Privacy policy 

Data rights and digital sovereignty is important to CodeSafe. This includes protecting Your privacy and ensuring You have the access and control to decide how Your data is used.  

1.1 Your privacy is important

This statement outlines the policy of CodeSafe Solutions Services Pty Ltd (including the following QIN products: QIN CodeSafe app & web platform) on how it uses and manages personal information provided to or collected by it.

QIN CodeSafe is bound by, and compliant with, the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“the Privacy Act“).

QIN CodeSafe may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to QIN’s operations and practices, and to make sure it remains appropriate to the changing QIN CodeSafe environment.

Easier access to their data

Our detailed privacy policy clearly explains what information we collect and process, why and when plus how we collect, hold, use and disclose Your personal information. We aim to make this as easy to understand as possible instead of technical legal language. 

A new right to data portability

Your data is 100% portable. Export it, share it, or permanently delete it from QIN CodeSafe, it will always be your choice.

 A clearer right to erasure (‘right to be forgotten’)

 You can delete your QIN CodeSafe account at any time. If you later change your mind and decide you’d like to have a QIN CodeSafe account once again, we will welcome you back with open arms.

Though, you will have to recreate all of your data via the QIN CodeSafe sign up process again. When we say we deleted it, your original data cannot be refreshed and it’s gone forever. 

Right to know when their personal data has been hacked

If QIN CodeSafe were ever hacked and/or suffered a serious data breach, we would inform you promptly as well as notify the relevant European and or Australian data protection supervisory authority. 

1.2 What kinds of personal information does QIN CodeSafe collect and how does QIN collect it?

CodeSafe primarily collects and holds personal information about users of the QIN software platform and mobile application (“the Platform/App“).

Personal information means any information about an identified or reasonably identifiable individual.

If you are a user of the Platform/App, QIN may collect your personal information:

• when you are completing the registration process for the Platform/App;
• when you are populating your user profile or other electronic forms on the Platform/App;
• when conducting customer satisfaction and marketing research surveys;
• in the course of giving you user support; and
• for other purposes related to the provision of the Platform/App.

In these circumstances, the kinds of personal information that QIN may collect and hold include:

• your name and email address; and
• If you choose to provide it:
  • Other contact details, such as postal address and telephone number;
  • Emergency contact details;
  • Location;
  • Medical details; and
  • Professional details such as your level of induction, licences and qualifications.

In addition, QIN CodeSafe may automatically collect and hold data about users of the Platform/App which could be classified as personal information, such as location data, information about how you use the Platform/App (including the devices and networks you use to access it) and cookies.

QIN CodeSafe may also collect and hold personal information about employees and staff of QIN’s clients (i.e. organisations who use the Platform/App for the purpose of their business). This information generally consists of basic contact details such as the person’s name, role, email address, business postal address and telephone number.

QIN CodeSafe will only collect personal information about an individual directly from that individual, unless it is unreasonable or impracticable to do so.

QIN CodeSafe will only collect personal information which is defined as sensitive information under the Privacy Act:

• where you consent and the collection is reasonably necessary for QIN’s functions or activities (for example, where you enter medical details into the Platform/App); or
• where the collection is authorised by law.

You have the right to seek to deal with us anonymously or using a pseudonym. However, in almost every circumstance it will not be practicable for us to deal with you or provide you with any services – except for responding to the most general enquiries – unless you identify yourself.

1.3 How does CodeSafe address privacy when developing QIN CodeSafe software and services? 

QIN CodeSafe is developed using a methodology called “Privacy by Design”. This is a way of thinking about privacy in advance and planning for it throughout the entire design and engineering process.

1.4 Will CodeSafe ever sell your data? 

We do not sell your data. We will never give access to your Data to a third party (unless we are legally required to). We will always be transparent with you about our business model, terms and management of your Data. In addition to our Privacy Policy, our Terms and Conditions also detail explicitly how our products work, including a detailed description of how your Data is handled.

1.4.1 How does QIN CodeSafe use and disclose personal information?

QIN collects, holds, uses and discloses personal information:

• for the primary purpose of providing the Platform/App and associated services to users and clients; and
• for secondary purposes:
  • that are related (or, in the case of sensitive information, directly related) to the primary purpose and reasonably expected; or
  • to which you have consented.

QIN CodeSafe will only use and disclose information which may be classified as a government or compliance related identifier (such as qualification and driver’s licence numbers) if it is reasonably necessary to verify your identity for the purposes of the Platform/App.

1.4.2 Job applicants, staff members and contractors

In relation to personal information of job applicants, staff members and contractors, CodeSafe’s primary purpose of collection is to assess and (if successful) to engage the job applicant, staff member or contractor, as the case may be.

The purposes for which CodeSafe uses personal information of job applicants, staff members and contractors include:

• administering the individual’s employment or contract, as the case may be;
• insurance purposes;
• engaging in marketing for CodeSafe; and
• satisfying CodeSafe’s legal obligations.

Where CodeSafe receives unsolicited job applications, these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.

1.4.3 Direct marketing

QIN CodeSafe may use your personal information in order to inform you of additional features in QIN that you may wish to take advantage of.

In each direct communication, you will be given the option to opt out.

QIN CodeSafe will never disclose your personal information for the purpose of direct marketing by third parties.

1.4.4 Who might QIN CodeSafe disclose personal information to?

If you are a user of the Platform/App, QIN CodeSafe may disclose your personal information to:

• QIN CodeSafe’s clients, to the extent that your personal information is related to the provision of the Platform/App to that client;
• government organisations collecting information; and
• QIN ‘Super-Users’ who are subject to non-disclosure agreements.

If you are an employee or staff member of a QIN CodeSafe client, CodeSafe may disclose your personal information to a third party for the purpose of assisting with client queries.

QIN CodeSafe will not disclose your personal information to overseas recipients.

1.5 Management and security of personal information

QIN CodeSafe has in place steps to protect the personal information QIN holds from misuse, interference, loss, unauthorised access, modification or disclosure by use of various methods including:

• storing personal information in a fully encrypted database; and
• limiting access to the database to those who have signed non-disclosure agreements.

1.6 Updating personal information

QIN CodeSafe endeavours to ensure that the personal information it holds is accurate, complete and up- to-date.

An individual may seek to update their personal information held by QIN CodeSafe by updating their user profile on the Platform/App or by contacting the CodeSafe Privacy Officer at any time.

The Australian Privacy Principles require QIN CodeSafe not to store personal information longer than necessary.

Under the Privacy Act, an individual has the right to obtain access to any personal information which QIN CodeSafe holds about them and to advise QIN CodeSafe of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation.

To make a request to access any information QIN CodeSafe holds about you, please contact the us at privacy@codesafe.com.au or call 1300 475 557.

QIN CodeSafe may require you to verify your identity and specify what information you require.

1.7 How do we resolve Your privacy issues and complaints? 

Have a concern regarding Your personal info? Tell us! Here’s how. 

If you have a complaint about how we handle Your personal information, we want to hear from You. You are always welcome to contact us through any of the following: 

If you would like further information about the way QIN manages the personal information it holds, please contact us at  Privacy Officer (privacy@codesafe.com.au or call 1300 475 557).

If you have any concerns, complaints or if you think there has been a breach of privacy, then also please contact the Privacy Officer who will first speak to you usually over the phone. If we then have not dealt satisfactorily with your concerns, we will meet with you to discuss further. If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner via:

• email: enquiries@oaic.gov.au
• telephone: 1300 363 992
• website: https://www.oaic.gov.au/

May 2021