This document sets out the policy from Red Earth Energy Storage Ltd relating to the protection of the privacy of personal information. Within this document, we will refer to Red Earth Energy Storage Ltd (ABN: 34 163 828 920) as simply ‘RedEarth’.
This policy document is intended to enable all users of RedEarth digital and offline assets and others who interact with the RedEarth to understand what types of personal information we collect, and what we do with such information in performing our functions and in light of our privacy obligations.
RedEarth is a local Australian assembler of solar PV energy storage products, with a local team who believe in doing something that matters for the industry and the way we do this, is by engineering our products to be beautifully designed, simple to install and customer-centric.
In some respects, the laws of jurisdictions outside Australia in which RedEarth currently does not operate may have additional requirements binding RedEarth. We are committed to discussing the requirements and will consider them, with due process and will comply with all such requirements.
1.1. What is personal information?
Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about a living individual who is either identified or reasonably identifiable.
Examples include an individual’s name, address, contact number and email address.
1.2. Our obligations
RedEarth is required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection/receipt to use and disclosure, storage, accessibility and disposal.
We are also required to comply with other laws, including more specific privacy legislation in some circumstances and in some jurisdictions, such as:
- the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth); and
- the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act.
1.3. Employee records
In Australia, RedEarth is generally exempt from the Privacy Act when we collect and handle employee records. However, our policy is to protect the personal information of our employees as we do other personal information.
2. The purposes for which we collect, hold, use and disclose personal information
RedEarth needs personal information to be able to perform its core functions, including administration of the online users who show interest in RedEarth, have shown interest in the National Installer Program, admission to clientship, professional development (including by the provision of materials), holding events, issuing certificates, and management of professional conduct. RedEarth holds events to benefit the local industry, we operate training events in a number of cities, discussion forums and other industry client groups.
RedEarth’s core services to clients include education, training, the provision of information, technical support and advocacy. The main purposes for which we collect, hold, use and disclose personal information are to provide quality services and benefits to our client base and users who follow our brand online, to alert them to issues and opportunities in which they might be interested, and to maintain and extend our services. Staff and our client base work together with local bodies to represent the views and concerns of the profession to governments, regulators, industries, academia and the general public. RedEarth also interacts with non-clients, both prospective clients and also the general public. Personal information is collected and used for those processes.
Likewise, RedEarth needs personal, company & project site information to be able to perform its core and secondary functions in relation to the provision of independent energy advisory services to the clients or their authorised representatives, as well as oversight and potential training of those authorised representatives (monitoring).
For those above purposes, RedEarth’s activities, in Australia, include:
National Installer Program (NIP) management
Managing clientships, for example, by:
- recording and updating clientship details and profile information
- sending notices RedEarth developments
- sending out renewal notices and advertising.
Email communications from RedEarth
As with comparable solar industry companies, RedEarth communicates frequently with its subscribed clients and others by email and other means – for example, mobile messaging and the post. The non-clients to whom we communicate include employees and contractors of the RedEarth. To ensure that our communications are effective, we employ software which reports deliverability rates, open rates, click through rates, unsubscribes, hard and soft bounces. We can see this information at individual record level if required, but only engage that functionality in very unusual circumstances.
Services and publications
- corresponding with clients and affiliated persons on issues of mutual interest
- distributing RedEarth publications and newsletters, including RedEarth Updates and Network News
- the provision of other professional information and materials to RedEarth clients and non-clients and RedEarth Authorised Representatives.
- supporting various industry advisory groups (SEIA, CEC, SEC etc)
- organising and holding RedEarth discussion groups to consider topics of interest to the solar install profession, organising, promoting and running live chats and live interviews including digitally, online and face-to-face; and
- providing RedEarth clients with access to and information about a range of current and future NIP services and benefits, including client benefits (see further below).
Education, training and events
- administering RedEarth’s Continuing Practice Development (CPD) program (including informing RedEarth clients about CPD requirements, developing, promoting and conducting CPD events for Clients and non-clients, keeping records of CPD attendance and conducting CPD audits)
- developing, promoting and conducting other RedEarth and RedEarth Advice events (whether digitally, online, face-to-face or otherwise), seminars and
- conferences (including organising speakers, locations and catering, and keeping attendance records)
- developing, administering, supporting and assessing the RedEarth educational programs. (CEC Approved units)
- informing potential RedEarth clients and intermediaries about the benefits of the NIP.
