Libertas understands the importance of privacy and is committed to protecting the personal information collected. The Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) contained in Schedule 1 of the Privacy Act govern the way in which Libertas uses and manages personal information, subject to certain exemptions. Chapter 3 of the Information Privacy Act 2009 (Qld) (IP Act) sets out the methods by which individuals can access and amend personal information held by Libertas.

The objectives of this Privacy Policy are to ensure that Libertas complies with the Privacy Act through:

a) a clearly expressed and up-to-date policy regarding the management of personal information by Libertas;

b) collection, use, storage, and maintenance of personal information in accordance with applicable legislation;

c) provision of the right to access and request amendment by individuals to their personal information held by Libertas in accordance with applicable legislation; and

d) maintenance of accurate records.

Libertas collects and holds personal information that is reasonably necessary for business activities and operations. Types of personal information collected by Libertas may include, but is not limited to:

a) names and contact details (such as address, email address, and telephone numbers).

b) information relevant to employment or engagement including age or birth date, job title, and health.

c) details of the service enquiries or service delivery, together with any additional information necessary to deliver those services and/or respond to the enquiries; or

d) IP addresses and domain providers of those accessing the Libertas public website. Additionally, our website uses cookies managed by third parties. The main purpose of cookies is to prepare customised web pages for users. Cookies do not identify individuals personally, but they may link back to a database record about the individual. The Libertas website may contain links to other websites operated by third parties. Libertas makes no representations or warranties in relation to the privacy practices of linked third-party websites or the content of any linked third-party website. Linked third-party websites are responsible for informing individuals about their own privacy practices.

Libertas collects, holds, uses, and discloses personal information for the purposes of carrying out its functions and operations. This information is used as follows.

a) Members of the public, external stakeholders, customers:

i. Providing information and services, including answering enquiries and providing information or advice about Libertas’ services; and

ii. Processing and responding to any complaint made.

b) Job applicants, employees, or third-party contractors:

i. Managing and maintain Libertas’ relationship with the individual or where the individual is a job applicant, managing the job application process; and

ii. Conducting business processing functions including providing personal information to Libertas’ contractors, service providers, or other third parties.

c) Visitors to Libertas sites:

i. Managing and maintaining visitor records (phone numbers, names, and images).

d) Internal purposes:

i. Administrative, marketing, planning, service development, quality control, and research activities, including analysing Libertas’ services and business need with a view to developing new or improved services and business practices;

ii. Updating Libertas records and keeping an individual’s employment agreement or contract details up to date; and

iii. Complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or cooperating with any government authority.

e) Third party advertising:
Libertas may use interest-based and targeted advertising services (Online Advertising Services) to advertise on third-party websites. The Online Advertising Services used by Libertas may include, but is not limited to,
Google, LinkedIn, and Facebook and may:

i. use cookies and other tracking technologies such as web beacons/pixel tags, device identifiers, and JavaScript to collect information about visitors to the Libertas website and elsewhere on the internet (e.g. IP addresses and website activity);

ii. store this information in Australia and other countries; or

iii. combine this information with information Libertas has collected at other times or through other sources (e.g. where the Libertas website is accessed on multiple devices).

The Online Advertising Services may use information about users to:

i. inform, optimise, measure, and customise the advertisements users see on the internet;

ii. group website users based on demographic characteristics (e.g. gender, age, territory); evaluate use of the Libertas website and other websites;

iii. provide other services relating to website activity;

iv. do other things in accordance with their privacy policies and other notices and terms, to the extent permitted by law (e.g. where a user has an account with their service); or

v. the Online Advertising Services may transfer the information they hold about users to service providers they engage or where otherwise required by law.

Where it is reasonable and practical to do so, personal information is collected directly from an individual. Examples of how personal information might be collected may include, but is not limited to:

a) filling out a form;

b) viewing the Libertas website; and

c) by email or through a conversation (including on the telephone).

Consent is sought prior to information collection and after being informed of the types of information to be collected and the method of collection. There may, however, be some instances where personal information will be collected indirectly because it is unreasonable or impracticable to collect personal information directly from an individual.

Generally, Libertas will only use or disclose personal information for the purposes for which it was collected (as set out above), unless an exemption applies under the Privacy Act. Libertas may disclose personal information to:

a) Libertas’ employees, related entities, suppliers, contractors, service providers, and other third parties, who assist Libertas in operating its business or with whom Libertas has commercial relationships; or

b) any organisation for any authorised purpose with an individual’s express consent.

Privacy Collection Notices provide information on the use and purpose of information collected by Libertas in individual circumstances and seek consent to the use and collection of personal information.

The security of the personal information held is important to Libertas. Libertas holds personal information in different ways, including in paper and electronic form. Libertas takes reasonable measures to ensure that personal information is stored safely to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure, including electronic and physical safety security measures.

Some of the steps taken by Libertas to protect records of personal information may include, but is not limited to:

a) maintaining up-to-date privacy and data protection policies and standards for employees and third-party contractors to follow.

b) providing Libertas employees with appropriate information security and privacy training.

c) using firewalls, passwords, access controls, intrusion detection systems, monitoring tools and virus scanning, and appropriate encryption to maintain network and system security.

d) securing buildings with access controls, alarms, guards, and CCTV systems.

At any time, an individual has a right to:

a) request to access their personal information Libertas holds; and

b) request correction to their personal information.

This can be done by making a written request or an amendment application to the Libertas Privacy Officer. An individual may contact the Privacy Officer to request guidance to ensure the application is in the required format. No fees will be charged for lodging a request for personal information; however, fees may be charged at Libertas’ discretion in cases where a request is complex in nature.

Libertas employees may also request access to and amendment of their information through Human Resources. The Privacy Officer will decide to provide access to or amend the relevant personal information.

The Privacy Officer will provide the employee with written notice of their decision, usually within 25 business days.

The Privacy Officer may refuse access to or amendment of the personal information in the circumstances prescribed by the relevant laws, including where an application under the IP Act:

a) relates to exempt information;

b) should have been made under the Right to Information Act 2009 (Qld);

c) does not comply with the application requirements; or

d) would substantially and unreasonably divert Libertas' resources from the performance of business functions.

If access or amendment is denied for an application under the IP Act, an individual may seek an internal or external review of the decision. An application for review must be made in writing within 20 business days after the date of the notice that access or amendment is denied. In the case of an internal review, an authorised person will decide to uphold or vary the initial decision and provide written notice to the individual of the decision within 20 business days.

If it’s believed that personal information has not been dealt with in accordance with the privacy legislation, complaints may be made in writing to the Libertas Privacy Officer seeking an internal review. The Privacy Officer will internally review the complaint and contact the complainant in writing to advise of the outcome, within a reasonable time.

If the complainant does not agree with the outcome of the review, a further internal review may be requested. The responsible Director will arrange for a further internal review to be carried out by an equally or more senior employee who has not previously been involved in the matter. The responsible Director will aim to provide a written response to the complainant within a reasonable time.

Please contact Libertas’ Privacy Officer with any queries or concerns about Libertas’ Privacy Policy or the way Libertas handles personal information using the following contact details:

Libertas Partners Pty Ltd
Privacy Officer
232 Adelaide St
Brisbane City QLD 4000

Email: info@libertas.com.au