Privacy Policy

This Privacy Policy applies to all personal information collected by Ascention Assets Pty Ltd ACN124 757 811(“Ascention Assets”) via the Ascention Assets website located at http://www.ascentionassets.com.au.

We respect your privacy and we comply with the Commonwealth Privacy Act 1998 (“Act”). The Act requires us to provide this Privacy Policy to you on request. This policy sets out our policies for management of personal information.  This policy was released on 1 September 2015 but may be superseded at any time in the future. A copy of the then current Privacy Policy can be obtained from http://www.ascentionassets.com.au.

The Act defines “personal information” as meaning “information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion”.

 

PART 1—CONSIDERATION OF PERSONAL INFORMATION PRIVACY

Australian Privacy Principle 1 — Open and Transparent Management of Personal Information

1.1        Ascention Assets manages personal information in an open and transparent way.

Compliance with the Australian Privacy Principles, etc.

1.2        Ascention Assets takes such steps as are reasonable in the circumstances to implement practices, procedures and systems relating to Ascention Assets’ functions and activities that:

(a)            ensure that Ascention Assets complies with the Australian Privacy Principles (“APPs”) and any APP code that may apply to Ascention Assets; and

(b)            enable Ascention Assets to deal with inquiries or complaints from individuals about its compliance with the APP or any such APP code.

APP Privacy Policy

1.3        Ascention Assets has a clearly expressed and up to date policy (“APP Privacy Policy”) about the management of personal information by Ascention Assets, namely this document.

1.4        Ascention Assets’ APP Privacy Policy contains the following information:

(a)             The kinds of personal information that Ascention Assets collects and holds, namely:

(i)               your name;

(ii)              your company's name, if applicable;

(iii)             email address;

(iv)            mobile number (if provided);

(v)             address;

(vi)            the device’s IP or Mac address that accesses our service, including, if available, the visitor’s:

A.              country, region, city and area or post code;

B.              GPS longitude and latitude;

C.              time zone and language;

D.              internet service provider or carrier; and

E.              connection type;

(vii)           platform and device used;

(viii)          browser name and version used;

(ix)            visitor's operating system;

(x)             pages viewed by the visitor;

(xi)            the visitor's search terms used; and

(xii)           any other information which you provide when accessing our website.

(b)             How Ascention Assets collects and holds personal information, namely personal information are:

(i)               collected directly from you through using our website;

(ii)              stored electronically on our secure servers located within and outside Australia; and

(iii)             secured by having processes in place that includes limitations on access to personal information within our organisation.

(c)              The purposes for which Ascention Assets collects, holds, uses and discloses personal information, namely:

(i)               identifying and corresponding with you and other parties generally to enable us to conduct our business, provide and market our services and to meet our legal and other obligations in respect to the provision of services;

(ii)              matters implicit in our management including, but not limited to:

A.              service monitoring, planning, evaluation and accreditation activities and compliance with quality assurance audits;

B.              the type of device that has connected to the service (e.g. IPhone, Android, Blackberry, IPod);

C.              the time that you have logged on to the service;  and

D.              the amount of data that was downloaded;

(iii)             marketing various other products and services, including use in:

A.              email campaigns;

B.              Google AdWords; and

C.              Google remarketing;

(iv)            any more specific purpose given at the time of the collection; and

(v)             generally anything necessary and expedient to achieve the above.

(d)             How an individual may access personal information about the individual that is held by Ascention Assets and seek the correction of such information, namely by contacting Ascention Assets at:

Ascention Assets Pty Ltd ACN124 757 811

c/- PO Box 849, Cannington, Western Australia

E-Mail: info@ascention.com.au

Web: www.ascentionassets.com.au

(e)             How an individual may complain about a breach of the APPs, or a registered APP Code (if any) that binds Ascention Assets, and how Ascention Assets will deal with such a complaint, namely:

(i)               an individual may make a complaint by contacting Ascention Assets via the contact details provided at clause 1.4(d); and

(ii)              Ascention Assets will deal with complaints by investigating the complaint and taking the appropriate action.

