FrontFoot Academy Pty Ltd ABN 92 661 780 347, FrontFoot Technologies Pty Ltd trading as Front Foot Law ABN 14 627 976 747 and their related bodies corporate (collectively referred to as Front Foot) are committed to managing personal information in accordance with relevant local privacy and data protection laws which apply to us, such as the Australian Privacy Principles under the Privacy Act 1988 (Cth), the General Data Protection Regulation (EU) 2016/679 (EU GDPR) and the Data Protection Act 2018 (UK) (UK GDPR).
Front Foot collects and administers a range of personal information for administration and business purposes. The kinds of personal information we collect and hold about you depends on the circumstances in which it is collected, including whether we collect information from you as a prospective client, customer, contractor, supplier, job applicant, employee or in some other capacity. Some of our main relationships and dealings are described below.
We only collect the personal information of clients where enquiries are made about or services or products, where it is reasonably necessary for or related to our activities. The types of personal information we may collect in such circumstances include name and contact details (such as email, telephone number, title and organisation).
When you enquire about our services or products, or become our customer, a record is made which includes your personal information. The type of personal information collect varies with the circumstances and service you request from us, but will typically include:
In rare and specific circumstances, we may collect what is classified as “sensitive information” under applicable privacy laws. We only ever do this to the extent such sensitive information is relevant to our functions and activities, and in accordance with applicable privacy laws.
We collect personal information when recruiting personnel, such as your name, title, date of birth, contact details, qualifications and work history (including references and information in a CV or cover letter as part of the application process). Generally, we will collect this information directly from you. We may also collect personal information from third parties in ways which you would expect (e.g. from recruitment agencies, employment websites or your referees). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions. We may also collect information from third party sources, including information from publicly accessible online profiles (such as LinkedIn).
Front Foot may collect personal information about others such as service providers, contractors and other individuals who interact with us on a commercial basis. The kinds of personal information we collect depends on the capacity in which you are dealing with Front Foot. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.
The way in which we handle the personal information of visitors to our websites is discussed below.
You can always decline to give Front Foot any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
Front Foot collects personal information reasonably necessary to carry out our business, to assess and manage our clients and customers’ needs, and provide products and services to you. We may also collect information for associated administrative functions e.g. billing, entering into contracts with you and/or third parties and managing customer and other business relationships. The purposes for which we usually collect and use personal information may include:
Front Foot generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
Front Foot also collects and uses personal information for market research purposes and to innovate delivery of our products and services.
We may use third party tracking tools to improve the performance and features of our websites, which are designed to collect information about website use without making you identifiable from the information. Such tools are created and managed by parties outside our control, and we are not responsible for what information may be actually captured by such third parties or how those third parties use and protect that information.
We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our website, if any, as well as the name of the website to which you’re headed when you leave our website. This information also includes the IP address of your computer/proxy server that you use to access the internet, your internet website provider name, web browser type, type of mobile device and computer operating system. We use all of this information to analyse trends among our visitors to our websites to help improve our websites.
Front Foot’s websites may contain links to third party websites. Front Foot is not responsible for the content or privacy practices of websites that are linked to our website.
Front Foot will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is not practicable for Front Foot to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, we may not be able to provide you with our products or services.
Front Foot takes reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. We store information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas). Front Foot maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security e.g. we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
We will only keep the personal information we collect about you for as long as necessary for the purposes set out in this Privacy or as required to comply with legal obligations to which we are subject. We take steps to destroy or de-identify information that we no longer require or as required by applicable law.
The purposes for which we use and disclose your personal information depends on our relationship with you. We will generally only use and disclose your personal information to respond to your queries, or to ensure our products and services comply with safety and quality assurance requirements.
Front Foot may disclose information to third parties we engage to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research. Personal information may also be shared between related and affiliated companies of Front Foot. Third parties to whom we disclose your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Front Foot will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
We may share your personal information with third parties to facilitate a transfer or sale of all or part of our assets or business or if we undergo or contemplate any corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity.
Front Foot may use or disclose your personal information for the purpose of informing you about our products and services, upcoming promotions, or other opportunities that may interest you. Under certain privacy laws we do not need your consent to send you marketing communications. Where consent is required, we will ask for this consent separately and clearly. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message. If you opt-out of receiving marketing material from us, we may still contact you about our ongoing relationship with you.
Front Foot works with customers, client, service providers and commercial interests across the globe. Your personal information may be disclosed to overseas recipients, including service providers who may handle, process or store your personal information on our behalf. We will only disclose yourpersonal information outside the jurisdiction it was collected where permitted under applicable laws. We take reasonable steps to ensure your personal information is treated securely, including entering into agreements with standard contractual clauses or equivalent measures.
If the EU GDPR or UK GDPR applies to you, you have the following additional and specific rights in relation to your personal information (where applicable):Access: To request a copy of any personal information we hold about you. Any request for a copy of your personal information must in writing. We will respond within a reasonable period and within one month (in compliance with the EU GDPR and UK GDPR).
Rectification: To rectification of your personal data if you believe it is inaccurate.
Deletion: To ask us to delete personal information we process about you, unless we need to retain it to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction: To restrict processing of your personal information if you believe it is inaccurate, our processing it to be unlawful, or we no longer need to process it (but we are unable to delete it due to a legal or other obligation, or because you do not wish for us to delete it).
Portability: To transfer a copy of your personal information to you or to another service provider or third party where technically feasible.
Objection: To object to your personal information being processed for a particular purpose or ask us to stop using your information.
Complaint: To lodge a complaint with the local data protection authority if you are unhappy with our treatment of your personal information, and you have contacted us as set out below.
Withdrawing consent: To withdraw, at any time, any consent you have previously given us to use your personal information. In certain circumstances even if you withdraw your consent, we may still process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations. To make a request to exercise any of these rights, please contact us using the contact details below.
You are entitled to access your personal information held by Front Foot on request. To request access to your personal information please contact Front Foot using the contact details set out below. We will take reasonable steps to ensure the personal information we collect, use or disclose is accurate. You can help us do this by letting us know if your personal details change or you notice errors in information we hold about you. If you believe any personal information we hold about you is inaccurate you can request we correct it, and we will take reasonable steps to correct it.
If your complaint requires more detailed consideration, we will generally acknowledge receipt and complete our investigation into your complaint promptly. We may request further information about your complaint and desired outcome then gather relevant information and documents. We will usually investigate and respond to complaints within 30 days of receipt. If it takes longer, we will let you know.
If you are not satisfied with our response to your complaint, or you believe we may have breached the Privacy Act or Australian Privacy Principles, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or at www.oaic.gov.au.
If you are located in Europe, you can take your complaint up with the local European Data Protection Authority. A list of the local authorities can be found on the European Data Protection Board’s website: https://edpb.europa.eu/about-edpb/about-edpb/members_en data protection. If you are located in the UK, you can take your complaint up with the Information Commissioner’s Office by telephone 0303 123 1113 or by using the contact details on the website: https://ico.org.uk/.
The contact details for Front Foot are:
Suite 702, Level 7
488 Bourke Street
MELBOURNE VIC 3000
+61 (0)3 8692 7235