PRIVACY POLICY
This document declares the undertakings by PADS - Personal Assistance Dog Solutions
(PADS) in relation to its handling of Your Data.
PADS undertakes to collect Your Data by means that are:
-
fair;
-
legal; and
-
transparent
If you disclose personal data to PADS in conjunction with an identifier such as your name,
PADS will collect Your Data.
PADS undertakes to collect Your Data from you and not from other parties.
Where PADS collects Your Data from sources other than you, it undertakes:
-
to do so only by legal means;
-
to do so only with your Consent; and
-
to declare to you what sources it uses, and under what circumstances.
PADS undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as "to support our
operations".
Data Security
PADS undertakes to store Your Data in a manner that ensures security against unauthorised
access, alteration or deletion, at a level commensurate with its sensitivity.
PADS undertakes to transmit Your Data in a manner that ensures security against
unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Data Use
Use refers to the application of Your Data by any part of PADS, or any staff-member or
contractor of PADS in the course of their work.
PADS undertakes to use Your Data only for:
-
the purposes for which it was collected;
-
such other purposes as are subsequently agreed between PADS and You;
-
such additional purposes as may be required by law. In these circumstances, PADS will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
-
such additional purposes as are authorised by law (in particular to protect PADS's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to PADS or have committed a breach of the criminal law)
PADS undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.
PADS undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date,
incomplete, or out-of-context.
Data Disclosure
Disclosure refers to making Your Data available to any party other than PADS and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
PADS undertakes to disclose Your Data only under the following circumstances:
-
in the course of business being conducted between You and PADS, where disclosure is necessary to a contractor, such as a local training provider. Where Your Data is disclosed in this way, PADS undertakes to exercise control over PADS' contractors to ensure that their actions are compliant with these Terms;
-
in other circumstances that are directly implied by the purpose agreed between You and PADS at the time of data collection or subsequently. Where Your Data is disclosed in this way, PADS undertakes to exercise control over PADS' contractors to ensure that their actions are compliant with these Terms;
-
with your consent, or at your request;
-
where required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena. In these circumstances, PADS will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
-
where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where PADS believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life of health of some person), provided that PADS will apply due diligence to ensure that the exercise of the permission is justifiable
In all cases, PADS undertakes to disclose only such of Your Data as is necessary in the
particular circumstances.
Data Retention and Destruction
PADS undertakes:
-
to retain Your Data only as long as is consistent with its purpose; and
-
to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.
-
Your Data may be retained beyond the expiry of its purpose if that is required by law. PADS will only retain Your Data while that situation is current, and will then destroy Your Data.
Access by You to Your Personal Data
PADS undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, PADS undertakes to enable access:
-
conveniently;
-
without unreasonable delay; and
-
without cost.
In the event that you dispute some aspect of Your Data, PADS undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You undertake:
-
not to seek access for frivolous purposes, or unreasonably frequently;
-
to accept that deletion of some data may not be consistent with the provision of particular services by PADS to you.
Access by You to Your Personal Data
PADS undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, PADS undertakes to enable access:
-
conveniently;
-
without unreasonable delay; and
-
without cost.
In the event that you dispute some aspect of Your Data, PADS undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You undertake:
-
not to seek access for frivolous purposes, or unreasonably frequently;
-
to accept that deletion of some data may not be consistent with the provision of particular services by PADS to you.
Information about Data-Handling Practices
PADS undertakes to make information available to you about the manner in which PADS handles your data:
-
in general terms, in a readily accessible manner; and
-
in more specific terms, on request.
Where Your Data is disclosed to a contractor, PADS undertakes to make information available to you on request about the manner in which PADS' contractors handle your data.
PADS undertakes to ensure that the information provided is meaningful, and addresses your concerns.
Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about PADS' behavior in relation to these Terms, you undertake:
-
to communicate them in the first instance:
-
to PADS only;
-
in sufficient detail;
-
through a channel made available by PADS for that purpose;
-
PADS undertakes:
-
to promptly provide acknowledgement of the receipt of communications and enact it's Complaint Handling Policy.
You further undertake to not pursue PADS through any Regulator or the media:
-
until and unless PADS has had a reasonable opportunity to respond to the initial communication; and
-
while PADS and you remain are conducting a meaningful dialogue about the matter.
Enforcement
PADS declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
Changes to These Privacy Undertakings
PADS undertakes:
-
not to materially change these Terms in a manner that reduces the protections for Your Data;
-
where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organisations;
-
where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
-
to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.
PADS-Personal Assistance Dog Solutions – reviewed July 1st 2022