Collection of Personal Information
A J Duffy will only collect personal information that is necessary for one or more of its functions or activities. Where possible information will be collected directly from the individual that it is about and only in lawful, fair and reasonably unintrusive ways. A J Duffy will take reasonable steps to ensure that when collecting personal information the individuals are aware of:
- The identity of A J Duffy.
- The purpose of collecting the information.
- The individual’s right to access the information.
- The types of organisations to which A J Duffy discloses the information.
- Any law requiring the information to be collected.
- The consequences for the individual of failing to provide the information.
A J Duffy will, where practicable, collect personal information directly from individuals and whenever possible, make sure individuals know when you collect information about them from a third party. A J Duffy will take reasonable steps to ensure the individual is aware of the matters detailed above.
Use and Disclosure
A J Duffy will not use or disclose personal information about an individual other than for its original (primary) purpose. The use or disclosure of the information for another purpose (secondary purpose) is not permitted unless the person has consented to its use or disclosure for that other purpose.
A J Duffy will take reasonable care to ensure that the personal information it collects, uses or discloses is accurate, complete and up to date.
A J Duffy will take reasonable steps to protect any personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. If the information is no longer needed, it will be destroyed or permanently de-identified.
A J Duffy has documented its policies on the use and management of personal information held. These policies are available on request.
Access and Correction
A J Duffy give individuals access to their personal information and will correct it if it is wrong and it is reasonable to do so. If access to information is refused, A J Duffy will provide reasons for such refusal.
A J Duffy will not use a government identifier as its own identifier.
Where it is lawful and practical, A J Duffy will give individuals the option of not identifying themselves when entering into transactions with it.
Transborder Data Flows
A J Duffy will not disclose personal information to a recipient in a foreign country who is not subject to comparable privacy obligations as those contained in the NPP’s unless A J Duffy has the consent of the relevant individual.
As a general rule, A J Duffy will not collect sensitive information. However, where sensitive information is to be collected, it will only be collected, used and disclosed with the individual’s consent or in accordance with the requirements under the NPP’s.