Privacy Policy
Corporate Governance Document
I Introduction
This Policy describes the handling of Personal Information (as defined in the Personal Information Privacy Act 1988 (Cth)) (“Privacy Act”) that is collected by Miss Gray and its related entities and bodies corporate (within the meaning of the Corporations Act 2001 (Cth)).
Miss Gray recognises the need for protecting privacy both locally and internationally, especially with respect to protecting an individual’s privacy and ensuring the protection of their information. Miss Gray being registered in the State of New South Wales, Australia, is bound by the Australian Privacy Principles as provided under the Privacy Act, and their respective amendments and updates from time to time.
This Policy outlines how Miss Gray manages personal information of all persons it deals with, whether they are employees, contractors, agents, clients, suppliers, or any person that provides personal information to Miss Gray.
The information provided in this Policy consists of Miss Gray’s current privacy standards, which we may vary from time to time, and will be clearly marked as a variation with the date of that variation. We urge you to familiarise yourself with this Policy and to review it periodically to ensure you are up-to-date with our most current privacy standards.
Use of our website (missgray.com) or our services is deemed as your acceptance of this Policy and any revision.
II Objectives
This Policy’s objectives are to ensure:
the protection of personal information that Miss Gray collects, uses, discloses, stores or handles;
demonstrates Miss Gray’s ongoing commitment and compliance with the Privacy Act;
to describe and outline the way in which Miss Gray may acquire and use personal information in its services;
describes your rights to access personal information, correct that information, or request removal of that information from our systems; and
provide you with an independent avenue to complain about a breach of the PIPEDA or the Privacy Act.
III Miss Gray’s Services, Functions and Role
Miss Gray is a bioenergetic service provider. We focus on premium service, excellent relationships and culturally sensitive practices. This includes the provision of services by a bioenergetic practitioner in energy medicine. These services are described in greater detail in the ‘Disclaimer’ on this Website..
IV What is personal information?
The Privacy Act means:
information about an identifiable individual and includes employee personal information but does not include:
a) contact information, or
b) work product information;
This is generally meaning information that may identify you as an individual, or which may be reasonably ascertained to identify you as an individual from the information or opinion gathered. This may include information that includes:
your name;
date of birth;
credit history;
transaction history;
your address;
your place of work or company information;
information in submitted forms, contracts or applications;
payment or banking details;
insurances;
contact details, including telephone numbers, emails, addresses, or social media;
enquiry or complaint details.
V Purpose
Miss Gray collects personal information from individuals in order to conduct various aspects of its business functions and activities.
This includes information from individuals who are clients, prospective clients, contractors, suppliers, agents, service providers, and employees.
We may collect information from documents such as emails, business cards, social media, supplementary forms, client forms, transactional documents, contracts, enquiries or other mediums, including referrals. We may also collect information from you through your use of the Miss Gray Website.
If required by law we may also collect personal information from you.
VI Cookies
Miss Gray may use Cookies when you access the Miss Gray Website. Cookies are small files that a website writes to a user’s hard drive when that user visits the website. Cookies cannot read information from the user’s hard drive or read information from other cookies.
The type of information that may be logged may include:
the type of browser and operating system used;
the previous website the user visited;
the user’s server IP address;
date and time of the user’s visit;
the address of the pages accessed; and
the document downloaded and the size of the download.
Via the use of a ‘cookie’, Miss Gray may record the pages visited on the Miss Gray website and the information accessed and viewed / used on the Miss Gray website only. This information is used anonymously and in aggregate, and is collected and logged for statistical purposes.
You may turn off cookies through your web browser or add security measures to restrict cookies on your browser.
VII Use
Miss Gray may use or disclose personal information for its business purposes, including, but not limited to:
to identify and communicate with you;
to send emails or direct marketing or sales activities;
in the provision of relevant services or goods;
to help improve Miss Gray’s quality of care and services;
for your immediate and ongoing health care; and
various business operations.
In the event we require your consent to use or disclose your personal information, this may be obtained by verbal or express communication.
VIII Collection of Unsolicited Personal Information
Miss Gray often receives information which is not solicited from third parties or our suppliers, clients, contractors or professional advisors. When we receive unsolicited personal information, we determine whether it could have been collected in accordance with the Privacy Act. If we cannot substantiate that the information was lawfully obtained, we take steps to destroy or de-identify the information, including notifying the party that provided the information that we have done so.
IX Collection Personal Information for Human Resources
When you apply for a position with Miss Gray, we may collect more personal or sensitive information from you. Some of these may include your ethnicity, language ability, political beliefs, philosophical beliefs, union memberships, sex life, litigation or convictions, formal complaints, or background checks, including police and credit checks. We require such information to comply with equal opportunity laws and ensure compliance with the Human Rights Code [RSBC 1996] Chapter 210.
One of Miss Gray’s core values is ensuring the health and wellness of our employees. From time-to-time, we may ask for sensitive information concerning your health and wellness, in particular your mental health. This is used to assess your suitability for certain tasks and to manage a healthy work environment, to ensure a safe and healthy work environment for all.
X Management of Personal Information
Miss Gray stores personal information electronically or hard copy, which are always secured either in secure systems or on our business premises. The Personal information is kept safe and secure from misuse, interference loss, unauthorised access, modification or disclosure; and is only used internally or disclosed under permitted business purposes.
