Symmetra is the trade name of the Symmetra group of companies including Symmetra Holdings Pty Ltd, Symmetra Pty Ltd and Symmetra Technology Services Pty Ltd. (incorporated in Australia) and Symmetra USA Inc (incorporated in Delaware, USA).
In this policy a reference to Symmetra or use of the word “we” means the Symmetra group of companies.
In this policy “personal information” or “personal data” means information or data which either in isolation or in combination with other information enables a person to be identified.
With regard to personal data collected in any country belonging to the European Union or data collected from any citizen of such country, Symmetra applies privacy and security standards consistent with the European Union General Data Protection Regulation (EU GDPR).
With regard to personal data collected in the USA, Symmetra applies the legal requirements of the State in which such collection occurs.
Symmetra respects and upholds your rights to privacy protection under the Australian Privacy Principles in the Privacy Act 1988 (Cth).
Symmetra adheres to the legal requirements of any other country in which it collects personal data.
This statement outlines how Symmetra deals with personal information collected through our website, through the use of Symmetra’s online tools or through any other means of direct communication between you and Symmetra.
Symmetra does not, under any circumstances, sell personal information to any other person or organisation. Symmetra does not share any personal information collected or analysed with any third party.
Visits to our Website
Our computers automatically record your visit to the website and log the following non-identifiable information for statistical purposes:
- the Internet Protocol address,
- the Internet Protocol address,
- the date and time our server received the request,
- the pages, documents and files visited,
- the address of the resource which linked you to our website,
- the type of browser and, in some cases, the operating system used,
- in some cases, data you send to our website from web forms (e.g. search terms).
This information is collated for analysis. It is then evaluated and published in reports that show Symmetra usage patterns and identify popular areas of the website. This helps us to continue to improve the content available on the website.
Voluntary Submission of Other Information
The following information would be captured only if and when you enter it voluntarily into a web form such a contact or event registration form:
- Name, business address, telephone numbers;
- Email addresses;
- Occupation or position;
- Interest in or attendance at Symmetra event; and
- Any other information received by us in the course of providing information, publications, seminars, consulting and advisory services to you or your organisation (as applicable).
Use of Information Held
We may use personal information about you:
- To assist in providing information, publications, seminars, consulting and advisory services to you or your organisation (as applicable);
- To provide newsletters, blogs and research papers to you and generally to promote Symmetra’s services;
- For our internal administrative, marketing, planning, product development and research requirements;
- To perform internal statistical analysis; and
- For seeking your feedback.
We will not disclose personal information about you to any person or organisation unless we are under legal obligation to do so. Any business associate, sub-contractor or alliance partner who has access to private information held by Symmetra is required to commit and bind themselves to the same Privacy undertakings as Symmetra. We do not sell lists or provide information about you to mailing houses or other organisations.
At any time you may opt out of receiving any form of communication from us. If you consent to Symmetra continuing to send you various forms of communication including emails, letters, newsletters or bulletins, simply do nothing. You will automatically continue to receive such communication. If you do not consent to Symmetra continuing to send you these forms of communication please notify us in writing, or unsubscribe yourself from our mailing list using the links provided in our emails.
Interactions with Software Platforms
You may engage with one of Symmetra’s online learning or assessment tools such as the ILI (Inclusive Leadership Index), Team Inclusion Pulse Survey or other related inclusion surveys; or Coassemble / eLearning Bites or NovoEd platform, and may be required to supply personal information to logon or to initiate the functioning of the tool.
Type of Information Collected
- The following types of personal information may be collected, when you engage with one of Symmetra’s online tools:
- Email address
- Place of employment;
- Role/Position at work
- Payment details such as credit card information
Symmetra will not collect sensitive information revealing your gender, race, ethnic origin, political opinion, sexual preference, religious or philosophical beliefs, trade union membership, marital status or details of health or disability unless you have specifically consented to the collection of such information and voluntarily submitted this information to us, and such information is being collected as part of a genuine effort to gather diversity, equity and inclusion data for the organisation for which you work.
Purpose of Collecting and Holding Personal Information
- To record identity of person engaging with online tool;
- To monitor numbers of employees from a given organisation accessing a Symmetra program or tool;
- To be able to respond to requests or queries; and
- To conduct statistical surveys or otherwise provide insight into diversity and equity within your employer organisation.
