top of page

PRIVACY POLICY

GENERAL

​

Frank Carbone is committed to providing the very best in services. These include specialised services of debt recovery, locating people and property, general and specialist investigation and reporting, credit related services as well as various other functions. We are able to assist you and others in location searches for lawful and legitimate purposes. Within strict legal parameters we undertake to benefit you and society at large whenever you or the public interest can be served by the location of particular persons or items.

​

We service the needs of a varied client base spanning large financial institutions, corporations, the legal profession, small business, as well as government and regulatory authorities, other groups and organisations, and the general public.

​

A fundamental part of our work requires us to access personal information. We have the highest regard for keeping this information confidential and maintain strict guidelines on access to and use of it.

​

We adhere to a policy of openness about how we use and manage information and in making ourselves accessible to you. Our strict policies on management of personal information are explained in this privacy policy statement which applies to all your dealings with us. If you use Frank Carbone’s functions and services, apply to use or enquire about them, or visit and/or use our website you agree and consent to the provisions of this privacy policy statement.

NATIONAL PRIVACY PRINCIPLES

On 21 December 2001, a new Commonwealth privacy law came into force in Australia. It provides ten National Privacy Principles (NPPs) and a framework for regulating the way in which private sector companies handle personal information.


Frank Carbone is bound by and committed to upholding the NPPs found in the Commonwealth Privacy Act which sets out standards for the collection, use, disclosure and handling of personal information. 

YOUR PRIVACY RIGHTS

Due to the sensitive nature of many of Frank Carbone’s operations respect for your privacy rights is one of our highest priorities. Your privacy is one of the most fundamental aspects of our relationship with you.


In today's digital age where the information superhighway of global databases and electronic technology is ever present your right to secure your personal information is critical. Even if you yourself do not travel the superhighway, it is likely your personal information will. 


What follows is an outline of exactly how we manage personal information necessary for us to provide our services. 

COLLECTION OF PERSONAL INFORMATION

Frank Carbone collects personal information about an individual on our database that is relevant and necessary for one or more of our functions or services. Following are examples of the personal information we may collect and hold.

​

  • We hold information about a person or organisation on our database for any reason, and the contact details of the individual or organisation who instructed us.

  • We may collect information either directly from you, the individual or organisation concerned, indirectly from third parties, or from publicly or commercially available sources.

  • We may collect information from qualified users such as credit providers, banks, finance houses, insurance providers and other credit reporting agencies who have a username and password provided by us. We may collect information from other reputable reference sources.. We hold information that helps identify you such as name, address, telephone number, and similar information. The information we collect may include your date of birth, gender, driver's license number and employment occupations. It may include the type of account you applied for, information about your financial transactions with us or third parties such as account balances, payment history and account activity. The information may include payment default records, serious credit infringements, court judgments, bankruptcy listings and credit enquiries. It may show who made the enquiries, for what type of matter or loan, and when.

  • We may also collect information about you from public sources including court records, other publications, and databases that are publicly available.

  • We may also collect information from our own records of your use of our services.

  • We may also collect information about you when you use our website. When you visit our website, we track usage patterns. During normal website usage, we collect and store only the name of your internet service provider, the website that referred you to us, the date and time of your visit, the pages accessed, and documents downloaded, and any search times entered.

  • We can identify you from this information. Our database records your activities on the website through our Audit Trail. This Trail is used for technical support and maintenance and may be used to investigate fraudulent use of our system if we have reason to believe improper use. The Audit Trail is available for viewing only by Frank Carbone staff and our technical support agents.

  • If you visit our website and give us personally identifiable information, or send us an email to request a service, or contact us for any reason we will collect and store the information in a manner appropriate to the nature of the data you give us including your name, mailing address, email address, type of request or communication and possibly additional information. At all times, the information provided by you is used to improve the services we provide to you.

  • We may also collect personal information when legally required to do so. All personal information is collected lawfully and fairly back to contents.

 

SENSITIVE INFORMATION 

There are greater restrictions on collection of sensitive personal information under the Commonwealth Privacy Act. This could include information about your health, your racial or ethnic origin, your political or religious beliefs, your sexual preference, your professional memberships, and if relevant, your criminal record.

