Privacy Policy
Signpay Pty Ltd T/A Admiin Privacy Policy
(last edited 28th March 2024)
WHAT IS THIS POLICY ABOUT?
Who does this policy apply to and what does it cover?
This policy describes how we, Signpay Pty Ltd (Admiin, Admiin, we, us or our), collects, uses, discloses and holds “personal information” collected from individuals.
What is our privacy commitment to you? We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) including the Australian Privacy Principles by protecting the privacy and confidentiality of your personal information.As an Administrative and finance company we also comply with:the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the supporting Anti-Money Laundering and Counter-Terrorism Financing Rules 2007 (Cth) (AML/CTF Rules).When we collect, use, disclose, store, access, destroy or correct your personal information, our actions will comply with the Privacy Act, including the Australian Privacy Principles, the AML/CTF Act and the AML/CTF Rules.
What kinds of personal information do we collect and hold? We collect and hold a wide range of personal information, and in some cases sensitive information, including:
- your contact details (such as your name, including previous names or aliases, email addresses, residential address, phone numbers, office address);
- your date and place of birth;
- your bank account details and other banking information and transaction history;
- copies or electronic verification of your primary identification documents (such as a passport, driver’s licence, birth certificate, medicare card or citizenship certificate etc);
- your browsing history on the Admiin website including tracking of the pages you visit on the Admiin website;
- and records of your communications and other interactions with us. From time to time, we may collect additional information related to surveys, specific promotions, services or activities. Wherever practicable, we will advise you of the information being collected and provide you with an opportunity to refuse the collection of the information.
How does Admiin collect your information?Admiin generally collects your personal information directly from you or when you use the Admiin website or complete Admiin forms. However, there are certain instances where we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. We will of course obtain your consent to do this.
Will I be notified that my personal information is being collected?
When we collect information from you, we will take reasonable steps to notify you (or otherwise ensure you are that you are aware) of the following:
- our identity and contact details;
- the facts and circumstances of the collection;
- details of any laws that require or authorise the collection;
- the purposes of collection;
- the consequences if we do not collect the information;
- that this policy contains information about how you can access or correct your information or make a complaint about Admiin;
- and whether we are likely to disclose the information overseas (and if so to which countries).One way to notify you of the above is by making you aware of this policy. If you give us personal information about others, we expect you will tell them about this privacy policy.
For what purposes does Admiin collect, hold, use and disclose your personal information?
We collect, hold, use and disclose personal information to carry out certain activities, provide products and services to customers and to comply with our legal obligations.
Some of the purposes for Admiin collecting personal information include:enabling us to establish your identity and process your application, process any changes to your account or continue to offer our services to you.
This is discussed in more detail below;
- sending you emails to confirm receipt and to confirm that we have processed your account request;
- contacting you by phone or email if we have any questions in relation to any relevant documentation;
- maintaining or updating your account records;
- administering our products or services;
- managing our relationship with you;
- managing our risks and help identify any illegal activity such as fraud;
- improving our business and services to you;
- complying with our legal obligations including by providing information to government bodies, regulatory bodies such as the -Australian Taxation Office (ATO) or to AUSTRAC and law enforcement agencies;
- and providing information to third parties as required or as authorised or provided by law.
We do not use your personal information to offer you other products or services or to send you marketing materials.
Is Admiin required by law to collect personal information?
Another reason we collect personal information is to comply with our legal obligations, such as anti-money laundering laws.
The AML/CTF Act imposes a number of obligations on Admiin to collect specific personal information prior to providing certain financial services and to identify, manage and mitigate any potential risk of money-laundering or of financing terrorist activity. The legislation also imposes certain reporting obligations on Admiin.
How does Admiin use your information?
We use your personal information to primarily allow us to carry out the activities, functions and purposes listed above. We also use your personal information for secondary purposes related to those activities or when allowed under the Privacy Act.
Can I refuse to give Admiin my personal information (including sensitive information)?