We store personal information collected through application of our online tools for as long as required to process and analyse the data or information in accordance with our contractual undertakings with clients. Personal data may be retained in order to conduct feedback or coaching sessions with individuals who have voluntarily engaged with our online tools. Only persons who need to see the data for professional reasons in Symmetra will have access to the data.
Other Data Collected
Apart from personal data which identifies you specifically, Symmetra may through its online tools collect other data which is created or assembled through your interaction with these tools.
This data is in the nature of answers to questions, pertaining to your work or workplace, recording your viewpoint or personal assessment of work-related issues, your solutions to actual or hypothetical workplace problems, workplace metrics and like matters.
Symmetra will not permit any of the above-described data to be released to any person so that your responses can be linked to you.
This opinion or information data is generally aggregated and depersonalised so that statistical or other generalised results can be obtained for educational, instructional or research purposes.
Symmetra acknowledges that “sensitive data “as defined by Art. 9 of the GDPR” which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership will not be collected unless you have given explicit consent in advance for this to be done. Such consent constitutes an exception to the prohibition as provided by Art. 9(2) of the GDPR. Symmetra will not have any cause to collect sensitive data under any of the other exceptions in Art 9(2) (b) to(j) of the GDPR.
Cross-border transfer of data.
We may find it necessary to transmit personal data across international borders so that the data can be processed and analysed by data-processing entities situated in a different country. This will only be done with the prior knowledge and consent of the subjects whose personal data in being transferred. The data-processing entities that Symmetra engages are required to adhere to strict international standards of security and privacy protection.
Symmetra adheres, as far as practically possible, to the requirements based on Article 45 of the GDPR 2016/79 in all cross-border transfers of personal data whether or not the data is sourced in the EU or involves EU Citizens. The GDPR is regarded as laying down the most stringent requirements for personal data protection.
Where a country is not recognised by the EU as having the same level of privacy protection as applies in the EU, Symmetra will transfer personal data to an entity in that country only after that entity has signed the Standard Contractual Clauses (SCCs) endorsed under the GDPR.
Following the declaration by the Court of Justice of the European Union in case C311/18 (Schrems II) and the opinion of the Swiss Federal Data Protection and Information Commissioner of 8 September 2020, certain changes were implemented in the United States as a result of which the EU Commission declared on 10 July, 2023 that private data protection in the USA is of equivalent level to that in the EU.
Symmetra will act in accordance with this declaration of the EU Commission on 10 July, 2023 unless and until the declaration is overruled by a Europen Court.
Access to Personal Information
Symmetra takes reasonable measures to ensure that your personal information is protected from unauthorised access or disclosure. You may request access to personal information we hold about you by contacting us.
Accuracy and Correction
Symmetra aims to ensure that all personal information that it collects is accurate, up-to-date and complete. If you have any reason to believe that any personal information held by Symmetra is inaccurate or requires updating, Symmetra requests that you notify us accordingly. Symmetra will take appropriate steps to rectify the information as soon as possible.
If you are a citizen of the European Union and personal data relating to you is being held by Symmetra you may apply for the erasure of such data if you satisfy any one of the conditions set out under Art 17 of the GDPR.
If you wish to access personal information which Symmetra holds about you, then kindly contact the Privacy Officer (details below).
If you are a citizen of the European Union and have any question, request or complaint in relation to personal data relating to you and held by Symmetra you may contact Symmetra’s European representative under Art. 27 of the European Union General Data Protection Regulation (GDPR) (details below).
If you wish to make a complaint about the manner in which Symmetra has handled your personal information, you can contact the Privacy Officer or Symmetra’s European Representative as set out in ‘How to Contact Us’. Symmetra will endeavour to reply to any complaint within 14 days of receipt and wherever possible will advise you of the reasons for the outcome of the complaint.
If you are not satisfied with the outcome, you can lodge a complaint with the Office of the Australian Information Commission
How to Contact Us
If you have a query or complaint about personal information pertaining to you and held by Symmetra or you wish to add to or correct any personal information, please contact:
Symmetra Pty Ltd
Level 2, 50 Bridge Street
Sydney NSW, 2000
T +61 2 8054 2389
Rickert Rechtsanwaltsgesellschaft mbH