Charter Hall Group (CHG) is the managing party of 360queen.com.au and is committed to ensuring the confidentiality and security of individuals' personal information.
Purpose and Scope
Charter Hall recognises that your privacy is important and we are committed to protecting and maintaining your privacy.
Charter Hall is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) and we take these obligations seriously.
Collection and use of personal information
In order to provide you with services, Charter Hall will need to collect your personal information. The personal information collected will depend on the services we provide to you. Generally, we will only collect the personal information we need to provide and market our products and services in the context of our day to day business.
Where possible, we will collect personal information directly from you and explain to you in general terms, why we are collecting it and how we will use or disclose it.
We may collect information about you from third parties, including but not limited to:
- financial advisers
- unit registrars and administrators
- suppliers, consultants or contractors
- potential, current or former employers and contractors
If we collect personal or sensitive information from someone other than you, we will advise you, where practicable, that we have the information, who it came from and the circumstances of the collection. Sensitive information, such as country of origin or health status will only be collected with your express consent.
Where possible, we will only use personal and sensitive information for the purpose for which it was collected. Occasionally this information may be used for another purpose, such as marketing. If so, the information will only be used if consent has been obtained or if the reason we want to use the information is directly related to the reason we initially collected it or it could be reasonably expected that we would use it for such a purpose.
Tenants and prospective tenants
We use personal information about tenants and prospective tenants to evaluate whether or not we will grant leases and/ or enter into agreements, document these leases/agreements, and manage relationships with tenants. We may also use personal information to manage tenancies, to update our records and keep contact details up to date so we can continue to provide and/or offer our products and services, to process, respond to any enquiry or complaint received and for security and risk management purposes including incident investigation, loss prevention, claims management and litigation and to comply with any law or regulation.
If you hold securities in Charter Hall or units in an investment product offered by Charter Hall, your personal information is used to carry out registry functions.
Registry functions include facilitating distribution payments and corporate communications, to inform you of updates concerning us and our products and services, to update our records and keep contact details up to date, to process and respond to any enquiry or complaint received and to comply with any law or regulation.
Unit registers are maintained by external parties who are required to have arrangements in place to protect personal information they collect on behalf of Charter Hall.
In general, we may collect any of the following: your name, gender, date of birth, phone numbers, postal and residential addresses, email address, occupation, professional experience and qualifications, financial information and bank account details.
From time to time, we may use your personal information to tell you about products or services we think you may interested in. If you do not want to receive direct marketing messages or want to change contact preferences you may request not to receive direct marketing by following the "unsubscribe" instructions on the communication or by contacting the sender using the details set out in the communication.
Visitors to Charter Hall owned or managed properties
Charter Hall uses camera surveillance systems (CCTV) to maintain the safety and security of property and individuals working at or visiting our properties. We will only use CCTV footage to personally identify you for security, risk management, loss prevention and incident investigation purposes. Images collected by CCTV may be provided to tenants, law enforcement bodies and insurers.
If you are involved in an incident we may ask for medical information and information from other consultants and third parties.
Charter Hall offers a free Wi-Fi Service at certain properties, including our shopping centres. If you are carrying a Wi-Fi enabled device within range of one of our Wi-Fi networks, we will automatically pick up location data transmitted from your device. This enables us to give you access to our network. We collect information about the devices including, for example, the type of device, its ID number or ‘MAC address’, and its movement throughout the centre. We will not use information from your device to personally identify you, unless you connect to our free Wi-Fi network.
If you apply for a position with us we may collect information from you (including your name, contact details, working history and relevant records checks), from a recruitment consultant, your previous employers and others who may be able to provide information to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.
Charter Hall may keep this information so we can contact you if an opportunity arises in the future.
Third party links
Disclosing personal information
Charter Hall is careful about how we use your information and who we share it with. We may share information with other members of the Charter Hall Group without disclosing this to you.
We may disclose your personal information to third parties who assist us in the operation of our business and/or the provision of our products and services such as custodians and unit registry providers. We may also disclose personal information to:
- financial institutions for payment processing,
- valuers where we are seeking to value a property or lease;
- credit reporting agencies or guarantors;
- claims management services,
- injury management services,
- property management services;
- regulatory authorities or government agencies or bodies where required by law.
Where possible, Charter Hall will not transfer personal or sensitive information to a party in a foreign country outside the Charter Hall Group, unless we are reasonably satisfied that the recipient of the information is subject to information privacy requirements similar to those of Australia, you have consented to the transfer, the disclosure is required or permitted by Australian law or court/tribunal order; or the information is required under a foreign law or regulation.
Keeping your personal information secured
We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
We may hold your personal information in either electronic or hard copy (paper) form. We retain your personal information in our computer systems and databases, and in our physical files. We use technologies and processes such as access control procedures, network firewalls, encryption, password protected databases and physical security measures to protect your personal information.
If we establish that your personal information has been accessed or disclosed without authorisation, Charter Hall has an obligation under the Privacy Amendment (Notifiable Breaches) Act 2017 (Cth) to investigate the circumstances of the breach and take appropriate action to correct it. Where it is determined that a reasonable person would conclude that the access or disclosure to your personal information would likely to result in serious harm to you, we will advise you and the Office of the Australian Information Commissioner (OAIC) of the incident and provide details of the remedial actions we are taking to correct it. “Serious harm” is defined as a situation where the person affected could suffer serious physical, psychological, emotional, economic or financial harm, or serious harm to their reputation. In such situations, Charter Hall will assess the data breach considering the list of relevant matters included in legislation.
Accessing Personal Information
We will take reasonable steps to ensure that the information we collect, use and disclose is relevant, accurate, up-to-date, and complete. You have the right to ask us what personal information we hold about you and request that changes be made to the information. If you wish to request access to the personal information we hold you can contact our Privacy Officer. If we correct personal or sensitive information about an individual which was previously provided to a third party, and the individual requests us to notify the third party of the correction, we will take all reasonable steps to give that notification, unless it is impracticable or unlawful to do so.
We may charge a fee for responding to a request for personal information to cover our reasonable costs in locating and supplying the information. There is no cost for asking for access to information and we will make sure any charge for suppling the information are not excessive.
There are a number of exceptions in the Privacy Principles that allow us to refuse your request for access to your personal information. The exceptions are summarised in Australian Privacy Principle 12 which available from the OAIC. If we deny a request for access, we will explain why.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, you can ask us to amend it. If you contact us for a correction, we will review the information to ascertain if correction is required and take the appropriate action. In some circumstances, we may not agree that the information should be changed. If this happens, we will provide a reason explaining our decision and we will add a note to the personal information stating that you disagree with it.
Where do I go to find out more information about Privacy?
Please contact Charter Hall's Privacy Officer if you would like to know more about the Privacy Act, or if you would like more information about the way Charter Hall uses personal information.
If you think Charter Hall has have breached your Privacy, or you wish to make a complaint about the way we have handled your personal information, please contact our Privacy Officer using the contact details set out below. We will investigate your complaint. After Charter Hall has completed its investigation, we will contact you to advise the outcome. If your complaint is not satisfactorily resolved, you may apply to the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined.
Charter Hall Privacy Officer
GPO Box 2704
Sydney NSW 2001
Phone: 02 8651 9000
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone 1300 363 992