PRIVACY POLICY

1 Introduction

This Privacy Policy relates to the processing of personally identifiable information (PII) as defined by the Privacy Act 1988 (Privacy Act) of Australia / EU General Data Protection Regulations (GDPR).The policy sets out the different areas where user privacy is concerned and outlines our obligations to you when collecting, storing and securing your personal information.

Sequoia-Services (Sequoia) needs to process personal information to support the delivery of products and services (as outlined below). Although exempt from specific requirements of the Privacy Act, we endeavour to apply the same protections and security controls to all personally identifiable information processed by Sequoia-Services (Sequoia) .

Additionally, as our services, surveys and questionnaires are open to completion by individuals located in the EU we are also required to comply with the General Data Protection Regulation (GDPR).

The main contact for GDPR or Privacy issues is Yvonne Sears, Director. Privacy@Sequoia-Services.com

This Privacy Policy is updated annually or when significant changes to how we process personal information occur. We will publicise on our website when significant changes occur, or in special circumstances where changes affect you personally, will contact you via email.


2 Processing Activities

We may process personal information for:
   • Management of general enquiries
   • Membership
   • Training Events
   • Webinars
   • Survey’s and questionnaires
   • Recruitment

The following outlines the objectives and type of information processed.

2.1 General Enquiries
Our website provides the opportunity for individuals to contact us for more information about our services. At this stage we only collect:
   • Name
   • Email Address
   • Subject
   • Message
These queries go through to a dedicated email account accessed only by Sequoia personnel who have a right to access.
Information may be collected on an opt-in (voluntary) basis for making contact by email or phone and for making use of website features such as the Sequoia Portal.
Once your query is closed your contact information will be erased unless we obtain explicit consent from you to maintain contact.

2.2 Membership
Sequoia relies on Partners throughout Australia and Internationally to bring you our unique service(s).
Your Sequoia membership agreement is direct with a Partner of your choosing, who is required to send Sequoia the following personal information:
   • Name
   • Contact Number
   • Email Address
   • Organisation Name
This information is only used to administer your account, to verify who you are on access to the portal and to keep you informed of changes, provide the latest information and blogs relevant to the membership group.
Your personal information will not be used by Sequoia for any other purpose or marketing activities that are not associated with membership offerings. Once you have cancelled your membership or your membership has lapsed, we will retain your account for a period of up to 6 months, in case you wish to reinstate your membership within that time without losing your membership history.

We have been very careful with who we have selected as Partners and they each have their own Privacy Policy outlining the information they collect about you, as appropriate and should be referred to within your contract agreement.

2.3 Training Events
Any training events that require a registration will specify the personal information to be collected as well as its purpose, at the time of collection. Typically, we will maintain a register containing:
   • Name
   • Contact Number
   • Email Address
   • Organisation Name
   • Date of training
   • Pass rate
   • Training history
   • Comments / Feedback
This information is only processed for:
   • The provision of training and awareness programs
   • Maintenance of your training history with Sequoia
   • Providing you information about upcoming events and training opportunities
If you choose to unsubscribe or request your account to be closed, requiring no further marketing from us, we will freeze your account for 6 months before removing your data. This is required should you need copies of training provided or wish to re-engage us for training.

If however, the time is lapsed and you rejoin after this 6 month freeze, then your training history will no longer be available.

2.4 Webinars
Any webinars that require a registration will specify the personal information to be collected as well as its purpose, at the time of collection. Typically, the information collected for a webinar will be limited to:
   • Name
   • Email Address
   • Organisation Name
This information is required to facilitate the webinar and send out a reminder or post webinar information.

We do not hold the information collected after the event unless you’re already a member or have authorised us to maintain contact. This will be outlined at the point of registration.

2.5 Survey’s and questionnaires:
From time to time we collect very basic personal information through questionnaires and surveys on our website to better define services offered by us, and to ensure that the advice and guidance is appropriate to your needs. Surveys and questionnaires are provided to you via email or through our website.
We typically collect the following demographics:
   • Name
   • Contact Number
   • Email Address
   • Organisation Name
At the time of completing the online requests for personal information you will be informed as to the purpose of data collection.
Results of surveys are tracked and stored in a database for future analysis and evaluation. This information is used to refine the services and future information sessions, blogs and training services.

