Change customers. You can find that separate Privacy Policy here.

Please keep in mind that if you are an employee or contractor of a Business Partner or supplier, you may also interact with us in other capacities and our other Privacy Policy may still apply to you in another capacity, such as an individual Containers for Change Customer or an Account Holder.

We may change this Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

What kinds of information does this Privacy Policy apply to?

Personal information is information or an opinion about an individual who is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your bank or credit card details.

Sensitive information is a type of personal information given additional protection under the Privacy Act and includes information about an individual’s racial or ethnic origin, religious beliefs and criminal record, as well as health, genetic and biometric information.

What personal information do we collect?

The types of personal information we collect will depend on how and why you engage with us, but may include the following types of personal information:

• If you are acting as a representative of any organisation we deal with, we may collect:
  • Personal and contact details: for example, your name, address, email address and telephone number – we expect that we will generally collect your business contact details and not your personal contact details;
  • Work information: for example, your job title at your organisation;
  • Signature: if you sign a contract with us on your organisation’s behalf, or act as a witness;
• • If you are submitting an application to be a Business Partner or supplier (or where an existing Business Partner or supplier wants to assign or novate a contract to you), the following information we collect in your application may be personal information:
  • Application information: for example, information about your experience and capacity, current operations, proposed arrangements if appointed as a business partner;
  • Guarantor information, if included in your application; and
  • Information to assess suitability: for example, criminal history records and other background checks and any other information relevant to your suitability, such as references;
  • Information about your potential participation in the Containers for Change scheme: for example, consumer and participation behaviours;
• If you are submitting an application to be a partner organisation, the following information we collect in your application may be personal information:
  • Collection activity: for example, collection address and current collection activity and details linked to your Containers for Change member number;
  • Personal and contact details: for example, your name, address, email address and telephone number, if included in your application – we expect that we will generally collect your business contact details and not your personal contact details;
  • Work information: for example, your job title at your organisation;
  • Signature: if you sign a contract with us;
• If you are a business partner, supplier or partner organisation (or personnel of any of them), we may collect:
  • Information about your performance: for example, container collection and processing capability and capacity;
  • Information about your participation in the Containers for Change scheme: for example, consumer and participation behaviours;
• If you are a Business Partner that signs up to have a COEX Partner Hub Account, we will collect:
  • Personal and contact details and work information: for example, name, job title, email address, phone number and business address for each of the businesses’ authorised contacts; and
  • Financial information: your organisation’s bank account details we need to set up your account and process payments to you.

We may also collect any personal information you decide (or someone from your organisation decides) to give us, for example, in the course of communications, your response to surveys issued by us, or if you apply for a review of a decision we make.

Generally, we will not collect your sensitive information unless you have provided your consent, and the information is reasonably necessary for our functions or activities, or if we are legally required or permitted to collect that information without your consent.

If we ask you to give us your personal information on a voluntary basis, for example, where we want to better understand the diversity of the businesses we work with, you can choose not to provide that information if you do not want to.

How do we collect personal information

We will usually collect personal information about you directly from you, for example, when you respond to an expression of interest, submit an application to us, communicate with us or complete a survey issued by us.

We may also collect personal information about you:

• from the organisation you work for, when others in that organisation provide your information to us;
• from third party organisations where that third party is permitted to share you information with us in the course of a project you, we and they are involved in;
• from organisations that conduct and provide background checks; and
• from publicly available sources, such as social media platforms, in order to undertake our integrity and investigation functions and activities.

Why do we collect, use and disclose personal information?

Within the context of this privacy Policy, we generally collect, hold, use and disclose your personal information for the purposes of our business relationship with the Business Partner, partner organisation or supplier with whom you work, including considering your application, managing our relationship, and evaluating performance.

We may also collect, hold, use and disclose your personal information:

• to help you set up Accounts connected with your business, and to verify that people connected to your Account are affiliated with you;
• to send you communications and updates about the scheme;
• to comply with our legal obligations, respond to complaints and claims, and investigate and protect ourselves and third parties against any activity that we reasonably suspect to be fraudulent, inappropriate or unlawful, to resolve any disputes and to enforce our agreements;
• to inform communications to and respond to requests for information from, the Queensland Government in relation to the performance of the Queensland beverage container refund scheme and related matters (e.g., customer complaints);
• to support our responsibilities as the appointed product responsibility organisation to administer and govern the Queensland beverage container refund scheme, such as
  • operating and facilitating the delivery of services in connection the Queensland beverage container refund scheme (e.g., collection programs); and
  • conducting audits, reviews and investigations into actual, potential or suspected illegal or unethical behaviour in connection with the Queensland beverage container refund scheme;
• to analyse and improve your and our services;
• to protect our legitimate interests, for example, taking or responding to legal action or making insurance claims; and
• where permitted by law, any additional purpose which we inform you about or which you have agreed to.

