Privacy policy

Last updated February 2016

1. Overview

This Privacy Policy summarises the privacy practices supporting Stellar Asia Pacific (“Stellar”) in its commitment, to meet its obligations as an organisation under the Privacy Act 1988. It covers the Stellar Asia Pacific website which may be accessed through www.stellarbpo.com.au and briefly references where information is collected as part of conducting its business on behalf of its Clients.  This policy also outlines the type of personal information Stellar may collect, the purposes in which personal information is held, and how that information is handled including; used, held and disclosed by it.

Stellar may transfer your personal information [1] to its affiliated offices overseas including the Philippines, United States of America and Europe.  By providing your personal information in any forms within this website you acknowledge and consent to this transfer of your personal information.

Stellar’s site provides links to third party websites. The use of your information by these third party non-Stellar companies and their sites is not within our control and therefore we cannot accept responsibility for the conduct of these companies.

Stellar is committed to providing the highest level of service to its shareholders, employees, clients (and their customers). We understand the importance of protecting and maintaining the privacy, security and accuracy of personal information we collect and/or use in the course of conducting our business and related services.

In providing outsourced Services to its clients (public agencies and/or private organisations), Stellar’s compliance when handling personal information, with the Australian Privacy Principles and any other protections applicable under Australian Law include:

  • Ensuring our own compliance with these Privacy requirements and the handling of personal information provided directly to our organisation, for our own business and administration purposes;
  • Ensuring that we meet privacy requirements as provided by our clients (organisations or agencies as the case may be); and
  • Working in partnership with our clients and suppliers to ensure that we jointly agree and meet all Privacy related responsibilities.

 

2.   Management of Personal Information

Collection of Personal Information

Purpose for Collection of Personal Information

Stellar primarily collects personal information from consumers or potential clients when a product or service is used or requested, completion of a survey, or when consumers, employees, suppliers and/or clients communicate with Stellar by email, telephone, in writing or in person. Our organisation also collects information about you if you are providing goods or services to Stellar or, if you apply for employment with us through the staff recruitment and selection process.

We will only collect information about an individual for purposes which are relevant to Stellar’s business. For example, we may collect an individual's name, contact information and other employment history details relevant to our business relationship with that person. In some cases we may also be required by law to collect personal information, and this information may be required to respect an individual's request or in order to provide our services.

In some instances if all necessary personal information is not provided, Stellar may be unable to process a request or provide the services you require.

Types of Personal Information Collected

Personal information collected and held by Stellar may include details such as: your name; date of birth; physical and or postal address; contact details (in the form of telephone numbers, fax numbers and email addresses); employment and education history; bank account or credit card details; the organisation in which you work and ABN. We may also collect anonymous information regarding visitors to our website. This may include IP address, previous sites visited, internet provider location and date and time of the visit.

Use or Disclosure of Personal Information

How is personal information disclosed?

Whether for Stellar or on behalf of its clients in the course of providing the outsourced contact centre services, Stellar’s usual practice is to collect personal information directly from the individual or their authorised representative.  We may collect personal information from a third party or a publicly available source such as list purchases, but only if the individual has consented to such collection or would reasonably expect us to collect their personal information in this way, or if it is necessary for a specific purpose such as the investigation of a complaint or otherwise part of the conduct of its client contact centre related services.  

We only collect personal information for purposes which are directly related to our business functions or activities in the course of conducting the outsourced contact centre services, and only when it is necessary for or directly related to such purposes.  The personal information that Stellar collects maybe for employment services, human resource and other corporate service functions management. The information will be collected in a non-intrusive manner, by fair and lawful means and in accordance with relevant regulatory guidelines and industry codes.

Dependant on the purpose for the collection of personal information by Stellar, this may be disclosed to third parties as applicable to the nature of services our organisation provides which may include:

  • Stellar’s clients and their related bodies corporate where required for specific business purposes;
  • Stellar’s suppliers and business partners (such as consultants, technology infrastructure and support and maintenance service providers)
  • Stellar’s related bodies corporate (includes in Australia, the Philippines, United States of America (North America) and Europe); or
  • Government organisations as required by law (for instance taxation or audit purposes, OAIC and other regulatory bodies as required).  

For instances where this personal information is used, held in or disclosed to a location outside of Australia, Stellar will take all reasonable steps to ensure that this personal information is managed in line with the Australian Privacy laws and APPs as required.

For prospective Stellar employees,’ personal information collected may be transferred to our related body in the Philippines for the purposes of processing your application through the initial recruitment practice and stored on servers located in Australia and the Philippines. By submitting your personal information, you agree to this transfer, storing and processing.

For prospective Stellar clients or suppliers, personal information collected may be transferred to our related body corporate in the Philippines for the purposes of categorising or processing requests and stored on servers located in Australia, the Philippines, United States of America and Europe. By submitting your personal information, you agree to this transfer, storing and processing.

For conducting its outsourced contact centre services on behalf of its client, Stellar will work in partnership with its clients to take reasonable steps to recommend required disclosures are made to the individual from whom personal information is collected.

Dealing with personal information

Use of personal information

Stellar will only use or disclose personal information for the purpose it was collected (or secondary purposes as permitted by relevant privacy laws) and as agreed with our clients unless consent is received from the individual to release the information or as required by law. Stellar will only transfer personal information to a recipient in a foreign country in circumstances where the information is stated to have appropriate privacy protection in the hands of the recipient in line with the Australian privacy legislation and the individual consents to the transfer.

Stellar will not adopt as its own customer identifier or disclose an identifier that has been assigned by a Commonwealth government agency or a service provider of an agency.

