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Privacy

Greenbank Group Privacy Policy 2017

1. INTRODUCTION

This policy describes the Greenbank group of companies policy of how we deal with Personal Information collected from our clients/Individuals and other stakeholders in an open and transparent manner.
This policy is in accordance with the Privacy Act 1988 and the Australian Privacy Principles (APPs) introduced in March 2014.
Greenbank is an “organization” covered by the Privacy Act and the APPs as detailed in section 6C of the Privacy Act.
2. KEY CONCEPTS & KEY DEFINITIONS
The Greenbank group of companies includes: GB Environmental Pty Ltd, Greenbank Environmental Pty Ltd; Greenbank Carbon Pty Ltd; Energy Bridge Group Pty Ltd and Renewable Energy Services Pty Ltd.
The Privacy Act and the new APPs basic objectives are to protect the privacy of Individuals balanced against the interests of entities carrying out their business.
“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not, as defined in section 6 of the Privacy Act.
“Individual” means a natural person as defined in section 6 of the Privacy Act.
“Permitted general situation” refers to specific exemptions from the Privacy Act and the APPs where an “organization” may specifically release Personal Information about an Individual where there is a serious threat to life, health or safety, suspected unlawful activity or misconduct and such information is required to take appropriate action, or to local a missing person, or is reasonably necessary to establish, exercise or defend a legal/equitable claim (or as further detailed in section 16A of the Privacy Act).
“Sensitive information” covers information or an opinion about an Individual’s: race, ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs amongst other things detailed in section 6 of the Privacy Act. It also covers health information, genetic information, and biometric information/templates.
3. OPEN & TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
Greenbank has implemented practices, procedures and systems in respect of our functions and activities to ensure that we comply with the APPs to enable us to deal with inquiries or complaints from Individuals about our compliance with the APPs.
At Greenbank, we are required by various Federal and State pieces of legislation to collect certain Personal Information from Individuals as part of our compliance obligations in creating and trading various types of environmental certificates across Australia.
As most of our business is conducted within Australia, we are unlikely to disclose Personal Information to an overseas entity unless legally obliged to make such disclosure.
The types of Personal Information we currently collect includes the following types of information from a system owner and/or installer of equipment:
a) Name; b) Address (including proof of address evidenced by electricity bills/rates notice etc.); c) Contact Details (email/phone numbers); price paid; and d) Bank account details.
Where we hold Personal Information about an Individual, we will, on request by that Individual, give the Individual access to their Personal Information held by us unless otherwise required in accordance with Part 5 of the APPs. In accordance with Part 5 of the APPs, we retain the right to charge for access to Personal Information to take into account our reasonable charges and time incurred in assessing the request (e.g. ASIC Searches; Privacy Advice etc.). If we refuse to grant you access to Personal Information belonging to you, we will provide you with a written response detailing the reasons behind such refusal, the mechanisms available for you to lodge a complaint about the refusal; and any other matter prescribed by the regulations.
You may make a request for us to correct any Personal Information held by us in respect to you as an Individual and we will make such corrections as are reasonable. If such information has previously been disclosed to another party, you may request us to inform that other party of any changes to your Personal Information and we will do so if reasonable in the circumstances unless it is impracticable or unlawful. If we refuse to rectify such information, we will provide you with a written response detailing the reasons for such refusal except where it would be unreasonable to do so, the mechanisms available to complain about the refusal; and another other matter prescribed by the regulations.
We will not collect Sensitive Information about you without your consent. However, we currently do not collect such information and have not plans to do so in the future.
All our documentation contains privacy statements noting that the parties providing Personal Information consent to that information being collected by us for the purposes of creating and trading environmental certificates.
Greenbank collects such information when clients’ and/or Individuals submit their application forms instructing us to create environmental certificates across the various markets in Australia. These instructions are received by us via email, facsimile, post and electronically via our proprietary “Formtrack” software application and/or “Phone App”.
Greenbank stores all relevant attachments received by email (not Formtrack) in physical hard copy and store all other relevant documentation electronically.
We will not disclose a client’s Personal Information unless: the client and/or Individual has consented to such disclosure; or it is necessary for the performance of our business functions (i.e. information required by: the various regulators; and/or industry bodies to enable us to create environmental certificates; and/or by the installer or wholesaler of the Individual’s system to confirm installation, sale and payment details in accordance with the parties contractual arrangements) or as required by the law, the Privacy Act and/or the APPs. 
Our general practice is to seek our in-house counsel to provide us with legal advice on the legal requirements to disclose any Personal Information of an Individual/client when such a request is received by us. Historically such requests have been received from Government bodies, regulators and/or trade associations. We make and file written notes validating any disclosures we make following a review of the Privacy Act, the APPs and this Privacy Policy by our in-house legal counsel.
Due to the nature of the Personal Information that we are required to collect from you by the various government regulators (e.g. the Clean Energy Regulator, the IPART, and the ESC etc.) the use of pseudonyms is not appropriate for communications with us.
We include our client’s email details (as received from our clients) on our database and provide pricing updates on a weekly basis to this distribution list as well as other types of email communications that are deemed of interest to our client base. As a matter of policy, we include opt-out notification in such emails so that our clients can decide not to receive these pricing and market email communications.
If you wish to make a compliant to us in respect of the privacy of your “personal information” please contact Ria Redmond our General Manager on 1300 473 362 or ria@green-bank.com.au. Greenbank will review your privacy compliant within 5 business days of receipt of written notification and provide.
We will conduct an annual internal audit to assess our privacy obligations.

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