Privacy policy

1. Introduction

Online 89 Pty Ltd is committed to fulfilling its obligations under the Privacy Act 1998 (Cth), as amended ("Privacy Act") and the Australian Privacy Principles ("APPs").
This policy sets out the standards, rights and obligations of parties in relation to the handling and maintenance of Personal Information by Online 89 Pty Ltd, including the collection, storage, use, disclosure, quality and security of Personal Information and access and correction rights of individuals in relation to their Personal Information.
Online 89 Pty Ltd will take such steps as are reasonable in the circumstances to implement practices, procedures and systems relating to Online 89 Pty Ltd's functions and activities to comply with the APPs.
A person who collects Personal Information on behalf of Online 89 Pty Ltd must comply with this policy and the requirements of the Privacy Act.

2. Scope

This policy applies to the collection, storage, use and disclosure by Online 89 Pty Ltd (or a person acting on behalf of Online 89 Pty Ltd) of records containing individuals' Personal Information.
This policy does not apply to the collection, storage, use and disclosure of Personal Information where:
  • the Personal Information is an Employee Record; and
  • the collection, storage, use and/or disclosure of the Employee Record relates to Online 89 Pty Ltd's employment relationship with the employee.

3. Definitions

Employee Record means a record of Personal Information relating to the employment of an employee of Online 89 Pty Ltd.
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.
Sensitive Information has the meaning set out in the Privacy Act and includes:
  • Personal Information about an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record; and
  • health information about an individual.

4. Collection of Personal Information

The kinds of Personal Information typically collected by Online 89 Pty Ltd include names, job titles and contact details of individuals and, in the case of applicants for employment, qualifications, work experience, competencies and inherently relevant health information.

Online 89 Pty Ltd may collect Personal Information from a variety of sources, including from individuals, advertisers, mailing lists, recruitment agencies, contractors and business partners. Online 89 Pty Ltd may collect Personal Information when an individual requests or acquires a product or service from Online 89 Pty Ltd, provides a product or service to Online 89 Pty Ltd, completes a survey or questionnaire, or when they communicate with Online 89 Pty Ltd by e-mail, telephone or in writing (for example if they contact customer service to make a complaint or provide feedback).

Online 89 Pty Ltd will hold Personal Information in documentary and/or electronic form under generally accepted standards of technological and operational security.
Online 89 Pty Ltd will:
  • Only collect Personal Information if the information is reasonably necessary for one or more of the functions or activities of Online 89 Pty Ltd. Typically, this will include for the purposes of:
    • Screening and assessing applicants for employment;
    • making contact with individuals and organisations Online 89 Pty Ltd deals with or wants to deal with;
    • marketing, promoting and providing products and services to customers;
    • selecting and doing business with suppliers and other industry participants; and
    • appointing and doing business with contractors.
  • If the Personal Information is Sensitive Information, only collect such information if the individual consents to the collection of the information or if the following applies:
    • The collection of the information is required by or authorised by or under an Australian law or a court/tribunal order; or
    • A permitted general situation (as defined in s16A of the Privacy Act) or permitted health situation (as defined in s16B of the Privacy Act) exists in relation to the collection of the information.
  • Only collect Personal Information by reasonable and fair means, without intimidation or deceptions or unreasonable intrusion.
  • Collect Personal Information about an individual only from the individual unless it is unreasonable or impracticable to do so.
  • If unsolicited Personal Information is received, determine within a reasonable time if Online 89 Pty Ltd could have collected the information as set out in (a) to (d) above and, if not and if the information is not otherwise contained in a record owned or deemed by regulation to be owned by the Commonwealth, Online 89 Pty Ltd will as soon as practicable either:
    • Destroy the information if it is lawful and reasonable to do so; or
    • Ensure that the information is de-identified.
  • At or before the time or, if that is not practicable, as soon as practicable after receiving Personal Information about an individual, take steps that are reasonable in the circumstances (if any) to notify the individual or ensure the individual is aware of:
    • The identity and contact details of Online 89 Pty Ltd;
    • If the Personal Information has been collected from someone other than the individual or if the individual is unaware that the Personal Information has been collected, the fact that Online 89 Pty Ltd has collected or so collects the information and the circumstances of that collection;
    • If the collection of the Personal Information is required or authorised by or under and Australian law, or a court/tribunal order, the details of such authority;
    • The purpose for which Online 89 Pty Ltd collects the information;
    • The main consequences (if any) for the individual if all or some of the Personal Information is not collected;
    • The type/s of any other person, entity or body to which Online 89 Pty Ltd usually discloses Personal Information of the kind collected;
    • How the individual may access and seek correction of Personal Information or lodge a complaint about Online 89 Pty Ltd's breach of the APPs and how Online 89 Pty Ltd will respond; and
    • Whether Online 89 Pty Ltd is likely to disclose the Personal Information to overseas recipients and, if so and if practicable, the countries in which such recipients are likely to be located.

