Privacy Policy

The Privacy Act - How it affects you

1.0 - Introduction

Redundancy Payment Central Fund Ltd (ABN 97 007 133 833) trading as Incolink (Incolink, we, us, our) understands the importance of, and is committed to protecting the privacy and the security of your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).

This Privacy Policy describes our policies and practices for collecting, storing, handling, using, and disclosing your personal information. It also explains how you may complain about a breach of the privacy laws and how we will deal with such complaints, how you can access the personal information we hold about you and how to have that information corrected.

2.0 - Who we are & what do we do?

Incolink is a joint enterprise of employer associations and industry unions in the commercial building, construction and civil allied industries in Victoria, Tasmania, South Australia and New South Wales. One of our main functions is to administer and operate redundancy, portable sick leave, and income protection insurance schemes (collectively, Funds) for the commercial construction sector. Our services are available to both our employer and worker members and key stakeholders in the industry.

In addition to the administration of the Funds, Incolink also provides a range of related services, such as employment advice, counselling support, onsite education and awareness, injury management and insurance related services. Incolink may also collaborate, work in partnerships, enter into joint ventures or such other legal relationships with third parties (collectively, Arrangements) in respect of the services referred to above and generally in furtherance of the administration of the Funds.

3.0 - What is personal information?

Personal information includes any information or opinion about you or information from which you can be reasonably identified, whether the information is true or not and whether the information is recorded in a material form or not. Personal information may include things such as your name, address, contact details, date of birth, government issued identifiers (such as your tax file number, Medicare number or driver’s licence number), and bank account details. It also includes sensitive information.

Sensitive information includes, without limitation, information or an opinion about your religious beliefs, membership of a trade union and health information.

4.0 - Collection of personal information

Incolink will only collect your personal information if the information is necessary to perform one or more of our functions or activities.

Generally, Incolink collects your personal information directly from you, through:

(a) interactions you have with Incolink, whether face-to-face or via completion of a manual or online form, telephone, video conference, email, or other electronic communication, including via an AI enabled chatbot;

(b) your use or access of Incolink’s websites and applications;

(d) your use of Incolink’s products or services, or Incolink’s use or acquisition of your products or services (or those provided by your employer);

(e) your pre-authorisation for dividend claims;

(f) you requesting information from Incolink;

(g) you communicating with us about our products or services or other questions, or Incolink’s use or acquisition of your products or services (or those provided by your employer); and/or

(h) your voluntary participation in marketing research and/or interviews facilitated by Incolink.

Incolink may also collect information about you from your employer or other third parties, such as from:

(i) an entity representing you or of which you are a member;

(j) an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for Incolink to provide its products or services to, or acquire products or services from, that entity through you or where necessary for that entity to supply products or services to Incolink;

(k) industry bodies, employer associations or unions and their representatives, including shop stewards;

(l) information services providers;

(m) medical/allied health providers;

(n) authorised representatives such as financial advisers, lawyers, accountants, insurance underwriters, insurance and discretionary claims management organisations and brokers;

(o) government agencies, law enforcement bodies, courts and other dispute resolution bodies;

(p) if for recruitment and employment purposes, an external recruitment, labour hire, or background screening services provider or third parties with whom you have previously worked;

(q) a publicly maintained record or other publicly available sources of information including social media platforms and similar websites, such as LinkedIn;

(r) collection technologies, for example cookies, web beacons, pixels, tags, and other technologies that may collect information.

Incolink will only collect personal information about you from third parties where it is unreasonable or impracticable to collect the personal information from you directly.

Where Incolink collects personal information about you from a third party, reasonable steps will be taken to ensure that you are made aware of how to contact Incolink to access your information, the purposes for which the information is collected, the types of organisations to which information is usually disclosed and any law that requires the particular information to be collected.