You can refuse to provide us with your personal (including sensitive) information. However if you refuse to provide us with this information, we may not be able to provide our services to you. You have the option of not identifying yourself or using a pseudonym when dealing with us. However, this will be limited to enquiries of a very general nature only. It is impracticable and, in some circumstances, it is unlawful for us to deal with individuals who have not identified themselves or who have used a pseudonym when providing our services because of our obligations under the AML/CTF Act and the AML/CTF Rules.
Does Admiin share your information with third parties?
We may exchange personal information with our agents, contractors and external service providers (including organisations that assist us by providing mail delivery or courier services for the purpose of picking up documentation in an efficient manner or that we outsource certain functions to such as technology support). We may also share your personal information with credit reference organisations and credit providers, third party account aggregation services, debt collectors, legal and financial advisors and auditors and financial institutions as we deem necessary. We may disclose your information to Australian regulators and entities established to help identify illegal activity and fraud such as AUSTRAC and the ATO and law enforcement agencies if required to do so. We may also disclose information to an external dispute resolution scheme. We may also disclose information to someone you have listed as a reference (e.g. a trade reference or a landlord reference) or to your nominated guarantor or to your appointed representatives (including your agent, broker, holder of your power of attorney, legal adviser, accountant or financial adviser). We will not sell or pass on your details to any non-associated business. We do not currently exchange any of your personal information with any overseas entities or with entities that do not have an Australian link. Where it is necessary for us to give third parties access to your personal information, we will take reasonable precautions to ensure that those third parties comply with the Privacy Act and the APPs when they handle your personal information.We will disclose your personal information if we are required or authorised to do so by law enforcement agencies, Court order, the Office of the Australian Information Commissioner, the Australian Electoral Commission, the Department of Family and Community Services or the Australian Taxation Office.
FREQUENTLY ASKED QUESTIONS
How does Admiin protect your personal information (including credit related personal information)?
We take reasonable steps to ensure that your personal information is safe and secure from unauthorised use and disclosure whether such information is stored electronically or in hard copy.We enter your personal information into our secure online portal and your information is securely stored on the cloud. All information stored electronically is password protected, encrypted, protected by firewalls and other protective software and very limited access is granted to that information.All hard copy files are kept securely and files which are no longer current are archived in a secured storage area.
How does Admiin dispose of personal information?
Files that have been finalised are archived and stored securely for 7 years. After that the hard copies are destroyed using a secure waste disposal service. When electronic equipment is decommissioned our IT contractors remove and destroy the hard drive to ensure all personal information is destroyed.
What happens if my personal information or credit related personal information is involved in a data breach?
Admiin has various security measures in place to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.In the unlikely event that Admiin’s security measures are compromised and your information is the subject of a data breach, Admiin will comply with its obligations for responding to data breaches outlined in the Privacy Act.Upon becoming aware of a data breach, Admiin will take urgent steps to contain the breach, mitigate any risk of harm and determine who may have been affected.Admiin will then assess the breach, including any potential for harm, and determine whether the breach is likely to result in serious harm to any person whose data was involved.If Admiin has reasonable grounds to believe that the breach is likely to result in serious harm to you, Admiin will notify you of the breach as soon as possible. Admiin will also notify the Office of the Australian Information Commissioner.Following a breach, Admiin will conduct a review of its security measures and implement any additional measures it considers necessary to enhance the security of your information.
What does this policy mean?
By using our services you consent to the terms of this policy.From time to time, your additional consent will be sought for the collection, use or disclosure of information for purposes other than as set out in this policy. If you do not agree to any part of this policy please contact the privacy officer listed below.
How do I access and correct my personal information?
