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1.0 Privacy Commitment
Lincoln Place is committed to protecting its employees, prospective employees, investors and customers’ privacy and personal information irrespective of how that information has been provided. Lincoln Place is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other privacy laws which govern the way in which organisations hold, collect, use and disclose personal information.
In the event a breach does occur Lincoln Place will respond to reduce the risk of damage in accordance with the Office of the Australian Information Commissioner (“OAIC”) mandatory data breach reporting requirements.
This policy applies to all Lincoln Place employees, directors, board members, temporary workers and independent contractors (collectively referred to in this policy as employee/s). It covers all information collected and/or disseminated by Lincoln Place, including information obtained via electronic devices used to access our services.
This policy also applies to prospective employees who may provide Lincoln Place with personal information in relation to potential employment.
3.0 Business Overview
Lincoln Place is an Australian real estate fund manager specialising in the creation, development, management, and operation of lifestyle retirement communities. Lincoln Place specialises in creating affordable independent living communities for over 50’s seeking an active lifestyle.
4.0 What does Lincoln Place Collect?
Information collected by Lincoln Place is used for the purpose for which it was primarily collected. Information collected from customers is used for the purpose of managing customer relationships, while information collected from employees and individuals applying for employment is used to assist Lincoln Place to operate and manage its business.
The personal information that is collected, held and used may include (but is not limited to):
- Personal identification and contact details
- Previous employment history
- Financial information, including pension and payment details
- Tax file and Medicare numbers
- Bank account details
- Next of kin and power of attorney details
- Criminal History
- Additional privacy measures are employed to protect sensitive information (such as health information).
5.0 Purpose of Collection
Personal information is collected from investors to allow Lincoln Place to process applications and to administer and report on investments.
Collection of personal information from a tenant in a Lincoln Place community allows Lincoln Place to make decisions on suitability of tenants for the community, leasing arrangements, collect rent, communicate with tenants as well as complete other associated documents.
5.3 Employees & Prospective Employees
Lincoln Place collects information necessary to undertake its employment processes, comply with industrial legislation and taxation requirements, promptly pay salaries and wages, properly manage its business, and in the event of an accident or emergency contact a next of kin.
Lincoln Place maintains a personnel file for each employee to assist in the management of employees and the operation of its business. This file contains a copy of the employee’s employment application, employment contract, most recent performance appraisals and any formal counselling and disciplinary documents. Other records associated with the administration of payroll and other employment matters may also be included in the file.
Prospective employee information is used by Lincoln Place to consider the application for employment and manage the recruitment process. If a candidate is unsuccessful in obtaining a position with Lincoln Place, Lincoln Place will retain their application and personal information including background and reference checks to contact the candidate if a position becomes available in the future.
Lincoln Place may use personal details to manage its business operations (including insurances and legal obligations), help run the organisation, to market other products that it may offer or to provide updates on developments within the business. If an individual would rather not have their personal information used for this purpose, they should let Lincoln Place know via the contact details located below.
6.0 How is Information Collected?
Personal information may be collected via face-to-face interviews, application forms and correspondence (written and verbal).
In most cases, and where possible, personal information is collected directly from the source. If this is not practical, the information may be obtained from another person or entity.
Lincoln Place will only collect personal information which is reasonably necessary to appropriately facilitate the provision of its services and appropriately operate and manage its business.
8.0 Use and Disclosure of Personal Information
Personal information is not disclosed to any other person except in the following circumstances:
- In the course of general business practice Lincoln Place may outsource functions, for example unit registry and custodial services, provided to residents as these third parties need to have access to personal information.
- During the recruitment process to contact referees and undertake background checks as well as any third-party service providers as may be necessary to progress an application.
- To anyone involved in providing services to employees of Lincoln Place including superannuation companies, relevant workers compensation organisations and government agencies including the Australian Tax Office and Department of Human Services.
- To anyone authorised by the individual to receive their personal information (consent may be express or implied).
- To organisations with whom Lincoln Place has contracted to assist in providing services, such as professional advisers.
- To anyone Lincoln Place is required or permitted by law to disclose personal information to.
- To police and law enforcement agencies where Lincoln Place requires a criminal history check.
Any exemptions to the clauses outlined in this policy will be considered on an individual basis. They are to be documented and discussed with the Office Administrator for consideration. The Office Administrator will provide permission in writing for any such exemption.
At all times Lincoln Place will take reasonable steps to ensure that the personal information collected and held is protected from misuse, loss, unauthorised access and disclosure. Much of this information is stored electronically in a secure environment. Any information that needs to be kept in hard copy is also protected via a range of measures including but not limited to:
Access to information systems is controlled via access management procedures
Company policies and procedures regarding keeping information secure which all employees are bound by
Lincoln Place regularly reviews and monitors compliance with policies and best practice
There are however inherent risks in transmitting information across the internet and Lincoln Place does not have the ability to control security of information collected and stored on third party platforms. In relation to its servers, Lincoln Place takes all reasonable steps to manage data stored to ensure data security.
11.0 Access and Correction
Individuals have the right to seek access to and/or correct the personal information Lincoln Place holds about them if they believe it to be inaccurate or out of date.
Customers of Lincoln Place can arrange this by contacting Lincoln Place’s Office Administrator (contact details listed below). The request should include a detailed description of the information required. To ensure information is only disclosed to relevant people the customer may be asked to provide identification or in the case of a telephone call asked to verify their identity via security questions.
Employees can update their personal information by completing the employee details form located in the payroll folder on the intranet and forward the completed form to firstname.lastname@example.org for any changes to personal details such as bank accounts, email addresses and pay variations. Employees with payroll self service can update address, email and contact details themselves.
Personal information records are held for a period considered appropriate by Lincoln Place. Should a person cease to be a customer/investor/resident/employee of Lincoln Place, any personal information which we hold about them will be held for the relevant retention periods required by law.
13.0 Enquiries and Complaints
Customers who have a question or wish to raise a concern about the treatment of their personal information should contact Lincoln Place as set out below.
Level 5, 50 Clarence Street
Sydney NSW 2000
Telephone: 1300 844 492
Lincoln Place will consider the question or complaint and acknowledge receipt within 48 hours and provide a response within 30 days. If a person feels that the issue remains unresolved or wants further investigation to take place they should contact:
Investors need to contact Link Market Services if they would like to understand how the registry handles their information: email@example.com
14.0 Policy Review and Refresher
Lincoln Place will review this policy from time to time and may change the contents in line with business needs and relevant legislation. If changes are made to this policy, the updated version will be available on the intranet. It is then up to each employee to ensure they read and understand them. If an employee is unclear on any details in this document, they should speak with their Manager, IT or HR. Employees should aim to have a read of this policy every couple of months to refresh their memory.