PRIVACY POLICY

 

Corporate Spectrum Pty Ltd

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Introduction

 

Corporate Spectrum Pty Ltd ("Corporate Spectrum", "we", "our" or "us") is committed to protecting the privacy, confidentiality and security of personal information and sensitive information handled in connection with our business activities and service delivery.

This Privacy Policy explains how Corporate Spectrum Pty Ltd collects, receives, accesses, uses, stores, discloses, retains and otherwise manages personal information and sensitive information in accordance with applicable Australian privacy legislation, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

References to "personal information" and "sensitive information" have the meanings given in applicable privacy legislation.

References to "you" include employees, workers, contractors, suppliers, website visitors, clients and any other individual whose personal information or sensitive information may be handled by Corporate Spectrum Pty Ltd.

By accessing our website, communicating with us, engaging our services or providing information to us, you acknowledge this Privacy Policy.

 

Our Role

Corporate Spectrum Pty Ltd provides workplace injury management, return to work, wellbeing, consulting, training and related support services.

 

When engaged by an employer, organisation, business or other client ("Partnering Client"), Corporate Spectrum Pty Ltd acts as an authorised representative and service provider of the Partnering Client for the purpose of delivering the agreed services.

 

Corporate Spectrum Pty Ltd would not ordinarily have access to personal information or sensitive information relating to employees, workers or other individuals unless the Partnering Client has engaged Corporate Spectrum Pty Ltd and authorised us to undertake activities connected with the agreed services.

 

Corporate Spectrum Pty Ltd generally receives, accesses, collects, uses, stores, discloses and otherwise processes information as reasonably necessary to perform the services for which it has been engaged and under the authority of the Partnering Client.

 

The Partnering Client remains responsible for the lawful collection, use and disclosure of personal information and sensitive information and for ensuring compliance with all applicable privacy, employment, workplace health and safety, workers compensation, rehabilitation, return to work and other legislative obligations.

 

Nothing in this Privacy Policy transfers, limits, reduces or replaces the legal obligations of a Partnering Client.

 

Collection of Information

Corporate Spectrum Pty Ltd will only collect personal information and sensitive information where reasonably necessary for one or more of our functions, activities or services.

Information may be collected:

• when a Partnering Client engages Corporate Spectrum Pty Ltd;

• through our website, online forms and electronic communications;

• through telephone conversations and meetings;

• during workshops, training programs and consultations;

• through written correspondence;

• when subscribing to updates, newsletters or publications;

• when applying for employment or engagement with Corporate Spectrum Pty Ltd;

• when providing services to Corporate Spectrum Pty Ltd as a contractor, consultant or supplier; and

• where otherwise necessary to provide services or comply with legal obligations.

 

Information Handled on Behalf of Partnering Clients

Where Corporate Spectrum Pty Ltd is engaged by a Partnering Client, we may receive, access, collect, use, disclose, store, retain and otherwise process personal information and sensitive information reasonably necessary to provide the agreed services.

 

Information may be obtained from:

• the Partnering Client;

• authorised representatives of the Partnering Client;

• employees and workers;

• treating practitioners;

• rehabilitation providers;

• insurers and claims administrators;

• workers compensation authorities;

• legal representatives;

• government agencies;

• regulatory authorities; and

• other sources authorised, required or permitted by law.

 

Where information is collected directly from an individual following appointment by a Partnering Client, such collection is undertaken for purposes connected with the agreed services and under the authority of the Partnering Client.

 

The appointment of Corporate Spectrum Pty Ltd by a Partnering Client constitutes authority for Corporate Spectrum Pty Ltd to undertake activities reasonably necessary to provide the agreed services, including communicating with workers if deemed appropriate, employees, treating practitioners, rehabilitation providers, insurers, claims administrators, legal representatives, government bodies, regulatory authorities and other relevant stakeholders where authorised or permitted by law.

 

To the maximum extent permitted by law, Corporate Spectrum Pty Ltd is entitled to rely upon information, records, representations, instructions, approvals, permissions and authorisations provided by a Partnering Client.

