GM Holden Ltd (Holden) recognises the importance of protecting an individual’s privacy. We appreciate that individuals are concerned about the security of their personal information and we are committed to protecting any personal information we hold.
Personal information is information or an opinion about an individual who is reasonably identifiable.
Holden dealers are independent of Holden and have privacy policies which differ from ours. Holden dealers are responsible for their own privacy policies and privacy practices. Please contact your Holden dealer directly for further information.
COLLECTING PERSONAL INFORMATION
Holden will be fair and open about the way we collect information about you and what we intend to do with the information.
Holden may collect and hold personal information about you such as your name, address, telephone number, driver’s license, date of birth, your vehicle’s vehicle identification number, registration date, registration number, change of address and telephone information, amount of your GM Holden MasterCard rebate and the expiry date of your rebate points, and any other information you may voluntarily provide to us.
Holden collects most personal information directly from you, for example when you provide information through market surveys, product focus groups, the websites operated by Holden, Holden’s customer assistance service (Customer Care) via mail, email and telephone enquiries, and during the recruitment process. Third parties may also share information with us, including our Dealers (such as vehicle purchasing, servicing and warranty information), related companies and Westpac (if you have a GM Holden MasterCard, Westpac provides Holden with some information for the purposes of ensuring that card holders are able to claim their GM Holden MasterCard rebate when purchasing an eligible Holden vehicle). We may also collect your personal information if you enter a competition or promotion we run (either directly or through our marketing agents), or through a recruitment or employment agency.
We may collect information about Dealer staff directly from those staff or from our Dealers, and about staff of our suppliers directly from those staff or from other staff of those suppliers. The information we collect about Dealer staff may include your name, position, contact details and training records. The information we collect about staff of our suppliers may include your name, position and contact details.
Other than the personal information set out in this policy, Holden does not collect any credit information about you. If we receive information about you from a third party, wherever practical we will make sure they undertake to comply with the Privacy Act.
Holden vehicles, like other modern motor vehicles, have a number of sophisticated computer systems that monitor and control several aspects of the vehicle’s performance. Holden vehicles use on-board vehicle computers to monitor emission control components to optimize fuel economy, to monitor conditions for air bag deployment and, if so equipped, to provide anti-lock braking and to help the driver control the vehicle in difficult driving situations. Some information may be stored during regular operations to facilitate repair of detected malfunctions; other information is stored only in certain collision events by computer systems, such as those commonly called event data recorders (EDR). The information from EDR’s, if available, is used to improve customer and driver safety, better understand what happens to our vehicles in the event of a collision and shall be provided to the police on request.
USING PERSONAL INFORMATION
Holden only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by an Australian law or court or tribunal order.
We may use personal information we collect about you for a number of purposes including:
- to tell you about other products and services that may be of interest to you;
- to learn more about your level of satisfaction, your expectations of us and our Dealers and how we can meet them (for example, in relation to Holden’s products and services, and the products and services provided by Dealers and contracted service providers such as Roadside Assistance);
- to ensure that any warranty claim is properly administered;
- to run a competition or promotion you have entered;
- to consider you for a position at Holden for which you have applied;
- to acquire goods or services from you or from your employer;
- to ensure that you are contacted as soon as possible in the event of a safety-related product recall;
- to improve driver safety and to better understand what happens to Holden vehicles in the event of a collision;
- for other purposes to which you have consented; and
- as required or permitted by relevant laws and regulations.
Generally, we may use your personal information for the purposes for which we collected it and for related purposes which would be reasonably expected by you.
If you do not provide your personal information, Holden is less able to perform the above functions.
DISCLOSING PERSONAL INFORMATION
Holden may need to disclose personal information outside of the jurisdiction from which it was collected. When we disclose your personal information overseas, Holden is generally required to take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia. In relation to health information about an individual, we will generally only disclose the information outside of the state or territory where we collected it if we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which upholds principles for fair handling of the information that are substantially similar to the principles that apply in the state or territory of collection.