5. Use and disclosure of Personal Information

  • Other than for Personal Information for the purpose of direct marketing or for government related identifiers (both of which are specifically discussed below), Online 89 Pty Ltd will not use or disclose Personal Information about an individual for a purpose (the secondary purpose) other than the primary purpose of collection unless:
    • the individual has consented to the use or disclosure; or
    • both of the following apply:
      • the secondary purpose is related to the primary purpose of collection and, if the Personal Information is Sensitive Information, directly related to the primary purpose of collection; and
      • the individual would reasonably expect Online 89 Pty Ltd to use or disclose the information for the secondary purpose; or
    • the use or disclosure is required or authorised by or under an Australian law or a court/tribunal order; or
    • a permitted general situation (as defined in s16A of the Privacy Act) or a permitted health situation (as defined in s16B of the Privacy Act) exists; or
    • Online 89 Pty Ltd reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body (in which case, Online 89 Pty Ltd will make a written note of the use or disclosure); or
    • the use or disclosure is not inconsistent with the requirements of the Privacy Act.
Overseas recipient
  • If and when Online 89 Pty Ltd ever discloses Personal Information of an individual to a third party that is overseas, without the individual's knowledge and consent, Online 89 Pty Ltd will take such steps that are reasonable in the circumstances and required by the Act to ensure that the overseas recipient does not breach the relevant APPs or this policy.
Government related identifier
  • A government related identifier is an identifier of an individual that is assigned by a Federal, State or Territory government agency, authority or contracted service provider (pursuant to the contract).
  • Online 89 Pty Ltd will only adopt a government related identifier to identify an individual if that adoption is required or authorised by or under an Australian law or allowed under regulations. Online 89 Pty Ltd will not disclose a government related identifier unless:
  • it is reasonably necessary to verify the identity of an individual for Online 89 Pty Ltd's activities or functions; or
  • it is reasonably necessary to fulfil Online 89 Pty Ltd's obligations to an agency or State or Territory authority; or
  • it is required or authorised by or under an Australian law or a court/tribunal order; or
  • relevant permitted general situations exist in accordance with the Privacy Act; or
  • Online 89 Pty Ltd reasonably believes it is reasonably necessary for enforcement related activities by, or on behalf of, an enforcement body; or
  • it is otherwise allowed under the regulations.
Direct marketing
  • Online 89 Pty Ltd will only use or disclose Sensitive Information about an individual for the purpose of direct marketing if the individual has given consent.
  • Online 89 Pty Ltd will only use or disclose other Personal Information collected from an individual for the purpose of direct marketing if the individual would reasonably expect Online 89 Pty Ltd to use or disclose the information for that purpose and Online 89 Pty Ltd has provided to the individual, and the individual has not exercised, a simple option of electing not to receive direct marketing communications.
  • If the individual would not reasonably expect the Personal Information to be used for direct marketing or the information was obtained from someone other than the individual, Online 89 Pty Ltd will only use the information for direct marketing if:
    • The individual has given consent, or
    • it is impracticable for Online 89 Pty Ltd to obtain that consent and, in each direct marketing communication with the individual, Online 89 Pty Ltd makes it clear that the individual may elect not to receive direct marketing communications and the individual has not so elected.
6. Data quality and integrity
  • Online 89 Pty Ltd will take such steps as are reasonable in the circumstances to make sure that the Personal Information it collects, uses or discloses is accurate, complete and up-to-date and relevant to the purpose of use or disclosure.

7. Data security


  • Online 89 Pty Ltd will take reasonable steps to protect the Personal Information it holds from misuse, interference and loss and from unauthorised access, modification or disclosure.
  • Online 89 Pty Ltd will take such steps that are reasonable in the circumstances to destroy or de-identify Personal Information (such as a job applicant's resume) if it is no longer needed by Online 89 Pty Ltd, is not contained in a record owned or deemed by regulation to be owned by the Commonwealth and is not required to be retained by or under an Australian law or court/tribunal order.

8. Access and correction

If Online 89 Pty Ltd holds Personal Information about an individual, it will, upon request by the individual and subject to the exceptions under the Act, provide the individual with access to the information, in the manner requested by the individual if it is reasonable and practicable to do so, within a reasonable period following the request.

If Online 89 Pty Ltd holds Personal Information about an individual and Online 89 Pty Ltd determines that the information, having regard to the purpose for which it is held, is inaccurate, out-of-date, incomplete, irrelevant or misleading, or the individual asks that the information be corrected, Online 89 Pty Ltd will take such steps (if any) that are reasonable in the circumstances to correct the information so that it is accurate, up-to-date, complete, relevant and not misleading.

If Online 89 Pty Ltd has corrected information, as set out in 8.2 above, which Online 89 Pty Ltd has previously disclosed to a third party, and the individual asks for that third party to be notified of the correction, Online 89 Pty Ltd will take such steps (if any) as are reasonable in the circumstances to notify that third party unless it is impracticable or unlawful to do so.

If Online 89 Pty Ltd refuses an individual's request for access to (including in the manner requested) or correction of Personal Information, as permitted by the Privacy Act, Online 89 Pty Ltd will within a reasonable period provide written reasons for such refusal (except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to be expected to do so) and the mechanisms available to complain about the refusal.

If Online 89 Pty Ltd has refused to correct Personal Information of an individual and the individual requests a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading be associated with the information, Online 89 Pty Ltd will take such steps as are reasonable in the circumstances to do so in a way that is apparent to users of the information.

9. Anonymity and pseudonymity

Unless Online 89 Pty Ltd is required or authorised by or under an Australian law or court/tribunal order or it is impracticable for Online 89 Pty Ltd to do so, Online 89 Pty Ltd will give individuals the option of not identifying themselves or of using a pseudonym when dealing with Online 89 Pty Ltd in relation to a particular matter.

10. Communication and contact

Online 89 Pty Ltd will manage Personal Information in an open and transparent way. To this end, this Privacy Policy will be published internally and provided to anyone who asks for it. The policy will also be posted on the Online 89 Pty Ltd website in an appropriate form.

Any person wishing to make an inquiry, request or comment or lodge a complaint under this policy may do so by phone, email or in writing to:

The Director:
Phone: 02 6241 4478
Fax: 02 6100 9268
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Address: PO Box 173 Gungahlin ACT 2912