(f)               Whether Ascention Assets is likely to disclose personal information to overseas recipients, namely Ascention Assets do not specifically disclose personal information to overseas recipients, except to the extent that:

(i)               the information may be stored on servers abroad; and

(ii)              Ascention Assets uses overseas third parties for web and event tracking analysis.

(g)             If Ascention Assets is likely to disclose personal information to overseas recipients, the countries in which such recipients are likely to be located if it is practicable to specify those countries in the APP Privacy Policy, namely the servers referred to in clause 1.4(f) Ascention Assets believe are:

(i)               USA;

(ii)              Germany; and

(iii)             Netherlands.

Availability of APP Privacy Policy, etc.

1.5        Ascention Assets takes such steps as are reasonable in the circumstances to make its APP Privacy Policy available:

(a)             free of charge; and

(b)             in such form as is appropriate.

Note: Ascention Assets makes its APP Privacy Policy available on Ascention Assets’ website.

1.6        If a person or body requests a copy of Ascention Assets’ APP Privacy Policy in a particular form, Ascention Assets will take such steps as are reasonable in the circumstances to give the person or body a copy in that form.

Australian Privacy Principle 2 — Anonymity and Pseudonymity

2.1        Individuals have the option of not identifying themselves, or of using a pseudonym, when dealing with Ascention Assets in relation to a particular matter.

2.2        Subclause 2.1 does not apply if, in relation to that matter:

(a)             Ascention Assets is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or

(b)             it is impracticable for Ascention Assets to deal with individuals who have not identified themselves or who have used a pseudonym.

 

PART 2 — COLLECTION OF PERSONAL INFORMATION

Australian Privacy Principle 3 — Collection of Solicited Personal Information

Personal Information other than Sensitive Information

3.1/3.2  Ascention Assets does not collect personal information (other than sensitive information) unless the information is reasonably necessary for, or directly related to, one or more of Ascention Assets’ functions or activities.

Sensitive Information

3.3        Ascention Assets does not collect sensitive information about an individual unless:

(a)             the individual consents to the collection of the information and the information is reasonably necessary for one or more of Ascention Assets’ functions or activities; and

(b)             subclause 3.4 applies in relation to the information.

3.4        This subclause applies in relation to sensitive information about an individual if:

(a)             the collection of the information is required or authorised by or under an Australian law or a court/tribunal order; or

(b)             a permitted general situation exists in relation to the collection of the information by Ascention Assets; or

(c)              a permitted health situation exists in relation to the collection of the information by Ascention Assets.

             Note: For permitted general situation, see section 16A of the Act. For permitted health situation, see section 16B of the Act.

Means of Collection

3.5        Ascention Assets collects personal information only by lawful and fair means.

3.6        Ascention Assets collects personal information about an individual only from the individual unless it is unreasonable or impracticable to do so.

Solicited Personal Information

3.7        This principle applies to the collection of personal information that is solicited by Ascention Assets.

Australian Privacy Principle 4 — Dealing with Unsolicited Personal Information

4.1        If:

(a)            Ascention Assets receives personal information; and

(b)            Ascention Assets did not solicit the information,

... Ascention Assets will, within a reasonable period after receiving the information, decide whether or not Ascention Assets could have collected the personal information under APP 3.

4.2        Ascention Assets may use or disclose the personal information for the purposes of making the decision under subclause 4.1.

4.3        If:

(a)            Ascention Assets decides that Ascention Assets could not have collected the personal information; and

(b)            the personal information is not contained in a Commonwealth record,

… Ascention Assets will, as soon as practicable but only if it is lawful and reasonable to do so, destroy the information or ensure that the information is de-identified.

4.4        If subclause 4.3 does not apply in relation to the personal information, APPs 5 to 13 apply in relation to the information as if Ascention Assets had collected the information under APP 3.

Australian Privacy Principle 5 — Notification of the Collection of Personal Information

5.1        At or before the time or, if that is not practicable, as soon as practicable after, Ascention Assets collects personal information about an individual, Ascention Assets will take such steps as are reasonable in the circumstances:

(a)             to notify the individual of such matters referred to in subclause 5.2 as are reasonable in the circumstances; or

(b)             to otherwise ensure that the individual is aware of any such matters.

