Privacy Policy

Gadget Access understands you as a client of our company may have concerns about the privacy, confidentiality, and security of information we may obtain from your company. Our policy is to protect our clients’ privacy and confidential information collected; this includes physical security, computer and network security, communications security and personnel security.

Gadget Access has undertaken to comply with the requirements of the Privacy Act, 1988, and the Privacy Amendment (Enhancing Privacy Collection) Act 2012 (Cth) (Act).

Collecting personal information

Gadget Access uses your personal information for the legitimate business purpose for which it was disclosed at the time of collection. We lawfully collect personal information that is necessary for our business to provide comprehensive quality services. The information we collect and hold will depend upon the investigation service you request from us and may include information you provide us when you engage our services. This information will include client details such as name, address, telephone and facsimile numbers, email addresses, together with information pertaining to the claimant and their associated claim.

We use this information to:

• set up and administer a service for the client;
• maintain client contact details;
• determine a customer’s requirements and provide the appropriate service;
• assess our clients and their needs; and
• improve our products and services.

This information is essential to the provision of our services.

Storage of Information

Gadget Access will take all reasonable steps to protect your personally identifiable information. We use appropriate security procedures and the latest technology to protect the information we hold.

Only staff authorised by the Directors have access to the data file information. Hard copies of information are stored in accordance with the requirements set out in Part IV of the Commonwealth of Australia Protective Security Manual.

We are also required to take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for a permitted purpose.

Disclosure of personal information

We do not disclose personal information to any outside third party organisation, unless we are contracted to do so by our clients. In this case, we make sure that the third party is bound by the same privacy rules we follow. We do not share information with entities outside of Australia.

Information will only be used or disclosed by Gadget Access as allowed by the Privacy Act 1988, and the Privacy Amendment (Enhancing Privacy Collection) Act 2012 (Cth) (Act).

Openness

You have the right to request access to any personal information we hold about you. You can request this information by contacting the Director of our company. Where we hold information that you are entitled to access, we will respond to your request in a reasonable time and endeavour to provide you with a suitable range of choices as to how access is provided.

If at any time you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request an amendment of it and we will either amend the information or make a record of your comment, as we think appropriate.

Making changes to personal information

Gadget Access endeavours to ensure information held is accurate, complete and up-to-date. Where you believe the information held is not accurate, complete or up-to-date, please advise Gadget Access and every effort will be made to correct the information.

Complaints

If you have a complaint about how we have collected or handled your personal information, please contact Gadget Access’ Director, who will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week.

Complaints Process

Gadget Access will endeavour to acknowledge receipt of a privacy complaint within 24 hours of receiving it and to complete our investigation into your complaint in a timely manner. This may include, for example, gathering the relevant facts, reviewing relevant documents and speaking to relevant individuals.

In most cases, we expect that complaints will be investigated and a response provided within 28 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will write and let you know.

If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au/privacy/making-a-privacy-complaint), or other regulatory bodies.

Code of Conduct

Gadget Access’ Code of Conduct is a reflection of the way all people who form part of our company should conduct their activities according to scrupulous standards of ethics, fairness and professional and legal obligations.

Our Code underpins the objective of our company to conduct all activities in a manner that is consistent with our values. Our organisation is supported by a documented framework of internal and external expectations and requirements which help us make the right decisions at the right time with every activity we conduct.

The principles underpinning our Code are:

1. We act with honesty, integrity and fairness.
2. We comply with all legal, regulatory and contractual obligations.
3. We strive to maintain our professional competence, due care and quality of work.
4. We maintain privacy and confidentiality at all times.
5. We do the right thing by our people.
6. We exercise accountability, respect and empathy.
7. We manage conflicts of interest in a proactive manner.

We act with honesty and integrity in all dealings:

Gadget Access strives to operate to the highest standards of honesty, integrity and fairness in its business operations and dealings with our people, clients and external bodies. To ensure these standards are maintained, we will:

• Conduct all investigations within the bounds of legality, morality and professional ethics;
• Adopt business practices that prevent improper conduct, inappropriate practices and behaviours;
• Perform all investigations with due diligence and care, using all lawful means to bring the investigation to a timely conclusion;
• Provide truthful, accurate, fact-based reports to our clients, detailing all the facts ascertained whether they be advantageous or detrimental;
• Not permit or tolerate prejudice or personal opinions which interfere with the search for the truth in an investigation;
• Commit only to what we honestly believe we can deliver;
• Ensure procedural fairness and uphold the principles of natural justice.

We comply with all Legal, Regulatory and Contractual Obligations

Gadget Access exercises responsible corporate governance to ensure adherence to laws, regulations and standards. Through our strict compliance system, we ensure that our company, clients and people are protected as comprehensively as possible. To ensure full compliance in the services we provide, we will:

• Comply at all times with our legal obligations, regulatory and contractual requirements, and voluntary codes of practice to which we subscribe and internal policies, including this Code of Conduct;
• Keep abreast of all changes in legislation which may affect the provision of our services;
• Provide training and information to staff and investigators to ensure they understand their legal, regulatory and contractual obligations as part of their individual roles;
• Ensure our people seek advice from management should a discrepancy appear between certain laws and regulations.

We strive to maintain our professional competence, due care and quality of work

Gadget Access understand that our clients expect our work to meet the highest professional standards. We take responsibility for our professional conduct and ensure that we bring the appropriate skills and capabilities to all services provided. To ensure we conduct our work to the highest level of professionalism and quality, we will:

• Respect the best interest of our clients by maintaining the highest standard of proficiency and reporting;
• Provide our services in accordance with our clients’ standards and professional requirements;
• Be accountable for our decisions and actions;
• Seek to continually improve our skills and knowledge to achieve excellence in our services;
• Continually train and develop our staff in order to maintain the highest standard of service;
• Maintain all respective licences and certifications through timely renewals and attain the appropriate level of continuing professional education;
• Report any issues, complaints or factors that may impact the good standing of our company and our clients;
• Seek feedback from our clients in order to continually improve our service.

