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Privacy Policy

APP Privacy Policy

Airnorth adheres to the Australian Privacy Principles that came into effect on 12 March 2014 pursuant to the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988.

Airnorth has adopted the following Policy in relation to the collection, use, storage, security and disclosure of personal information including personal information given to Airnorth by third parties.

Note:  The APP Privacy Policy applies to Airnorth employees and customers.

Collection of Information
Airnorth will collect personal information by lawful and fair means and not in an unreasonably intrusive way.

Personal information collected
Airnorth will only collect personal information about an individual that is necessary for one or more of its functions or activities. This may include the individual’s name, address, telephone number, date of birth, email address, social media handle and identification including drivers licence, passport and proof of age card with current address.  Supporting documents that provide evidence of current residential address such as utility bills, rates notice, bank statement etc may be collected.

Sensitive information collected
Airnorth may also collect sensitive information.

For employees, this may include membership of a professional or trade association, tax file number, bank details, criminal record and medical information.

For customers, this may include membership to loyalty programs, credit card details, health and special medical or access assistance or dietary requirements relating to religious beliefs.

Airnorth will not collect sensitive information about an individual unless:

  • the individual has consented
  • collection is required or authorised by law
  • the information is required to establish or defend a legal or equitable claim
  • the individual is incapable of consenting and the information is needed because of a serious and imminent threat to the life or health of the individual.

Information collection mechanisms
How personal information is collected will depend on Airnorths relationship or interactions with an individual, both directly and indirectly.

For employees, personal information may be collected directly during the recruitment processes, via reservations, during a survey, online and via social media.  This information may be held in hard copy personnel files and/or electronically on a secured company drive.

For customers, personnel information may be collected via the reservations department, the website or social media, when individuals write or call Airnorth. Interactions may also be in person when individuals use Airnorth services or participate in promotions.  This information will be held electronically on Airnorth’s server.

Indirectly
There may be occasions when Airnorth collects information about an individual indirectly such as:

  • Airline and non-airline partners participating in Airnorth programs
  • travel agents, booking agents and other airlines, including when individuals make an inquiry but do not complete a booking
  • When a third party books or purchases good or services on behalf of others
  • Our service providers
  • Airports and their service providers
  • Freight and associated service providers
  • Third parties that provide Airnorth with marketing leads
  • Immigration, customs, border, security, law enforcement and other government and regulatory authorities
  • Businesses for whom we provide marketing and data analysis services
  • Providers of third-party websites, apps and social media platforms

If information about other individuals is provided, regardless of whether they are travelling together, that individual is responsible for telling those individuals and letting them know that they can find a copy of this Privacy Policy on the Airnorth website.

Company Requirements
At the time of collection (or as soon as practical afterwards), Airnorth will take reasonable steps to ensure the individual is aware of:

  • the identity of Airnorth and how to contact it
  • the fact that he or she is able to access the information
  • the purpose for which the information is collected
  • the organisations or type of organisation to which Airnorth may disclose the information
  • any law that requires the particular information to be collected
  • the consequences (if any) for the individual if all or part of the information is not provided.

Use and Disclosure

Primary Purpose
Airnorth will use and disclose personal information about an individual to achieve the purpose for which it was collected.

For employees, this may include recruitment, training, performance management, terms and conditions of employment, emergency contact details, professional memberships, leave entitlements and processing the payroll.

For customers, this may include processing travel arrangements or freight requirements, applying discounts, enabling participation in loyalty programmes and arranging and facilitating the safe travel of unaccompanied minors, carers or customers requiring medical assistance.

Secondary Purpose
Airnorth will not use or disclose personal information about an individual for any purpose other than the primary purpose unless:

  • the individual has given consent
  • there is a related secondary purpose within the individual’s reasonable expectation, or
  • there are specified law enforcement, public health or public safety issues.
  • The conditions for the use and disclosure of personal information are detailed in Australian Privacy Principles published in the Australian Government Office of the Australian Information Commissioner (http://www.oaic.gov.au/).