Surveys, research and competitions
- conducting surveys and market research for product and service improvement purposes and to compile statistics and analyse trends including surveys of RedEarth’s internal staff.
- conducting competitions and lucky draws.
- receiving, investigating and taking action on complaints about how the RedEarth has collected or handles personal information.
- recruiting Red Earth Energy Storage Ltd staff and contractors
- processing payments
- answering queries and resolving complaints; and
- using aggregated information for business analysis.
RedEarth may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or:
- which are required or authorised by or under the law (including, without limitation, privacy legislation); or
- for which the individual has provided their consent.
2.2. Direct marketing
RedEarth may use personal information of RedEarth clients and non-clients, specifically your name and relevant address details and information about preferences for direct marketing, both as to the preferred communication channels for receiving direct marketing from RedEarth and the types of products and services of interest, to let people know about the RedEarth services, facilities and benefits and those of third-party partners, contractors and/or suppliers to RedEarth, where we have recipient consent.
Under Australian law, RedEarth is not permitted to do so unless we have consent. The RedEarth is committed to abiding by the law in all jurisdictions.
Where permitted by law to do so, RedEarth or our partners, contractors and/or suppliers may contact persons for direct marketing purposes in a variety of ways, including by mail, email, SMS, telephone, or online advertising.
For example, where RedEarth has consented, we send:
- RedEarth clients our publications (see list above)
- information under our RedEarth client benefits and other program offerings and advertising of the availability of goods, facilities and/or services in the classes of personal and business products and services, news publications and subscriptions, technology, lifestyle offers, office supplies, business support services, professional development offerings and opportunities, including RedEarth training events; and
- RedEarth client research, including client surveys.
The RedEarth offerings may vary from time to time.
If you are a prospective RedEarth client and have provided consent, we may use your personal information to contact you with information about the RedEarth including RedEarth updates and Network News (if you have completed a non-client subscriber form) and our current and future client benefits and events.
Communication of your consent
Under Australian law, you may communicate your consent to the RedEarth use of your personal data for Direct Marketing by:
- when providing RedEarth with your personal data through our website, clicking on the submit or register or equivalent button indicating your consent
- when providing the RedEarth with your personal data through a form, signing on the form indicating your consent; or
- following the instructions in the document on which you are providing your personal data to RedEarth.
Communicating about core issues
As a matter of law, RedEarth clients are clients of the company, RedEarth Energy Storage Ltd. Consequently, RedEarth must be in a position to communicate with its clients about certain core matters, including continuing education, technical upgrades or development, and professional conduct.
Subject to the above, where you have consented to receive direct marketing communications from RedEarth, your consent will remain current until you advise us otherwise. However, you can, at no cost, opt out at any time, in the following ways:
- clients and prospective clients of RedEarth can update their communications preferences (including opting out of participating in surveys) by simply clicking on ‘unsubscribe’; and/ or
- clients, prospective clients and non-clients of RedEarth can:
send a letter to the RedEarth Communications Team, Red Earth Energy Storage,15 Fienta Place, Darra, Queensland, Australia 4076
- or send an email to [email protected]com.au
- advise the RedEarth team that if they receive a marketing call that they no longer wish to receive these calls; and
- use the unsubscribe facility that RedEarth included in our commercial electronic messages (such as emails and SMS) to opt out of receiving those messages.
Notification of source
If RedEarth has collected the personal information that we use to send you direct marketing material from a third party (for example a direct mail database provider), under Australian law you can ask us to notify you of our source of information, and RedEarth’s policy is to do so unless this is unreasonable or impracticable.
3. The kinds of personal information we collect and hold
The type of personal information that the RedEarth collects and holds about you depends on the type of dealings that you have with us. For example, if you:
- join as a client of RedEarth, we collect information including your name, address, contact number, address, email address, employment details, potentially accreditation and CPD details (optional), communication preferences and payment details; and we allocate you an internal client number on our database systems.
