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Smart Start Interlocks Privacy Policy

Introduction

Ajen Monitoring Systems trading as Smart Start Interlocks Australia take privacy seriously. Ajen is committed to maintaining the privacy of personal information that is collected from customers, prospective employees, and all parties (individuals) connected with Ajen.

This document has been created so individuals can fully understand how their personal information is collected, managed and used in Ajen’s business. It is important that Ajen is open and transparent about the data collected and how the data is used.

The document covers all activities of Ajen, and thus all activities of the subdivision Smart Start Interlocks Australia and associated entities, a leading provider of monitoring devices and consumables in Australia.

Ajen recognise the importance and is committed to protecting the privacy of individuals through protection of the personal information it holds. Ajen handles personal information in an open and transparent manner consistent with the objectives of the Australian Privacy Principles.

Personal Information

Personal information is any information capable of identifying an individual, or where identity can reasonably be ascertained from the information. Examples of personal information include, but are not limited to an individual’s:

  • name
  • address
  • date of birth
  • phone number
  • drivers licence details
  • email address
  • financial information
  • photographs

Ajen services result in data obtained through alcohol interlocks and other monitoring services. This data is classified as personal information and can be labelled monitoring data for the purpose of this document.

Collection

Ajen only collects personal information for the operation of the business and when required by law in accordance with the Privacy Act. At or before the time personal information is collected, Ajen will take all reasonable steps, including verbal notification and through explanations in the client information booklet and lease agreements (available at the time of installation), to ensure individuals are aware of:

  • The fact information is being collected about them
  • The purpose of the data collection
  • Who has access to the data
  • The laws that govern the data collection
  • The consequences (if any) of not providing accurate and up to date information
  • How individuals can gain access to the personal information collected about them

Personal information will be collected from

  1. the forms a client voluntarily submits,
  2. the monitoring device whilst in use,
  3. phone calls with Ajen,
  4. in-person communication (eg: conversations between individuals and Ajen agents),
  5. any other voluntary transactions with Ajen.

Ajen collects personal information where required by law or if the service or product requires it. For example, the type of information collected by Ajen includes, but is not limited to:

  • contact details
  • license details
  • date of birth
  • concession information (where applicable)
  • customer enquiries
  • requests
  • complaints
  • service details (information regarding the monthly service)
  • other transactional information, and
  • credit reporting data or credit references

Additionally, monitoring data is collected through Ajen’s services. This includes alcohol interlock data and other monitoring data. Interlock data will encompass all data collected via the interlock device(including logged events and photographs). This data is then used for the primary purpose of Ajen’s business, to provide monitoring of a driver’s BAC in relation to vehicle use. Monitoring data is classified as sensitive information.

Sensitive information

Sensitive information is a special category of personal information and includes any information or opinion about an individual’s: racial or ethnic origin, political opinion, membership of apolitical association, religious belief or affiliations, sexual preferences or practices, criminal record. Ajen collects the following sensitive information:

from

  1. monitoring data to be used by the courts, and
  2. limited aspects of an individual’s criminal record (only relating to drink driving offences). This information is required for the performance of Ajen’s business (i.e. to facilitate the alcohol interlock program) and as such, is provided with complete informed consent of the individual. This is outlined in the client information booklet and lease agreements.

Use, retention, and disposal

The use of personal information is strictly limited to:

  1. the operations of the primary business goal (i.e. to facilitate the relevant state government’s alcohol interlock program),
  2. to direct business operations, and
  3. for the purposes of research to improve business operations and governmental programs.  Ajen does not sell or use personal information in any way not specified in the client information booklet and lease agreements.

All personal information is retained by Ajen throughout the service period. All physical documents are stored for a minimum of seven years and can only be destroyed and disposed of with the permission of the relevant State Government. All digital forms of information are stored indefinitely. Demographic and business transactional data are stored indefinitely, subject to legal requirements.

Storage and Security

Ajen will take reasonable steps to protect the personal information collected from misuse, loss, theft as well as against unauthorised access, modification or disclosure, alteration and destruction.

Data is stored in paper based and electronic form. Paper based data is archived and stored using guidelines under relevant Australian Standards (AS ISO 15489). Electronic Data is encrypted and protected by secure methods by utilising Smart Start Inc’s proprietary software known as Smartrac. Data is stored on computers servers located in Melbourne and backed up securely at an alternate location within Australia.