5.2        The matters for the purposes of subclause 5.1 are as follows:

(a)             The identity and contact details of Ascention Assets, namely the contact details provided at clause 1.4(d);

(b)             If:

(i)          Ascention Assets collects the personal information from someone other than the individual; or

(ii)         the individual may not be aware that Ascention Assets has collected the personal information,

... the fact that Ascention Assets so collects, or has collected, the information and the circumstances of that collection, namely:

(iii)        when the information was collected;

(iv)        from whom the personal information was collected, unless if doing so would be an interference with the privacy of that individual (for example, the use or disclosure breaches APP 6 because that individual would not reasonably expect their personal information to be disclosed in an APP 5 notice and no other exception in APP 6 applies) (see APP 6); and

(v)         the method of collection, for example, whether that personal information was collected through use of a hidden radio-frequency identification tag (RFID tags), software (such as cookies), or biometric technology (such as voice or facial recognition);

(c)              If the collection of the personal information is required or authorised by or under an Australian law or a court/tribunal order, the fact that the collection is so required or authorised (including the name of the Australian law, or details of the court/ tribunal order, that requires or authorises the collection);

(d)             The purposes for which Ascention Assets collects the personal information, namely the purposes referred to at clause 1.4(c);

(e)             The main consequences for the individual if all or some of the personal information is not collected by Ascention Assets, namely:

(i)          you may not be eligible to use our service; or

(ii)         Ascention Assets may not be able to properly investigate or resolve your complaint;

Note: This is not an extensive list of consequences that my result if personal information is not collected, but just some examples of possible consequences.

(f)               Any other APP entity, body or person, or the types of any other APP entities, bodies or persons, to which Ascention Assets usually discloses personal information of the kind collected by Ascention Assets, namely the organisations (or the types of organisations) to which Ascention Assets usually disclose personal information are:

(i)          our clients;

(ii)         companies engaged by Ascention Assets for the purposes outlined in clause 1.4(c);

(iii)        our own lawyers, accountants and auditors, including quality auditors and advisers if necessary for them to provide their services or conduct their business;

(iv)        contractors that provide information technology services and the like, if necessary for them to provide their services to our business, and

(v)         other persons or organisations that need to be given personal information in order for us to provide our services and conduct our businesses properly;

(g)             That Ascention Assets’ APP Privacy Policy contains information about how the individual may access the personal information about the individual that is held by Ascention Assets and seek the correction of such information, namely via the contact details provided at clause 1.4(d);

(h)             That Ascention Assets’ APP Privacy Policy contains information about how the individual may complain about a breach of the APPs, or a registered APP code (if any) that binds Ascention Assets, and how Ascention Assets will deal with such a complaint, namely via the contact details provided at clause 1.4(d);

(h)             Whether Ascention Assets is likely to disclose the personal information to overseas recipients, namely Ascention Assets do not disclose personal information to overseas recipients, except to the extent that:

(i)               the information may be stored on servers abroad; and

(ii)              Ascention Assets uses overseas third parties for web and event tracking analysis; and

(i)               If Ascention Assets is likely to disclose the personal information to overseas recipients, the countries in which such recipients are likely to be located if it is practicable to specify those countries in the notification or to otherwise make the individual aware of them, namely the servers referred to in clause 5.2(i) Ascention Assets believe are the countries referred to in clause 1.4(g).

 

PART 3—DEALING WITH PERSONAL INFORMATION

Australian Privacy Principle 6 — Use or Disclosure of Personal Information

Use or Disclosure

6.1        If Ascention Assets holds personal information about an individual that was collected for a particular purpose (the primary purpose), Ascention Assets does not use or disclose the information for another purpose (the secondary purpose) unless:

(a)            the individual has consented to the use or disclosure of the information; or

(b)            subclause 6.2 or 6.3 applies in relation to the use or disclosure of the information.

Note: APP 8 sets out requirements for the disclosure of personal information to a person who is not in Australia or an external Territory.