Should you wish to access or correct your personal information please contact us by phone, email or mail. You may request access to the personal information Admiin holds about you. You can also ask for corrections to be made. Admiin does not charge a fee for requesting that your personal information is corrected or for us to make the corrections. However, in processing your request for access to your personal information a reasonable cost may be charged to cover the cost of locating the information and staff time in compiling the information to give to you. For security reasons, before we can provide you with access to personal information we will need to confirm your identity. We will generally provide you access to your personal information within 30 business days of receipt of the request (unless unusual circumstances apply). If your correction request is taking longer than expected and will take in excess of 30 days to resolve we will contact you and let you know what is happening and a date by which you can reasonably expect a response.If we agree that our records need to be corrected and we have previously disclosed that information to a credit reporting agency or other person, we will tell them about the correction too.In some circumstances, we have the right to deny your request for access to personal information, for example, if giving you the information would unreasonably affect someone else’s privacy, or pose a threat to someone’s life, health or safety, or prejudice an investigation of unlawful activity, or where the personal information relates to existing or anticipated legal proceedings and the information would not be accessible by the process of discovery in those proceedings. If this occurs we will notify you accordingly and specify the reason why any such request has been refused. If you do not agree with the refusal, you may lodge a complaint about the refusal. If we refuse your request to correct your personal information you have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
What information is collected by using our website?
Each time you visit Admiin’s website we, or our Internet Service Provider (ISP), may collect information about you, including a record of the date and time of your visit, which pages you viewed and forms you completed and your IP address. Admiin’s website makes use of technology called cookies. Cookies are small pieces of information stored on your hard drive or in memory. Most internet browsers are set up to accept cookies but you can disable cookies if you wish to. We use cookies to improve the functionality of our website.Our website may, from time to time, contain links to the websites of other organisations. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy and credit reporting privacy statements.
How do I make a complaint about privacy to Admiin or contact Admiin’s Privacy Officer?
If you have any questions or feedback about privacy or wish to obtain a hard copy of this policy please do not hesitate to contact us. If you wish to make a complaint about the way in which we have handled your personal information (including credit related personal information) or believe we have breached the Privacy Act, the APPs or the CR Code, you may contact us as set out below:
Website: https://www.admiin.com
Email: hello@admiin.com
Address: Privacy Officer, Signpay Pty Ltd
Level 6, 151 Macquarie St, Sydney NSW 2000
We will acknowledge your complaint as soon as reasonably possible after receipt. We will also let you know if we need any additional information from you in order to resolve your complaint.We always strive to resolve complaints as quickly as possible and generally within 10 business days. If your complaint is taking longer than expected to resolve we will contact you with an update and a date by which you can reasonably expect a response. In the case of a credit information related complaint we may need to consult with other credit providers or credit reporting bodies which can take some time. Accordingly, for credit information related complaints, if we cannot resolve the matter within 30 days we will contact you with an update and a date by which you can reasonably expect a response. We will also seek your agreement to extend this timeframe. If you are not satisfied with the manner in which we have handled your complaint or with our response there are other bodies you can go to for an external review of your complaint.The Financial Ombudsman Service (FOS) can consider most complaints involving providers of financial services.
FOS contact details are:
Website: www.fos.org.au
Phone: 1300 78 08 08Address:
Financial Ombudsman Service: GPO Box 3 Melbourne VIC 3001
The Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Address: Office of the Australian Information Commissioner GPO Box 5218Sydney NSW 2001
Changes to our Privacy and Credit Reporting Privacy Policy Admiin may change the manner in which it handles personal information from time to time for any reason. If we make a change, this Policy will be updated accordingly.
Implementation Date
This policy is effective from March 2024.
KEY DEFINITIONS
CP derived information means any personal information (other than sensitive information) about an individual that:is derived from credit reporting information about the individual that was disclosed to Admiin by a credit reporting body; has any bearing on the individual’s credit worthiness; and is used, or has been used, or could be used, in establishing the individual’s eligibility for consumer credit.
Credit eligibility information means:information about an individual that is disclosed to Admiin by a credit reporting body; or CP derived information about an individual.
Personal information means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Sensitive information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or (viii) sexual orientation or practices; or
(ix) criminal record; that is also personal information; or
(b) health information about an individual; or
(c) genetic information about an individual that is not otherwise health information; or
(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(e) biometric templates.
