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 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:
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.
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:
Personal information will be collected from
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:
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 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:
The use of personal information is strictly limited to:
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.
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:
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:
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.
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.
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:
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.
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.
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:
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.
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:
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 email@example.com or firstname.lastname@example.org, or by phone at 1300 256 900.
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.
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.
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:
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.
31 Korong Road
Heidelberg West, VIC 3081
Phone: +61 (03) 8339 2062
Fax: (03) 9303 7386
Email: email@example.com; firstname.lastname@example.org
Further information relating to privacy can be found at the Australian Federal Privacy Commissioner’s web-site: www.privacy.gov.au