This policy is to establish the means for the Varley Group to comply with the requirements of the Privacy Amendment (Enhancing Privacy Protection) Act 2012.


All personal information collected by the Varley Group is covered by this Policy other than information collected as part of Employee Records.


The Varley Group is committed to protecting personal information it collects from people including but not limited to:

  • Customers, suppliers and contractors who are natural persons;

  • Prospective employees;

  • Visitors.

The Varley Group will only collect such personal information that is reasonably necessary for or directly related to business operations and associated activities. Information will only be collected with the knowledge and consent of the individuals concerned and only by means that are fair and lawful.

The types of personal information the Varley Group will collect and the reasons for this collection are outlined in the table below:

What personal information is collected

The purpose for which personal information is collected

Person’s name

Email address

Postal address

Telephone number/s

Position title / organisation

Identification of visitors to a Varley Group site

Respond to an enquiry about products and / or services

Industry networking

Potential suppliers

Potential customers

Potential service provider / contractor

How information is collected

How information is held

Individuals presenting in person

Individuals make contact with the Varley Group:

Via website enquiry form

At meetings and trade shows

By email

By phone

Hard copy to be scanned, then destroyed

Electronic copy stored on restricted access network drive with appropriate access protocol


The Varley Group will establish, implement, review and update processes to ensure that it complies with all relevant requirements of the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Australian Privacy Principles.

A person about whom personal information is collected, held and used may seek to have access to that information at any time by making a request to the HR Manager In the event that the person seeks to have inaccurate information corrected, this request must be made in writing. The record will be amended within 7 days of such a request being made. No fees or charges will apply to a person seeking to access information about themselves and / or seeking to have a correction made to such information.

In the event that the Varley Group is compelled by law to disclose personal information it holds reasonable efforts will be made to advise the person of this disclosure provided that in doing so the Varley Group is not contravening a lawful instruction. In any case, the Varley Group will make a written note on the relevant file that such a disclosure was made.

Unsolicted personal information and personal information that is no longer required by the Varley Group will be securely and confidentially destroyed.

A person who wishes to make a complaint about the collection, use, accuracy or disclosure of information about themselves must address the complaint to the Managing Director.

All employees must comply with the established processes to ensure that personal information is collected and used for a legitimate purpose and that all personal information is properly controlled. Anyone found to be in breach of this policy will be subject to disciplinary action.