Guardian Mentor Pty Limited is a company that is committed to protecting the privacy of its customers and business partners.
Whilst our company strives to deliver more convenient, customised services that meet your present and futureneeds, Guardian Mentor also appreciates the uncertainty that comes with interacting in a constantly changing environment. We are sensitive to the concerns that our clients may have with regards to the confidentiality, security and use of their personal information via our web site and other channels of communication such as telephony, fax, e-mail and the normal postal service.
We therefore would like to reassure you of our position on this matter. Guardian Mentor encourages you to check our privacy statement regularly as this privacy statement may change from time to time. If you have any suggestions or concerns that are not addressed in this privacy statement, please contact us. Please take some time to read through this statement and understand our position on privacy.

oGuardian Mentor's Privacy Principles

Guardian Mentor operates in accordance with the following corporate privacy principles based on the guidelines as identified by the office of the Federal Privacy Commissioner
:
Principle 1: Collection of Information
Personal information will only be collected to the extent necessary by lawful and fair means, for one or more specified purposes that are relevant to Guardian Mentor's operations. When personal information is collected directly from the individual to whom it relates the purpose of collection will be identified and it will only be collected with the person's consent.

Principle 2: Use and Disclosure of Information
P2.1 Personal information will only be used for:
a) a purpose for which it was collected or for a directly related purpose;
b) improvement of customer service;
c) the derivation of anonymous or aggregated information;
d) the prevention or lessening of a threat to the life or health of the individual concerned or another person;
e) purposes permitted, required or authorised by or under law; f) the enforcement of the criminal law or of a law imposing a pecuniary penalty or for the protection of public revenue, where the use is reasonably necessary, or; g) any other purpose, where the person concerned has consented to its use for that purpose.

P2.2 Personal information will not be disclosed to a third party unless:
a) the person concerned has consented to the disclosure;
b) the third party is an agent or contractor of Guardian Mentor and is required to keep the information confidential and to use the information only for the purpose for which it was disclosed;
c) it is the usual practice of Guardian Mentor to pass information to a third party and the individual from whom the information was collected was notified of this practice at the time of collection;
d) there are reasonable grounds to believe that disclosure is necessary to prevent or lessen a threat to the life or health of the individual concerned or another person;
e) the disclosure is permitted, required or authorised by or under law, or;
f) the disclosure is reasonably necessary for the enforcement of the criminal law or a law imposing a pecuniary penalty, or for the protection of public revenue.

Principle 3: Data Quality
Prior to the use and disclosure of personal information, reasonable steps will be taken to ensure that personal information is relevant and to the extent necessary, accurate, complete and up to date for the purpose for which it is to be used. If Guardian Mentor holds personal information about an individual and the individual is able to establish that the information is not accurate, complete or up-to-date, Guardian Mentor will take reasonable steps to correct the information so that it is accurate, complete and up-to-date. If the individual and Guardian Mentor disagree about whether the information is accurate, complete and up-to-date, and the individual asks Guardian Mentor to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, Guardian Mentor will take reasonable steps to do so. Guardian Mentor will provide reasons for denial of access or correction.

Principle 4: Data Security
Safeguards will be maintained to protect personal information against unauthorised access, alteration, destruction, use or disclosure and against accidental loss.

Principle 5: Openness
Guardian Mentor will have clearly expressed policies on its management of personal information and these will continue to be readily available. Guardian Mentor will take reasonable steps to let individuals know, generally, what sort of personal information it holds, for what purposes, and how it collects, uses, and discloses that information.

Principle 6: Access and Correction
Where Guardian Mentor holds personal information about an individual, it will provide the individual with access to the information on request, in a form or manner suitable to the individual's reasonable needs, except to the extent where:
(a) providing access would pose a serious and imminent threat to the life or health of any individual; or
(b) providing access would have an unreasonable impact upon the privacy of other individuals; or
(c) the request for access is frivolous or vexatious; or
(d) the information relates to existing legal dispute resolution proceedings between Guardian Mentor and the individual, and the information would not be accessible by the process of discovery in those proceedings; or
(e) providing access would reveal the intentions of Guardian Mentor in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
(f) providing access would be unlawful; or
(g) denying access is specifically authorised by law; or
(h) providing access would be likely to prejudice an investigation of possible unlawful activity; or
(i) providing access would be likely to prejudice:
ooo(i) the prevention, detection, investigation, prosecution or punishment of
oooooo(a) criminal offences; or
oooooo(b) breaches of a law imposing a penalty or sanction
ooo(ii) the enforcement of laws relating to the confiscation of the proceeds of ooocrime;
ooo(iii) the protection of the public revenue;
ooo(iv) the prevention, detection, investigation or remedying of Seriously oooImproper Conduct; or
ooo(v) preparation for, or conduct of, proceedings before any court or tribunal, oooor implementation of its orders; by or on behalf of an enforcement agency; oooor
(j) ASIO, ASIS or an enforcement agency performing a lawful national security function asks Guardian Mentor not to provide access on the basis that providing access would be likely to cause damage to the national security of Australia. Where providing access would reveal evaluative information generated within Guardian Mentor in connection with a commercially sensitive decision-making process, Guardian Mentor may give the individual an explanation for the decision, rather than direct access to the information. If Guardian Mentor has given an individual such an explanation and the individual believes that direct access to the evaluative information is necessary to provide a reasonable explanation of the reasons for the decision, Guardian Mentor will, at the request of the individual, undertake a review of the decision. The review will be undertaken by personnel other than the original decision maker. Wherever direct access by the individual is impractical or inappropriate, Guardian Mentor and the individual should consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties. If Guardian Mentor levies charges for providing access to personal information, those charges:
(i) will not be excessive; and
(ii) will not apply to lodging a request for access.