Any personal information that is retained after we have a specific need, we will take reasonable steps to destroy or de-identity this personal information.
XI Accuracy of Personal Information
Miss Gray uses its reasonable endeavours to ensure that the personal information it collects, uses or discloses is accurate and up-to-date. In the even your personal information changes, we encourage you to contact us and notify of such changes. We may contact your periodically to confirm your personal information to ensure that it is accurate and up-to-date.
XII Anonymity
You may choose to remain anonymous or use a pseudonym (a name that is not your own) when dealing with Miss Gray. However, we may not be able to provide you relevant services or goods if we cannot identify you.
XIII Direct Marketing
Miss Gray often sends out marketing materials and promotional offers to its contacts in our systems. In the event you wish to not receive these communicates, please notify us by emailing boutique@missgray.com with the subject heading ‘Privacy’.
XIV Disclosure of Personal Information within Australia and Overseas
Miss Gray operates an international business model and from time-to-time we may be required to disclose your personal information to other organisations we deal with to facilitate services or supply/procurement of certain goods. Prior to disclosing personal information, we ensure that those groups adhere to strict privacy protection requirements and also seek privacy protection obligations in relation to information disclosed. We do this through confidentiality agreement, reviewing the legal systems and privacy laws in the jurisdiction the group is domiciled and also their privacy and procedure policies.
At times, we may be required by law to provide personal information or for statutory purposes in order to prevent breaches of law. This may require disclosure to authorities, security agencies, regulatory bodies, customs officials or other executive branches of government. Such disclosures are generally advised in privacy statements from time to time.
Miss Gray may share your personal information you submit to us for any permitted purpose required to fulfil services or supply of goods. Organisations that we deal with outside of Australia are required to comply with our privacy policy and must maintain confidentiality of personal information supplied on an as needed basis or for any purpose set out in this Privacy Policy.
Please be aware that cross-border privacy protection principles do not apply to personal information if a permitted general situation exists, which include, but are not limited to: preventing a serious threat to life, health or safety, suspected unlawful activity, serious misconduct, locating missing persons, diplomatic or consular functions or activities, Defence force activities outside of Australia.
XV Destruction and de-identification of Personal Information
Miss Gray will take all reasonable steps to destroy, delete, de-identify personal information after its needs are no longer required.
XVI Access to and correction of Personal Information and the Complaint Process
If Miss Gray holds personal information relating to you, then you have the right to request access to that personal information and to correct that information. Miss Gray will endeavour to provide you with access to any such request within 7 days of receiving a request. We may require that you provide us with certain details to authenticate who you are and that you have a right of access to such information. This might include a 3-point identification check.
When requesting access to personal information from Miss Gray, there may be instances where we are required to charge you a reasonable fee for any expenses incurred by Miss Gray for such access. In these circumstances, if you are unable or unwilling to pay those expenses, we may not be able to provide you with access to your personal information.
In this event Miss Gray fails to grant access or to implement a proposed correction, we will provide you with a written explanation that outlines our position and reasons for not providing you with access or implementing a correction. You will be able to respond to such letter, however, any such disclosure or correction will be subject to Miss Gray’s discretion
XVII Credit Reporting
Miss Gray from time-to-time may ask you to complete a credit application which will permit the disclosure of your personal information to an approved credit reporting agency. Miss Gray provides various goods and services under commercial terms and those terms may require that you undergo a credit check.
If we require that as part of commercial arrangement with Miss Gray for you to complete a credit check, or you are guaranteeing the obligations of a credit applicant, we will require that you sign our credit application permitting us to obtain credit related personal information.
In order to obtain such reports, we may be required to disclose personal information provided by you, and we may hold and disclose any types of credit-related personal information about you. The information collected will be also be used to determine whether you are a suitable customer in relation to your credit worthiness.
XVIII Third Party Websites
We may include hyperlinks to other websites on the Miss Gray website or in correspondence to you, via email or through other mediums from time-to-time. Those third-party websites are not party to or subject to Miss Gray’s policies, including this Privacy Policy. We strongly encourage that you familiarise yourself with those third party’s privacy policies, as well as any other policies and procedures that may be relevant to your needs. Miss Gray does not warrant the accuracy or correctness of any third-party website and urges that you make your own independent enquiries.
XIX Compliance with this Policy
Miss Gray’s implementation of this Privacy Policy is done so through its procedures, current business practices, staff training and auditing. All Personnel, including agents, contractors, employees and officers of Miss Gray are made aware of this Privacy Policy and handle personal information in accordance with this Privacy Policy. All Personnel are required to uphold and protect individual’s Personal Information in accordance with the Privacy Act and this Privacy Policy.
XX Further Information
Miss Gray’s Privacy Officer is responsible for all matters pertaining to this Privacy Policy. Privacy related matters may be emailed to boutique@missgray.com or formally notified by post to our head office address. All reasonable endeavours will be made to respond to such requests and we resolve any complaint within 30 days from the day it is received by Miss Gray. If you believe that Miss Gray has not appropriately dealt with your request, you may refer your complaint to
XXI Approval and Revision
This Policy and Procedure was approved by the directors of Miss Gray on 31 March 2019.
*Uncontrolled when printed.