In this Privacy Statement, the terms “we” “our” and “us” refer collectively to the participating airlines to the extent they participate in the Airline Customer Advocate (ACA) and binds the personnel engaged directly in providing the services of the ACA.
This Privacy Statement explains in general terms how we protect the privacy of the personal information you provide to us when using the services of the ACA.
This Privacy Statement will also apply to any personal information about you that is provided to us by someone else such as the applicable participating airline or your authorised representative.
This Privacy Statement does not apply to employee records, which are generally exempt from the Privacy Act.
Generally, the information we collect is the contents of your complaint and the applicable airline’s response, including any attachments and any other information provided or obtained in the course of processing your complaint.
These details include your name, contact details, flight and other travel details, and may include your frequent flyer number or other loyalty program membership details, dietary requirements and health issues relevant to your travel arrangements (if any). As we are required by law to obtain your consent to the collection of "sensitive information" we will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Privacy Statement.
As well as any information that you, your representative or the applicable participating airline lodge on our website, we may collect personal information about you when you deal with us over the telephone, send us correspondence, visit our web site or if you have contact with us in person.
As well as collecting information directly from you and the airline to which your complaint relates, there may be occasions when we collect information about you from a third party. For example, from someone making a complaint or arranging travel on your behalf or from third party contractors who provide airline or related services.
We collect your personal information for the purposes of processing your complaint, clarifying issues raised in your complaint or the airline’s response, and assisting to resolve your complaint as appropriate.
The personal information we collect may be essential for us to be able to perform the ACA services and accurately identify who is using those services.
We may disclose your personal information to third parties, for example:
- our contractors to whom we may contract out certain of the services provided by the ACA, including employment service providers, IT and data storage service providers;
- the applicable airline’s service providers used to provide the services which are the subject of your complaint, including ground handling providers, baggage or freight forwarders, caterers, reservations services and medical or special assistance providers;
- operators of frequent flyer or other relevant loyalty programs;
- travel agents used by you to obtain the relevant airline services;
- third parties referred to in your complaint;
- financial institutions used to process payment for the airline services which are the subject of your complaint; and
- our professional advisers, for example those who may conduct research and analysis about the ACA services on our behalf.
In these situations, we prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it.
We may also disclose your personal information to law enforcement agencies and governments around the world for law enforcement security, customs or immigration purposes.
Your information may also be shared between related companies of the relevant participating airline, where necessary to fulfil its purposes.
Other than the above, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
We will, on request, provide you with access to the information we hold about you, unless there is an exception which applies under the Privacy Act. Your request to provide access to this information will be dealt with in a reasonable time.
We may recover from you our reasonable costs of supplying you with access to this information.
If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the Privacy Act.
We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.
If the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.
We may transfer to people in foreign countries any of your personal information but only to fulfil the purposes set out in this Privacy Statement, for example to:
- participating airlines’ offices overseas;
- data processors, including operators of global travel distribution systems;
- other airlines, hotels and other travel and freight service providers involved in providing services in association with the services to which your complaint relates; and
- information technology and business process service providers.
If you wish to gain access to your personal information, have a complaint about a breach of your privacy or you have any query on how your personal information is handled please forward your request, complaint or query to the address below. We will respond to your query or complaint as soon as possible.
Airline Customer Advocate
Level 18, 363 George Street
Sydney, NSW 2000
This Privacy Statement applies to the participating airlines only to the extent of their participation in the ACA. The ACA itself is not an organisation that is subject to the Privacy Act.
For a copy of the Privacy Statement relating to a specific participating airline please contact the applicable airline.
Privacy complaints about an organisation’s acts or practices may be investigated by the Privacy Commissioner who has the power to make a determination including a declaration that the claimant is entitled to compensation.
We may amend this Privacy Statement as our requirements or the law changes. Any changes to this Privacy Statement will be updated on this website so please visit this website periodically to ensure that you have our most current privacy statement.