 

Authority to Provide Information

By engaging Corporate Spectrum Pty Ltd, the Partnering Client represents, warrants and acknowledges that:

• it has lawful authority to provide information to Corporate Spectrum Pty Ltd;

• information supplied has been lawfully collected;

• any required privacy notifications, disclosures, collection notices or communications required by law have been provided;

• any consent, authority, approval or authorisation required by law has been obtained and remains current;

• disclosure of information to Corporate Spectrum Pty Ltd is lawful;

• individuals have been notified where required by law; and

• information supplied may lawfully be used, disclosed and processed for the purposes of the engagement.

 

Corporate Spectrum Pty Ltd is entitled rely upon the authority, instructions and representations of the Partnering Client without independently verifying their accuracy, completeness, legality or ongoing validity.

 

To the maximum extent permitted by law, Corporate Spectrum Pty Ltd accepts no responsibility for any failure by a Partnering Client to comply with privacy obligations, notification requirements, consent requirements, collection obligations or disclosure obligations.

 

Where Corporate Spectrum Pty Ltd reasonably believes information has been supplied without appropriate authority, Corporate Spectrum Pty Ltd reserves the right to refuse, suspend, restrict or cease receiving, accessing, using or processing that information.

 

Consent and Withdrawal of Consent

Where consent is required under applicable law, the Partnering Client is responsible for obtaining, managing and maintaining that consent.

 

Any individual seeking to withdraw consent should generally direct their request to the employer or Partnering Client responsible for collecting the information.

 

Corporate Spectrum Pty Ltd may act on instructions received from a Partnering Client concerning consent withdrawal, subject to legal, regulatory, workers compensation, insurance, operational, contractual and record-retention requirements.

 

Withdrawal of consent may affect the ability of Corporate Spectrum Pty Ltd and/or the Partnering Client to provide services or comply with legal obligations.

 

Types of Information We May Handle

Depending on the nature of the services provided, information may include:

• names and contact details;

• addresses;

• email addresses;

• telephone numbers;

• dates of birth;

• employment details;

• position information;

• training and qualification records;

• attendance and leave records;

• injury management information;

• return to work information;

• workers compensation information;

• rehabilitation information;

• wellbeing-related information where reasonably connected with the services being provided;

• correspondence and communication records;

• medical certificates and related documentation; and

• other information reasonably necessary to perform the agreed services.

 

Sensitive Information

Corporate Spectrum Pty Ltd may collect, access or process sensitive information where reasonably necessary to provide services and where authorised, required or permitted by law.

Sensitive information may include:

• health information;

• medical information;

• injury management information;

• return to work information;

• rehabilitation information;

• functional capacity information;

• disability-related information; and

• other sensitive information reasonably required to perform the agreed services.

 

Sensitive information will only be handled where reasonably necessary for service delivery or otherwise authorised, required or permitted by law.

 

Website Information

When you visit our website, information may automatically be collected, including:

• IP address;

• browser type;

• operating system;

• pages visited;

• files downloaded;

• referring websites;

• access dates and times; and

• general website activity information.

This information assists with website administration, website security, analytics and service improvement.

 

Cookies and Analytics

Our website may utilise cookies, analytics tools and similar technologies.

These technologies assist us to:

• monitor website performance;

• understand website usage;

• improve functionality;

• improve user experience; and

• support website security.

Cookies may generally be disabled through browser settings, although doing so may limit certain website functionality.

 

Monitoring of Communications

Corporate Spectrum Pty Ltd may monitor, record, retain and review business communications including telephone calls, emails, online meetings, video conferences and electronic communications whereby permitted by law.

This may occur for:

• service delivery;

• quality assurance;

• training;

• compliance;

• dispute management;

• security; and

• business improvement purposes

 

Use of Information

Corporate Spectrum Pty Ltd may use information:

• to provide services;

• to support workplace injury management activities;

• to support return to work activities;

• to support worker wellbeing initiatives where applicable;

• to deliver consulting and training services;

• to communicate with stakeholders;

• to prepare reports, recommendations and documentation;

• to maintain records;

• to administer engagements and contracts;

• to manage complaints;

• to undertake quality assurance activities;

• to comply with legal obligations; and

• to protect legitimate business interests.

 

 

 

Artificial Intelligence (AI) and Automated Technologies

Corporate Spectrum Pty Ltd may utilise Artificial Intelligence (AI), machine learning technologies, large language models and other automated technologies to assist with the delivery, administration and improvement of services.