4.1 - Kinds of personal information Incolink collects

Generally, the kinds of personal information Incolink may collect and hold in the course of providing our services or products are:

(a) personal details such as name and date of birth;

(b) contact details such as address, telephone number(s) and email address;

(d) identification information including viewing, or obtaining copies of, your driver’s licence, Medicare card, passport, birth certificate or extract, citizenship certificate, evidence of permanent residence or relationship status, and we may do this using a multiple identification verification process;

(e) information about events happening to, or involving you in the workplace;

(f) workers’ compensation records;

(g) where you have previously made an insurance claim, details of the products or schemes which were utilised;

(h) Tax File Number (TFN);

(i) where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;

(j) memberships to other organisations such as unions and/or any other representative associations or bodies;

(k) payment details, including bank account number;

(l) employee contract information including but not limited to gross salary, compensations and other employee benefits;

(m) details about your work experience and qualifications;

(n) financial information;

(o) health information, where applicable and lawful, including details about your physical and psychological wellbeing as well as details such as vaccination history:

(i) where you consent to the collection of such information and if relevant to the provision of our products and services, including any insurance or discretionary claims you make and/or dispute; or

(ii) where you are applying for a position with Incolink and it is relevant to Incolink’s assessment of whether you are able to perform the inherent requirements of the particular role;

(p) where you are applying for a position with Incolink, information collected in the course of the recruitment process, including background checks, including visa checks, reference checks, and (where necessary) police checks; and

(q) other information required for Incolink’s functions and activities.

In some circumstances Incolink may also hold other personal information about you.

4.2 - Sensitive Information

We will only collect sensitive information about you if it is reasonably necessary for our business functions, services and activities and if you consent to the collection (unless an exception applies). For example, we may collect voice or facial biometric information to verify your identity or authorise payments, and may do this using a multiple identification verification process.

In addition, we may collect sensitive information indirectly from third parties you deal with, for example in relation to your health information, from a health practitioner (such as a psychologist or physiotherapist) or from insurance and discretionary claims management companies where required to effectively respond to a claim.

5.0 - What if you choose not to provide information to us?

You are under no obligation to provide your personal information to Incolink. However, if you do not provide certain personal information, Incolink may be unable to properly provide its products and services to you and/or administer the Funds including through the Arrangements, which may affect your entitlements or benefits under the Funds.

5.1 - Anonymity and Psuedonymity

Where practical, you may deal with us anonymously or using a pseudonym. The majority of our services, however, will require collection of your name and other personal information to allow us to provide you with the appropriate products, services or responses.

6.0 - For what purpose do we hold, use and disclose personal information

Incolink collects, holds, uses, and discloses personal information for the purpose for which it was collected. Typically, this will include administering the Funds that Incolink manages, managing your membership details and making any payment which you may become entitled to receive. We also collect, hold, use and disclose personal information to carry out our business functions in relation to our related services such as counselling (including drug and alcohol, crisis intervention) and employment support.

If Incolink holds, uses or discloses personal information for a purpose other than the primary purpose for which it was collected (the secondary purpose), Incolink will ensure that:

(a) the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that Incolink would hold, use or disclose the personal information in that way;

(b) you have consented to the use or disclosure of the personal information for the secondary purpose; or

6.1 - Automated Systems and Artificial Intelligence

Incolink may use automated systems or tools that involve artificial intelligence, such as algorithms or machine learning (including systems or tools provided by third parties) to support the delivery of Incolink’s products and services, including to help us to efficiently analyse your personal information and sensitive information that we hold.

This may include the use of artificial intelligence tools for:

(a) intelligent claims processing;

(b) predictive analytics;

(d) reducing technical debt;

(e) virtual assistants;

(f) AI powered call routing; and

(g) 24/7 virtual support.

These artificial intelligence tools may be used to support Incolink’s processes. They do not replace human decision-making in claims processing.

7.0 How do we hold personal information?

Incolink strives to maintain the relevance, reliability, accuracy, completeness, and currency of the personal information we hold, and to protect its privacy and security. Incolink takes reasonable technical and organisational measures to protect the security of the personal information held.

