Document Managers Pty Ltd has adopted and will apply the National Privacy Principles contained in the Privacy Amendment (Private Sector) Act 2000 (.the Act.), to govern the ways in which it collects, uses and disposes of personal information that comes into its possession.

Collection
Document Managers will only collect personal information that is needed for it to operate its business activities effectively. Document Managers will always endeavour to obtain personal information directly from the individual concerned. When this is impracticable or not reasonable, it will collect personal information fairly and by lawful means and without being unreasonably intrusive. In collecting personal information, Document Managers will take reasonable steps to ensure the individual knows that it is Document Managers that is collecting the information; why the information is being collected; who will receive the information in normal circumstances; any legal requirements governing the information; how the individual can access the information held on them by Document Managers; and what the consequences would be if the individual did not provide the information sought unless precluded from doing so under the provisions of the Act or by any other law.

Use and Disclosure
Document Managers will only use or disclose personal information for the purpose(s) originally explained when the information was collected and for any related purpose that would reasonably be expected by both the individual concerned and Document Managers. If Document Managers uses personal information it holds for direct marketing of its products or services, it will always provide the individual the opportunity at the point of first contact and at any time afterwards at the individuals request to decline receipt of any further marketing information. Otherwise, Document Managers will neither use nor disclose personal information without the person.s consent, unless legally required.

Data Quality
Document Managers will take reasonable steps to ensure that the personal information it uses is accurate, complete and up-to-date.

Data Security
Document Managers will take reasonable steps to protect all personal information in its possession, to ensure integrity of the information and that it is only accessed by on the express authority of Document Managers. Personal information that is no longer needed by Document Managers nor required to be held by law will be destroyed by secure means, or de-identified so that the data cannot be traced back to the person to whom it relates to.

Openness
Document Managers will place this policy on its website. Printed copies of this policy will be made available on request at Document Managers' registered office.

Access and Correction
In order to view personal information held on them, a person on whom Document Managers holds personal information may apply in writing to the:

Privacy Officer
Document Managers Pty Ltd
Suite 1402B, Level 14, 275 Alfred Street, North Sydney, NSW 2060, Australia

Document Managers will take reasonable steps to confirm the identity of the person making the request and will respond within 14 days of receiving the request. However, where the request is more complex or time consuming to comply with, Document Managers will provide access to the information requested within 28 days.

Document Managers reserves the right to deny access to personal information if providing access:

• could pose a possible threat to life or health
• could cause an unreasonable impact on the privacy of others
• would be in response to a frivolous or vexatious request
• relates to existing or anticipated commercial negotiations involving ELO Digital, and Document Managers' legitimate commercial interests could be prejudiced as a result
• is in any way unlawful
• could in any way prejudice law enforcement or security
• either within or external to Document Managers' operations

Document Managers reserves the right to give the individual an explanation for any decision made rather than direct access to the relevant information if giving access to personal information involves revealing evaluative information generated within Document Managers in connection with a commercially sensitive decision making process.

Where there is disagreement about direct access or where direct access to personal information is impractical or inappropriate, Document Managers will discuss the possible use of a mutually acceptable intermediary.

If an individual advises Document Managers that personal information held on them is inaccurate, incomplete or not up to date, Document Managers will take reasonable steps to update the information accordingly.

Document Managers will endeavour to provide reason(s) for denial of access to or correction of personal information it holds unless precluded from doing so by the provisions of the Act or any other law.

Identifiers
Document Managers will not use an identifier assigned to an individual by a Government Agency (.the Agency.) as its own identifier; nor will it provide such an identifier to a third party without the individual.s consent, unless:

• disclosure is necessary for Document Managers to fulfil its obligations to the Agency
• it is required for health or other emergency reasons
• it is required or authorised by law
• Details of the person(s) investigating the complaint
• it is required for law enforcement

Transborder Data Flows
Document Managers will not transfer personal information outside Australia without the consent of the individual unless:

Sensitive Information
Document Managers will not, without the consent of the individual, collect information concerning that individual.s racial or ethnic origins; political opinions; membership of a political , professional or trade association or trade union; philosophical or religious beliefs or affiliations; sexual preferences or practices or health information unless:

• It is required by law
• It will prevent or lessen life or health threatening situations and it is not possible or practical to gain the individuals consent

Website
Reading or downloading materials from Document Managers' website(s) will not identify you personally; the information we receive is statistical. Document Managers' website like many other commercial websites may collect the following information during your visit:

• The fully qualified domain name from which you accessed our site, or alternatively your IP address;
• The date and time you accessed each page on our website
• The URL of and webpage from which you accessed our site ("the referrer")
• Details of the person(s) investigating the complaint
• The web browser you are using and the Document Managers web pages you accessed.

This information will be used by Document Managers to administer and improve the website.

Document Managers does not use cookies to connect your personal identity with your computer address or to track the navigational or browsing habits of identified visitors.

A cookie is a very small text file placed on to your computer when you visit a website. At some places in the site, "cookies" may be used to enhance your online experience. The cookie is not used to collect or store information about the user, only to allocate a temporary identifier to the session. Most browsers now recognise when a "cookie" is offered, and permit you to refuse or accept it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your Internet service provider.

When you elect to contact us with a comment or request for information, we may preserve the details you have input and make it available to the appropriate Document Managers staff member for the relevant action to be taken.

Complaints
Complaints concerning any aspect of Document Managers' management of an individual.s personal information may be directed in writing to:

The Privacy Officer
Document Managers Pty Ltd
Suit 1402B, Level 14, 275 Alfred Street, North Sydney, NSW 2060, Australia

Complaints lodged should be as detailed as possible, setting out the full circumstances of the matter to enable Document Managers' Privacy Officer to identify the relevant department/business unit and effect a through enquiry/review.

The Privacy Officer will maintain a record of all complaints received, which includes the following:

• The name and contact details of the complainant
• The date the complaint was received
• The nature of the complaint and the Document Managers business unit involved
• Details of the person(s) investigating the complaint
• The outcome of the investigations
• The dates and details of all contacts made with the complainant

These records will be held in a secure manner by the Privacy Officer, and will only be accessible to Senior Executives of Document Managers or of the subsidiary company or operating business unit to which the complaint relates. Otherwise, they will only be made available, if required or authorised by law or to assist with any inquiry carried out by the office of the Federal Privacy Commissioner.

The Privacy Officer will also be responsible for investigating privacy complaints, or for referring complaints to the designated Privacy Officer of the Document Managers subsidiary company or operating business unit concerned. The latter will be responsible for advising the Privacy Officer of Document Managers of the progress of their investigations and for providing a final report to the complainant with a copy to the Privacy Officer of Document Managers.

All complaints will be acknowledged within 7 working days and a full response given within 28 days. Where it is not possible to complete the investigation of a complaint within 28 days, the complainant will be contacted once 28 days have elapsed with an estimate of when it will be completed.