We maintain privacy and confidentiality at all times

The nature of our work gives us access to confidential and personal information. It is our responsibility to ensure the security of all confidential and personal information entrusted to us. To fulfil our privacy and confidentiality obligations, we will:

• Comply at all times with current privacy legislation, including the Privacy Act 1988 and APPs, relevant state legislation, and our regulatory and contractual requirements;
• Honour privacy and confidentiality commitments made to our clients and take all reasonable steps to ensure the confidentiality and security of the personal information we hold;
• Comply with contractual requirements dealing with the management of confidential information;
• Not discuss or share information from our clients with any third party without the direct authorisation from our clients;
• Be cognisant of an individual’s right to privacy at all times during an investigation;
• Always inform individuals of the process being undertaken and the reason private information is required, who it will be disclosed to and what it will be used for.

We do the right thing by our people

Gadget Access is committed to ensure that our people can carry out their work in an environment free from any form of discrimination. It is our responsibility to maintain the highest standards of personal conduct. To do this, we will:

• Not discriminate on the grounds of sex, gender, sexual orientation, race, colour, language, religion or belief, political or other opinion, national or social origin, association with a national minority, disability, age, sexual orientation, property, birth or other status;
• Comply with any legislative and other requirement of the Commonwealth, State, Territory or local government, including the Anti- Discrimination Act 1977, Age Discrimination Act 2004, Australian Human Rights Commission Act 1986, Disability Discrimination Act 1992, Racial Discrimination Act 1975, Sex Discrimination Act 1984;
• Foster a work environment that is free from intimidation, harassment and any form of hostility.

Accountability, respect and empathy

Gadget Access recognises diversity in our society and embraces a culture based on acceptance and cultural diversity to support the worth, dignity and uniqueness of each person we work with. While conducting our work, we distinguish between cultural needs and individual, personal needs and preferences. To ensure that we are sensitive to, and meet the needs of the diverse people we work with, we will:

• be prepared to be flexible and adapt our service practices to suit individual client needs;
• make sure, wherever practical, that arrangements are made to meet the specific language, cultural and communication needs of clients we interview and being aware of how these needs affect understanding;
• being familiar with, and using wherever necessary, qualified language interpreters or cultural interpreters to help meet the communication needs of clients, including those who require assistance because of their English skills or because they are speech or hearing impaired;
• create a culture of diversity that permeates every function within our organization.

We manage conflicts of interest in a proactive manner

Gadget Access strives to avoid any conflict of interest and will disclose any situation which might constitute a real or apparent conflict of interest. We have robust processes in place to avoid and respond to conflicts of interest and provide a reporting framework that enables employees to disclose and take reasonable steps to avoid any conflicts of interest, real or apparent, relating to their employment. Our responsibility to avoid conflicts of interest means that we must:

• Remain free from influence, or the appearance of influence, of any conflicting interests;
• Avoid outside activities, situations or relationships that would impair, or appear to impair our professional judgment;
• Not provide or accept any type of gratuity during the course of the work or service provided;
• Ensure that employees and contractors are familiar with our policy dealing with actual conflicts of interest and potential or perceived conflicts of interest;
• Ensure that all employees and investigators declare any conflict of interest in relation to any matter in which they are involved.

Anti Corruption Policy

Objective:

Gadget Access recognises that our reputation for conducting business in an ethical and honest way is a core company value that must be valued and protected.

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations and to ensure that Gadget Access conducts business in a socially responsible manner.

Scope:

This policy applies to all staff, employees and entities working on behalf of Gadget Access.

Forms of Corruption

Gadget Access prohibits corruption, bribery and extortion in all forms.

Employees are prohibited from directly or indirectly offering, giving, soliciting or receiving any form of bribe, kickback, payment or anything of value to or from any person or organisation including government agencies, individual government officials, private companies or their employees under any circumstances. Gifts, entertainment or travel must not be given or received as a reward or encouragement for preferential treatment.

Gadget Access does not participate in party politics. It does not make payments to political parties or individual politicians.

Employees are prohibited from using any funds, assets, resources, time or employees including in-kind contributions of services to make any political contribution or assist any party or individual politician or candidate.

Gadget Access does not make charitable donations or sponsorships that could be perceived as bribes or payments to gain an improper business advantage.

Avoiding and Managing Business Integrity issues

Gadget Access’ management takes responsibility and accountability to ensure that as a company we will:

• Comply with all applicable anti-bribery and corruption laws;
• Act honestly and with integrity at all times in the conduct of our services;
• Maintain measures to prevent and detect bribery and corruption by Gadget Access personnel;
• Be alert for instances of corrupt conduct and report any suspected or actual breach of this policy;
• Ask questions and seek advice if unsure about obligations under this policy.

We will not:

• Offer or accept gifts or hospitality if doing so might impair objective judgement, improperly influence a decision or create a sense of obligation;
• Use company property or funds (directly or indirectly) for any unlawful, unethical or improper purpose;
• Authorise, provide, invite or accept any monetary or another benefit to obtain, retain or improve business or a business advantage;
• Make a facilitation payment;
• Offer or give anything of value to a government official (or their representative) to induce or reward improper conduct in the course of their duties or responsibilities;
• Permit or turn a blind eye to someone else doing something (whether by acting or failing to act) that contravenes this policy; or
• Encourage someone else to do something (whether by acting or failing to act) that contravenes this policy.