Do we use your personal information for direct marketing?

Some of the updates we send you about the scheme may constitute direct marketing.

Where we have your consent, we may send you direct marketing communications and information about our services from time to time. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You may opt-out of receiving marketing materials from us by using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us using the details provided at the end of this Privacy Policy.

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

• any other Business Partner, and scheme participant, including the State of Queensland, for purposes related to the scheme, such as sharing contact details so Business Partners can interact in accordance with their obligations;
• any other partner organisation or supplier, where relevant, such as where we interact with a network of organisations to deliver projects, or where we connect partner organisations with each other;
• to customers and members of the public, to facilitate the delivery of services by you to them, or where relevant to resolving an issue that involves them and you or your organisation;
• our third-party suppliers and service providers, including providers of campaign, promotion, accounting, auditing, legal, banking, payment, debt collection, delivery, data processing, data analysis, document management, research, investigation, technology and training services; and
• other personnel within your organisation.

We may also disclose personal information to:

• anyone to whom our assets or businesses (or any part of them) are transferred;
• third parties authorised by you to receive information held by us;
• government agencies, regulatory bodies and law enforcement agencies (and their service providers) for reporting, investigations, screening, compliance and law enforcement purposes, or as otherwise required, authorised or permitted by law;
• other persons, as necessary to facilitate our dealings with you, such as professional advisors and consultants who are engaged to delivery training to you or advise on compliance.

With your permission, we may also profile you publicly to celebrate excellent work you are doing in connection with the scheme.

Disclosure of personal information outside Australia

Your personal information may be handled by our third-party suppliers and service providers located outside of Australia. Sometimes, this may constitute a disclosure of personal information. The countries in which these organisations are located will vary, but in the course of our business operations we typically disclose personal information to supplier organisations located in the Philippines, India, Singapore, the United States, Canada, the United Kingdom and New Zealand.

We will take reasonable steps to ensure that any disclosure of personal information to an overseas recipient complies with the Privacy Act. Generally this means that we will require the overseas recipient to deal with such personal information in a way that is consistent with the Australian Privacy Principles.

Our use of cookies and similar technologies

We may record certain information about your use of our websites and mobile applications, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer or device.

Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and browsing sessions. We use ‘cookies’ or other similar tracking technologies on our websites and mobile applications to record certain information about your use of our websites and mobile applications, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer or device. We use this information to help us track your usage, remember your preferences and deliver relevant advertising to you when you are on other websites or social media platforms.

You can disable cookies through your internet browser, but our websites and mobile applications may not work as intended for you if you do so.

Data collected by cookies may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Security and storage of your personal information

We hold personal information in electronic or hard copy form (or both) at our offices, on our servers and in some cases, in cloud storage on third party servers.
We take reasonable steps and have safeguards in place to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your personal information. These include but are not limited to:

• implementing encryption technologies where practicable, passwords and access restrictions;
• deploying anti-malware and anti-virus software; and
• securing hard copy personal information within offices and other storage facilities via restricted access to those offices and facilities.

However, we cannot guarantee the security of your personal information at all times, and there are inherent risks with the transmission of data, including personal information, over the internet.

Links to third party sites

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage you to read them before using those websites.

Accessing or correcting your personal information

You can request to access or correct the personal information we hold about you by contacting us using the details at the end of this Privacy Policy. Sometimes, we may not be able to comply with your request and, where this is the case, we will tell you why. We may also need to seek further details from you to verify your identity before providing you with access to, or making changes to, your personal information.

The accuracy of the personal information we hold and use is important to us. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Making a complaint

We take your privacy concerns seriously. If you have a question or wish to make a complaint regarding our privacy practices or the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

Contact us

If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to request access to, or a correction of, your personal information, or make a complaint, please contact us using the details set out below:

Privacy Officer
Email: privacy@containersforchange.com.au
Telephone: 13 42 42

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
Address: GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au