Shire Agents is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers.

This Personal Information is obtained in many ways including [interviews, correspondence, by telephone and facsimile, by email, via our website www.yourbusinessname.com.au, from your website, from media and publications, from other publicly available sources, from cookies- delete all that aren’t applicable] and from third parties. We don’t guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

•          For the primary purpose for which it was obtained

•          For a secondary purpose that is directly related to the primary purpose

•          With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

•          Third parties where you consent to the use or disclosure; and

•          Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

[Your business name] will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website.

Good to Book Privacy and Disclosure Statement 

[Last updated 7 March 2022]

Thank you for making a booking with us or coming to stay. We look forward to providing you with an enjoyable experience. By booking or staying with us, you are consenting to our use of your personal information as disclosed in this statement. This statement has been made available to you prior to your stay to enable you to give informed consent. 

If you are a ‘rogue guest’, we may share your information with Good to Book.

We are a member of Good to Book (GtoB), an on-line, searchable data-base with servers based in Australia but providing services around the globe. GtoB provides a platform for accommodation providers to upload data about rogue guests and to search potential or booked guests by name to see if they have had a rogue guest listing on the GtoB database within the last 3 years. 

As a member of GtoB, we may upload information about rogue guests to the GtoB database. By making a booking with us, you expressly consent to us sharing your personal information with GtoB if we believe you are a rogue guest, and for GtoB to use your information in accordance with their Privacy Policy https://goodtobook.com/privacy-policy/.  

The personal information we collect from you for use on the GtoB database is voluntary. This means you do not have to give it to us however we may refuse our accommodation services if you don’t provide the information and agree to these terms. Remember: We will only upload your personal information to the GtoB database if you are a rogue guest. We have obligations with GtoB to be honest and fair when uploading information or using the GtoB platform and we take these obligations seriously. 

By ‘rogue guest’ we mean a guest that has caused damage to the accommodation property, caused excessive cleaning requirements, been violent, exhibited behaviour that required the police to become involved or otherwise treated the property, guests, owners or staff in a manner unacceptable to industry standards.

The GtoB database also sends alerts to local registered accommodation providers if a rogue guest has stayed in their area and access is made available to the police for law enforcement and tracking purposes.

Why do we use the GtoB platform?

We use the GtoB platform as a risk management tool. If we can reduce the number of rogue guests staying with us, we can offer a better experience to our great guests and keep our overheads lower.

What do you consent to?

By booking or staying at our accommodation, you agree to the collection by us of your personal information and the personal information of any guests staying with you. This includes the collection of a scanned copy of acceptable identification. 

By making the booking you are telling us you have the consent of your guest(s) for us to collect and use their personal information as well. You should provide a copy of this statement to any person you are booking on behalf of. 

By booking or staying with us:

• You consent to our storage and use of your personal information for our own business purposes as set out in our privacy policy above; and
• You consent to our use of your personal information and that of any guests staying with you to search the GtoB database to make sure there are no rogue listings matching your details; and
• You consent to us providing your personal information and that of any guests staying with you, to GtoB via their platform, if we form the view that you are a ‘rogue guest’. Note that we will only upload your information to the GtoB platform if we encounter problems with your conduct during your stay. GtoB will then store and use that information for their own business purposes in accordance with their own privacy policy; and
• You consent to your personal information being transferred across Country borders. For example, if you are a New Zealand resident, you consent to both us and GtoB transferring your information outside of New Zealand. Depending on which Country you are in, your personal information may be transferred to a Country that does not have the same or as high a level of protections available under local laws, as are available under the privacy laws in your Country. 

You can find the privacy policy for GtoB at https://goodtobook.com/privacy-policy/

Any information we upload to the GtoB platform is uploaded for evaluative purposes. The information will be used by other GtoB members to evaluate if they wish to enter into a contract with you to provide their accommodation services to you in the future. 

How do we use the information available on the GtoB database?

If you make a booking with us or show up at our accommodation seeking a booking, we will search your name, and potentially the names of any persons staying with you, in the GtoB database. If your name shows up as a rogue guest, we may refuse your stay (and will refund any money you have paid to us) or we may impose additional requirements on your stay (for example, a higher-than-normal security bond). 

What information can we upload to the GtoB database?

If you cause damage to our property, excessive cleaning or are otherwise violent, abusive or problematic (for example if we need to call the police for any reason), we will upload your information into the GtoB database to alert other accommodation providers about your conduct. The information we will upload includes your full name, any other name you have used, the names of any persons travelling with you, an image of the identification you produced at check-in and its relevant department number (for example, your driver’s license and number), security footage or other recorded footage which identifies you (if any), your car registration number and state of registration and further information around your stay. We will also hold this information in our own records together with any supporting evidence we have. We do not have any obligation to let you know we have uploaded your information and any information we upload to the GtoB database is also confidential. You will not have the right to see the information we upload.  

If you are listed as a rogue guest, what is the consequence to you?

Your details will be entered into the GtoB database and any other accommodation providers who are members of GtoB can search your details and receive alerts about your conduct. If you request to stay at other accommodations while you are listed on the GtoB database, accommodation providers who are GtoB members may either refuse you accommodation or impose restrictions on your stay. 

Access to the GtoB database is also made available to local law authorities, although this is not the core purpose of the database.

How long will my personal information be used by GtoB

Your information will remain in the GtoB database for 3 years from the date your information was last uploaded to the platform. You can contact GtoB directly if you have questions about their platform or your listing. Their email address is admin@goodtobook.com.

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