(last edited 28th March 2024)
WHAT IS THIS POLICY ABOUT?
Who does this policy apply to and what does it cover?
This policy describes how we, Signpay Pty Ltd (Admiin, Admiin, we, us or our), collects, uses, discloses and holds “personal information” collected from individuals.
What is our privacy commitment to you? We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) including the Australian Privacy Principles by protecting the privacy and confidentiality of your personal information.As an Administrative and finance company we also comply with:the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the supporting Anti-Money Laundering and Counter-Terrorism Financing Rules 2007 (Cth) (AML/CTF Rules).When we collect, use, disclose, store, access, destroy or correct your personal information, our actions will comply with the Privacy Act, including the Australian Privacy Principles, the AML/CTF Act and the AML/CTF Rules.
What kinds of personal information do we collect and hold? We collect and hold a wide range of personal information, and in some cases sensitive information, including:
- your contact details (such as your name, including previous names or aliases, email addresses, residential address, phone numbers, office address);
- your date and place of birth;
- your bank account details and other banking information and transaction history;
- copies or electronic verification of your primary identification documents (such as a passport, driver’s licence, birth certificate, medicare card or citizenship certificate etc);
- your browsing history on the Admiin website including tracking of the pages you visit on the Admiin website;
- and records of your communications and other interactions with us. From time to time, we may collect additional information related to surveys, specific promotions, services or activities. Wherever practicable, we will advise you of the information being collected and provide you with an opportunity to refuse the collection of the information.
How does Admiin collect your information?Admiin generally collects your personal information directly from you or when you use the Admiin website or complete Admiin forms. However, there are certain instances where we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. We will of course obtain your consent to do this.
Will I be notified that my personal information is being collected?
When we collect information from you, we will take reasonable steps to notify you (or otherwise ensure you are that you are aware) of the following:
- our identity and contact details;
- the facts and circumstances of the collection;
- details of any laws that require or authorise the collection;
- the purposes of collection;
- the consequences if we do not collect the information;
- that this policy contains information about how you can access or correct your information or make a complaint about Admiin;
- and whether we are likely to disclose the information overseas (and if so to which countries).One way to notify you of the above is by making you aware of this policy. If you give us personal information about others, we expect you will tell them about this privacy policy.
For what purposes does Admiin collect, hold, use and disclose your personal information?
We collect, hold, use and disclose personal information to carry out certain activities, provide products and services to customers and to comply with our legal obligations.
Some of the purposes for Admiin collecting personal information include:enabling us to establish your identity and process your application, process any changes to your account or continue to offer our services to you.
This is discussed in more detail below;
- sending you emails to confirm receipt and to confirm that we have processed your account request;
- contacting you by phone or email if we have any questions in relation to any relevant documentation;
- maintaining or updating your account records;
- administering our products or services;
- managing our relationship with you;
- managing our risks and help identify any illegal activity such as fraud;
- improving our business and services to you;
- complying with our legal obligations including by providing information to government bodies, regulatory bodies such as the -Australian Taxation Office (ATO) or to AUSTRAC and law enforcement agencies;
- and providing information to third parties as required or as authorised or provided by law.
We do not use your personal information to offer you other products or services or to send you marketing materials.
Is Admiin required by law to collect personal information?
Another reason we collect personal information is to comply with our legal obligations, such as anti-money laundering laws.
The AML/CTF Act imposes a number of obligations on Admiin to collect specific personal information prior to providing certain financial services and to identify, manage and mitigate any potential risk of money-laundering or of financing terrorist activity. The legislation also imposes certain reporting obligations on Admiin.
How does Admiin use your information?
We use your personal information to primarily allow us to carry out the activities, functions and purposes listed above. We also use your personal information for secondary purposes related to those activities or when allowed under the Privacy Act.
Can I refuse to give Admiin my personal information (including sensitive information)?
