Leinad Land Management Pty Ltd (ACN 662 299 461) (LLM) respects the privacy of individuals and is committed to protecting personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles. Where LLM provides credit, it is also bound by Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code 2025 (CR Code).

This policy applies to personal information collected, held, used and disclosed by LLM in the course of operating Dublin Pit and conducting its business activities.

Collection of Personal Information

LLM will only collect personal information where it is reasonably necessary for its business, operational, safety, environmental, legal or administrative functions.

Personal information may include:

• names, addresses, email addresses, phone numbers and business contact details;

• employee, contractor, supplier, customer and visitor details;

• identification documents, licences, tickets and competency records;

• site induction, training and attendance records;

• emergency contact and next of kin details;

• payment, account, credit application and invoicing information;

• photographs, load images, site records and CCTV/security footage where used;

• incident, hazard, injury, first aid or emergency response records;

• correspondence, emails, phone records and other business communications;

• website or system access information where applicable.

Sensitive Information

LLM will only collect sensitive information where the individual has consented, where it is reasonably necessary for LLM’s functions or activities, or where required or permitted by law. Sensitive information may include health information, injury records, medical information, fitness for work information, or information required for emergency response, incident management or legal compliance.

How Personal Information is Collected

LLM may collect personal information directly from individuals or from authorised third parties.

Information may be collected through:

• employment and contractor forms;

• site inductions and sign-in/sign-out systems;

• SafetyPal, Weightrax, MYOB and other business systems;

• training and competency records;

• customer account and credit applications;

• weighbridge records, dockets and load documentation;

• emails, phone calls and business correspondence;

• supplier, contractor and transport operator documentation;

• incident, hazard and emergency response records;

• government agencies, regulators, consultants, auditors or industry bodies where relevant;

• general business dealings with employees, customers, suppliers, contractors, transport operators and visitors.

Unsolicited Personal Information

If LLM receives unsolicited personal information, it will determine whether the information could have been lawfully collected. If the information is not required, LLM will take reasonable steps to destroy or de-identify it where lawful and reasonable to do so.

Purpose for Collecting Personal Information

LLM collects personal information to conduct its business and meet legal, operational, safety, environmental and administrative requirements.

This may include:

• managing employment, contractor and visitor access;

• completing site inductions and verifying competency;

• managing health, safety, environmental and quality requirements;

• managing incidents, hazards, emergencies and corrective actions;

• operating weighbridge, product, stock, customer and sales systems;

• supplying, purchasing, invoicing and managing products and services;

• managing customer accounts, credit applications and payments;

• meeting legal, regulatory, insurance, audit and reporting obligations;

• communicating with workers, contractors, customers, suppliers, consultants, transport operators, regulators and emergency services;

• maintaining site security, safety and compliance records.

Use and Disclosure of Personal Information

LLM will use personal information for the primary purpose for which it was collected, for a related secondary purpose that the individual would reasonably expect, with the individual's consent, or where the use or disclosure is required or authorised by or under an Australian law or a court or tribunal order or another exception under the Australian Privacy Principles applies.

LLM will use personal information for the purpose it was collected, related business purposes, or where required or permitted by law.

Personal information may be disclosed to:

• LLM employees, managers, directors and authorised representatives;

• contractors, consultants, auditors and service providers engaged by LLM;

• emergency services, medical providers or insurers where required;

• government agencies, regulators or authorities where required by law;

• business partners, suppliers, customers or transport operators where relevant to business activities;

• legal, accounting, financial, insurance or professional advisors;

• other parties where the individual has consented or where disclosure is required or permitted by law.

LLM will not use or disclose sensitive information unless it is reasonably necessary for LLM’s functions or activities, the individual has consented, or the use or disclosure is required or permitted by law.

Credit Information and Credit Reporting

LLM may supply goods and services on account. Where LLM provides credit to an individual, or takes a guarantee from an individual, LLM may be a credit provider under Part IIIA of the Privacy Act. This section is LLM's credit reporting policy for the purposes of the Privacy Act and the CR Code, and applies to credit information and credit eligibility information instead of Australian Privacy Principles 1.3 and 1.4.

LLM obtains credit reports about individuals from credit reporting bodies in order to assess applications for credit and to assess whether to accept a person as a guarantor. To obtain a report, LLM discloses identification information about the individual to the credit reporting body. LLM does not disclose information about overdue payments, defaults or serious credit infringements to credit reporting bodies, and does not disclose repayment history information or financial hardship information.

