Marketing

We want to provide you with choices regarding certain ways in which we use your personal data, particularly around marketing and advertising. We have established a marketing communications preference centre where you can view and make certain decisions about how your personal data is used.

Unless you have previously unsubscribed, you may receive our marketing communications (including by post, email and telephone) if you, or the business you work for:

• Currently receive an Iress product or service;
• Have received an Iress product or service in the past;
• Have expressly consented to a third party sharing your contact details with Iress (or to a category in which Iress’ business activities would fall) so that we may send you marketing communications, including where you have attended an event which has been sponsored by Iress and you have agreed to the event organiser sharing your contact details with event sponsors;
• Have expressed an interest in Iress, our products or services by providing us with your contact details for example:

- by email, post or during a conversation with us

- by submitting your contact details via our website or a social media site

- by providing us with your business card or entering into an Iress prize draw or competition

- via a marketing campaign / survey

If you would prefer not to receive any communications or would like to tailor the way we contact you, please visit our preference centre.

Opting out

You can ask us to stop sending you marketing messages at any time by visiting our preference centre and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, we will stop sending you marketing messages but if you are an Iress customer then we will still need to process your personal data for the purpose of supplying you with our products or services.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For detailed information on the cookies we use and the purposes for which we use them, please see our cookies policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Third parties to whom we may provide your personal data

We may have to share your personal data with the parties set out below, or use certain third parties in the course of collecting your personal data, for the purposes set out in the table in paragraph 4 above.

Internal third parties

Other companies in the Iress Group and who are based in Australia, South Africa, Canada, Singapore and New Zealand and provide IT and system administration services, service delivery and payment administration, provision of support services and reporting.

This includes staff engaged in the fulfilment of any contracts we have with you, the processing of your payment details and the provision of support services.

External third parties

• Third party service providers (including contractors and designated agents). We use third party service providers to help us with the following activities: workplace technology (e.g. document management and storage), hosting, communications (including audio and video conferencing) and marketing (e.g. notifications, surveys). Please contact us if you would like to receive a full list of the third party service providers who may process your personal data in the course of assisting us with these activities.
• If you are a client, or a user of our products in an organisation with whom we have a contract - third party processors who we are authorised to use pursuant to our contract with you.
• Professional advisers: including lawyers, bankers, auditors and insurers who provide consultancy and accounting services.
• HM Revenue & Customs, Companies House, regulators and other authorities based in the United Kingdom to whom we have a reporting obligation in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers of your personal data

We may share your personal data within the Iress Group. This may involve transferring your data outside the European Economic Area (EEA).

In addition, some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will always ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (they are subject to a “finding of adequacy”). For further details of countries which are subject to a finding of adequacy, see European Commission: Adequacy of the protection of personal data in non-EU countries.

- Where the country to which we are transferring your data is not subject to a finding of adequacy, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We ensure that there are appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Following an audit by the British Standards Institution (BSI) we have achieved ISO/IEC 270001 accreditation. This is an internationally recognised certificate for best practice framework for managing information security.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider any applicable legal requirements, together with the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

If you require further information regarding the period for which we will retain your personal data please contact us.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or commercial purposes in which case this data will cease to be your personal data and we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to find out more about any of the rights set out above, or wish to exercise any of them, please contact us.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11. Version control

Details of changes to this privacy notice are set out in the table below.

We are required to comply with all applicable privacy legislation in the jurisdictions in which we conduct our business.

Iress Ltd and its branches and subsidiaries ("Iress", "us" or "we") are committed to protecting the personal information we hold.

This privacy notice describes the type of information we collect, how we use and disclose it and how we protect that information. By providing us with your information, you consent to us collecting, using, disclosing and transferring that information as set out in this privacy notice.

Information collected

At times we may request that you supply us with personal information. Generally this information is requested when you subscribe for a product, or request a service or information from us - such as when you request a fact sheet or a demonstration of our products and services.