- are involved on an advisory discussion or other client groups we obtain your name, address, contact numbers, email, addresses, professional credentials and dietary requirements.
- undertake a RedEarth professional training program, we collect the same type of information as for RedEarth clients, as well as your signature to identify you for post-training examinations
- contact RedEarth with an enquiry, depending on the nature of the enquiry, we record details about you and relating to the enquiry
- attend a RedEarth trade stand at an exhibition or seminar, we collect your contact details and employment details.
- are a supplier to the RedEarth, we collect contact address details, usually including but not limited to all forms of contact and address, billing information and information about the goods or services you supply
- are a sponsor of RedEarth, we collect contact address details, usually including but not limited to all forms of contact and address, and information about the sponsorship;
- buy or otherwise obtain professional information and materials from RedEarth, we collect contact address details.
- apply for a job in RedEarth, we collect the information you include in your application for employment, including your cover letter, resume, contact details and referee reports
- are a client of the general public who contacts RedEarth who elects not to rely on anonymity or pseudonymity, we collect contact address details, usually including but not limited to email addresses and phone numbers and details about the reason for the contact.
In each case, we seek to keep the personal information we need updated and accurate.
3.2. Collection of information through our website
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used.
There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
3.3. What if you don’t want to provide your personal information?
It is RedEarth’s policy is to provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name.
For example, its RedEarth’s policy is to enable you to access our website and make general phone queries without having to identify yourself and to enable you to respond to our surveys anonymously.
In some cases, however, if you don’t provide us with your personal information when requested, we may not be able to respond to your request or provide you with the product or service that you are seeking. For example, you must identify yourself to become a RedEarth client and, if you attend a training exam from the RedEarth training program, we will check your photo ID and/may check your CEC accreditation, to confirm that you are the person who is entitled to sit for the exam.
4. How we collect and hold personal information
4.1. Methods of collection
RedEarth is required by the Privacy Act to collect personal information only by lawful and fair means. If it is reasonable and practicable, we will collect personal information we require directly from you.
RedEarth collects personal information in a number of ways, including:
- by email
- over the telephone
- through written correspondence (such as letters and emails)
- on hard & digital copy forms (including event registration forms, network registration forms, competition entry forms and surveys)
- in person (for example, at job interviews)
- through our website (for example, if you make an online enquiry or complete and submit a web form such as ‘Register for training’ a RedEarth National Installer Program application form, or if you participate in a live chat)
- at seminars and functions (for example, if you fill out an enquiry form or leave us your business card)
- electronic systems such as applications, and
- from third parties, including:
- educational providers that assist us in running our educational programs (including organising and conducting assessments) (Eg Green RTO)
- direct marketing database providers
- public sources, such as telephone directories, CEC website, professional and trade associations,
4.2. Collection notices
Where RedEarth collects personal information directly from you, RedEarth’s policy is to take reasonable steps to notify you, including:
- our identity and how to contact us
- the purposes for which we are collecting the information;
- whether the collection is required or authorised by or under an Australian law or a court or tribunal order;
- the third parties (or types of third parties) to whom we would normally disclose information of that kind;
- whether any of those third parties are located overseas and, if practicable to specify, the countries in which they are located; and
We do this at or before the time of collection, or as soon as practicable afterwards.
RedEarth will generally include these matters in a collection notice. For example, where personal information is collected on a paper or website form, we will generally include a collection notice, or a clear link to it to this policy, on the form.
Where RedEarth collects information about you from a third party, our policy is to take reasonable steps to make sure that you are made aware of the collection details listed above and, if you may not be aware that we have collected the information, of the fact and circumstances of the collection.