For employees, this may include employment references, confirmation of employment details for financial or property businesses, for the health and safety of the employee or for statistical purposes.

Due to the nature of its activities, Airnorth may be required to disclose personal information to government agencies or other entities for airline and passenger security purposes.

Airnorth may also disclose personal information to third parties, such as contractors, it uses to fulfil services to customers. At present, Airnorth uses contractors to:

  • provide catering services
  • provide ground handling facilities
  • conduct market research and marketing activities
  • process travel bookings received online
  • process credit card payments
  • co-ordinate the collection of monies from trade debtors.

In these situations, Airnorth will prohibit the third party contractor from using the personal information except for the specific purpose for which it was supplied.

Direct Marketing
Airnorth may use and disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing when:

  • the information was collected from the individual; and
  • the individual would reasonably expect Airnorth to use or disclose the information for that purpose; and
  • the individual may request not to receive direct marketing communications; and
  • the individual has not made such a request to Airnorth.

Airnorth may also use and disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing when:

  • the information was collected from the individual and the individual would reasonably expect Airnorth to use or disclose the information for that purpose; or it is impractical to obtain that consent; and
  • the individual may request not to receive direct marketing communications; and
  • in each direct marketing communication with the individual; a prominent statement is included that the individual may make such a request or Airnorth draws the individual’s attention to the fact that may make such a request; and
  • the individual has not made such a request to Airnorth.

 Airnorth may use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.

Request not to receive Direct Marketing
An individual may request not to receive direct marking communications and request Airnorth not use or disclose of the information and request where the source of the information if obtained from another organisation. 

Airnorth will respond to such requests within a reasonable timeframe.

Data Quality and Security
Airnorth will take reasonable steps to:

  • ensure that the personal information it collects, uses or discloses is accurate, complete and up-to-date
  • protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure
  • destroy or permanently de-identify personal information if it is no longer needed for the purposes for which the information may be used or disclosed under the Australian Privacy Principle.

Access and Accuracy
An individual may request to view the personal information Airnorth holds about him/her.

Airnorth will provide the information unless there is an exception which applies under the Australian Privacy Principles. If the request is refused, Airnorth will provide the individual with the reason(s) for the refusal and consider whether the use of a mutually agreed intermediary will allow sufficient access to meet the needs of both parties.

Airnorth may charge for allowing access to personal information but such charges will not be excessive and will not apply to the lodgement of a request for access. The charges will be advised so far as practicable, prior to the request being processed. The request may not be processed if the fees are not paid.

Airnorth will take reasonable measures to update and correct details as and when notification is received.

Anonymity
Where it is lawful and practicable, individuals will have the option of not identifying themselves when entering into transactions with Airnorth.

Transfer of Information Overseas
Where information is sought from overseas in relation to a customer, the customer must consent to the transfer of information and the recipient must be in a jurisdiction that has comprehensive privacy laws.

Airnorth may do this if:

  • it reasonably believes that the recipient of the information is subject to a law, similar binding scheme or contract to the Australian Privacy Principles
  • the customer consents to the transfer
  • it is impracticable to obtain the customer’s consent or it is likely that the customer will give consent
  • the transfer is for the customer’s benefit
  • the transfer is necessary to perform the airline’s contract with the customer.

Overseas recipients of personal information are likely to be located in Timor Leste if the customer is planning to travel to Timor Leste.

Availability of the APP Privacy Policy
The APP Privacy Policy is included in the Corporate Policy and Procedures Manual and is available on the Airnorth website.  A copy may also be provided by the Privacy Officer on request.

Complaints
Complaints about a breach of the Australian Privacy Principles may be made in the first instance to the Privacy Officer.  The complaint will be investigated by the Privacy Officer

Privacy Officer
Airnorth has appointed a Privacy Officer to deal with any enquiries or issues that may arise out of the APP Privacy Policy.

The Privacy Officer can be contacted as follows:
Safety and Compliance Manager
Airnorth
PO Box 39548
WINNELLIE NT 0821
Phone: 08 8920 4017
Email: compliance@airnorth.com.au