6.2        This subclause applies in relation to the use or disclosure of personal information about an individual if:

(a)         the individual would reasonably expect Ascention Assets to use or disclose the information for the secondary purpose and the secondary purpose is:

(i)              if the information is sensitive information—directly related to the primary purpose; or

(ii)             if the information is not sensitive information—related to the primary purpose; or

(b)         the use or disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order; or

(c)         a permitted general situation exists in relation to the use or disclosure of the information by Ascention Assets; or

(d)         a permitted health situation exists in relation to the use or disclosure of the information by Ascention Assets; or

(e)         Ascention Assets reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

6.4        Ascention Assets takes such steps as are reasonable in the circumstances to ensure that the information is de-identified before Ascention Assets discloses it in accordance with subclause 6.1 or 6.2.

Written Note of Use or Disclosure

6.5        If Ascention Assets uses or discloses personal information in accordance with paragraph 6.2(e), Ascention Assets makes a written note of the use or disclosure.

Related Bodies Corporate

6.6        If Ascention Assets collects personal information from a related body corporate, this principle applies as if Ascention Assets’ primary purpose for the collection of the information were the primary purpose for which the related body corporate collected the information.

Exceptions

6.7        This principle does not apply to the use or disclosure by Ascention Assets of:

(a)            personal informationfor the purpose of direct marketing; or

(b)            government related identifiers.

Australian Privacy Principle 7 — Direct Marketing

Direct Marketing

7.1        If Ascention Assets holds personal information about an individual, Ascention Assets does not use or disclose the information for the purpose of direct marketing except as permitted by subclauses 7.2, 7.3, 7.4 and 7.5.

Exceptions — Personal Information other than Sensitive Information

7.2        Ascention Assets may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:

(a)            Ascention Assets collected the information from the individual;

(b)            the individual would reasonably expect Ascention Assets to use or disclose the information for that purpose;

(c)             Ascention Assets provides a simple means by which the individual may easily request not to receive direct marketing communications from Ascention Assets; and

(d)            the individual has not made such a request to Ascention Assets.

7.3        Ascention Assets may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:

(a)         Ascention Assets collected the information from:

(i)              the individual and the individual would not reasonably expect Ascention Assets to use or disclose the information for that purpose; or

(ii)             someone other than the individual; and

(b)         either:

(i)              the individual has consented to the use or disclosure of the information for that purpose; or

(ii)             it is impracticable to obtain that consent; and

(c)         Ascention Assets provides a simple means by which the individual may easily request not to receive direct marketing communications from Ascention Assets; and

(d)         in each direct marketing communication with the individual:

(i)               Ascention Assets includes a prominent statement that the individual may make such a request; or

(ii)              Ascention Assets otherwise draws the individual’s attention to the fact that the individual may make such a request; and

(e)            the individual has not made such a request to Ascention Assets.

Exception — Sensitive Information

7.4        Ascention Assets may use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.

Exception — Contracted Service Providers

7.5        Ascention Assets may use or disclose personal information for the purpose of direct marketing if:

(a)         Ascention Assets is a contracted service provider for a Commonwealth contract;

(b)         Ascention Assets collected the information for the purpose of meeting (directly or indirectly) an obligation under the contract; and

(c)         the use or disclosure is necessary to meet (directly or indirectly) such an obligation.

Individual may request not to receive Direct Marketing Communications, etc.

7.6        If Ascention Assets uses or discloses personal information about an individual:

(a)             for the purpose of direct marketing by Ascention Assets; or

(b)             for the purpose of facilitating direct marketing by other organisations,

... the individual may:

(c)              if paragraph (a) applies—request not to receive direct marketing communications from Ascention Assets;

(d)             if paragraph (b) applies—request Ascention Assets not to use or disclose the information for the purpose referred to in that paragraph; and

(e)             request Ascention Assets to provide its source of the information.

7.7        If an individual makes a request under subclause 7.6, Ascention Assets will not charge the individual for the making of, or to give effect to, the request and:

(a)         if the request is of a kind referred to in paragraph 7.6(c) or (d)—Ascention Assets will give effect to the request within a reasonable period after the request is made; and

(b)         if the request is of a kind referred to in paragraph 7.6(e)—Ascention Assets will, within a reasonable period after the request is made, notify the individual of its source unless it is impracticable or unreasonable to do so.

Interaction with other Legislation

7.8        This principle does not apply to the extent that any of the following apply:

(a)             the Do Not Call Register Act 2006;

(b)             the Spam Act 2003; and

(c)              any other Act of the Commonwealth, or a Norfolk Island enactment, prescribed by the regulations.

