PFS Group is committed to protecting the personal information we have collected. This policy is a component of, and supports, our Privacy and Credit Reporting Policy. We are required to protect personal information we collect from loss, unauthorised access and unauthorised disclosure (data breach). PFS is obliged under the Australian Privacy Principles to take such steps as are reasonable to protect personal information
from misuse, interference and loss; and
from unauthorised access, modification or disclosure.
PFS is also obliged to ensure the security of credit eligibility information. All staff members must adhere to the data security requirements and procedures for customer information as outlined in the Privacy and Credit Reporting Policy, this Policy and the Staff Induction Manual. A failure to provide adequate security may lead to an interference with the privacy of an individual. Should we suspect or believe that a data breach has occurred we will undertake the following 5 steps: 1. Identify 2. Contain 3. Assess 4. Notification 5. Review
We will maintain systems and procedures to ensure that any suspected or actual data breach can be identified, reported and escalated to management responsible for the implementation of the Data Breach Response Plan. Any employee who suspects a data breach has occurred must ensure that a Data Breach Report Form is completed and sent promptly to the Compliance Manager.
Once identified, we will take all reasonable steps that can be taken to contain that breach.
The Data Breach Response Plan and the Data Breach Report Form provide for the proper assessment of the breach including:
the type of information involved;
whether the breach can be remedied and the information recovered;
the identity and number of individuals affected or likely to be affected;
the possible financial, economic, social and emotional impact on any individual;
the nature of the breach (i.e. was it loss, access or disclosure of electronic or paper-based data and was it accidental or deliberate);
the perpetrator of the breach (i.e. internal staff, contractors, third parties whether local or overseas);
the risk of further breaches if remedial action is not taken (i.e. is a systemic problem or one-off);
whether criminality evident (i.e. theft or hacking); and
whether the information was encrypted, de-identified or difficult to access.
If we believe (not just suspect) on reasonable grounds that a data beach is likely to result in serious harm to any of the individuals concerned we will:
Prepare the statement required by the Privacy Act (1988) including the following information:
our contact details;
a description of the breach we believe has occured;
the kind of information involved in the breach;
recommendation about the steps the individuals should take in response; and
if the breach was caused by a third party service provider we engage, we will include their name and contact details.
Provide a copy of the statement to the Office of the Australian Infoamtion Commissioner
Provide a copy of the statement to each affected individual by a means determined to communicate effectivly with said individual and include additional information such as:
our response to contain the data breach and prevent its recurrence
any assistance we can offer to the individuals
that we have reported the breach to the Office of the Australian Information Commissioner and if relevant any law enforcement agency/ies
how individuals can make a complaint to the Office of the Australian Information Commissioner
To prevent future breaches of the same kind, the Data Breach Response Plan must include a requirement for us to conduct a review of our policies, systems and procedures which may include the following:
a post-investigation audit of physical and technical security controls
a review of policies and procedures
additional training of staff members including scenario practices
identify external resources that may assist to prevent future breachs, i.e. auditing firms, public relations firms, legal advisers
review authority levels for access to and transfer of electronic data
whether the Data Response Plan was adequate