We may disclose personal information we collect about you for different purposes including:
- to assist our related companies (such as General Motors and Holden New Zealand) and other service providers (such as information technology service providers, payroll service providers, recruitment service providers, third parties that provide services in relation to Holden’s internal feedback and reporting programs i.e. Awareline program, service providers who assist us with “onboarding” new staff, mailing houses, Holden Assist, Holden Roadside Assistance) so that they can provide the services that we have contracted out to them;
- to provide information to our Dealers so that they can provide goods or services to you or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you;
- to your nominated referees so that we may check your references if you are applying for a position with Holden; and;
- as required by relevant laws and regulations.
Holden may disclose personal information to such entities located in the following countries/regions:
- the USA;
- other countries in Europe;
- South America;
- Asia; and
- the Middle East;
We will not sell, rent or trade your information to/with any other organisation.
We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to Holden collecting, using and/or disclosing your personal information, this may affect Holden’s ability to deliver and improve its products and services.
MARKETING AND PRIVACY
Holden sends marketing materials to its customers and other people who have provided Holden with personal information from time to time about products and services offered by Holden, its Dealers and its affiliates.
If you do not wish to receive marketing materials from Holden, its Dealers or its affiliates, please complete the opt-out provision on the marketing information sent to you and return it to Holden (or contact Holden Customer Care on 1800 033 349 or at email@example.com). Holden will note your request and respect your wish not to receive any marketing materials.
If you choose not to receive any marketing materials from Holden, you may miss out on special product and service offerings and opportunities.
PROTECTING PERSONAL INFORMATION
Holden will keep your personal information secure by taking reasonable steps to protect it from misuse, loss and unauthorised access, modification and disclosure.
Holden stores personal information in transmission logs and archive systems for a period Holden considers reasonable depending on the primary purpose for which that information was collected. Only properly authorised people who have a need to access personal information to perform their job will be able to see or use that information. The physical and electronic security systems at Holden comply with the guidelines of the Information Commissioner.
Personal information will be de-identified or destroyed when it is no longer required such that it cannot be re-identified at a later date. The de-identification and destruction process will be in accordance with the guidelines of the Information Commissioner.
Holden will ensure that its employees receive training (and refresher training) about the management of personal information relevant to their respective roles and responsibilities.
ACCESSING AND REQUESTING CORRECTION OF PERSONAL INFORMATION
We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under the privacy legislation, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your personal information we will tell you why.
If you wish to obtain access to and/or correct your personal information held by Holden, please contact Holden Customer Care on 1800 033 349 or email us at firstname.lastname@example.org.
Holden will provide written acknowledgement of receiving your request for access within 7 days of receipt. Unless it does not agree to your request for access to personal information, in most cases Holden will provide you with access within 30 days of receipt of your request. If you request corrections to your personal information and Holden agrees with your request, these changes will be made as soon as practicable. If Holden does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you remain dissatisfied you may also complain to the Information Commissioner (at www.oaic.gov.au).
RESOLVING YOUR CONCERNS
If you have a complaint regarding Holden’s management of your personal information, please prepare your complaint in writing and email it to us at email@example.com.
Holden will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint.
PRIVACY AND Holden EMPLOYEES
However, Holden recognises that employee records should nevertheless be handled carefully, and Holden will comply with any obligations that may apply to employee personal information under other applicable laws.
Holden may disclose personal information held in its employment records for different purposes including: to our related companies (such as General Motors and Holden New Zealand) and to service providers (such as information technology service providers, payroll service providers, recruitment service providers, third parties that provide services in relation to Holden’s internal feedback and reporting programs i.e. Awareline program and service providers who assist Holden with “onboarding” new staff) so that they can provide the services that Holden has contracted to them to perform.
Holden employees may seek to access, update or correct the personal information which Holden holds about them by contacting their Human Resources Manager. Such requests will be assessed on a case by case basis.
(a) independent contractors;
(b) secondees into Holden who remain employees of the seconding client or firm;
(c) voluntary work experience students; or
(d) job applicants.