Much of the information Incolink holds about you is stored electronically in secure data centres owned by either Incolink or an external service provider. Some of your personal information is stored in paper files, which are held in secure premises including secure offsite storage.

Other measures Incolink takes include:

· ensuring that the personal information that it collects is accurate, complete and up to date;

· destroying or permanently de-identifying personal information if it is no longer needed for any purpose for which the information may be used or disclosed under the Privacy Act, unless Incolink is otherwise required or authorised by law to retain the information;

· requiring all staff to complete training about information security; and

· regular monitoring and review of compliance with internal policies and industry best practice.

Incolink is not responsible for the acts or omissions of any third parties who may hold your personal information.

8.0 Who does Incolink disclose personal information to, and why?

In order to operate the Funds and perform its other activities and functions, Incolink may disclose personal information that it holds in relation to you.

To protect your personal information, we enter into agreements with our service providers that require them to comply with the Privacy Act and to only use the personal information we disclose to them for the specific services we ask them to provide.

We may also disclose your personal information to others, where:

(a) we are required or authorised by law;

(b) you have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or

Specifically, Incolink may disclose personal information held by Incolink to organisations including, but not limited to:

(a) principal contractors on building sites;

(b) industry bodies, employer associations or unions and their representatives including shop stewards;

(d) employer members of Incolink;

(e) government agencies such as Centrelink and the Child Support Agency, law enforcement bodies, courts and other dispute resolution bodies;

(f) people or entities considering acquiring an interest in Incolink’s enterprise or assets;

(g) recruitment and labour hire agencies (as required);

(h) professional advisors such as financial advisers, lawyers, accountants, agents, contractors, consultants and related bodies corporate;

(i) third party service providers including, but not limited to, printing companies and document disposal agencies;

(j) third parties who Incolink deals with or engages to provide certain services or product offerings to members and may wish to provide related services or product offerings independently of Incolink;

(k) third parties who Incolink engages to conduct surveys, brand research and reviews in relation to the services, programs and offerings it provides to members;

(l) any third parties including without limitation any of the parties listed above that may be a party to the Arrangements and who may use the information Incolink discloses as part of the arrangement for that other party’s own purposes; and

(m) any other third parties that Incolink enters into an agreement with for any purposes that Incolink considers may benefit you.

Incolink may also disclose personal information and sensitive information if it believes that there is a serious and imminent threat to an individual’s life, health, or safety if there is or a serious threat to public health or public safety.

8.1 Overseas disclosure

In limited circumstances, Incolink may disclose your personal information to a recipient that is located outside Australia if necessary to provide our products and services, including making any payment which you may become entitled to receive, for example to respond to a claim if you or your beneficiary reside overseas.

The secure data centres storing personal information and owned by Incolink or a third party are located in Australia, although some third parties may back up or mirror their data in overseas jurisdictions.

Overseas recipients may have different privacy and data protection standards. However, any overseas disclosure does not affect our commitment to safeguarding your personal information. Incolink will not disclose your personal information to recipients outside of Australia unless:

(a) we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act, including the APPs;

(b) the recipient is subject to an information privacy scheme substantially similar to the Privacy Act; or

9.0 - Do we use or disclose personal information for marketing?

Incolink also uses personal information that we hold about you to send you details of promotional offers and special events that we believe may interest you but will not do so if you tell us not to. You may opt out of receiving direct marketing materials from Incolink at any time. If you do not wish to receive direct marketing materials from Incolink, please contact our Privacy Officer using the

contact details provided in clause 15 of this Policy and request not to receive direct marketing materials from Incolink in the future. Alternatively, you can use the ‘unsubscribe’ function found at the bottom of any direct marketing emails that Incolink send to you, in which case your name will be removed from the relevant email distribution list.

10.0 - Access to and correction of personal information

At any time, you may request access to any personal information that Incolink holds about you. You may request access to your personal information in a particular manner (such as by having a copy of the personal information that Incolink holds about you, emailed, or posted to you).

