PROSEGUR CASH PRIVACY POLICY

1.    Information about PROSEGUR CASH

Prosegur Australia Pty Limited (“Prosegur”, “we”, “our” or “us”) is the Australian entity of Prosegur and provides cash logistics and cash processing services, products and solutions for Australian business including financial institutions, retail, government and hospitality. Prosegur’s headquarters are in Madrid, Spain but we operate and have offices all over the world.  Address details for all Prosegur offices are on our [CONTACT US URL] page.

For European Union data protection purposes, when act as a controller of your personal information, Prosegur Compañia de Seguridad S.A. Company is our representative in the European Union.

 

2.    Purposes  

a.    The purpose of this Policy is to protect the privacy of all individuals in their dealings with Prosegur.
b.    This Policy is to advise individuals of the kind of information Prosegur may gather, how that information may be used and disclosed, how an individual may seek to correct and/or update their information as well as identifying the process for making complaints.
c.    It is also the purpose of this Policy to manage personal information in a way that protects the privacy of that information and to also communicate clearly the personal information handling practices of Prosegur.
d.    Through this Policy individuals will have a better and more complete understanding of the sort of personal information which Prosegur holds and the way we handle that information.
e.    This Policy adopts and Prosegur will apply the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) as amended, to govern the way in which we collect, use and dispose of personal information that comes into our possession.

3.    Scope

a.    This Privacy Policy applies to Prosegur Australia Pty Limited (Prosegur).
b.    This Policy can be amended at any time at Prosegur’s discretion.
c.    This policy applies to all Prosegur Branch offices operating within Australia and to personal information on any individual interacting with Prosegur in any capacity.

4.    Responsibility

It is the responsibility of every employee of Prosegur in the context of their particular work and responsibilities to apply this policy when handling other people’s personal information.

5.    Availability

This policy will be placed on Prosegur’s website and copies will be available in all of its call centres and major office locations to be provided to people on request.
 

2.  What personal information do we collect? 

Prosegur will only collect personal information that is needed for it to operate its business activities effectively.  Such information includes:

a.    personal information relevant to an employee’s employment with Prosegur;
b.    information relating to customers (and their directors) who choose to conduct business with Prosegur
c.    information relating to contractors who provide services to, or on behalf of Prosegur.

The personal information we collect may include: name; mailing or street address; email address; telephone number; facsimile number; age; profession; occupation; employment history; educational history; medical information; security information from police and other governmental departments; tax file numbers; superannuation account information; bank account information; licences and/or qualifications held.
 

3.    How do we collect personal information?

When you visit our website or use our services we may collect personal information.  The ways in which we collect it is as follows:
a.    Information provided by you to us directly.  When you visit or use parts of our websites and/or services we may ask you to provide personal information to us.  For example, we ask for your contact information when you respond to a job application or an email offer, join us on social media, take part in training and events, contact us with questions or request support.  You do not have to provide us with your personal information but it might mean you cannot access some parts of our website or services.
b.    Information we collect automatically.  Some information is collected from you automatically when you visit our website or use our services, like your IP address and device type.  We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on.  Some of this information is collected using cookies and similar tracking technologies.  If you want to find out more about the types of cookies we use, why and how you can control them, take a look at our cookie notice.
c.    Information from third parties.  Whilst the majority of the information we collect is from you directly, sometimes we might collect personal information about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners or medical professionals and government agencies.  We use this information to supplement the personal information we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal information you provide.
 

4.    How do we store your personal information?

Personal information is stored via:

a.    Documents & paper copies (including secure archival storage)
b.    Personnel files (hard copy)
c.    Workers compensation files (hard copy)
d.    Electronic means (e.g. CRM; ADP; system drives)

All personal information is stored securely to protect it from being inadvertently or deliberately accessed. Where applicable (e.g. workers compensation) systems are audited to ensure our processes are working.
 

5.    How do we use your personal information?

Prosegur will only use personal information for the purpose(s) originally explained when the information was collected and for any related purpose that would reasonably be expected by both the individual concerned and Prosegur.  For example, Prosegur would also use the name and address of a customer who requested the cash servicing of an ATM for invoicing purposes and to advise the person concerned of new or changed products and services available from Prosegur.

If Prosegur uses personal information it holds for direct marketing of its products or services, it will always provide the individual the opportunity at the point of first contact and at any time afterwards at the individual’s request to decline receipt of any further marketing information.  Otherwise, Prosegur will not use your personal information without your consent, unless:

a.    required for health or other emergency reasons;
b.    to investigate suspected fraud or unlawful activity;
c.    it is required or authorised by law;
d.    it is required for law enforcement.
 

