External Privacy and Credit Reporting Policy

This policy sets out how Oji Fibre Solutions (“OjiFS”) collects, uses and discloses “personal information” concerning job applicants, customers, suppliers, guarantors and other third parties. OjiFS includes:

• Oji Fibre Solutions (NZ) Limited (NZBN 9429 035 963 813)
• Oji Fibre Solutions (QLD) Pty Ltd (ABN 63 615 258 234)
• Oji Fibre Solutions (AUS) Pty Ltd (ABN 36 050 218 221)
• Oji Cardboard Carton Solutions Pty Ltd (ABN 29 620 846 719)
• Oji Foodservice Packaging Solutions (AUS) Pty Limited (ABN 41 078 906 500)
  

Scope

This policy applies to all personal information and credit-related information that OjiFS collects from job applicants, customers, suppliers, guarantors and other third parties.

Principles

1. Applicable Laws

The Privacy Act 1988 (Cth) (for Australia) (“Australian Privacy Act”) applies to personal information and credit-related information collected by OjiFS’s Australian entities.

The Privacy Act 2020 (for New Zealand) (“New Zealand Privacy Act”) applies to the personal information collected by OjiFS’s New Zealand entities.

The Australian Privacy Act and the New Zealand Privacy Act are referred to in this policy as “Privacy Legislation”.

2. What is personal information?

“Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable; whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

3. What personal information does OjiFS collect and hold?

The types of personal information OjiFS may collect and hold include, without limitation:

• Name, and contact details (including phone numbers, addresses and emails)
• Details from curriculum vitae and information provided by nominated referees
• Date of birth
• Identification details (such as drivers licence details or other form of ID)
• Details of products and services provided
• Details needed to deliver products and services or answer any questions
• Marketing preferences
• Details held by an individual’s employer (such as job titles)
• Feedback about OjiFS’ products or services
• Financial details including annual earnings
• Payment information (such as credit card or bank details)
• Trade reference details
• Assessments, evaluations, scores and other information relating to creditworthiness
• Credit-related information
• Online identifiers such as cookies and IP addresses
• CCTV footage

OjiFS may also collect sensitive personal information including information about an individual’s financial position, criminal record, or their membership of a trade union or other professional body.

OjiFS collects personal information where an individual:

• Submits a job application to OjiFS
• Provides information to OjiFS in account application forms or through an online inquiry
• Purchases goods from OjiFS
• Contacts OjiFS or where OjiFS contacts an individual (by phone, email or in person)
• Takes part in a competition or survey or subscribes to a mailing list
• Visits OjiFS’ website or online portals

OjiFS may also collect personal information from third parties such as:

• OjiFS’ related companies
• Publicly available sources of information including government database services; social media accounts
• Market research providers
• Credit reporting bodies
• Law enforcement agencies and other government entities
• Trade references
• OjiFS’ service providers who collect information on OjiFS’ behalf, including recruitment or temporary staffing agencies, background check providers, former employers
• An individual’s authorised representatives or legal advisors

An individual may choose not to share their personal information with OjiFS. In such cases, OjiFS may be unable to progress an individual’s application for employment, to provide products or services to that individual, or may be delayed or prevented from fulfilling contractual or legal obligations.

5. How does OjiFS use personal information?

OjiFS may use personal information for any of the following purposes:

• For the particular purpose for which an individual shared personal information
• To assess a person’s eligibility for employment at OjiFS
• To provide products and services
• To maintain, manage and develop OjiFS’ relationship with customers, potential customers, suppliers and service providers
• For marketing purposes
• To carry out market research and analysis and improve the provision of goods or services
• For internal administrative purposes, such as (but not limited to) procedural assessment, risk management, staff training, accounting, billing, product and service reviews
• To assess eligibility to be provided with credit
• To assess credit history, including creditworthiness or credit capacity
• To process payments and to assist in the collection of overdue payments
• To monitor activity on OjiFS’ websites
• To identify and inform third parties about other products, services or offerings that may be of interest
• To monitor security when an individual attends OjiFS’ premises
• Managing insurance
• For the purposes of law enforcement and court proceedings
• For any other purpose required or permitted by Privacy Legislation or applicable law