The credit information LLM collects and holds is identification information, information about applications for credit and credit accounts, and information about guarantees given or proposed. LLM collects it from the individual, from any guarantor, from trade references and from public registers, and holds it in its business systems and in secure physical and electronic records. Credit eligibility information is the information a credit reporting body discloses to LLM and the information LLM derives from it, which is held in the same way. What LLM usually derives from a credit report is an assessment of whether to open an account, the credit limit to apply and the payment terms to offer.

LLM uses and discloses credit information and credit eligibility information to assess applications for credit, to set and review credit limits and payment terms, to assess whether to accept a person as a guarantor, to administer accounts and collect amounts owing, and to comply with its legal obligations. LLM may disclose that information to guarantors and proposed guarantors, debt collection agents and its professional advisers, in each case only as permitted by the Privacy Act and the CR Code. LLM will not disclose credit information or credit eligibility information to entities that do not have an Australian link.

An individual may ask LLM for access to, or correction of, the credit information and credit eligibility information LLM holds about them, or complain about LLM's compliance with the Privacy Acty or the CR Code, by contacting LLM's Privacy Officer. LLM will respond to a request or a complaint within 30 days and does not charge for making a request or for correcting information. If LLM corrects information it has previously disclosed to a credit reporting body, LLM will notify that body of the correction. If an individual is not satisfied with LLM's response to a complaint, they may complain to the Office of the Australian Information Commissioner.

Direct Marketing

LLM may use personal information to provide information about its products, services or business activities where appropriate and permitted by law. Individuals may opt out of direct marketing communications at any time by contacting LLM or using any opt-out method provided in the communication.

Overseas Disclosure

LLM is not likely to disclose personal information to overseas recipients. If overseas disclosure is required, LLM will take reasonable steps to ensure the disclosure complies with the Privacy Act and Australian Privacy Principles.

Quality of Personal Information

LLM will take reasonable steps to ensure personal information it collects, uses and discloses is accurate, complete and up to date. Individuals should advise LLM if their personal information changes or requires correction.

Security of Personal Information

LLM will take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure. 

Personal information may be stored in physical files, electronic systems, cloud-based systems and business software used by LLM.

When personal information is no longer required, LLM will take reasonable steps to destroy or de-identify it, unless it must be retained for legal, insurance, compliance, operational or record-keeping purposes.

If LLM suspects that an eligible data breach may have occurred, it will assess the matter within 30 days. If LLM is satisfied that an eligible data breach is likely to result in serious harm to an individual, LLM will notify the individual and the Office of the Australian Information Commissioner as soon as practicable, as required by the Privacy Act, and will also notify any affected credit reporting body or credit provider where credit information is involved.

Access and Correction

Individuals may request access to, or correction of, personal information held by LLM.

LLM will respond to a request for access or correction within 30 days of receiving it. Access may be refused where permitted by law, including where providing access would breach privacy, legal privilege, safety, investigation or regulatory requirements. If LLM refuses access or correction, it will give written reasons and explain how the individual may complain.

Complaints

Individuals may contact LLM if they believe their privacy has been breached or if they have concerns about how personal information has been handled.

LLM will acknowledge a privacy complaint within 7 days of receiving it, and will investigate the complaint and respond in writing within 30 days of receiving it.

If an individual is not satisfied with LLM's response, they may complain to the Office of the Australian Information Commissioner: GPO Box 5218, Sydney NSW 2001; telephone 1300 363 992; www.oaic.gov.au.

Anonymity and Pseudonymity

Individuals have the option of dealing with LLM anonymously or by using a pseudonym, unless it is impracticable for LLM to do so or LLM is required or authorised by law to deal with identified individuals. It is not practicable for LLM to deal with an individual anonymously where the individual seeks credit, enters an LLM site, applies for employment, or asks LLM to supply goods or services. If the personal information LLM requests is not provided, LLM may not be able to supply goods or services, provide credit, or permit site access.

Contact Us

Requests for access or correction, and privacy complaints, should be directed to LLM's Privacy Officer:

Privacy Officer, Leinad Land Management Pty Ltd,

Address: Lot 799, Thompsons Beach Road, Dublin SA 5501,  Email: admin@leinadlm.com.au,   Telephone: 1300 367 143.

Availability and Review of this Policy

This policy is available upon request and may be reviewed and updated from time to time.