Privacy Policy
Contents
- About Airservices and this Privacy Policy
- Personal information collected and stored by Airservices
- How Airservices uses and discloses personal information
- Overseas Disclosure
- How Airservices stores your personal information
- Access to and correction of personal information
- Social Media Integrations
- IP addresses
- Feedback / Complaints / Contact
- Changes to our Policy
1. About Airservices and this Privacy Policy
Airservices Australia (Airservices) is a government-owned corporation responsible for providing safe, secure, efficient and environmentally responsible services to the aviation industry. Airservices manages air traffic operations across Australian Airports and provides the aviation industry with aeronautical data, telecommunications, navigation services and aviation rescue and fire-fighting services.
In undertaking these functions and activities, Airservices handles personal information and this Privacy Policy explains how Airservices manages personal information in accordance with the requirements of the Australian Privacy Principles as contained in the Privacy Act 1988 (Cth).
Airservices only collects, uses and discloses personal information that is reasonably necessary for, or directly related to, the performance of its functions or activities under its enabling legislation, the Air Services Act 1995 (Cth). Airservices is committed to protecting the privacy of personal information in our care. Personal information (including sensitive information) will only be used or disclosed for the purpose for which it was collected unless the law requires or permits a use or disclosure for another purpose, or permission is given by the individual to use or disclosure the information for that other purpose.
By providing personal information to us, you agree that this Privacy Policy will apply to how Airservices handles your personal information, and you consent to us collecting, using and disclosing your personal information as set out in this Policy.
If you do not agree with any part of this Policy, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Policy, this may affect our ability to provide services to you, or it may negatively impact the services Airservices can provide to you.
2. Personal information collected and stored by Airservices
Airservices’ primary purpose when collecting personal information is to carry out its functions or activities. Examples of the type of personal information which Airservices collects includes:
- personal contact details;
- personnel records;
- financial payment records;
- contract, tender and submission documents;
- litigation and compensation records;
- employee conflict of interest declarations;
- mailing, subscription, and customer lists;
- FOI applications.
We also conduct the following administrative activities:
- personnel information in relation to staffing matters;
- complaint handling procedures;
- freedom of information requests and privacy queries;
- maintaining our website.
Airservices must store all personal information securely, and must restrict access to only those employees who require access in order to perform their duties or fulfil Airservices’ functions. Most personal information held by Airservices is stored electronically on cloud-based and local databases, shared drives, and in emails, or physically on hard copy files. Airservices also holds personal information in a variety of records and databases, including:
- Noise complaints & information service records
- Personnel/employee/recruitment records
- Service desk case management system records.
Airservices must take all necessary steps to ensure that the personal information it holds is protected from misuse, loss and interference. Further, when information is no longer required, that it is securely destroyed in accordance with the Archives Act 1983 (Cth) and relevant disposal authorities or forwarded to National Archives.
Airservices will collect personal information directly from you unless it is unreasonable or impracticable to do so. This may occur when you deal with us either in person, by telephone, letter, email, when you visit our website or when you connect with us via social media. Generally, this collection will occur through the use of forms, applications or other documents completed in relation to the provision of services, or the recording of information during phone calls, interviews or other forms of communication
Airservices may indirectly collect personal information from an external source or third party. For example, from other employers (for reference and employment checks), from superannuation funds or from other government agencies.
You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent.
3. How Airservices uses and discloses personal information
Under the Privacy Act Airservices may disclose personal information for the primary purpose for which it was collected. Personal information may also be disclosed for a secondary purpose in certain circumstances. This can occur where a person gives consent for their personal information to be used or disclosed for the secondary purpose.
There are also limited circumstances in which Airservices may use or disclose information for a different purpose (secondary purpose) without a person’s consent, including where:
- a person would reasonably expect us to disclose the personal information for the secondary purpose, and the secondary purpose is either directly related to the primary purpose (for sensitive information); or related to the primary purpose (for other personal information);
- it is required or permitted by law (such as, disclosure to a third party pursuant to a court order or subpoena);
- it is necessary to lessen or prevent a serious threat to the life or health or safety of an individual, or to protect the health or safety of the general public; or
- it is a permitted general situation or health situation, as defined by the Privacy Act; or
- it is for the purpose of an enforcement related activity and the use or disclosure of the information is reasonably necessary.
Other than the above, Airservices will not disclose your personal information without your consent unless Airservices reasonably believes that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law.
4. Overseas Disclosure
Airservices may disclose certain personal information to third parties located overseas for the purpose of providing services to or for us, including the storage and processing of such information, systems administration, and systems maintenance purposes. This disclosure occurs pursuant to commercial arrangements. Airservices takes reasonable steps in its commercial arrangements to ensure any third party recipient of personal information manages that personal information in accordance with the Australia Privacy Principles under the Privacy Act.