​

In order to provide our functions and services, or to make, pursue or defend a legal claim, it may be necessary for us to collect sensitive personal information about you. By accepting the provisions of this privacy policy statement, you consent to its collection by us.

​

We will collect sensitive personal information when required by law.

HOLDING, USING OR DISCLOSING INFORMATION 

Your personal information is treated with the utmost confidentiality. It is held in a carefully controlled and secure database not accessible by the general public. It is restricted to persons with a genuine purpose for consulting it (other than you). Appropriate controls are in place to protect the database of information from misuse and loss and from unauthorised access, modification, or disclosure.


Frank Carbone does not use or disclose personal information for any purpose that is unrelated to our functions and services you would not reasonably expect (except with your consent or when the law requires it).


Unless you are informed otherwise, the personal information we hold is used for general client services including such things as managing the debt recovery and credit related aspects of our business and for providing our locating, reporting and investigation services. Depending on the service required this means that we may disclose personal information to:

​

  • Approved organisations or individuals who provide credit related services such as credit providers, insurance providers, credit reporting and credit reference agencies, insurance investigators, and those organisations or individuals authorised by us to have access to the information.

  • Approved credit related organisations, which could include businesses to whom you have applied for credit or a loan such as credit providers, to assist them in assessing your suitability to be provided with credit, or capacity to repay credit, or in assessing whether to accept you as a person or guarantor for a loan applied for by somebody else. It may also include insurance providers, other credit reporting agencies, credit reference agencies and commercial organisations that need to see the information in order to make similar assessments about you or a related transaction or to contact you.

  • Public bodies such as courts, tribunals, regulatory authorities, and government departments authorised by law including law enforcement bodies and agencies.

  • Any other individual or organisation permitted by law to receive the information.

  • Anyone authorised by you as specified by you in writing.

 

At all times only qualified people and organisations are allowed access to Frank Carbone database. Frank Carbone has in place rigorous security measures and oversight procedures for monitoring and determining the legitimacy of the individuals, businesses, and organisations we deal with and who seek access to our database. They must always acknowledge the confidentiality of the information. They must undertake to respect an individual's right to privacy. They must comply with the NPPs and this policy. Frank Carbone keeps a comprehensive list of qualified users and subscribers and has in place mechanisms for periodic review of the accuracy of this information. See 'Frank Carbone EXPECTATIONS' in this privacy policy statement.

UP-TO-DATE INFORMATION

We will take reasonable steps to ensure that the personal information we collect, use, or disclose is accurate, complete and up to date.

​

When personal information is no longer needed, we will take all reasonable steps to destroy or remove it in compliance with the Commonwealth Privacy Act and the NPPs. All information stored in electronic form will be deleted or de-identified from all systems. See 'SECURITY OF DATA AND ITS STORAGE' in this privacy policy statement.

SECURITY OF DATA AND ITS STORAGE

We respect our obligation to maintain confidentiality and security of data. We will take all reasonable steps to protect the personal information we hold in your files from misuse and loss and from unauthorised access, modification, or disclosure. We ensure confidentiality and security of data transmitted over the net.

​

Your information is stored in hard copy documents or as electronic data. Frank Carbone has stringent controls in place to maintain electronic and hard copy data quality. All computer equipment containing personal information is in a secure, patrolled environment with access by a limited number of qualified staff at Frank Carbone. We have comprehensive security policies and procedures in place as part of our internal security policy.

​

We maintain physical security over our data stores and premises using coded locks and security systems. We maintain computer and network security by use of a firewall and other security systems such as user identifiers and passwords to control access to our computer systems. Our database login is secured by use of 128-bit encryption of data transmission, secure socket layers protocol and password anonymity. 
Our system ensures that passwords are changed regularly. Our system administrator can identify users by their user identification.