Australian Privacy Principle 8 — Cross-Border Disclosure of Personal Information

8.1        Before Ascention Assets discloses personal information about an individual to a person (the “Overseas Recipient”):

(a)         who is not in Australia or an external Territory; and

(b)         who is not Ascention Assets or the individual,

... Ascention Assets takes such steps as are reasonable in the circumstances to ensure that the Overseas Recipient does not breach the APPs (other than APP 1) in relation to the information.

8.2        Subclause 8.1 does not apply to the disclosure of personal information about an individual by Ascention Assets to the Overseas Recipient if:

(a)               Ascention Assets reasonably believes that:

(i)         the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the APPs protect the information; and

(ii)         there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme; or

(b)         both of the following apply:

(i)               Ascention Assets expressly informs the individual that if he or she consents to the disclosure of the information, subclause 8.1 will not apply to the disclosure; and

(ii)              after being so informed, the individual consents to the disclosure; or

(c)         the disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order; or

(d)         a permitted general situation exists in relation to the disclosure of the information by Ascention Assets, other than a situation where the collection, use or disclosure is reasonably necessary for:

(i)               the establishment, exercise or defence of a legal or equitable claim; or

(ii)              the purposes of a confidential alternative dispute resolution process.

Australian Privacy Principle 9 — Adoption, Use or Disclosure of Government Related Identifiers

Adoption of Government Related Identifiers

9.1        Ascention Assets does not adopt a government related identifier of an individual as its own identifier of the individual unless:

(a)             the adoption of the government related identifier is required or authorised by or under an Australian law or a court/tribunal order; or

(b)             subclause 9.3 applies in relation to the adoption.

Use or Disclosure of Government Related Identifiers

9.2        Ascention Assets does not use or disclose a government related identifier of an individual unless:

(a)             the use or disclosure of the identifier is reasonably necessary for Ascention Assets to verify the identity of the individual for the purposes of Ascention Assets’ activities or functions; or

(b)             the use or disclosure of the identifier is reasonably necessary for Ascention Assets to fulfil its obligations to an agency or a State or Territory authority; or

(c)              the use or disclosure of the identifier is required or authorised by or under an Australian law or a court/tribunal order; or

(d)             a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) of the Act) exists in relation to the use or disclosure of the identifier; or

(e)             Ascention Assets reasonably believes that the use or disclosure of the identifier is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or

(f)               subclause 9.3 applies in relation to the use or disclosure.

Note 1: An act or practice of an agency may be treated as an act or practice of Ascention Assets, see section 7A of the Act.

Note 2: For permitted general situation, see section 16A of the Act.

Regulations about Adoption, Use or Disclosure

9.3        This subclause applies in relation to the adoption, use or disclosure by Ascention Assets of a government related identifier of an individual if:

(a)             the identifier is prescribed by the regulations;

(b)             Ascention Assets is prescribed by the regulations, or is included in a class of organisations prescribed by the regulations; and

(c)              the adoption, use or disclosure occurs in the circumstances prescribed by the regulations.

 

PART 4—INTEGRITY OF PERSONAL INFORMATION

Australian Privacy Principle 10 — Quality of Personal Information

10.1      Ascention Assets take such steps as are reasonable in the circumstances to ensure that the personal information that Ascention Assets collects is accurate, up to date and complete.

10.2      Ascention Assets take such steps as are reasonable in the circumstances to ensure that the personal information that Ascention Assets uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up to date, complete and relevant.

Australian Privacy Principle 11 — Security of Personal Information

11.1      If Ascention Assets holds personal information, Ascention Assets takes such steps as are reasonable in the circumstances to protect the information:

(a)              from misuse, interference and loss; and

(b)              from unauthorised access, modification or disclosure.

11.2      If:

(a)             Ascention Assets holds personal information about an individual;

(b)             Ascention Assets no longer needs the information for any purpose for which the information may be used or disclosed by Ascention Assets under this APP Privacy Policy;

(c)              the information is not contained in a Commonwealth record; and

(d)             Ascention Assets is not required by or under an Australian law, or a court/tribunal order, to retain the information,

... Ascention Assets takes such steps as are reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.