It is possible that information will be transferred to an overseas recipient located in a jurisdiction where you may not be able to seek redress under the Privacy Act, or that does not have an equivalent level of data protection as in Australia. To the extent permitted under the Privacy Act, Airservices will not be liable for how these overseas recipients handle, store and process your personal information. By providing your personal information to us, you consent to our disclosure of your personal information to these overseas recipients.
From time to time Airservices may also deal with other service providers located overseas. It is not possible for Airservices to set out in this Policy all of the countries to which Airservices may send your personal information. If you have any specific questions about where or to whom your personal information will be sent, please contact privacy@airservicesaustralia.com.
5. How Airservices stores your personal information
All personal information collected by Airservices is held in electronic systems such as (but not limited to):
- SAP (payroll)
- Content Manager (record management system)
- PageUp (online recruitment and on-boarding management system)
- SuccessFactors (learning and development management system)
- SuccessFactors (performance management system)
- Active Directory (Authentication system)
- Azure Active Directory (Cloud based authentication system).
- Microsoft Office Suite (including Outlook, Excel and Word)
- Corporate Network Drives
Airservices protects the security and confidentiality of the personal information we hold. All personnel records are classified as OFFICIAL: Sensitive; Personal-Privacy, and given protection that is consistent with that classification. Airservices restricts the access to recruitment, human resources and payroll staff on a need-to-know basis.
In order to enable the storage and processing of this type of information, Airservices may disclose certain personal information to third parties located overseas for the purpose of providing services to or for us, systems administration, and systems maintenance purposes. Airservices takes reasonable steps to ensure any third party recipient of personal information manages that personal information in accordance with the Australia Privacy Principles under the Privacy Act. However, it is possible that information may be transferred to an overseas recipient located in a jurisdiction where you may not be able to seek redress under the Privacy Act, or that does not have an equivalent level of data protection as in Australia. To the extent permitted under the Privacy Act, Airservices will not be liable for how these overseas recipients handle, store and process your personal information. By providing your personal information to us, you consent to our disclosure of your personal information to these overseas recipients. If you have any specific questions about the storage, processing or administration of your personal information, including where or to whom your personal information will be sent, please contact privacy@airservicesaustralia.com.
Airservices also disposes of files in strict accordance with the General Disposal Authorities issued by the National Archives of Australia.
6. Access to and correction of personal information
Individuals can access information about themselves in documents (other than exempt documents) under the Privacy Act 1988 or Freedom of Information Act 1982 (FOI Act). You may obtain original documents which you have given to us or copies of personal documents on your file which you have provided to us or that we have sent to you. Both the Privacy Act and section 15A of the FOI Act require that Airservices responds to requests for access to personal information within 30 days. Under the FOI Act you can also access documents held by Airservices, including policy documents and personal information, subject to exemptions necessary to protect essential public or private interests.
If an individual believes the information held by Airservices requires amendment, a written request should be sent to the Privacy Officer at privacy@airservicesaustralia.com outlining what aspects of the information requires amendment. There is no cost for making a written request which will be processed within 30 days.
For security reasons, Airservices reserves the right to ask applicants to provide proof to confirm the identity of the person seeking access or correction to personal information before responding to such a request. Airservices also reserve the right to deny access for any reason permitted under applicable law. If Airservices denies access or correction, Airservices will provide written reasons for such denial.
Making a complaint to us
Airservices will investigate any complaint about its handling of personal information. Complaints should include enough detail for the Privacy Officer to identify the nature of the issue. All requests (including complaints about how Airservices has managed personal information) should be sent to the Privacy Officer by email at privacy@airservicesaustralia.com.
Making a complaint to the Office of the Australian Information Commissioner (OAIC)
If a person is unsatisfied with our response, they can write to the OAIC. The OAIC can investigate privacy complaints about the protection of personal information, order compensation to be paid where warranted and direct organisations to change the way they handle personal information. If a person needs help lodging a compliant with the OAIC, they can call the OAIC Enquiries Line on 1300 363 992. For further information please refer to the OAIC’s website.
A person can make a complaint directly to the OAIC rather than to Airservices, however it is likely that the OAIC would recommend that a person try to resolve the complaint directly with us in the first instance.
7. Social Media Integrations
Airservices’ websites may use social media features (such as “Like” and “Share” buttons). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. These social media features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the social media feature to function properly.
Your interactions with these social media features are governed by the privacy policy of the third party company providing them. For more information about the data practices of these third party companies, and to find out more about what data is collected about you and how the third party uses such data, please refer to their privacy policy directly.
8. IP addresses
When you access our website, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet. On its own, an IP address is not personal information, as any one computer or device may be used by multiple people. We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website.
9. Feedback / Complaints / Contact
If you have any enquiries, comments or complaints about this Policy or our handling of your personal information, please contact our Privacy Officer at privacy@airservicesaustralia.com. We will respond to any enquiries or complaints received as soon as practicable.
10. Changes to our Policy
Airservices may amend this Policy from time to time. If we make a change to the Policy, the revised version will be posted on our website.
Last updated 19 July 2021