6. Disclosure of personal information

OjiFS may disclose personal information:

• For the purpose for which it was collected
• To third parties, in circumstances where an individual would reasonably expect OjiFS to do so
• As otherwise permitted by Privacy Legislation

The types of third parties to which OjiFS may disclose personal information include:

• OjiFS’ related companies
• Professional advisors and service providers (such as lawyers, accountants, data storage providers, IT service providers)
• A proposed purchaser of OjiFS’ business and assets
• Debt collection agencies and other parties that assist with debt recovery
• Government and regulatory authorities
• Credit reporting bodies, for the purposes permitted under Privacy Legislation

7. Credit-related information

OjiFS discloses personal information to credit reporting bodies in order to obtain credit-related information from them. Those credit reporting bodies use that information to carry on their credit reporting business.

Credit-related information means both:

• Credit information, which is information which includes an individual’s identity; the type, terms and maximum amount of credit provided to an individual, including when that credit was provided and when it was repaid; repayment history information, financial hardship information (including information that any repayments are affected by a financial hardship arrangement) and default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information; and publicly available information; and
• Credit eligibility information, which is credit reporting information and any information that OjiFS derive from it.

OjiFS may use credit-related information to confirm an individual’s identity, assess creditworthiness and an individual’s capacity to be a guarantor.

Credit reporting bodies may include information about an individual in reports provided to other credit providers to assist them to assess credit worthiness. An individual can ask a credit reporting body not to use their credit report for the purposes of pre-screening or direct marketing.

OjiFS may share personal information with the following credit reporting bodies:

• For New Zealand customers: CreditWorks Group Limited: www.creditworks.co.nz
• For Australian customers: CreditorWatch Pty Ltd: www.creditorwatch.com.au

A copy of the Credit Reporting and Privacy Policies of the above credit reporting bodies is available through their websites. An individual may contact them to make a complaint. If an individual believes on reasonable grounds that they are, or are likely to be, a victim of fraud, they may request that the credit reporting bodies do not use or disclose their credit information.

8. Transfer of information overseas

OjiFS may disclose personal information and credit-related information to overseas recipients, including to OjiFS’s related companies in New Zealand, Australia, Hong Kong, Malaysia, or Japan.

9. Retention and destruction of information

OjiFS will keep personal information and credit-related information for as long as is necessary to meet the purpose for which it was collected, or as otherwise required by law. When OjiFS no longer requires this information, OjiFS may destroy or dispose of that information in a secure manner, or permanently de-identify it.

10. Third party websites

An individual may follow a link from OjiFS’ website to a third party’s website. OjiFS is not responsible for the treatment of personal information submitted to that third party through its website. Third parties will collect and use personal information in accordance with their own privacy policies.

11. Updates

OjiFS may revise or update this Privacy Policy from time to time. The most recent version of OjiFS’ Privacy Policy will be available at www.ojifs.com. This policy was last updated in June 2023.

12. Contact Us

If an individual:

• has any questions about this Privacy Policy
• wishes to correct or update information OjiFS holds about them
• wishes to request access to or correction of personal information or credit-related information
• wishes to make a complaint about a breach by OjiFS of Privacy Legislation (including the way OjiFS has collected, disclosed or used personal information or credit-related information),

OjiFS’s Privacy Officer may be contacted at:

Oji Fibre Solutions

Private Bag 92106

Auckland 1142

Email: legal@ojifs.com

OjiFS will provide a response as soon as practicable. In some cases, in accordance with Privacy Legislation, OjiFS may charge a fee for access to information or refuse to provide access.

13. Complaints

If an individual is unhappy with the way OjiFS handles a complaint or a request to access information, that individual may contact the Office of the Australian Information Commissioner or the New Zealand Privacy Commissioner. Their respective contact details are available at www.oaic.gov.au and www.privacy.org.nz.