You can refuse to provide us with your personal (including sensitive) information. However if you refuse to provide us with this information, we may not be able to provide our services to you. You have the option of not identifying yourself or using a pseudonym when dealing with us. However, this will be limited to enquiries of a very general nature only. It is impracticable and, in some circumstances, it is unlawful for us to deal with individuals who have not identified themselves or who have used a pseudonym when providing our services because of our obligations under the AML/CTF Act and the AML/CTF Rules.
Does Admiin share your information with third parties?
We may exchange personal information with our agents, contractors and external service providers (including organisations that assist us by providing mail delivery or courier services for the purpose of picking up documentation in an efficient manner or that we outsource certain functions to such as technology support). We may also share your personal information with credit reference organisations and credit providers, third party account aggregation services, debt collectors, legal and financial advisors and auditors and financial institutions as we deem necessary. We may disclose your information to Australian regulators and entities established to help identify illegal activity and fraud such as AUSTRAC and the ATO and law enforcement agencies if required to do so. We may also disclose information to an external dispute resolution scheme. We may also disclose information to someone you have listed as a reference (e.g. a trade reference or a landlord reference) or to your nominated guarantor or to your appointed representatives (including your agent, broker, holder of your power of attorney, legal adviser, accountant or financial adviser). We will not sell or pass on your details to any non-associated business. We do not currently exchange any of your personal information with any overseas entities or with entities that do not have an Australian link. Where it is necessary for us to give third parties access to your personal information, we will take reasonable precautions to ensure that those third parties comply with the Privacy Act and the APPs when they handle your personal information.We will disclose your personal information if we are required or authorised to do so by law enforcement agencies, Court order, the Office of the Australian Information Commissioner, the Australian Electoral Commission, the Department of Family and Community Services or the Australian Taxation Office.
FREQUENTLY ASKED QUESTIONS
How does Admiin protect your personal information (including credit related personal information)?
We take reasonable steps to ensure that your personal information is safe and secure from unauthorised use and disclosure whether such information is stored electronically or in hard copy.We enter your personal information into our secure online portal and your information is securely stored on the cloud. All information stored electronically is password protected, encrypted, protected by firewalls and other protective software and very limited access is granted to that information.All hard copy files are kept securely and files which are no longer current are archived in a secured storage area.
How does Admiin dispose of personal information?
Files that have been finalised are archived and stored securely for 7 years. After that the hard copies are destroyed using a secure waste disposal service. When electronic equipment is decommissioned our IT contractors remove and destroy the hard drive to ensure all personal information is destroyed.
What happens if my personal information or credit related personal information is involved in a data breach?
Admiin has various security measures in place to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.In the unlikely event that Admiin’s security measures are compromised and your information is the subject of a data breach, Admiin will comply with its obligations for responding to data breaches outlined in the Privacy Act.Upon becoming aware of a data breach, Admiin will take urgent steps to contain the breach, mitigate any risk of harm and determine who may have been affected.Admiin will then assess the breach, including any potential for harm, and determine whether the breach is likely to result in serious harm to any person whose data was involved.If Admiin has reasonable grounds to believe that the breach is likely to result in serious harm to you, Admiin will notify you of the breach as soon as possible. Admiin will also notify the Office of the Australian Information Commissioner.Following a breach, Admiin will conduct a review of its security measures and implement any additional measures it considers necessary to enhance the security of your information.
What does this policy mean?
By using our services you consent to the terms of this policy.From time to time, your additional consent will be sought for the collection, use or disclosure of information for purposes other than as set out in this policy. If you do not agree to any part of this policy please contact the privacy officer listed below.
How do I access and correct my personal information?
