Introduction
Adams Australia (being Adams Australia Pty Ltd ABN 67096457377), and its representatives, offer supply chain and product solutions, as arranged with our clients, in Australia and overseas.
In the course of our business in Australia, we collect confidential information. This privacy policy has been developed to ensure that such information is handled appropriately.
We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way that information must be treated.
Who does the privacy policy apply to?
This policy applies to any client or business partner in relation to whom we currently hold, or may in the future collect, information.
What information does the privacy policy apply to?
This policy applies to confidential information. In broad terms, 'confidential information' is information or opinions relating to a particular business that can be identified and considered confidential.
Information is not confidential where the information cannot be linked to an identifiable client.
How do we manage the confidential information we collect?
We manage the confidential information we collect in numerous ways, such as by:
- implementing procedures for identifying and managing privacy risks;,
- implementing security systems for protecting information from misuse, interference and loss from unauthorised access, modification or disclosure;
- providing staff with training on privacy issues;
- appropriately supervising staff who regularly handle confidential information;
- implementing mechanisms to ensure any agents, contractors or service providers who deal with us comply with the APPs;
- implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints; and
- appointing a privacy officer within the business to monitor privacy compliance.
Subject to our professional obligations, we will take reasonable steps to destroy or de-identify confidential information if that information is no longer needed for the purposes for which we are authorised to use it.
What kinds of information do we collect and hold?
Personal information
The personal information we may collect and hold about you differs, depending on whether you are a customer, service provider, contractor, agent or a prospective employee or prospective service provider or contractor, but may include:
- sensitive information (see below);
- contact information;
- financial information;
- date and place of birth;
- employment arrangements and history;
- insurance information;
- banking details; and
- any other personal information required to perform the services for you or engage you.
Sensitive Information
‘Sensitive information’ includes information that may have serious ramifications for the individual or business concerned if used inappropriately.
We may collect sensitive information if it is relevant in providing services or engaging you, which may include any of the following (this list is not exhaustive):
- production records;
- contracts with suppliers and customers;
- contact details for suppliers and customers;
- records of incidents and non-compliances;
- audit reports;
- laboratory test results;
- We will not collect sensitive information without the client’s consent to which the information relates unless permitted under the Privacy Act.
How and when do we collect confidential information?
Our usual approach to collecting confidential information is to collect it directly from the individual or business concerned directly.
How do we hold personal information?
Our usual approach to holding confidential information includes holding that information:
- physically, at our premises; and
- electronically:
- on secure online servers;
- on a private cloud;
- by a third-party data storage provider; and
- on our website.
We secure the confidential information we hold in numerous ways, including:
- using security systems to limit access;
- using secure servers to store personal information;
- using unique usernames, passwords and other protections on systems that can access personal information; and
- holding certain sensitive documents securely.
Why do we collect, hold, use or disclose confidential information?
We take reasonable steps to use and disclose confidential information for the primary purpose for which we collect it. The primary purpose for which information is collected varies, depending on the particular service being provided or the individual or client from whom we are collecting the information but is generally as follows:
- in the case of customers – to provide services to you or your business;
- in the case of contractors, service providers, and agents – to assist us in providing our services to our customers;
- in the case of potential employees and potential service providers and contractors – to assess your suitability for employment or engagement.
- Personal information may also be used or disclosed by us for secondary purposes that are within an individual’s reasonable expectations and that are related to the primary purpose of collection.
- We may also collect and use customers’ personal information:
- to keep records of transactions to assist in future enquiries and enhance our customer relationship with you;
- to verify your identity;
- to send you special offers in relation to our services;
- to provide you with updates and alerts that are relevant to you or your business;
- to refer you to other advisers; and
- to invite you to events.
We may collect and use contractors’, service providers’ and agents’ confidential information:
- to conduct checks to ensure that the contractor, service provider or agent and prospective employee, contractor and service provider can perform or is performing the services to our standards; and
- for payment purposes.
We may disclose confidential information to:
- contractors, service providers and agents including third party technology providers we engage from time to time, such as our data storage providers and email filter providers;
- employers of individuals;
- our external auditors;
- your advisers or other referral partners in order to provide services to you, or to assist our functions or activities
- our related entities; and
- insurance providers and brokers.
Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
Will we disclose confidential information outside Australia?
No, unless by prior agreement with you.
How do we handle data breaches?
A data breach occurs when confidential information is lost or subjected to unauthorised access, use, modification or disclosure or other misuse or interference.
We have implemented a data breach response plan to assist us to effectively contain, evaluate and respond to data breaches in order to mitigate potential harm to any persons or clients affected by a data breach.
In summary, our data breach response plan:
- directs our staff as to the steps they should take in the event of an actual or suspected data breach;
- appoints a team to handle data breaches;
- specifies a strategy for assessing and responding to data breaches;
- sets out the process for notifying any affected persons, the Privacy Commissioner and other relevant parties; and
- outlines the review process to help prevent data breaches in the future.
We will generally notify you if we reasonably believe that your confidential information has been subjected to a data breach if:
- there is a risk of serious harm to you or your business;
- notification could enable you to avoid or mitigate serious harm;
- the compromised confidential information is sensitive or likely to cause humiliation or embarrassment to you; or
- we are required to notify you by law.
We will also notify the Privacy Commissioner if we reasonably believe that your personal information has been subjected to a data breach that is likely to result in serious harm to you.
Where appropriate, we may also notify other third parties of a data breach.
How do you make complaints or access and correct your confidential information?
It is important that the information we hold about you is up-to-date. You should contact us if your information changes.
Access to information and correcting confidential information
You may request access to the confidential information held by us or ask us for your information to be corrected by using the contact details in this section.
We will grant you access to your information as soon as possible, subject to the request circumstances.
In keeping with our commitment to protect the privacy of this information, we may not disclose confidential information to you without proof of identity.
We may deny access to confidential information if:
- the request is unreasonable;
- providing access would have an unreasonable impact on the privacy of another person;
- providing access would pose a serious and imminent threat to the life or health of any person; or
- providing access would compromise our professional obligations; or
- there are other legal grounds to deny the request.
We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed before it is levied.
If the confidential information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
Complaints
If you want to complain about an interference with your privacy, you must follow the following process:
The complaint must first be made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
If the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to Contact
A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:
Sally-Anne Cody
Adams Australia Pty Ltd
136 Fitzmaurice St, Wagga Wagga, NSW 2350
scody@adamsaustralia.com.au
Changes to the Policy
We may update, modify or remove this policy at any time without prior notice. Any changes to the privacy policy will be published on our website.
This policy is effective from 18th November, 2025. If you have any comments on the policy, please contact your Adams Australia team representative.