If you believe that any personal information that Incolink holds about you is inaccurate, out of date, incomplete, irrelevant, or misleading, you can request that Incolink correct this information. Incolink will respond to your requests for access or correction of your personal information within a reasonable time. Incolink will endeavour to comply with such a request if it is reasonable and practicable to do so. Requests for access to, or correction of, any personal information that Incolink holds about you can be made by contacting Incolink’s Privacy Officer using the contact details provided in clause 15 of this document.

To obtain access to your personal information:

(a) you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected. Proof of identity may include providing identification documents, biometric information, bank statements or completing a multiple identification verification process;

(b) Incolink requests that you be reasonably specific about the information you require; and

(c) Incolink may charge you a reasonable administration fee, which reflects the cost to Incolink for providing access in accordance with your request.

There may be some situations where Incolink may not allow you to access personal information that it holds about you or may refuse to correct personal information. In these situations, Incolink will provide you with reasons for this decision and will provide you with information about the mechanisms available to you to challenge the refusal. Additionally, where Incolink declines to correct any personal information that it holds about you, you may request that Incolink associate with the information a statement that you claim that the information is inaccurate, out of date, incomplete, irrelevant or misleading. Incolink will then take reasonable steps to associate such a statement with your personal information.

11.0 - Users of our website

If you visit www.incolink.org.au (website) to read, browse or download information, our system may record information such as the date and time of your visit to the website, the pages accessed and

any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes only.

Like many websites, our website may use “cookies” from time to time. Cookies are small text files that we transfer to your computer’s hard drive through your web browser to enable our systems to recognise your browser. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer always allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the website may not function fully for users that disallow cookies. While we take great care to protect your personal information on our website, unfortunately no data transmission over the internet can be guaranteed to be fully secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online, particularly with respect to information you send to us via email or by submitting information using the website. We have no way of protecting that information until it reaches us. Incolink will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information due to its website being linked to the internet. The website may contain links to other sites. We are not responsible for the privacy practices, policies, or content of those sites.

12.0 - Notification of Eligible Data Breaches

Due to the Privacy Amendment (Notifiable Data Breaches) Act (Cth) 2017, we are legally required to notify affected individuals of any eligible data breaches. To comply with this legal requirement, we have implemented a Data Breach Response Plan in order to deal with actual or potential data breaches as well as the notification process to be followed when notifying you.

13.0 - Complaints Process

If you believe that your privacy has been breached, please contact us using the details below and provide details of the incident so that we can investigate it.

Our procedure for investigating and dealing with privacy breaches is as follows:

· Complaints can be made in writing and submitted to the Privacy Officer using the details in clause 15 below.

· We will treat your complaint confidentially. The Privacy Officer, or their nominated representative, will investigate your complaint and contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how it may be resolved.

· We will aim to ensure that your complaint is resolved within a reasonable time and in an appropriate manner with which you are satisfied.

· If you are not satisfied with our response or our proposed resolution of your complaint, then you may lodge a formal privacy complaint with the Office of the Australian Information Commissioner (OAIC).

The OAIC can be contacted at
Post: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001
Phone: 1300 363 992
Email: [email protected]
Website: www.oaic.gov.au

14.0 - Policy Version and Amendments

This Policy was last reviewed and updated in September 2026.

We may change this Policy (including the way we handle personal information) from time to time for any reason, including to comply with the Privacy Act, by posting the amended policy on our website. The amended policy will be effective upon being posted on this website. Please check our website regularly to ensure that you have the most recent version of the Policy. This Policy is not legally binding on Incolink in any way.

15.0 - Contact Details

If you have any questions concerning how Incolink handles personal information, if you wish to gain access to or correct any personal information about you held by Incolink, or if you have any concerns or a complaint regarding the treatment of your personal information or a possible breach of your privacy, please contact:

Post: The Privacy Officer, Incolink, 1 Pelham Street, Carlton VIC 3053
Phone: (03) 9639 3000
Email: [email protected]

ABN 97 007 133 833 © Redundancy Payment Central Fund Ltd 2020. All rights reserved.