4.3. Unsolicited information
Unsolicited personal information is personal information the RedEarth receives that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, RedEarth’s policy is to destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
5. Disclosure of personal information to third parties
Under the RedEarth’s policy, personal information may be disclosed to the following third parties where appropriate for the purposes set out under heading 2 above:
- financial institutions for payment processing;
- persons involved in external dispute resolution involving RedEarth
- RTO’s TAFE’s and other educational service providers involved with or engaged by RedEarth for the redEarth training program
- marketing leads to RedEarth National Installer Program
- referees whose details are provided to us by job applicants
- third parties who have complained about Clients (including to advise them of the conduct and outcome of the complaint)
- RedEarth’s contracted service providers, including:
• information technology service providers
• publishers of our newsletters
• conference organisers
• marketing and communications agencies
• call centres and call training centres (including the third party that conducts client surveys on our behalf)
• mailing houses, freight and courier services
• printers and distributors of direct marketing material
• external business advisers (such as recruitment advisers, auditors and lawyers); and
• transcript recording service providers, in relation to disciplinary proceedings
- law enforcement and regulatory bodies as required by law
- as required or authorised by or under an Australian law or the order of an Australian court or tribunal
- other professional bodies of which a RedEarth client is also a client in relation to disciplinary proceedings; and
- RedEarth may also share personal information with the Clean Energy Council in relation to the professional conduct administration of RedEarth clients and public practitioners’ quality reviews, but only in so far as that personal information is relevant to the other company.
6. Data quality and security
RedEarth holds personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities. RedEarth’s policy is to take reasonable steps to:
- make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant; and
- protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
You can also help us keep your information up to date; by letting us know about any changes to your personal information, such as your email address or phone number.
The steps we take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.
While RedEarth strives to protect the personal information and privacy of website users, we cannot guarantee the security of any information that you disclose online: you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact the RedEarth by phone or post.
If you become aware of any security breach, please let us know as soon as possible.
Third party websites
7. Access and correction of your personal information
Individuals have a right to request access to the personal information that RedEarth holds about them and to request its correction.
8.1. Clients and prospective clients
RedEarth clients and prospective clients can readily correct their own personal information, including changing their communication preferences, by emailing [email protected] .
If you are not a RedEarth client, you can contact our Communications team (details under heading 11 below) if you would like to access or correct the personal information that we hold about you. We may ask you to verify your identity before processing any access or correction requests, to ensure that the personal information we hold is properly protected.
If you ask RedEarth to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, RedEarth’s policy is to take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
If RedEarth corrects personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, RedEarth’s policy is to take reasonable steps to do so, unless this would be impracticable or unlawful.
Timeframe for access and correction requests
Except in the case of more complicated requests, RedEarth will endeavour to respond to access and correction requests within 30 days.
What if we refuse your request for access or correction?
If RedEarth refuses your access or correction request, or if we refuse to give you access in the manner you requested, RedEarth’s policy is to provide you with a written notice setting out:
- the reasons for our refusal (except to the extent that it would be unreasonable to do so); and
- available complaint mechanisms.
In addition, if we refuse to correct personal information in the manner you have requested, you may ask us to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, and we will take reasonable steps to associate the statement in such a way that will make it apparent to users of the information.
If you have a complaint about how RedEarth Energy Storage Ltd has collected or handled your personal information, please contact our Communications team (details under heading 1 below).
They will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within one week.
If your complaint can’t be resolved in the first instance, we will ask you to complete a Complaint Form, which details (for example) the date, time and circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with and how would you like your complaint resolved.
We will endeavour to acknowledge receipt of the Complaint Form within five business days of receiving it and to complete our investigation into your complaint in a timely manner. This may include, for example, gathering the facts, locating and reviewing relevant documents and speaking to relevant individuals.
In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the Complaint Form. If the matter is more complex and our investigation may take longer, we will write and let you know, including letting you know when we expect to provide our response.
Our response will set out:
- what action, if any, RedEarth will take to rectify the situation.
If you are unhappy with our response, you can refer your complaint to the Clean Energy Council or, in some instances, other industry bodies, such as the Smart Energy Council or SEIA
10. Retention of personal data
All personal data that has been collected from you by RedEarth will only be kept for a limited duration that is relevant to the purpose for which your personal data is to be used and for as long as required by applicable law.
11. Further information
Please contact the RedEarth team if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details for privacy queries and complaints are set out below.
RedEarth Energy Storage Ltd
15 Fienta Place, Darra,
Queensland, Australia 4076
P: 1800 733 637
13. Changes to this policy