We will retain personal information for up to 1 year (unless deletion is requested by the data subject) after last contact with an individual for the purpose of offering services related to the original survey.
Your details will not be passed on to any third parties.

2.6 Recruitment
We will from time to time collate and be in receipt of résumés from prospective employees.
Records are likely to include:
   • Name
   • Address
   • Salary expectations / Reward
   • Previous employment details
   • Education
   • References
Our recruitment process is supported by professional recruitment services who will process personal information specifically for candidate selection and assessment. You may be required to complete an online Psychometric test as part of the recruitment process which will enable us to determine not only your suitability for the role but will be used to support your personal development thereafter. You are more than welcome to obtain a copy of the assessment regardless of whether you are successful.

If you are a successful candidate we will also request to collate the following as required by statutory requirements for employment in Australia:
   • Evidence of Education
   • References
   • Police Check
   • Visa / Passport / Birth Certification – to verify your ‘right to work’ in Australia
We retain résumés and contact details for up to 3 months if there is not an immediate opportunity available for you. At this point we will either delete the information or contact you to request consent to further retain your details if we believe that you remain a good fit for the company.


2.7 Rights of Data Subject

2.7.1 Right to access, amend or delete
You have a right under the Privacy Act to contact us at any time in writing to Privacy@Sequoia-Services.com to find out what information we have related to you. You can also request to have your personal information amended or deleted from our records.
We will oblige your request unless there is a statutory requirement for us to retain PII for a specific period or if it were to impede the service(s) provided.

2.7.2 Right to complain
You have the right to contact us at any time in writing to Privacy@Sequoia-Services.com to inform us of any actual or potential issues in the processing of your personal information.
We will endeavour to manage your complaint and resolve any issues you may have. If at this time you are dissatisfied with the outcome you may contact:
         Yvonne Sears - Director
         PO BOX, Halifax St., Adelaide.
         SA 5000

         0448 695 163

If at this stage you are still not satisfied with the outcome, please contact the Office of the Australian Information Commissioner. https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint Or your local Governing Body.


3 Information Security

We take Information Security seriously and endeavour to adequately protect information provided to us through the course of our services to prevent:
   • Breaches of confidentiality: For instance, information being given out inappropriately, or being accessed by unauthorised persons.
   • Loss of integrity: For instance, incomplete, out of date or inaccurate records.
   • Loss of availability: For instance, information or information systems being unavailable when needed to provide a service.

The collection, use, storage and disposal of personal information is managed in accordance to industry best practice, specifically ISO 27001 Information Security Management.

There are inherent risks associated with the transmission of information over the internet, including via email. You should be aware of this when sending personal information to us via email, via our website or social media platforms.
We will only record your email and contact details when you send a message to us, subscribe to a newsletter, complete a survey, or provide a business card. We will only use this information for the purpose for which it was collected.

3.1 Storage of Personal Information
Information submitted in online forms may be stored in email, files or databases for use in handling and responding to inquiries by Sequoia-Services or authorised partners. Our website, Sequoia portal and personal information is stored in Australia.

3.2 Subscription
Our website operates an email newsletter program used to inform subscribers about products and services supplied by ISDefence. Users can subscribe through an online automated process should they wish to but do so at their own discretion.

3.3 Cookies
Our website www.Sequoia-Services.com uses tracking software to monitor its visitors to better understand how the site is used. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google's privacy policy here for further information [ http://www.google.com/privacy.html ].
Other cookies may be stored to your computer’s hard drive by external vendors where the website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.

3.4 External Links
Although our website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout the website or our Blogs (External links are clickable text / banner / image links to other websites). 
Sequoia-Services (Sequoia) cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and Sequoia-Services (Sequoia) cannot be held liable for any damages.

3.5 Document Control
Policy Published Feb 2018

If you have any comments on this Policy, please contact us at: Privacy@Sequoia-Services.com

We will take your comments in to consideration within the next scheduled review.