Welcome to Milton Graham.
Milton Graham recognises the importance of protecting information including the special protection of Personal Information.
Who is Milton Graham?
Milton Graham is part of the illion group of companies trading that provide services involving personal information which are listed here and below.
illion Australia Pty Ltd
Trading as Milton Graham
D-U-N-S 75 340 7170
ACN 006 399 677
To simplify matters Milton Graham may is referred to as “us” “we” and “our” in this policy.
Personal Information we collect
The Personal Information we collect from or about individuals, is the information that is reasonably necessary for our business purposes, including providing include receivables optimisation services to our Commercial Customers. We may collect a range of Personal Information from or about an individual including their:
- date of birth;
- driver’s licence number;
- marital status;
- phone number/s;
- email address;
- residential / business / postal address;
- employment history;
- liabilities; and
- repayment information.
We will only collect sensitive information (such as race, religion, ethnicity, health information, criminal record, sexual orientation, trade union memberships etc.) if you have given us express consent to do so, and:
- the information is reasonably necessary for us to carry out our functions or activities;
- the use of the information is required or authorised under an Australian law, court or tribunal order.
By disclosing your sensitive information to us you consent to the collection and use of this information in accordance with this Policy.
How we collect and hold Personal Information
As a provider of receivables optimisation services we collect information from individuals directly as well as our customers and third party service providers. This includes our Commercial Customers such as Credit Providers, Utilities and Telcos, we also collect information from Court records, publicly accessible databases (such as ASIC or Personal Insolvency records) along with or other individuals or authorised parties.
We also collect Personal Information about our customers, or employees or officers of our customers and prospective job applicants, so that we can meet internal operational requirements, complete business transactions, conduct research, deliver products and services, administer accounts, provide customer support, and meet regulatory requirements.
We are serious about the security of the information we collect. To protect this information we employ technical, contractual and administrative steps to ensure that this information is protected against any unauthorised access, disclosure or misuse. Technical controls include firewalls and network segmentation, Web Application Firewall (WAF), Network based Intrusion Prevention System (IPS), Network Data Loss Prevention (DLP), Anti-virus/Anti-Malware with Advanced Threat Protection (ATP), Endpoint Protection Anti-virus/Anti-Malware software with daily signature update across workstations and servers.
All our employees undertake training in handling information, with particular emphasis on preserving the privacy interests of individuals. We also limit physical and digital access to our premises and computer networks to those that require such access.
Purpose of collection, holding, using and disclosing Personal Information
We collect, hold, use and disclose Personal Information in order to provide services to individuals and our Commercial Customers. Some of the most common purposes for this will be:
- for identity verification purposes for individuals and our Commercial Customers;
- managing our relationship with individuals and our Commercial Customers;
- assisting our Commercial Customers in debt management and debt recovery;
- assisting our Commercial Customers in risk management;
- undertaking research, analytics and/or benchmarking;
- for audit and compliance purposes and to comply with our legal and regulatory obligations;
- processing and managing applications to work with us;
- for planning, product development and research;
- include in our databases so that we can provide it to our customers as part of the product or service they select (our customers include major corporations, small and medium sized businesses and government bodies and agencies);
- share with our group companies, affiliates and partners who will collect, hold, use and disclose Personal Information shared with them by us to create and sell risk analysis and other information products, including products which enable contact among businesses; and
- for any other purpose you have consented to or which is permitted under the Privacy Act.
While this list is not exhaustive, any purposes outside of this list will be consistent with those permitted under the Privacy Act.
Accessing and correcting Personal Information
We recognise the accuracy of the Personal Information we hold about an individual is critical to our business so encourage individuals to obtain their information and identify and correct any errors where they exist.
To access Personal Information we have established the Public Access Centre with the following contact points:
Telephone: 1300 734 806
While we take reasonable steps to ensure that the Personal Information held by us is up to date, we generally rely on our Commercial Customers and individuals to inform us if the information we hold about them is inaccurate or incomplete.
Once Personal Information is provided it is important that any errors are corrected, these should be raised through the Public Access Centre on the details above or complete and return this Correction Request form.
Making a Complaint
While we aim to address matters quickly and efficiently we understand there are times when things may go wrong and an individual may want to make a complaint.
To make a complaint it may be beneficial to complete the on-line form to ensure all relevant information is available, otherwise please speak with us on the contact number above. Alternatively you may find it helpful to click here to complete an Online Form or download a Complaint lodgement Form.pdf (25KB) and return it to:
Attention to: Complaints Department
Company: Milton Graham
Postal Address: PO Box 7405
St Kilda Rd Melbourne VIC 3004
Fax: (03) 9828 3447
As per our complaint handling policy We will acknowledge receipt of a complaint within five business days and commit to investigating the complaint and providing a response within 30 business days, provided that we have access to all necessary information. In cases where further information, assessment or investigation is required, we will seek to agree on an acceptable alternative time frame.
If the complaint continues to be unresolved there may be the option to escalate the matter to an external body. If the matter relates to privacy this could be to the Office of the Australian Information Commissioner or if it relates to illion’s data registry the matter could be referred to the Credit & Investment Ombudsman.
Disclosure of information overseas
Our businesses operate across Australia and New Zealand. Australia and New Zealand privacy laws are substantially similar. Where we disclose information to our New Zealand related companies as part of our internal operations, we will comply with Australian law in respect of Australian information and New Zealand law in respect of New Zealand information.
While our Commercial Customers are local businesses they may have parts of their operations overseas. We supply our services to the local business only so may not be aware of what data they disclose overseas. It is not possible to identify other countries where Australian domiciled Commercial Customers might allow their information to be disclosed to.
Our entities have access to a global business marketing database and commercial credit products on which we record the names of the officers of business enterprises in Australia. It is not practical to list all the countries in this world-wide network.
You authorise us to disclose Personal Information:
- where Milton Graham engages anyone to do something on its behalf (for example, suppliers of internet support services, auditors, process servers or lawyers) then Milton Graham and the service provider may exchange information for the purposes for which the service provider has been engaged;
- to compile online transaction and registration information for internal analysis such as researching and identifying market segments and needs (these analyses produce only aggregate data about individuals);
- to our related companies, affiliates and partners in Australia and New Zealand and with members of the illion group of companies, affiliates and partners world-wide only where permitted by law
- to customers of illion group companies, affiliates or partners;
where it is required or permitted by law to do so.
We may use technology known as a “cookie” to collect statistical information about you when you visit the Milton Graham Site or use any of our products or services. Cookies are small pieces of information captured when your device is used to access online content. They can record information about your visit to the Milton Graham Site, allowing it to remember you the next time you visit and provide a more meaningful experience.
From time to time we may collect, use, store and disclose non-identifiable information relating to your use of the Milton Graham Site or any our websites or any of our products or services. For example, we may record information such as the areas of the Milton Graham Site that you visit along with the time, date and URL of the pages you access, the device you access the Milton Graham Site from, your IP address and/or the previous website that you visited before linking to the Milton Graham Site. We normally use this information in the aggregate to administer and improve our web site, and monitor proper website usage.
From time to time we may use your Personal Information that you have provided to us to provide you with current information about our services, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or a third party.
By providing us with your Personal Information, you consent to us using your information for this purpose, including by mail, email, SMS, social media and telephone. If you do not wish to receive marketing information from us you may at any time unsubscribe from receiving such information by responding via the channel in which you received the marketing communication. We will take all reasonable steps to meet your request at the earliest possible opportunity.
You acknowledge and agree that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide (if any).
Milton Graham will not use your Personal Information for Direct Marketing purposes.