Consideration of personal information privacy

Stellar will only ask for personal information where required to complete a business function.  Whenever it is lawful, practicable and (where business is conducted on behalf of our clients) within client service specifications, individuals will have the option of interacting anonymously when dealing with Stellar.

In some instances if all necessary personal information is not provided, Stellar may be unable to assist you, process a request or provide the services you require.

Stellar’s information collection activities are usually driven by specific client requirements and as such quality and retention periods will be client specific.

 

3.   Storage and Security of your personal information

Security

Stellar takes reasonable precautions to protect personal information held from misuse, loss, theft, as well as against unauthorised access, modification or disclosure, alteration and destruction.  

In addition to electronic data protection through password access, data back-up and firewalls) these measures include:

  • administrative processes;
  • technical safeguards; and
  • physical infrastructure and site security

Stellar has comprehensive security policies and procedures in place to ensure maximum protection of personal information held by both Stellar and our Clients.

As part of Stellar’s commitment to continuous improvement process and delivery of quality standards, regular audits will be undertaken to ensure that Stellar’s Privacy Policy and associated procedures comply with legislative requirements.

What do we do with personal information when it is no longer needed?

Stellar retains information where required in line with its retention policies, however where personal information is no longer required for the purposes for which it was collected, or if the law no longer requires us to retain it Stellar takes all reasonable steps to securely destroy or otherwise de-identify the personal information.

 

4.   Requesting Access to and Correction of and Individual’s Personal Information

Stellar takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date.  However, the accuracy of that information depends largely on the information you provide. That's why we recommend that you advise us if there are errors or changes required to your personal information such as your name or contact details.

You have at any time, the right to ask Stellar for personal information held about you and advise us of any inaccuracy or changes required to that information.  When requesting access to your personal information, this must be in writing with attention to Stellar’s Privacy Officer (contact details found below in the Contact Us section of this Privacy Policy).  

Upon request from an individual, you will be asked for minimum access requirements such as; to verify your identity, specify what information you require access to and in some instances the reason for your request in order to provide you the most relevant information (although you are under no obligation to provide a reason for your request).  You will be given a reasonable chance to correct your personal information that is not accurate, complete and up to date.  

For requests under a client’s services, this verification will be in accord with Stellar’s client(s) process and policies for access to an individual’s personal information.

Stellar intends to respond to requests for access to personal information a reasonable period after the request is made, but no later than thirty (30) calendar days from the date of receipt of written request.  Stellar may also charge a fee for any reasonable costs incurred by us in providing access to personal information.

In certain circumstances, Stellar or its clients may not be required by law to allow access to or correction of personal information and reasons will be provided in writing if this is the case.

Further information about access to personal information can be found within the Australian Privacy Principles (Chapter 12 – App 12 Access to personal information).

 

5.   Exclusions

Exemptions under the Act (and to this Privacy Policy) may apply in certain circumstances of Stellar’s handling of personal information that relates to:

  • current or former employee record or relationship with Stellar;
  • where the personal information is not held by Stellar;
  • where prescribed by law [2].

 

6.   Privacy Breach and Complaint Management

Training and privacy education

Upon commencement of employment, all Stellar employees complete an induction day. Induction includes a formal privacy notification, where all employees are advised of Stellar’s Privacy Policy.  Employees must sign a form to acknowledge they have read and understood this privacy notification.

Ongoing training and awareness will be conducted for all staff to further enhance understanding and ensure compliance.

Complaint handling process regarding breach of privacy

Stellar takes complaints about our handling of your personal information seriously.  If you believe there has been a potential breach of this Privacy Policy or privacy legislation in relation to your personal information, or your personal information has not been properly handled or protected, please contact Stellar’s Privacy Officer in the first instance, for the opportunity to resolve your complaint (contact details found below in the Contact Us section of this Privacy Policy).

Your complaint must be in writing and should outline the reason for your complaint.  Each complaint received by Stellar staff in relation to a breach of privacy is provided to Stellar’s Privacy Officer who will then notify you of the process for dealing with the breach (or potential breach). After investigation of your complaint, the Privacy Officer will negotiate with you, an appropriate resolution.

Stellar’s Privacy Officer(s) aim to respond to all enquiries of Stellar’s management of your personal information or answer questions regarding our privacy policy promptly and no later than within thirty (30) calendar days of receipt of your complaint.

If a resolution cannot be reached, or you are not satisfied with the resolution of your complaint, you have the right to contact the Office of the Australian Information Commissioner (OAIC) who may investigate your complaint.  For more information on how to contact the OAIC visit their website at http://www.oaic.gov.au/.  

 

7.   Updates to Stellar’s Privacy Policy

From time to time, Stellar may review and update its privacy policy. Revised versions will be updated on this website.  Stellar is committed to continuous improvement and therefore, if you have questions or wish to provide feedback in relation to this Privacy Policy Stellar encourages you to contact our Privacy Officer with your enquiries or suggestions.

 

8.   Contact Us

Stellar’s Privacy Officer can be contacted by:

________________________________________________

[1] ‘Personal information’ means information or an opinion, whether recorded in material form or not, which identifies an individual or from which an individual’s identity can be reasonably ascertained. This may include name, address and telephone number.

[2] These may include but are not limited to:

  • Privacy Act 1988 - Division 3, Section 7B;
  • Australian Privacy Principles: Chapter C: Permitted general situations;
  • Australian Privacy Principles: Chapter D: Permitted health situations;
  • Australian Privacy Principles: Chapter 5: Notification of the collection of personal information;
  • Australian Privacy Principles: Chapter 6: Use or disclosure of personal information.

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