​

Personal information will be collected, recorded, amended, or deleted only by authorised means and by authorised persons. New computer files are reviewed by approved and qualified staff. All files containing personal information are accessible only by staff requiring them for the completion of their specific duties. When personal information stored in electronic format is no longer required for the purpose it was collected or for the purpose of meeting legal requirements, Frank Carbone de-identifies or destroys it.

Our processes for disposing of computer hardware ensures that such personal information is deleted before such equipment is offered for re-sale.

​

When paper files, letters, correspondence, and any other hard copy documents that contain personal information are no longer needed, we shred them or dispose of them in a secure document’s destruction service security bin.

​

Our database system regularly reviews the Audit Trail for security breaches and reports any possible breaches to the system administrator.

​

Frank Carbone does not provide information electronically, by telephone or by facsimile until and unless the identity of the receiver is verified and their reason for wanting the information is shown to be reasonable and in compliance with the NPPs and this privacy statement.

​

We will undertake regular audit checks to ensure compliance with the applicable code of practice and all privacy and industry legislation. In addition, we will undertake regular audits by independent external auditors. The security of our database is periodically reviewed.

​

At all times we provide a discreet environment for confidential discussions. Frank Carbone’s employees who handle personal information are trained to understand and respect the strict confidentiality of the information and the privacy of individuals. They have strict guidelines in the handling of that information. In order to work at Frank Carbone employees must sign confidentiality agreements that are re-issued annually.

​

We further protect personal information by placing security controls on data access ensuring that our staff can only access the appropriate information relevant to their roles and responsibilities. Access to information by our staff is recorded on our database enabling us to identify at any time individuals who have accessed that information. Breaches of your privacy by staff are treated very seriously. Frank Carbone will impose rigorous disciplinary procedures, including termination of employment.

​

Frank Carbone has appointed privacy officers to ensure that our management of personal information is in accordance with this policy statement, the Commonwealth Privacy Act and the NPPs. We will not share your information with any unauthorised persons.

FRANK CARBONE EXPECTATIONS OF THIRD PARTIES

Frank Carbone often relies on third parties such as banks, finance houses, credit providers, insurance providers and our agents and contractors to provide our specialised services. These third parties are bound by confidentiality agreements and are prohibited from using information gained by Frank Carbone for any other purpose. We make sure they are aware of our obligations under the Commonwealth Privacy Act and the NPPs, that they are aware of their own obligations under the Commonwealth Privacy Act and the NPPS and agree to be bound by these obligations.

​

If you are a third party giving us personal information about other individuals, we rely on you to have made them aware that you intend to give us their information, why we use it, the third parties we may disclose it to, and how they can access it (as described in this policy).

​

If you have not done so you must notify Frank Carbone before you provide the relevant information.
We also rely on you to ensure the personal information we collect from you is accurate, complete, and up to date. We may contact you to confirm or change the details of your personal information. You can contact us at any time to update your personal information.

​

If we give you another's personal information, you and your representatives must only use it for the purposes Frank Carbone agree to. Where relevant you must meet the requirements of the NPPs set out in the Commonwealth Privacy Act when collecting, using, disclosing, and handling personal information on Frank Carbone’s behalf. This obligation extends to your agents, employees, and contractors.

​

In some cases, we will require you to specifically consent to the collection, use or disclosure of your personal information by Frank Carbone. Your consent will usually be required in writing and in some cases, your consent may be implied through your conduct such as when you continue a telephone call after we have advised you that the personal information will be collected, used, or disclosed. See 'SENSITIVE INFORMATION' in this privacy policy statement. 

YOUR RIGHT TO ACCESS YOUR INFORMATION

Under the Commonwealth Privacy Act, you have the right to obtain a copy of personal information held by us about you or query and dispute any information or listings we have. You can request us to correct any errors in that information. We will take reasonable steps to correct the information so that it is accurate, complete, and up to date.