Should you wish to access or correct your personal information please contact us by phone, email or mail. You may request access to the personal information Admiin holds about you. You can also ask for corrections to be made. Admiin does not charge a fee for requesting that your personal information is corrected or for us to make the corrections. However, in processing your request for access to your personal information a reasonable cost may be charged to cover the cost of locating the information and staff time in compiling the information to give to you. For security reasons, before we can provide you with access to personal information we will need to confirm your identity. We will generally provide you access to your personal information within 30 business days of receipt of the request (unless unusual circumstances apply). If your correction request is taking longer than expected and will take in excess of 30 days to resolve we will contact you and let you know what is happening and a date by which you can reasonably expect a response.If we agree that our records need to be corrected and we have previously disclosed that information to a credit reporting agency or other person, we will tell them about the correction too.In some circumstances, we have the right to deny your request for access to personal information, for example, if giving you the information would unreasonably affect someone else’s privacy, or pose a threat to someone’s life, health or safety, or prejudice an investigation of unlawful activity, or where the personal information relates to existing or anticipated legal proceedings and the information would not be accessible by the process of discovery in those proceedings. If this occurs we will notify you accordingly and specify the reason why any such request has been refused. If you do not agree with the refusal, you may lodge a complaint about the refusal. If we refuse your request to correct your personal information you have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
What information is collected by using our website?
Each time you visit Admiin’s website we, or our Internet Service Provider (ISP), may collect information about you, including a record of the date and time of your visit, which pages you viewed and forms you completed and your IP address. Admiin’s website makes use of technology called cookies. Cookies are small pieces of information stored on your hard drive or in memory. Most internet browsers are set up to accept cookies but you can disable cookies if you wish to. We use cookies to improve the functionality of our website.Our website may, from time to time, contain links to the websites of other organisations. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy and credit reporting privacy statements.
How do I make a complaint about privacy to Admiin or contact Admiin’s Privacy Officer?
If you have any questions or feedback about privacy or wish to obtain a hard copy of this policy please do not hesitate to contact us. If you wish to make a complaint about the way in which we have handled your personal information (including credit related personal information) or believe we have breached the Privacy Act, the APPs or the CR Code, you may contact us as set out below:
Website: https://www.admiin.com
Email: hello@admiin.com
Address: Privacy Officer, Signpay Pty Ltd
Level 6, 151 Macquarie St, Sydney NSW 2000
We will acknowledge your complaint as soon as reasonably possible after receipt. We will also let you know if we need any additional information from you in order to resolve your complaint.We always strive to resolve complaints as quickly as possible and generally within 10 business days. If your complaint is taking longer than expected to resolve we will contact you with an update and a date by which you can reasonably expect a response. In the case of a credit information related complaint we may need to consult with other credit providers or credit reporting bodies which can take some time. Accordingly, for credit information related complaints, if we cannot resolve the matter within 30 days we will contact you with an update and a date by which you can reasonably expect a response. We will also seek your agreement to extend this timeframe. If you are not satisfied with the manner in which we have handled your complaint or with our response there are other bodies you can go to for an external review of your complaint.The Financial Ombudsman Service (FOS) can consider most complaints involving providers of financial services.
FOS contact details are:
Website: www.fos.org.au
Phone: 1300 78 08 08Address:
Financial Ombudsman Service: GPO Box 3 Melbourne VIC 3001
The Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Address: Office of the Australian Information Commissioner GPO Box 5218Sydney NSW 2001
Changes to our Privacy and Credit Reporting Privacy Policy Admiin may change the manner in which it handles personal information from time to time for any reason. If we make a change, this Policy will be updated accordingly.
Implementation Date
This policy is effective from March 2024.
KEY DEFINITIONS
CP derived information means any personal information (other than sensitive information) about an individual that:is derived from credit reporting information about the individual that was disclosed to Admiin by a credit reporting body; has any bearing on the individual’s credit worthiness; and is used, or has been used, or could be used, in establishing the individual’s eligibility for consumer credit.
Credit eligibility information means:information about an individual that is disclosed to Admiin by a credit reporting body; or CP derived information about an individual.
Personal information means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Sensitive information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or (viii) sexual orientation or practices; or
(ix) criminal record; that is also personal information; or
(b) health information about an individual; or
(c) genetic information about an individual that is not otherwise health information; or
(d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(e) biometric templates.
