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Privacy Statement

Introduction - our obligation to our Stakeholders

This policy is intended to assist Willmott Forests Limited staff, its stakeholders and other individuals to understand the purpose of Willmott Forests Limited's collection and use of personal information.  Rights of access to information and the procedure for lodging complaints in relation to alleged breaches of privacy by Willmott Forests are also addressed.

Willmott Forests Limited acknowledges its responsibilities in the proper handling of personal information it collects and holds. The Privacy Act 1988 "as amended" formalises Willmott Forests' existing privacy obligation to individuals whose personal information is held by Willmott Forests.

We are committed to the privacy of our stakeholders and will protect carefully any confidential information they provide to us. We will not collect sensitive or private information about our stakeholders without their express consent.

To protect and to guarantee stakeholders' privacy, we have appointed a Privacy Officer to monitor our compliance with privacy obligations imposed by law, and those we assume voluntarily.

If you have any queries, comments or complaints about our privacy issues please contact the Privacy Officer C/- Compliance Team on (03) 9696 1355.

There are many obligations imposed upon us to protect stakeholders' privacy under various acts of parliament.  For more information about National Privacy Principles (NPP), access can be obtained through the Australian Privacy Commissioner's website at http://www.privacy.gov.au/.

1. Use and Disclosure

Willmott Forests Limited in the provision of forestry investment management to its stakeholders may be required to disclose information to third parties including its insurance underwriters, financers, solicitors and government regulatory bodies or in cases relating to public interest (such as law enforcement and public health and safety).

Willmott Forests Limited may also, as permitted by the Privacy Act, disclose your information where necessary in an emergency, investigation of suspected criminal activity or where Willmott Forests is authorised or required by law (e.g. legislation or court order) to disclose it.

Willmott Forests Limited may use (but not disclose) information for a secondary purpose of direct marketing provided:

  • information is not sensitive information;
  • it is impractical for Willmott Forests Limited to seek the stakeholder's consent before that particular use;
  • stakeholder has not previously made a request not to receive direct marketing material;
  • each direct marketing communication includes contact details of Willmott Forests Limited and notice informing the stakeholder of the right to object to receiving further direct marketing material.

2.  Collection

Collection of personal information must be fair, lawful and not intrusive.  Willmott Forests Limited will only collect personal information necessary for our functions and operations.

At or before the time of collection of personal information, stakeholders or potential stakeholders will be told:

  • the purpose of collecting the information;
  • they are able to access their personal information collected;
  • the organisations (or types of organisations) to which Willmott Forests Limited usually discloses this kind of information;
  • any law requiring the particular information to be collected;
  • any consequences that may arise for the stakeholder if they do not provide all or part of the information requested;
  • details of how to contact our Privacy Officer.

If it is not practicable to give the above information at or before the time of collection, it will be provided as soon as practicable after the collection has occurred.

3. Data Quality

Reasonable steps will be taken to ensure that the personal information collected, used or disclosed is accurate, complete and up to date.

  • information is received in writing from stakeholders directly;
  • the database is updated on receipt of such notification to ensure as far as possible that information it holds is accurate, complete and current.  Updating personal information will be treated as "collection" and will be undertaken in accordance with the provision on collection contained in Part 2 of this policy;
  • Willmott Forests' personnel will liaise with stakeholders & authorised representatives directly to receive adequate and accurate information required to complete tasks and requests regarding our stakeholders;

4.  Data Security

Reasonable steps will be taken to protect personal information collected from misuse, loss and unauthorised access.

  • Authorisation must be received in writing from our stakeholder's, authorising Willmott Forests Limited to release information regarding themselves and their forestry investment to third parties on their behalf. A Authorisation form can be obtained from our Grower Information section on our website:
  • This authority is recorded within stakeholder's files and on Willmott Forests' database. These authorisations can be revoked at any time at the request of the stakeholder;
  • Willmott Forests' personnel are trained as required in all aspects of releasing stakeholder information to external parties;
  • The Customer Relations Manager (or nominated person) is responsible for recording and updating stakeholder's personal, investment and authorisation information;
  • The data is contained within a database with multiple security measures including network access security, password access to the database and security within the database on individual records.

Reasonable steps will also be taken to destroy or permanently de-identify personal information that is no longer required for any purpose.

5. Openness

Willmott Forests Limited has set up a policy on its management of personal information. This document is to be made available to anyone who asks and is available on the Willmott Forests Limited website.

Willmott Forests Limited will, upon request, let anyone know:

  • the kind of personal information we hold;
  • the purpose for holding the personal information; and
  • how we collect, hold, use and disclose the information.

6. Access and Correction

Willmott Forests Limited will, wherever possible, allow access by individuals to the information it holds about them and correct that information if it is wrong, except to the extent that:

  • providing access would have an unreasonable impact upon the privacy of other individuals;
  • the request for access is frivolous or vexatious;
  • the information relates to legal proceedings (existing or anticipated) between Willmott Forests Limited and the stakeholder;
  • it would be unlawful to provide access;
  • denying access is required or authorised by law; or
  • providing access would be likely to prejudice investigations into possible unlawful activity or other law enforcement activities.

Any access requests should be made in writing, addressed to:                                   

Privacy Officer
Willmott Forests Limited
Locked Bag 4011
SOUTH MELBOURNE  VIC  3205

Willmott Forests will endeavour to respond to requests within 30 days of receipt. Should a request for access be declined, a reason for this will be provided, together with an outline of the procedure to have this decision reviewed.

7.  Identifiers

An identifier is a number used by a government agency (or its agent or contactor) to identity an individual (ie. Tax File Number, Pension Number).  Willmott Forests Limited will not adopt an identifier like this as its own identifier, and generally speaking, should not use or disclose an identifier assigned by a government agency.

8. Our Employees and Training

We provide training and communication programs designed to educate employees about the meaning and requirements of the Willmott Forests Limited Privacy Policy.

Employees who intentionally or negligently breach the Privacy Policy are subject to disciplinary action.

Employees are expected to report violations and may do so confidentially to their  Manager or Compliance Manager.

9. Trans-border data flows

Willmott Forests Limited must take steps to protect an individual's privacy if personal information is sent outside Australia.

Information may only be transferred if:

  • Willmott Forests Limited reasonably believes a law, binding scheme or contract applies at the destination which effectively delivers privacy standards substantially similar to the NPP's;
  • the individual consents to the transfer;
  • the transfer is for the benefit of the individual and it's impracticable to obtain consent, but it's likely consent would have been given;
  • the transfer is required by a contract between the individual and the organisation, or a contract between the organisation and a third party in the interests of the individual; or
  • Willmott Forests Limited has taken reasonable steps to ensure the information won't be held, used or disclosed by its recipient inconsistently with the NPP's.

10. Sensitive Information

Willmott Forests Limited is not allowed to collect sensitive information from an individual unless:

  • the individual has consented;
  • collection is required or authorised by law;
  • the information is required to establish or defend a legal or equitable claim; or
  • the individual is incapable of consenting and the information is needed because of a serious and imminent threat to the life of health of the individual.
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