Effective February 2018
Security of data
We are obliged under the Australian Privacy Principles to take such steps as are reasonable to protect personal information:
- from misuse, interference and loss
- from unauthorised access, modification or disclosure
We are also obliged to ensure the security of credit eligibility information.
Should we suspect or believe that a data breach has occurred we will undertake the following 5 steps:
We will maintain systems and procedures to ensure that any suspected or actual data breach can be identified, reported and escalated to management responsible for the implementation of the Data Breach Response Plan. Any member of the firm who suspects a data breach has occurred must ensure that a Data Breach Report Form is completed and sent promptly to the Chief Operating Officer.
Once identified, we will take all reasonable steps that can be taken to contain that breach.
The Data Breach Response Plan and the Data Breach Report Form provide for the proper assessment of the breach including:
- the type of information involved
- whether the breach can be remedied and the information recovered
- the identity and number of individuals affected or likely to be affected
- the possible financial, economic, social and emotional impact on any individual;
- the nature of the breach (i.e. –was it loss, access or disclosure of electronic or paper-based data and was it accidental or deliberate)
- the perpetrator of the breach (i.e. internal staff, contractors, third parties whether local or overseas)
- the risk of further breaches if remedial action not taken (i.e. is systemic problem or one-off)
- whether criminality evident (i.e. theft or hacking)
- whether the information was encrypted, de-identified or difficult to access
If we believe (not just suspect) on reasonable grounds that a data breach is likely to result in serious harm to any of the individuals concerned we will:
Prepare the statement required by the Privacy Act 1988 including the following information:
- our contact details;
- a description of the breach we believe has occurred;
- the kind of information involved in the breach;
- recommendation about the steps the individuals should take in response and
- if the data breach was caused by a third party service provider we engage, we will include their name and contact details.
- Provide a copy of the statement to the Office of the Australian Information Commissioner
Provide a copy of the statement to each affected individual affected by means determined to communicate effectively and include additional information such as:
- our response to contain the data breach and prevent its recurrence
- any assistance we can offer to the individuals
- that we have reported the breach to the Office of the Australian Information Commissioner and if relevant any law enforcement agency/ies
- how individuals can make a complaint to the Office of the Australian Information Commissioner
To prevent future breaches of the same kind, the Data Breach Response Plan must include a requirement for us to conduct a review of our policies, systems and procedures which may include the following:
- a post-investigation audit of physical and technical security controls
- a review of policies and procedures
- additional training of staff members including scenario practices
- identify external resources that may assist in to prevent future breaches, i.e. auditing firms, public relations firms, legal advisers
- review authority levels for access to and transfer of electronic data
- whether the Data Breach Response Plan was adequate.
All staff / client privacy queries, concerns or suggestions should be directed to Wallmans' privacy officer, the Chief Operating Officer.