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Ajen Privacy Policy

Introduction

Ajen Monitoring Systems and the division Smart Start Interlocks Australia take privacy seriously. Ajen is committed to maintaining the privacy of personal information that is collected from customers, prospective employees, and all parties connected with Ajen.

This document has been created so you can fully understand how your personal information is used in our business. It is important that Ajen is open and transparent about the data we collect and how the data is used.

The document covers all activities of Ajen, and thus all activities of the subdivision Smart Start Interlocks Australia and associated entities, a leading provider of monitoring devices and consumables in Australia.

Ajen is pleased to comply with the Australian Privacy Principles.

Personal Information

Personal information is any information capable of identifying an individual, or where identity can reasonably be ascertained from the information. Examples of personal information include, but are not limited to: an individual’s name, address, phone number, or a photograph.

Ajen services result in data obtained through alcohol interlocks and other monitoring services. This data is classified as personal information, and can be labelled monitoring data for the purpose of this document.

Collection

Ajen only collects personal information for the operation of the business and when required by law.

At or before the time we collect personal information from you, Ajen will take all reasonable steps, including verbal notification and through explanations in the client information booklet and lease agreements (available at the time of installation), to ensure you are aware of:

Personal information will be collected from (i) the forms a client voluntarily submits, (ii) the monitoring device whilst in use, (iii) phone calls with Ajen, (iv) in-person communication, and (v) any other voluntary transactions with Ajen.

Ajen collects personal information where required by law or if the service or product requires it. For example, the type of information collected by Ajen includes, but is not limited to: contact details, license details, concession information (where applicable), customer enquiries, requests, complaints, service details (information regarding the monthly service), other transactional information, and credit reporting data or credit references.

Additionally, monitoring data is collected through Ajen’s services. This includes alcohol interlock data and other monitoring data. Interlock data will encompass all data collected via the interlock device (including logged events and photographs). This data is then used for the primary purpose of Ajen’s business, to provide monitoring of a driver’s BAC in relation to vehicle use. Monitoring data is classified as sensitive information.

Sensitive information

Sensitive information is a special category of personal information, and includes any information or opinion about an individual’s: racial or ethnic origin, political opinion, membership of a political association, religious belief or affiliations, sexual preferences or practices, criminal record. Ajen collects the following sensitive information: (i) monitoring data to be used by the courts, and (ii) limited aspects of an individual’s criminal record (only relating to drink driving offences). This information is required for the performance of Ajen’s business (i.e. to facilitate the alcohol interlock program) and as such, is provided with complete informed consent of the individual. This is outlined in the client information booklet and lease agreements.

Use, retention, and disposal

The use of personal information is strictly limited to (i) the operations of the primary business goal (i.e. to facilitate the relevant state government’s alcohol interlock program), (ii) to direct business operations, and iii) for the purposes of research to improve business operations and governmental programs. Ajen does not sell or use personal information in any way not specified in the client information booklet and lease agreements.

All personal information is retained by Ajen and throughout the service period and is retained indefinitely. All physical documents are stored for a minimum of seven years, and can only be destroyed and disposed of with the permission of the relevant State Government. All digital forms of information are stored indefinitely. Demographic and business transactional data are stored indefinitely, subject to legal requirements.

Storage and Security

Ajen will take reasonable steps to protect the personal information we collect. Data is stored in paper based and electronic form. Paper based data is archived and stored using guidelines under relevant Australian Standards (AS ISO 15489). Electronic Data is encrypted and protected by secure methods by utilising Smart Start Inc’s proprietary software known as Smartrac. Data is stored on computers servers located at the Sydney location of Ultraserve and backed up securely and stored in the Texas location of SSI.

Access

On request, Ajen will take reasonable steps to let you know, generally, what sort of personal information we hold about you, for what purposes, and how we collect, hold, use and disclose such information.

In the case where Ajen holds information about you, you may request access to this information by contacting our head office (contact details found in section 0 of this document). Note that we have identity validating procedures in place to verify an individual’s identify.

However, we have the right to refuse access to this information. Possible reasons for this include:

  1. where providing access would pose a serious threat to the life or health of any individual; or
  2. where providing access would have an unreasonable impact on the privacy of other individuals; or
  3. the request for access is frivolous or vexatious; or
  4. where information relates to anticipated or current legal proceedings and such information would not be accessible through the process of discovery in those proceedings; or
  5. providing access would be unlawful; or
  6. denying access is required by law; or
  7. where providing access would be likely to prejudice an investigation by Ajen or law enforcement agencies.

If access to this personal information is denied, we will notify you of the reason for this restricted access.

If we hold information about you that you establish is not accurate, correct and up-to-date, we will take reasonable steps to correct the information. If we refuse to do so, we will provide reasons for this refusal.

Disclosure

Personal information is limited to certain Ajen employees and approved third parties where required for the operation of business duties. These third parties include each state’s Road Government Agency (NSW’s Roads and Maritime Services; VicRoads; QLD’s Department of Transport and Main Roads; SA’s Department of Planning; Transport and Infrastructure; WA’s Department of Transport; NT’s Department of Transport; ACT’s Road Transport Authority), alcohol education assessors, the relevant courts, and relevant policing bodies.

Ajen employees and approved third parties will not collect, use, disclose, alter, retain or destroy personal information accept in accordance with Ajen, relevant government bodies, approved third parties, the courts, or law enforcement agencies.