Principle 7: Identifiers Guardian Mentor will not adopt as its own identifier an identifier that has been assigned by a government agency (or by an agent of, or contractor to, a government agency acting in its capacity as agent or contractor). Guardian Mentor will not use or disclose an identifier assigned to an individual by a government agency except where paragraphs (c) to (f) of Principle P2.2 apply.

Principle 8: Anonymity
Where ever it is lawful and practicable, individuals will have the option of not identifying themselves when dealing with Guardian Mentor.

Principle 9: Transborder data flows
Guardian Mentor will not transfer personal data outside Australia unless:
(a) Guardian Mentor reasonably believes that the recipient of the information is subject to a statute, binding scheme or contract which effectively upholds principles for fair information handling that are substantially similar to these rules; or
(b) the individual concerned consents to the transfer; or
(c) the transfer is necessary for the performance of a contract between the individual concerned and Guardian Mentor, or for the implementation of pre-contractual measures taken in respect to the individual's request; or
(d) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual concerned between Guardian Mentor and a third party; or
(e) the transfer is for the benefit of the individual concerned; and
ooo(i) it is not practicable to obtain the consent of the subject of the information to that transfer; and
ooo(ii) if it were practicable to obtain such consent, the subject of the information would give it; or
ooo(iii) if Guardian Mentor has taken reasonable steps to ensure that the information which it has transferred will not be collected, held, used or disclosed by the recipient of the information inconsistently with these rules.

Principle 10: Sensitive Information
Guardian Mentor will not collect personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation unless;
(a) the subject of the information has consented; or
(b) the collection is required or specifically authorised by law; or
(c) the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the subject of the information is physically or legally incapable of giving consent; or
(d) the collection is necessary for the establishment, exercise or defence of a legal claim.

o How is my personal information collected?

The types of personal information that we collect from you will depend on how you interact with Guardian Mentor's web site and directly with its consultants. Guardian Mentor from time to time acquires personal information pertinent to the nature of it's business and used solely for this purpose, from reputable third party list providers who subscribe to the same privacy principles as Guardian Mentor. In general, you may be asked to provide Guardian Mentor with personally identifiable information when you;
• Send us your comments or suggestions
• Report a technical problem
• Register with a site
• Update your listing details
• Request sales and advertising information
• Volunteer to test Guardian Mentor's products We value your trust in us and in all cases, your information will be held in the strictest confidence. One of the primary purpose's in gathering information on our clients is to gain a better understanding of your needs and wants, and develop new and innovative solutions.

o How secure is my information?

Guardian Mentor maintains a centralised database system and implements industry standards for the security and protection of information collected from its clients. This information is securely stored and access is restricted to authorised Guardian Mentor personnel only, ensuring that your personal information is protected and safeguarded at all times. The information you submit to Guardian Mentor is used only for the purpose stipulated at the time that the information is collected. Guardian Mentor is required by law not to reveal, disclose, sell, distribute, rent, licence, share or pass on to any third parties, any personal information that you may have provided to us unless we have your express consent to do so.

o How we use your information?

The information we gather from you enables us to provide better services that are tailored to your needs. We use the information gathered via our online form in any one of the following ways:
• To make changes to your profile at your request
• To register information at your request
• To respond to your submission or inquiry
We will only record your e-mail address if you send us a message. It will only be used for the purpose for which you have provided it, as outlined above. Your personal identifiable information will not be used for any other purpose, and we will not disclose it without your consent. The information and feedback you provide is used to identify ways of improving our services and identifying new products that best suit your needs. This information is not shared with any other third parties unless explicitly and expressly communicated when you submit the information. The information is contained and access is restricted to Guardian Mentor authorised personnel only.

o How can I access my personal information?

Should you at any time need to know what information Guardian Mentor has regarding you personally or your organisation, you may make direct telephonic inquiries through our main switch board or via e-mail enquiries, to the company's Information Officer, who will be pleased to address your request promptly and to your satisfaction.

o What if I have a complaint?

We welcome the opportunity of hearing any complaints that you may have about Guardian Mentor or the services it provides, as this is viewed as good feedback on how well we are servicing our clients. Please direct your complaints to the Managing Director either telephonically or via e-mail - complaints.

o What else should you know about privacy?

Here are some more pointers to assist you in further protecting you privacy on the Internet. Remember to close your browser when you have finished your user session. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe. You, as an individual, are responsible for the security of and access to your own computer. Please be aware that whenever you voluntarily disclose personal information over the Internet (for example: in discussion forums, via email or in chat sites) that this information can be collected and used by others. In short, if you post personal information in publicly accessible online form you may receive unsolicited messages from other parties in return. Ultimately, you are solely responsible for maintaining the secrecy of your username and passwords and/or any account information. Please be careful and responsible whenever you are using the Internet.