Such technologies may be used for:

• administrative support;

• document preparation and drafting;

• workflow management;

• reporting and analysis;

• information review;

• communication support;

• training materials;

• quality assurance activities; and

• operational support.

Any use of AI technologies is intended to support, and not replace, professional judgment, human oversight or legal obligations.

Corporate Spectrum Pty Ltd will take reasonable steps to:

• implement appropriate privacy, confidentiality and security safeguards;

• minimise personal information processed where reasonably practicable;

• restrict access to authorised users;

• maintain human oversight over significant outputs;

• review AI-assisted outputs where appropriate; and

• utilise AI technologies only for legitimate business purposes connected with service delivery.

AI-generated content, summaries, reports, recommendations, communications and draft documentation may contain inaccuracies, omissions, assumptions or outdated information. Partnering Clients remain responsible for reviewing information and exercising their own judgment before relying upon recommendations, reports, communications or documentation.

Corporate Spectrum Pty Ltd may use Australian and overseas technology providers and may change AI systems, software platforms, technology providers or business systems from time to time without prior notice.

The Partnering Client remains responsible for ensuring any notices, disclosures, permissions, authorities or consents required by law have been obtained before information is provided to Corporate Spectrum Pty Ltd.

 

Disclosure of Information

Corporate Spectrum Pty Ltd may disclose information:

• to Partnering Clients;

• insurers and claims administrators;

• workers compensation authorities;

• treating practitioners and rehabilitation providers;

• legal, accounting and professional advisers;

• government departments and regulatory authorities;

• information technology providers;

• software and cloud service providers;

• bookkeeping providers;

• authorised contractors and subcontractors; and

• other parties where authorised, permitted or required by law.

 

Third-Party Service Providers

Corporate Spectrum Pty Ltd is a small business operation.

Access to information is generally restricted to the Directors of Corporate Spectrum Pty Ltd.

Corporate Spectrum Pty Ltd may engage authorised third-party providers including:

• information technology providers;

• cyber-security providers;

• cloud and software providers;

• bookkeeping providers;

• accounting advisers;

• telecommunications providers;

• backup and disaster recovery providers;

• professional advisers; and

• occasional subcontractors.

Third-party providers may only access information to the extent reasonably necessary to perform authorised functions.

Authorised subcontractors are expected to be subject to confidentiality obligations and may only access information reasonably necessary to perform their duties.

 

 

Personnel Access

Access to personal information and sensitive information is restricted to authorised persons with a legitimate business need to access such information.

Access is generally limited to:

• the Director/s and employees of Corporate Spectrum Pty Ltd;

• authorised subcontractors;

• authorised information technology providers;

• authorised bookkeeping and accounting providers; and

• other authorised service providers whereby reasonably necessary.

 

Monthly Reports and Document Control

Corporate Spectrum Pty Ltd prepares reports, records, recommendations, updates and related documentation using information available at the time of preparation.

 

Partnering Clients are responsible for reviewing documentation supplied by Corporate Spectrum Pty Ltd and notifying Corporate Spectrum Pty Ltd as soon as reasonably practicable if:

• information requires amendment;

• information requires correction;

• additional information should be included;

• information should be updated;

• information should be removed where lawful and appropriate; or

• circumstances have changed.

 

Corporate Spectrum Pty Ltd may rely upon information supplied by Partnering Clients and third parties when preparing reports and related documentation.

 

Unless otherwise agreed in writing, Corporate Spectrum Pty Ltd is not responsible for independently verifying the accuracy, completeness, adequacy, reliability or currency of information supplied by others.

 

Corporate Spectrum Pty Ltd does not accept responsibility for inaccuracies arising from incomplete, inaccurate, misleading or outdated information supplied by third parties.

 

Information Security

Corporate Spectrum Pty Ltd takes reasonable steps to protect information against misuse, interference, loss, unauthorised access, unauthorised disclosure and unauthorised modification.

 

Security measures may include:

• multi-factor authentication on business systems, user accounts and devices where supported and reasonably practicable;

• password protection and access controls;

• Microsoft 365 and OneDrive environments;

• secure cloud-based platforms;

• off-site backup arrangements;

• cyber-security controls;

• managed information technology services;

• business continuity measures; and

• disaster recovery processes.

 

Information may be stored electronically, physically, within Microsoft environments, through authorised cloud providers and through secure backup solutions designed to reduce the risk of data loss and support business continuity.