 

PART 5—ACCESS TO, AND CORRECTION OF, PERSONAL INFORMATION

Australian Privacy Principle 12 — Access to Personal Information

Access

12.1      If Ascention Assets holds personal information about an individual, Ascention Assets will, on request by the individual, give the individual access to the information.

Exception to Access — Agency

12.2      Ascention Assets is not an agency and accordingly clause 12.2 is not applicable to Ascention Assets.

Exception to Access — Organisation

12.3      Despite subclause 12.1, Ascention Assets is not required to give the individual access to the personal information to the extent that:

(a)             Ascention Assets reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or

(b)             giving access would have an unreasonable impact on the privacy of other individuals; or

(c)              the request for access is frivolous or vexatious; or

(d)             the information relates to existing or anticipated legal proceedings between Ascention Assets and the individual, and would not be accessible by the process of discovery in those proceedings; or

(e)             giving access would reveal the intentions of Ascention Assets in relation to negotiations with the individual in such a way as to prejudice those negotiations; or

(f)               giving access would be unlawful; or

(g)             denying access is required or authorised by or under an Australian law or a court/tribunal order; or

(h)             both of the following apply:

(i)          Ascention Assets has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Ascention Assets’ functions or activities has been, is being or may be engaged in; and

(ii)         giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or

(i)               giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or

(j)               giving access would reveal evaluative information generated within Ascention Assets in connection with a commercially sensitive decision-making process.

Dealing with Requests for Access

12.4      Ascention Assets will:

(a)         respond to the request for access to the personal information within a reasonable period after the request is made; and

(b)         give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.

Other Means of Access

12.5      If Ascention Assets refuses:

(a)             to give access to the personal information because of subclause 12.2 or 12.3; or

(b)             to give access in the manner requested by the individual,

... Ascention Assets will take such steps as are reasonable in the circumstances to give access in a way that meets the needs of Ascention Assets and the individual.

12.6      Without limiting subclause 12.5, access may be given through the use of a mutually agreed intermediary.

Access Charges

12.7      Ascention Assets is not an agency and accordingly clause 12.7 is not applicable to Ascention Assets.

12.8      If Ascention Assets charges the individual for giving access to the personal information, the charge will not be excessive and will not apply to the making of the request.

Refusal to Give Access

12.9      If Ascention Assets refuses to give access to the personal information because of subclause 12.2 or 12.3, or to give access in the manner requested by the individual, Ascention Assets will give the individual a written notice that sets out:

(a)             the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so;

(b)             the mechanisms available to complain about the refusal; and

(c)              any other matter prescribed by the regulations.

12.10    If Ascention Assets refuses to give access to the personal information because of paragraph 12.3(j), the reasons for the refusal may include an explanation for the commercially sensitive decision.

Australian Privacy Principle 13 — Correction of Personal Information

Correction

13.1      If:

(a)             Ascention Assets holds personal information about an individual; and

(b)             either:

(i)               Ascention Assets is satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading; or

(ii)              the individual requests Ascention Assets to correct the information,

... Ascention Assets will take such steps as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

Notification of Correction to Third Parties

13.2      If:

(a)             Ascention Assets corrects personal information about an individual that Ascention Assets previously disclosed to another APP entity; and

(b)             the individual requests Ascention Assets to notify the other APP entity of the correction,

... Ascention Assets will take such steps as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.

Refusal to Correct Information

13.3      If Ascention Assets refuses to correct the personal information as requested by the individual, Ascention Assets will give the individual a written notice that sets out:

(a)             the reasons for the refusal except to the extent that it would be unreasonable to do so;

(b)             the mechanisms available to complain about the refusal; and

(c)              any other matter prescribed by the regulations.

Request to Associate a Statement

13.4      If:

(a)             Ascention Assets refuses to correct the personal information as requested by the individual; and

(b)             the individual requests Ascention Assets to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading,

... Ascention Assets will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.

Dealing with Requests

13.5      If a request is made under subclause 13.1 or 13.4, Ascention Assets:

(a)         will respond to the request within a reasonable period after the request is made; and

(b)         will not charge the individual for the making of the request, for correcting the personal information or for associating the statement with the personal information (as the case may be).