Marvel group of companies- Compliance Statement
Each company in the Marvel group of companies (we, our, us) is committed to complying with the Privacy Act 1988 (Cth) (Act).
We have adopted and are implementing a Privacy Compliance Program covering the collection, use, disclosure and destruction of personal information (Compliance Program). We are committed to ensuring that all of the directors, employees and contractors undertake and follow the Compliance Program, which provides systems, procedures, information, education and template documentation.
We recognise that a breach of the Act can be a very serious matter, which can lead to severe consequences for us, our employees, our contractors and our customers. Accordingly, such breaches are unacceptable and will not be tolerated by us.
All of our directors, employees and contractors have a responsibility to ensure that they avoid breaching the Act by becoming familiar with the Act’s provisions.
All of our directors, employees and contractors must also comply at all times with the standards, procedures, documentation and checklists implemented by us from time to time.
Our Compliance Program is an educative and preventative mechanism for minimising the risk of us, our employees, and our contractors breaching the provisions of the Act.
The aim is for us to:
The Act is a Commonwealth statute that deals with the collection, use, storage, disclosure and destruction of “personal information” collected from or about individuals.
Different parts of the Act have different penalties and remedies. At present, the maximum fine that can apply to a breach of the Act is $2.5 million for individuals and the greater of $50 million, three times the value of any benefit obtained through the misuse of the personal information, or 30% of a company’s adjusted turnover in the relevant period, for companies.
In addition to monetary fines, the Privacy Commissioner (through the Office of the Australian Information Commissioner) and the Courts can also impose a range of remedies, including compensation and injunctions.
Management and employee responsibilities
Compliance with the Act is the responsibility of all our management, employees and contractors.It is essential to ensure that all our management, employees and contractors are familiar with and understand the provisions of the Act, do not breach those obligations, and follow our policies and procedures in relation to the collection, use and disclosure of personal information.
To avoid non-compliance with the Act, all our directors, employees and contractors must thoroughly read and act in accordance with the policies and procedures set by us from time to time.
Troy Pascarl, Office Manager has been appointed as the Privacy Officer for the Marvel group of companies.
The Privacy Officer is responsible for establishing, overseeing and our Compliance Program. The Privacy Officer is also responsible for collating and retaining the records relating to compliance with the Act.
Please immediately contact Troy Pascarl on 03 9112 9214 if you have or become aware of any issues or concerns regarding compliance with the Act.
Given the large fines and other adverse consequences of a breach of the Act, reporting incidents of breaches and potential breaches is strongly encouraged.
Reporting a breach or potential breach has a number of benefits for us, as well as for employees and contractors. They include:
Please report any concerns or breaches to the Privacy Officer. These breaches or potential breaches must be recorded in our Compliance Breach Register.
There will be no adverse consequences on you if you report someone else’s breach of the Act.
We take our obligations under the Act very seriously. Failure to comply with our policies and procedures will result in disciplinary action being taken against you.
These actions are in addition to any investigation or prosecution under the Act by the Privacy Commissioner or affected customers.
Compliance with the Act is a continuing obligation that is constantly under review. We are committed to continuing to allocate the staff and resources that are necessary for compliance.
The Privacy Officer will meet with the management of the Marvel group of companies at regular intervals to report on the effectiveness of the Compliance Program and to discuss ways (if necessary) that it can be improved.
For further information on our compliance procedures, or your obligations under the Act, please contact Troy Pascarl on 03 9112 9214.
Your comments and feedback are also welcome, to assist with further developing and refining our compliance procedures.