In addition to electronic data protection through password access, data backup and firewalls other protection measures include:

  • Administrative processes
  • Technical safeguards and
  • Physical infrastructure and site security

Access

On request, Ajen will take reasonable steps to let individuals know what sort of personal information is held about them, for what purpose, and how such information is collected, held, used and disclosed.

In the case where Ajen holds information about an individual, the individual may request access to this information by contacting head office (contact details are at the end of this document).

Note: Identity validating procedures are in place to verify an individual’s identity.

However, Ajen have the right to refuse access to this information. Possible reasons for this include:

  1. where providing access would pose a serious threat to the life or health of any individual; or
  2. where providing access would have an unreasonable impact on the privacy of other individuals; or
  3. the request for access is frivolous or vexatious; or
  4. where information relates to anticipated or current legal proceedings and such information would not be accessible through the process of discovery in those proceedings; or
  5. providing access would be unlawful; or
  6. denying access is required by law; or
  7. where providing access would be likely to prejudice an investigation by Ajen or law enforcement agencies.

If access to this personal information is denied, Ajen will notify the individual of the reason for this restricted access.

If information is held about an individual that they believe is inaccurate, incorrect or incomplete, Ajen will take reasonable steps to correct the information as required by the Act. If Ajen refuse to do so, they will provide reasons for this refusal.

Disclosure

Personal information is limited to certain Ajen employees and approved third parties where required for the operation of business duties. These third parties include each state’s Road Government Agency (NSW’s Roads and Maritime Services; VicRoads; QLD’s Department of Transport and Main Roads; SA’s Department of Planning; Transport and Infrastructure; WA’s Department of Transport; NT’s Department of Transport; ACT’s Road Transport Authority), alcohol education assessors, the relevant courts, and relevant policing bodies.

Ajen employees and approved third parties will not collect, use, disclose, alter, retain or destroy personal information accept in accordance with Ajen, relevant government bodies, approved third parties, the courts, or law enforcement agencies.

Accordingly, interlock service providers are not able to access or view any sensitive information, including monitoring data. Such providers are only able to view restricted personal information, financial information, and other information required in their business role.

Personal information, including monitoring data and other related information, will be shared with the relevant government bodies and third-party assessment agencies where required by contract and law. This is outlined in the client information booklet and lease agreement. Additionally, monitoring data can be shared with other third parties if permission has previously been given permission for such an arrangement.

Note: Data can be shared with law enforcement agencies where requested.

Under Privacy law, Ajen is required to provide a Privacy statement to each participant and obtain consent from the participant as to the collection, storage and disclosure of personal information and other participant information to the relevant state’s Road Government Agency.

The privacy statement must form part of the Standard Contract between Ajen and the participant.

Trans border data flows

As Ajen is an Australian based company, we will only transfer personal information about an individual to someone (other than the company or the individual) who is in a foreign country if:

  1. They reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the National Privacy Principles; or
  2. The individual consents to the transfer; or
  3. The transfer is necessary for the performance of a contract between the individual and Ajen, or for the implementation of pre-contractual measures taken in response to the individual's request; or
  4. The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Ajen and a third party; or
  5. All of the following apply:
    (a) The transfer is for the benefit of the individual;
    (b) It is impracticable to obtain the consent of the individual to that transfer;
    (c)  If it were practicable to obtain such consent, the individual would be likely to give it; or
  6. Ajen has taken reasonable steps to ensure the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the National Privacy Principles.

Data quality

Ajen takes all reasonable steps to make sure that the personal information that is collected, used, and disclosed is accurate, complete, and up to date.

Anonymity

Wherever it is lawful and practical, individuals have the option of not identifying themselves when entering transactions with Ajen.  However, most of our services require identifiable information.

Employees

Ajen will hold and retain any information provided by potential employees, including personal information outlined in CVs, cover letters and other documents. Ajen will not intentionally collect or store sensitive information regarding potential employees.

Ajen holds personal information on its employees where required for the operation of the business and when required by law. Ajen may collect, hold, use and disclose employee’s personal information for all purposes connected with our employment relationship. This relationship includes hiring, training, administration of personnel records (including pay and leave records) and managing performance. Personal information collected and held on employees includes, but is not limited to:

  • name,
  • date of birth,
  • pay and tax information,
  • leave information,
  • criminal record checks,
  • bank and superannuation information and
  • all information provided in cover letters and CVs provided to Ajen at the time of employment.

