Privacy and Confidentiality Policy

Nathalia Coachlines is committed to maintaining the privacy of our customers and staff. Being one of Australia’s leading transport operators and offering unique transport management programs, Nathalia Coachlines is required through its daily operations to collect and maintain employee and customer information.

Nathalia Coachlines follow the Privacy Act 1988 as well as other laws and codes governing our industry.

We ensure that our staff are trained in our policies and procedures around privacy and are only able to access confidential information relating to the specific tasks or roles required within the business.

Privacy

The National Privacy Principles (NPPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act) govern

the way in which your Personal Information is collected, used, disclosed, stored, secured and disposed. Nathalia Coachlines will only collect and retain the information of our customers that is necessary to maintain a high-quality service and meet our customer contract requirements.

Examples of Personal Information collected include: names, addresses, email addresses, phone numbers and date of birth. This Personal Information is obtained in many ways including interviews, correspondence, by telephone, by email, via our Transport Management System, our subcontractors, from publicly available sources and from third parties.

Personal Information is collected for the primary purpose of providing our services and for

recruitment requirements. Nathalia Coachlines may use Personal Information for secondary purposes closely

related to the primary purpose, in circumstances where such use or disclosure would be reasonably

expected.

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by Nathalia Coachlines only:

For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law

Nathalia Coachlines may collect ‘sensitive information’ in limited circumstances relating to employment such as health information, employment records, educational qualifications and criminal records for the purposes of medical or background screening for employment application purposes. By providing this information to us, unless you indicate otherwise, Nathalia Coachlines will assume that you have given your consent to the collection of such sensitive information.

Third Parties

Where reasonable and practicable to do so, Nathalia Coachlines will collect your Personal Information only from

you. However, in some circumstances Nathalia Coachlines may be provided with information by third parties. In such a case Nathalia Coachlines will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

Third parties where you consent to the use or disclosure
For accreditation purposes, including background checks; and
Where required or authorised by law

Security of Personal Information

Personal Information is stored in a manner that reasonably protects it from misuse and loss and from

unauthorised access, modification or disclosure.

All information regarding customers or employees of Nathalia Coachlines is held in secure databases and programs or in locked storage facilities.

Records of personal information are kept as per the records management policy for the retention period required by law or standards and regulations.

Confidentiality

Employees are at all times required to keep confidential all commercially sensitive or personal information that they are privy to. Personal information and discussion about personal information is only communicated in strict accordance with the role of the person in possession of the information (i.e. Managing Director) or with the consent of the person(s) involved.

The requirement to maintain confidentiality must be maintained after employment with Nathalia Coachlines ends.

Intellectual Property

All work, creativity, innovations, concepts, symbols, procedures instructions, information, data and records remain the property of the respective Operating Company. No reproduction or sharing of this knowledge outside of the Group is permitted without written consent of the relevant General Manager or the Chief Executive.

Storage

When Personal Information is no longer needed for the purpose for which it was obtained, Nathalia Coachlines will take reasonable steps to destroy or permanently de-identify Personal Information. However, most of the Personal Information is or will be stored in files which will be retained for a minimum of 7 years.

Access to your Personal Information

If staff would like to access, review, correct or update personal information, they may contact the Managing Director. Requests are to include the staff member’s email address, name and telephone number and specify clearly what information is to be accessed, reviewed, corrected or updated.

On request, Nathalia Coachlines will provide the staff member with access to the information its holds

within a reasonable time frame, unless providing access is exempt under the Australian Privacy

Principles. Nathalia Coachlines will provide written reasons, including the relevant exemption under the

Australian Privacy Principles, if any request is refused.

Maintaining the Quality of your Personal Information

It is important that Personal Information is up to date. Nathalia Coachlines will take reasonable steps to make

sure that Personal Information is accurate, complete and up-to-date. If it is found that the information Nathalia Coachlines has is not up to date or is inaccurate, staff are to advise Nathalia Coachlines to update a staff member’s records to ensure it continues to provide quality services.

If any queries or complaints are raised about the Privacy Policy, these will be addressed by the Managing Director.