6. How do we share your personal information?

There will be times when we need to share your personal information with third parties.  We will only disclose your personal information to:

a.    Other companies in the Prosegur group of companies;
b.    Third party service providers and partners who assist and enable us to use the personal information;
c.    Regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights.  Where possible and appropriate, we will notify you of this type of disclosure.
d.    An actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business;
e.    Other people where we have your consent.
 

7. Data quality

Prosegur will take reasonable steps to ensure that the personal information it uses is accurate, complete and up-to-date.

8. Access and correction

A person on whom Prosegur holds personal information may apply in writing to the:

    Privacy Officer
    Prosegur Australia Pty Limited
    Level 2 – 112 Talavera Road
    Macquarie Park NSW 2113
    privacy.au@prosegur.com

To view the personal information held on them.

Prosegur will take reasonable steps to confirm the identity of the person making the request and will respond within 14 days of receiving the request.  However, where the request is more complex or time consuming to comply with, Prosegur will provide access to the information requested within 28 days.

Prosegur reserves the right to deny access to personal information if providing access:
a.    could pose a possible threat to life or health;
b.    could cause an unreasonable impact on the privacy of others;
c.    would be in response to a frivolous or vexatious request;
d.    relates to existing or anticipated legal proceedings which could be prejudiced as a result;
e.    relates to existing or anticipated commercial negotiations involving Prosegur, and Prosegur’s legitimate commercial interests could be prejudiced as a result;
f.    is in any way unlawful;
g.    could in any way prejudice law enforcement or security;
h.    could prejudice the prevention, detection or investigation of seriously improper;
i.    conduct, either within or external to Prosegur’s operations.

Should giving access to personal information involve revealing evaluative information generated within Prosegur in connection with a commercially sensitive decision making process, Prosegur reserves the right to give the individual an explanation for the decision made rather than direct access to the relevant information.

Where there is disagreement about direct access or where direct access to personal information is impractical or inappropriate, Prosegur will discuss the possible use of a mutually acceptable intermediary.

If an individual advises Prosegur that personal information held on them is inaccurate, incomplete or not up to date, Prosegur will take reasonable steps to update the information accordingly.  Should there be a disagreement between Prosegur and the individual about whether the personal information is complete or up-to-date and the individual requests, Prosegur will take reasonable steps to associate a statement from the individual that the information is not correct with the relevant record(s) held by Prosegur.

Prosegur reserves the right to levy a reasonable charge to meet the costs of providing access to personal information, although there will be no charge for the act of making the request for access.

Prosegur will always provide reason(s) should it deny access to or correction of personal information it holds.

9. Anonimity

Where lawful and practical, Prosegur will give individuals the option of not identifying themselves when dealing with the Company

10. Trans-border Data Flows

Prosegur may transfer information to, and process it in, countries other than Australia – such as Madrid and Germany where our data hosting providers’ servers are located.   These countries may have different laws to Australia, however, when we disclose personal information to a third party in another country, we put safeguards win place to ensure that your personal information remains protected.  

11.  Sensitive Information

Prosegur will not, without the consent of the individual, collect information concerning that individual’s racial or ethnic origins; political opinions; membership of a political, professional or trade association or trade union; philosophical or religious beliefs or affiliations; sexual preferences or practices or health information unless:

a.    It is required by law;
b.    It will prevent or lessen life or health threatening situations and it is not possible or practical to gain the individuals consent;
c.    The collection is necessary in relation to a legal or equitable claim.
d.    It is relevant to an employee’s workers compensation claim, rehabilitation or return to work programme.

Prosegur will also collect health information where it is necessary to assess a person’s fitness to perform the full and inherent requirements of their employment.  In so doing, Prosegur will take account of any relevant legal requirements and/or rules established by competent health or medical bodies that deal with obligations of professional confidentiality which bind the organisation.
 

12.   Breaches or suspected breaches of personal information

Prosegur recognises its responsibility under the legislation and in this regard has established a Data Breach Response plan. The plan exists in the unlikely event of a breach of privacy related information. This would include scenarios such as the accidental or deliberate leakage of sensitive material outside the company.

Any employee who suspects a breach of this policy has occurred, or who thinks that they may have accidentally leaked sensitive material outside the business, should immediately contact the:

    Privacy Officer
    Prosegur Australia Pty Limited
    Level 2 – 112 Talavera Road
    Macquarie Park NSW 2113
    privacy.au@prosegur.com

© 2019 Prosegur Cash, S.A. All rights reserved.