Additionally, Ajen requires police checks on employees and third parties for certain aspects of its business (for example, employees performing alcohol interlock services).

Ajen has the right to perform staff and employee drug and alcohol tests as outlined in our workplace Drug and Alcohol Policy.

Internet

Website

The Ajen website can be found at the following address: www.ajen.com.au. For the Smart Start website and Agent Support website, please visit www.smartstartinterlocks.com.au and www.agentsupport.com.au, respectfully.

Visits to the Ajen, Smart Start, and Agent Support websites may be logged. The information that may be collected includes, but is not limited to:

  • operating system
  • domain name
  • the address of any linked site which referred to the Ajen website
  • servers IP address
  • the date and time of the visit
  • internal traffic in different areas of the website, including files downloaded.

This information is only able to be collected for internal improvement. This data is not shared or provided to any party or organisation outside of Ajen.

Individuals can complete and send through forms on all three websites. Personal information is collected for business purposes, and if this information is not provided, Ajen cannot contact the individual to provide support.

Ajen may use contact details provided to deliver information relating to our products and services via email. If an individual does not wish to receive such messages, they can notify us via email at info@ajen.com.au or info@smartstartinterlocks.com.au, or by phone at 1300 256 900.

Social Media

Ajen makes use of social media and online connection tools. This includes, but is not limited to: Facebook, Twitter, Google Plus, YouTube, and LinkedIn. When contacting Ajen and Smart Start Interlocks via these services, it is important to acknowledge the privacy policies of the respective websites.

Additionally, a Twitter plugin may be used by our website. Twitter functions are offered by Twitter Inc., 795 Folsom St., Suite600, San Francisco, CA 94107, USA. By using these functions, an individual can share a contribution on Twitter and follow Ajen on Twitter, if they have their own Twitter account. This involves transmitting data to Twitter.

As a provider of websites that host these functions, Ajen have no knowledge of the content of the data transferred to and used by Twitter. Individuals should visit http://twitter.com/privacy for further information about Twitter's data protection and privacy declaration. Privacy preferences can be changed at Twitter in account settings.

Occasionally, Ajen will link to third party websites. Although Ajen make all reasonable efforts to ensure safety and accuracy, they cannot accept any responsibility or liability for these third-party websites.

Complaints

Ajen incorporates the criteria set out by Standards Australia AS ISO 10002:2006 (Customer Satisfaction – Guidelines for complaints handling) into its complaint handling procedures. This ensures complaints surrounding compliance to policies and procedures are handled in the same manner as complaints with respect to privacy.

Ajen Monitoring Systems maintain a complaint register and issues are resolved using guidelines from their Quality management system. If an individual wishes to make a complaint to Ajen, they can contact us on their preferred method outlined below.

Privacy Breath and notification

If an individual believes Ajen has not dealt with their personal information in accordance with Privacy laws, they may lodge an information privacy complaint. They can contact Ajen using their preferred contact method detailed at the end of this document and provide details of the incident so it can be investigated.

Ajen are required to notify the relevant state’s Road Government Agency immediately if they become aware that disclosure of information may be required by law, or any unauthorised disclosure of information has occurred.

Ajen will immediately notify the state’s Road Government Agency if they become aware of any:

  • breach or possible breach of Privacy Law, by any of Employees or Authorised Service Agents; or
  • complaint concerning the use, disclosure, transfer or handling of any Personal Information

Any such notification will include the particulars of the breach and the proposed response to the breach including any investigation, timeframe, and the steps that will be taken to remedy the breach and prevent further breaches.  

Updates

Ajen maintains a publishes all changes to it Privacy Policy on the public facing websites at www.ajen.com, www.smartstartinterlocks.com.au, and www.agentsupport.com.au.

Contact Details

If an individual has any questions or concerns relating to this privacy policy, or a complaint regarding the treatment of their personal information or a possible breach of their privacy, they can contact Ajen using the following methods:

Ajen Monitoring Systems Pty Ltd

31 Korong Road
Heidelberg West, VIC 3081
Phone: +61 (03) 8339 2062
Fax: (03) 9303 7386
Email: info@ajen.com.au; info@smartstartinterlocks.com.au

Further Information

Further information relating to privacy can be found at the Australian Federal Privacy Commissioner’s web-site: www.privacy.gov.au