 

While Corporate Spectrum Pty Ltd takes reasonable steps to implement safeguards, no method of storage, transmission or cyber-security protection can guarantee absolute security.

Corporate Spectrum Pty Ltd is not responsible for the privacy, security, availability or operational practices of third-party software vendors, cloud providers, telecommunications providers, internet service providers or external platforms except to the extent required by law.

 

Overseas Storage and Processing

Corporate Spectrum Pty Ltd may utilise technology providers, software platforms, cloud services, backup solutions and AI-enabled technologies that involve overseas storage, processing, transmission, backup or access to information.

 

Where overseas providers are utilised, Corporate Spectrum Pty Ltd will take reasonable steps to ensure appropriate confidentiality, privacy and security safeguards are maintained.

 

The Partnering Client remains responsible for ensuring any notifications, disclosures, permissions, authorities or consents required by law relating to overseas processing have been obtained.

 

Data Breach Response

Corporate Spectrum Pty Ltd maintains procedures intended to assist with identifying, assessing, managing and responding to suspected privacy incidents and data breaches.

In the event of a suspected or actual privacy incident, Corporate Spectrum Pty Ltd may:

• investigate the incident;

• take steps to contain and remediate the issue;

• engage information technology, cyber-security, legal, forensic or other specialist advisers;

• notify affected Partnering Clients where appropriate;

• assess notification obligations;

• cooperate with authorities or regulators where required; and

• take reasonable steps to reduce the likelihood of further incidents.

 

Where required by law, Corporate Spectrum Pty Ltd will comply with applicable mandatory data breach notification requirements.

Despite reasonable safeguards, Corporate Spectrum Pty Ltd cannot guarantee that information will never be accessed, altered, disclosed, destroyed or lost.

 

Data Retention

Corporate Spectrum Pty Ltd retains information for as long as reasonably necessary to:

• provide services;

• comply with legal obligations;

• comply with workers compensation obligations;

• comply with contractual obligations;

• respond to disputes, claims and complaints;

• maintain business records; and

• protect legitimate business interests.

Corporate Spectrum Pty Ltd may retain information where required or permitted by law notwithstanding any request for deletion.

 

Access, Correction and Complaints

Individuals may request access to, or correction of, personal information held by Corporate Spectrum Pty Ltd by contacting us in writing.

Where information is maintained on behalf of a Partnering Client, Corporate Spectrum Pty Ltd may refer the request to the relevant Partnering Client.

Privacy complaints should be submitted in writing together with supporting information where available.

Corporate Spectrum Pty Ltd will investigate complaints and respond within a reasonable period.

If you are dissatisfied with the outcome, you may contact the Office of the Australian Information Commissioner (OAIC).

 

No Reliance

Information, reports, recommendations, templates, guidance materials, training content, communications and other documentation provided by Corporate Spectrum Pty Ltd are prepared based upon information available at the relevant time and for the purposes of the agreed engagement.

 

Such information is not legal, medical, insurance, taxation, accounting, financial or regulatory advice and should not be relied upon as such.

 

Partnering Clients remain responsible for their own decisions, actions, risk management activities and compliance obligations.

 

Corporate Spectrum Pty Ltd makes no representation, warranty or guarantee that any report, recommendation, guidance, communication, template or service will ensure compliance with legislative, regulatory, contractual or organisational requirements.

 

To the maximum extent permitted by law, Corporate Spectrum Pty Ltd shall not be liable for any loss, damage, liability, cost, claim or expense arising from reliance upon information, records, instructions, approvals, authorisations or representations supplied by a Partnering Client or third party, including where such information is inaccurate, incomplete, misleading, outdated or unlawfully obtained or disclosed.

Contact Us

Corporate Spectrum Pty Ltd
Email: info@corporatespectrum.net.au

 

Disclaimer

Corporate Spectrum Pty Ltd does not provide legal, medical, insurance, taxation, accounting or financial advice.

Partnering Clients remain solely responsible for their own compliance obligations, decisions, actions, policies, procedures and statutory responsibilities.

Advice, guidance, recommendations and support provided by Corporate Spectrum Pty Ltd are provided for consideration by the Partnering Client and should be assessed having regard to the Partnering Client's own circumstances, obligations and independent professional advice.

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