​

Under the Act there are some exceptions to access to personal information by you:


(a) where providing access would pose a serious and imminent threat to the life or health of any individual; 
(b) where providing access would have an unreasonable impact upon the privacy of other individuals; 
(c) where your request for access is frivolous or vexatious; 
(d) where the information relates to existing or anticipated legal proceedings between you and us, and the information would not be accessible by the process of discovery in those proceedings; 
(e) where providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations; 
(f) where providing access would be unlawful; 
(g) where denying access is required or authorised by or under law; 
(h) where providing access would be likely to prejudice an investigation of possible unlawful activity; 
(i) where providing access would be likely to prejudice:
(i) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or
(ii) the enforcement of laws relating to the confiscation of the proceeds of crime; 
(iii) the protection of the public revenue; 
(iv) the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
(v) the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders;
by or on behalf of an enforcement body; or
(j) an enforcement body performing a lawful security function asks us not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia.

​

Where providing the information to you would reveal evaluative information generated within our organisation in connection with a commercially sensitive decision-making process, we may give you an explanation for the commercially sensitive decision rather than direct access to the information. The NPPs prevent us from giving you an explanation for a commercially sensitive decision in circumstances where it does not apply.

​

If you wish to request access to your information, advise us of inaccuracy, or complain that Frank Carbone’s actions breach this Privacy Policy Statement, please see the 'How to Contact Us' in this privacy policy statement.

​

We ask you to send your query or complaint in writing. Upon receipt, we will send you a written acknowledgement of your correspondence within 30 days. We will make our records of personal information available to you upon being reasonably satisfied with your identity and as promptly as we can. We will investigate the matter and advise of steps we have taken to respond to the matter or to resolve it. Where information is incorrect or a listing is queried, Frank Carbone will investigate and where appropriate make the necessary amendments.

​

We will not charge you a fee for lodging your request for access. We may charge a fee to verify the application and locate, retrieve, review, and copy any material requested. If the request is extensive, we will notify you in advance of the cost. Authorised staff are available to help you refine your request if required.

​

If we disagree about whether the information is accurate, complete, and up-to-date, and you ask us to include a statement claiming that the information is not accurate, complete or up to date, we will take reasonable steps to do so. 


We will always provide reasons for denial of access or a refusal to correct personal information.
If you are not satisfied with our response you can telephone the Commonwealth Privacy Commissioner's hotline on 1300 363 992.

IDENTIFIERS

We do not use your tax file number (TFN), Medicare Number or any other government agency or other agency identifiers as our customer identifier or to link people with information. 

TRANSBORDER DATA FLOWS

It is not our policy to transfer personal information to foreign countries with less privacy protection. At all times only authorised organisations and individuals are allowed access to Frank Carbone database. We will only transfer personal information outside Australia to a country where there is less privacy protection with your consent, or when it is necessary to provide our functions and services as set out in this privacy policy statement and in compliance with the NPPs.

RECORDING TELEPHONE CALLS

In some cases, in order to assess and maintain customer service quality, or for security reasons we may record your telephone calls. If we do, we will advise you of our intention to do so and usually seek your consent. In some cases, your consent may be implied when you continue a telephone call after you have been advised that the call will be recorded.

PRIVACY POLICY REVIEW

In order to comply with our legal obligations and the constant changes in technology and industry practice, it may be necessary from time to time for us to review and revise our privacy policy and procedures. If our policy is changed in any way, we will post amended versions on our website.
 

ACCESSIBILITY

Feedback from you is valuable information to us. We are dedicated to delivering quality information and providing easy access to our services in conformity with the NPPs and their framework for regulating access to personal information. Visitors to our website and users are invited to provide feedback on our services. Due to the sensitive nature of many of our operations these comments will be treated as strictly confidential and will not be open to public access.

DIRECT MARKETING

Frank Carbone does not do any direct marketing as part of its functions and services.

HOW TO CONTACT US

Our Privacy Officer can be contacted at Frank Carbone, PO Box 569 North Adelaide, SA 5006 Australia.
We can be emailed at admin@frankcarbone.com.au and our website can be viewed at www.frankcarbone.com.au

WEBSITE POLICY
The Frank Carbone website may contain links to other sites. This privacy statement is for our website only and does not apply to linked sites. We encourage you to read the privacy statements of each website that collects your personally identifiable information.

​

​

​

​

bottom of page