Accordingly, interlock service providers are not able to access or view any sensitive information, including monitoring data as defined in section 0. Such providers are only able to view restricted personal information, financial information, and other information required in their business role.

Personal information, including monitoring data and other related information, will be shared with the relevant government bodies and third party assessment agencies where required by contract and law. This is outlined in the client information booklet and lease agreement. Additionally, your monitoring data can be shared with other third parties if you have previously given permission for such an arrangement.

Note that data can be shared with law enforcement agencies where requested.

Trans border data flows

As Ajen is an Australian based company, we will only transfer personal information about an individual to someone (other than the company or the individual) who is in a foreign country if:

  1. We reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the National Privacy Principles; or
  2. The individual consents to the transfer; or
  3. The transfer is necessary for the performance of a contract between the individual and Ajen, or for the implementation of pre-contractual measures taken in response to the individual's request; or
  4. The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Ajen and a third party; or
  5. All of the following apply:
    1. The transfer is for the benefit of the individual;
    2. It is impracticable to obtain the consent of the individual to that transfer;
    3. If it were practicable to obtain such consent, the individual would be likely to give it; or
  6. Ajen has taken reasonable steps to ensure that the information, which it has transferred, will not be held, used or disclosed by the recipient of the information inconsistently with the National Privacy Principles.

As stated in section 0, Ajen stores back up data in servers located within the USA. By transferring data across the national border, we are subject to, and comply with, the requirements of National Privacy Principle 9.

Data quality

Ajen takes all reasonable steps to make sure that the personal information we collect, use, and disclose is accurate, complete, and up-to-date.

Anonymity

Wherever it is lawful and practical, individuals have the option of not identifying themselves when entering transactions with Ajen. However, most of our services require identifiable information.

Employees

Ajen will hold and retain any information provided by potential employees, including personal information outlined in CVs, cover letters and other documents. Ajen will not intentionally collect or store sensitive information regarding potential employees, except where outlined in section 0.

Ajen holds personal information on its employees where required for the operation of the business and when required by law. This includes, but is not limited to: name, date of birth, tax information, bank and superannuation information and all information provided in cover letters and CVs provided to Ajen at the time of employment. Additionally, Ajen requires police checks on employees and third parties for certain aspects of its business (for example, employees performing alcohol interlock services).

Ajen has the right to perform staff and employee drug and alcohol tests as outlined in our workplace Drug and Alcohol Policy.

Internet

Website

The Ajen website can be found at the following address: www.ajen.com.au. For the Smart Start website and Agent Support website, please visit www.smartstartinterlocks.com.au and www.agentsupport.com.au, respectfully.

Visits to the Ajen, Smart Start, and Agent Support websites may be logged. The information we may collect includes, but is not limited to: operating system, your domain name, the address of any linked site which referred you to the Ajen website, your servers IP address, the date and time of the visit, and internal traffic in different areas of the website, including files downloaded.

This information is only able to be collected for internal improvement. This data is not shared or provided to any party or organisation outside of Ajen.

Individuals are able to complete and send through forms on all three websites. Personal information is collected for business purposes, and if this information is not provided we cannot contact you to provide support.

Ajen may use contact details provided to deliver information relating to our products and services via email. If you do not wish to receive such messages, please notify us via email at info@ajen.com.au or info@smartstartinterlocks.com.au, or by phone at 1300 256 900.

Social Media

Ajen makes use of social media and online connection tools. This includes, but is not limited to: Facebook, Twitter, Google Plus, YouTube, and LinkedIn. When contacting Ajen and Smart Start Interlocks via these services, it is important to acknowledge the privacy policies of the respective websites.

Additionally, a Twitter plugin may be used by our website. Twitter functions are offered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. By using these functions, you can share a contribution on Twitter and follow us on Twitter, if you have your own Twitter account. This involves transmitting data to Twitter.

As a provider of websites that host these functions, we have no knowledge of the content of the data transferred to and used by Twitter. Please visit http://twitter.com/privacy for further information about Twitter's data protection and privacy declaration. You can change your privacy preferences at Twitter in your account settings.

Occasionally, we will link to third party websites. Although we make all reasonable efforts to ensure safety and accuracy, we cannot accept any responsibility or liability for these third party websites.

Complaints

Ajen incorporates the criteria set out by Standards Australia AS ISO 10002:2006 (Customer Satisfaction – Guidelines for complaints handling) into its complaint handling procedures. This ensures complaints surrounding compliance to policies and procedures are handled in the same manner as complaints with respect to privacy Ajen Monitoring Systems maintain a complaints register and issues are resolved using guidelines from their Quality management system. If you wish to make a complaint to Ajen, you may contact us on your preferred means. Our details are outlined in Section 0 of this document.

Updates

Ajen maintains a publically accessible Privacy Policy at www.ajen.com, www.smartstartinterlocks.com.au, and www.agentsupport.com.au. Ajen publishes all changes to its privacy policy on our public facing website.

Contact Details

If you have any questions or concerns relating to this privacy policy, please contact us using the following methods:

Ajen Monitoring Systems Pty Ltd

Unit 1/11 Zakwell Circuit
Coolaroo VIC, 3048
Phone: +61 3 8339 2062
Fax: (03) 9303 7386
Email: info@ajen.com.au; info@smartstartinterlocks.com.au

Further Information

Further information relating to privacy can be found at the Australian Federal Privacy Commissioner’s web-site: www.privacy.gov.au