Personal information which we may collect from you includes the following:

General

your name;

• your job title and company details;
• your address;
• your phone/fax and email details;
• your date of birth;
• payment information such as your bank account details;
• your education and work experience in applications we receive from you;
• your user name, and passwords for our online products;
• information about your internet-enabled device and browsing patterns such as your IP address, operating system and browser type.

Although we generally only collect information that has been provided directly by you, there are times that we may collect information from third parties e.g. a company that provide services to us or an information service provider.

Use of information

Your information is collected and may be used by us:

to verify your identity;

• to meet our legal and regulatory obligations;
• to enable you to use our online products, our website or receive the benefit of certain services;
• to help us improve and develop our website, online products and services;
• to understand our user demographics and use of our website and online products;
• for administration and client relationship management;
• to answer questions and respond to comments, requests or queries you send us, including any application for employment;
• for corporate and investor communications (in compliance with ASIC or other regulator’s requirements); 
• to manage fiscal components; 
• to send invoices or reminder notices or otherwise notify you of changes to our online products or services, and any other purpose related to or ancillary to any of the above.

We may keep your information for a reasonable period for these purposes.

Sharing of information

We may share your personal information with:

the companies in our corporate group; 

• our personnel, subcontractors, agents and advisors who have a need for that information as they assist us in running our business, this website or providing related services; 
• our subcontractors, suppliers and advisors to the extent necessary and relevant for the provision of our online products or services; 
• third party vendors to satisfy our third party data payment arrangements; 
• those other persons we believe are reasonably necessary to comply with our legal and regulatory requirements and/or exercise any rights we have under our contracts

Where we wish to share your personal information with third parties who are not listed above then we shall seek your consent before doing so, unless the data is anonymised (i.e. it doesn’t identify individuals) – in which case we may share the information without first obtaining your consent.

We may disclose your information to members of our corporate group located overseas. Countries in which we are based include Australia, the United Kingdom, Singapore, Malaysia, Hong Kong, South Africa, New Zealand and Canada. We have appropriate controls in place in relation to intra-group transfers.

In addition, we may transfer your information to countries or jurisdictions which do not provide the same level of data protection as the country in which you reside (including without limitation to the US), if necessary for achieving the purposes set out above. If we do make such a transfer, we will, if appropriate, put a contract in place to ensure your information is protected.

By submitting your personal data, you agree to such transfer, storing and processing as set out above. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Use of cookies

Please see our cookies policy.

Marketing

We may share your information with our business partners for marketing purposes or we may send you information about other organisations' products and services. We may contact you by mail, telephone, fax, email or other electronic messaging service with offers of products, services or information that may be of interest to you. By providing us with your contact details you consent to being contacted by these methods for these purposes. If you do not wish to receive marketing information from any companies within our group or our business partners (other than on the website which you have requested information about) please indicate this on the relevant form where we collect your information, or contact us using the details below.

Security

We take appropriate steps and maintain electronic, physical, procedural and organisational safeguards using industry standard techniques and controls to protect the information we hold (including your personal information) from misuse, loss, unauthorised access, modification or disclosure.

Changes

We reserve the right, at our discretion, to change, modify, add or remove portions from this notice at any time so we encourage you to review this privacy notice regularly.

Third Party Sites

Our corporate website contains links to other websites, including social media sites and widgets. We are not responsible for the content or privacy practices (including the delivery of any cookies) of these websites. We strongly encourage you to read the privacy notices and policies of those websites before providing those third parties with your information.

Access and correction

You have the right to access, request corrections to and copies of the personal information we hold about you.  For quality control and training purposes we may monitor or record your communications with us.

Contact

If you have any questions or comments about this privacy notice, or any concerns about our handling of your personal information, please contact our Compliance Manager whose contact details appear below.

If you wish to make a formal complaint, please make your complaint in writing to our Compliance Manager. We will consider your complaint promptly and contact you to seek to resolve the matter.

The Compliance Manager 
Iress Limited
Level 18, 385 Bourke St, Melbourne, VIC, 3000

Phone: +61 3 9018 5800 
Email: corporate@iress.com