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Privacy Policy

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    Purpose and Scope

    Probe recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This information includes existing and prospective customers of our clients and potential and existing employees and contractors that Probe collects personal information from or is provided with such information from our clients. This policy identifies how Probe collect and manage personal information. Probe is committed to handling personal information in an open and transparent manner consistent with the objectives of the Australian Privacy Principles.

    Probe respects and are bound to all rights to privacy under the Australian Privacy Act 1988 (Cth), the Australian Privacy Principles, the Data Protection Act 2018 (DPA), the EU and United Kingdom General Data Protection Regulation (GDPR), New Zealand Privacy Act 2020 and the South Africa Protection of Personal Information Act 2013 as applicable (the Act). Probe complies with all of the statutory requirements in respect of the collection, use, management, disclosure, quality, security, access to and correction of personal information. This policy explains how and why Probe collect, use, hold and disclose your personal information. We may refer to these applicable acts and regulations as “Data Protection Legislation” in this privacy policy.

    Application

    This policy applies to all employees of Probe and all Probe related entities including Probe Operations Pty Ltd, Probe Group International Pty Ltd, GM Legal Pty Ltd, Convai Pty Limited, Convai (NZ) Limited, Probe Contact Solutions Australia Pty Ltd, Australian Support Services Pty Ltd, Probe Contact Solutions New Zealand and Probe Asia Pacific Pty Ltd and Probe North America Inc. Where the word ‘Probe’, ‘we’, ‘us’ and ‘our’ is used, it applies equally to Probe related entities. Where the word ‘employee(s)’ is used it applies equally to agency workers, contractors or subcontractors.

    What is personal information?

    When used in this policy, the term ‘personal information’ means any information or opinion about an identifiable individual or an individual who is reasonably identifiable from the information or opinion. Information or an opinion may be personal information regardless of whether it is true. This may include an individual’s name, address, telephone number, email address, credit card details, account number, and profession or occupation. If the information Probe collects personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information. This policy explains how Probe processes ‘personal data’ in the European Union (EU) as required under the GDPR.

    What types of personal information do Probe collect and hold?

    Probe may collect the following types of personal information:

    • name;
    • signature;
    • mailing or street address;
    • email address and telephone and fax number;
    • age or birth date;
    • system access passwords;
    • profession, occupation or job title;
    • where you are our employee, your personnel records including your employment agreement, pay records, leave records, tax status, criminal record checks, superannuation records, educational qualifications, training records, and performance and disciplinary records;
    • where you are our customer, details of the products and services you have purchased from us or our customers (on whose behalf we may provide products or services) or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
    • Where you are a customer of our client and we are verifying your identity, your name, residential address and date of birth;
    • where you are a customer of our client and we are discussing overdue debts, details of your employment and bank account details;
    • credit card details;
    • details of your creditworthiness and credit history;
    • any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and
    • information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.

    Probe may collect the following information deemed to be sensitive:

    • Health information relating to an individual;
    • Racial or ethnic origin; and
    • Criminal record checks.

    The way Probe hold information will depend on why such information is being collected and for which client. Much of the personal information we collect and hold is done so by us when we are acting as the ‘agent’ or service provider of our customer. For example, we provide digital customer experience solutions and operate customer contact centres on behalf of many companies globally, from retailers to banks and other institutions. When you contact one of our operators at a contact centre, you may not necessarily be aware that the call centre is operated by Probe on behalf of our customer. Probehave set out in the Annexure to this policy some more detail around the information we may collect and hold in respect of each of our key businesses. Please read this carefully.

    We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous data or aggregated information about how users use our websites. Probe do not re-identify this information to turn it into personal information.

    We may, in further dealings with you, extend this personal information to include your address, purchases, services used, and subscriptions, records of conversations and agreements and payment transactions etc.

    • Where we are acting as a Data Controller, we will process your personal information based on your consent and our legitimate interest.
    • Where we are acting as a Data Processor, acting on behalf of companies that employ our services, the legal basis for processing your data is based on the performance of a contract. Therefore, we will not store, process or transfer your data unless we have an appropriate lawful reason to do so. Please contact the company about further information about how they process your personal information.

    How do Probe collect and hold your personal information?

    Personal information is only collected by lawful and fair means in accordance with the Act. We collect personal information directly from an individual unless it is unreasonable or impracticable to do so. When collecting personal information from an individual, we may collect in the following ways:

    • through your access and use of our website;
    • through your use of telephone and mobile communication (including but not limited to fixed line IVR services);
    • through your use of electronic devices including tablets, supplied by us to you, or otherwise connecting to our systems in order to facilitate and enable you to perform your duties or to provide services to us;
    • during conversations between you and our representatives;
    • during correspondence between you and our representatives, including electronic correspondence;
    • when you engage with us via social media; or
    • when you complete an application, contract or purchase order.

    Some of the personal information Probe holds or deals with is not actually collected by Probe. Because Probe is a leading provider of business process outsourcing, much of the data and personnel information it deals with is provided to it by its clients, and has not actually been directly collected by Probe from the individual concerned.

    It is impracticable for us to collect information directly from you when we are acting as the ‘agent’ or service provider of our client, as our client has already collected the relevant information from you (or another third party), and our client has provided it to us for our use in providing services to or on behalf of our client. For example, we act on behalf of many customers in sending email communications. To enable us to do so we may use our customer’s database of personal information which our customer has supplied to us. It is impracticable for us to ‘recollect’ this information from individuals directly before we use it as requested by our client.

    In respect of personal information which is provided to us by our clients, we do seek client assurances that all such personal information has been collected lawfully and in compliance with privacy laws and regulations we are subject to and that all required consents have been obtained for, and disclosure statements made in respect of, the intended use of that personal information. Probe however will not be responsible for, and accepts no liability in respect of, any failure by a client to do so.

    We may also collect personal information from third parties who are not our clients including, for example, from third party companies such as data providers and brokers, credit reporting bodies, law enforcement agencies and other government entities.

    If you apply for a job or contract with us, we will collect personal information about you from your referees. With your consent we may also use a third party service to ensure your employment, educational and identity records are valid. We may also check some details about our suppliers from publicly available sources, such as the Australian Business Register and ASIC databases.

    We collect limited information about users of our websites, for diagnostic and analytic purposes. We use cookies and gather IP addresses to do so, but we do not trace these back to individual users.

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