Data Privacy & Protection Policy
1. Overview
Rockfast takes data privacy and protection very seriously and this document details the data privacy and protection policy of the company.
2. Purpose
Inform staff and other parties of the Rockfast data privacy and protection policy and to ensure the responsible use and protection of customer data within our payroll software services.
3. Scope
This Data Privacy & Protection Policy applies to Rockfast International Pty. Limited’s (Rockfast) InHouse, Hosted (Cloud) HR & Payroll applications and platform (collectively, the “Services”), and other Rockfast websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Rockfast.
At Rockfast we are committed to protecting the privacy and security of personal information in compliance with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs). This policy outlines our practices for the collection, use, disclosure, and protection of personal data within our payroll software solutions. We are also committed to safeguarding the privacy and security of our customers’ personal information. This policy outlines our approach to handling customer data within our payroll software services in compliance with the prevailing legislation as stated above.
This Data Privacy & Protection Policy does not apply to any third-party applications or software that integrate with the Services through the Rockfast platform (“Third Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Software as a Service Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”).
4. Authority
The authority for this policy is the Rockfast Management comprising of:
Director, Rockfast at rockfast@rockfast.com.au
Business Manager, Rockfast at businessmanager@rockfast.com.au
5. Policy
The organisation (e.g., your employer or another entity or person) that entered into the Software as a License Agreement (“Customer”) controls their instance of the Services and any associated Customer Data.
5.1 Information we collect and receive
Rockfast Software may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals granted access to Rockfast software services (“Services”) by a Customer (“Authorised User”) may, from time to time, submit Customer Data to Rockfast when using the Services.
- Other Information. Rockfast also collects, generates and/or receives Other Information:
- Usage Information.
- Services Metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way Authorised Users work. For example, Rockfast Software may log the features, content and links you interact with, and activity logs for all actions (e.g. assignment, modification, edit, copy, delete) taken by Authorised users when interacting with the Services.
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device information. Rockfast may collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We may, for example, use a business address submitted by your organisation, or an IP address received from your browser or device to determine approximate location.
- Usage Information.
- Additional Information Provided to Rockfast: We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, employment portals, request support, interact with our social media accounts or otherwise communicate with Rockfast.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as basic user profile level information (e.g. name, email address), is not provided, we may be unable to provide the Services.
5.2 How we use information
Customer Data will be used by Rockfast in accordance with Customer’s instructions and consent, including any applicable terms in the Software as a Service Agreement and Customer’s use of Services functionality, and as required by applicable law. Rockfast is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to the application, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Rockfast uses ‘Other Information’ in furtherance of our legitimate interests in operating our Services, Websites and business. Specifically, Rockfast uses ‘Other Information’:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Software as a Service Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
- To comply with applicable legislation, legal process and/or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide additional features and improvements to functionality. Rockfast tries to make the Services as useful as possible for our Customers and their Authorised Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorised User, make Services suggestions based on historical use and predictive models, identify organisational trends and insights, to customise a Services experience or create new features or improvements or develop new products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Rockfast. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Rockfast may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
- To anonymise data to protect customer identities in analytics and reporting
If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Rockfast may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Data Privacy & Protection Policy as “Personal Data.”
5.3 Data retention
Rockfast will retain Customer Data in accordance with a customer’s instructions and consent, including any applicable terms in the Software as a Service Agreement and Customer’s use of Services functionality, and as required by applicable law. Rockfast may retain Other Information pertaining to you for as long as necessary for the purposes described in this Data & Protection Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Rockfast to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
Rockfast will securely dispose of data when it is no longer needed using Rockfast approved methods such as data wiping or physical destruction. This process is carried under Customer’s consent.
5.4 How we share and disclose information
This section describes how Rockfast may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Rockfast does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Rockfast will solely share and disclose Customer Data in accordance with a customer’s instructions, including any applicable terms in the Software as a Service Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Customer Access. Authorised Users and other nominated Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, an Authorised User’s email address which could be made visible to other Authorised Users within the Customer, or restricted to specific roles (e.g. manager or company admin) or security profiles.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth within the section “Subprocessors”.
- Change in Business structures. If Rockfast engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of Rockfast assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, or as part of new product offerings or features provided to Customers which provide anonymised benchmark metrics for comparative performance between Customers.
- Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This may include the Notifiable Data Breaches (NDB) scheme contained within the Australian Privacy Act, and data breach notification provisions contained within the European Economic Area General Data Protection Regulation (GDPR). For example, where Personal or Sensitive Information is lost or subject to unauthorised access or disclosure and will likely result in serious harm to an individual / risk to the rights and freedoms of natural persons, Rockfast will take appropriate response action in accordance with applicable law.
- Enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Rockfast or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Rockfast may share Other Information with third parties’ consent to do so.
5.5 Security
Rockfast takes security of data very seriously. We take all reasonable steps to ensure that all Customer Data and Other Information is encrypted, secured and protected from misuse, loss and unauthorised access and modification.
We implement stringent access controls ensuring that only authorised personnel can access customer data. We conduct periodic internal checks and assessments to identify and rectify vulnerabilities.
5.6 Changes to this policy
Rockfast may change this Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this policy on the Rockfast website and encourage you to review our Data Privacy & Protection Policy to stay informed. If we make changes that materially alter your privacy rights, Rockfast will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Data Privacy & Protection Policy, you may contact us at rockfast@rockfast.com.au
5.7 Data protection officer
To communicate with our Data Protection Officer, please email rockfast@rockfast.com.au
5.8 Your rights
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Authorised User account.
Customers determine their own polices to control the level of access Authorised Users have to directly update or correct information contained within Rockfast Revelation Payroll and HR applications. In circumstances where Authorised Users do not have permissions to make updates or corrections directly, they may contact the Customer to request the update, correction or removal of Personal Data under their control. Rockfast personnel have limited ability to access Customer Data.
To the extent that Rockfast’s processing of your Personal Data is subject to the General Data Protection Regulation, Rockfast’s relies on its legitimate interests, described above, to process your data. Rockfast may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Rockfast’s use of your Personal Data for this purpose at any time.
5.9 Sub processors
Rockfast requires its Sub processors to satisfy equivalent obligations as those required from Rockfast as a Processor.
5.9.1 Infrastructure Sub Processors – Service Data Storage
Rockfast production systems for the Services are currently located in co-location facilities in Australia. Data may be shifted among data centres to ensure performance and availability of Services. The following table describes the country and legal entity engaged in the storage of Customer Data by Rockfast.
| Entity Name | Entity Type | Entity Country |
|---|---|---|
| Microsoft Azure | Cloud Service Provider | Australia |
6. Data Breach Response
In the event of a data breach, prompt steps to notify affected customers and relevant authorities are taken. A sound incident response plan is in place to address and effectively mitigate breaches.
7. Policy Compliance
7.1 Compliance Measurement
The IT team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner.
7.2 Exceptions
Any exception to the policy must be approved by the directors in advance.
7.3 Non-Compliance
An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. Additionally, the company may at its discretion seek legal remedies for damages incurred as a result of any violation. The company may also be required by law to report certain illegal activities to the proper enforcement agencies.
8. Training and Awareness
Periodic updates to staff are provided on data privacy and protection policies. From time to time the management team engages in awareness programs to keep staff informed about any evolving updates in data protection practices.
