Ford Australia's Privacy Commitment to You | Ford Australia
Ford Australia Privacy Policy
Version date: June 2023
Table of Contents
- Introduction
- What is personal information?
- Managing Connected Vehicle data
- What types of personal information do we collect?
- How do we collect your personal information?
- For what purposes do we collect, use and disclose your personal information?
- What happens if you don't provide personal information?
- To whom do we disclose personal information?
- Does personal information leave Australia?
- How do we protect personal information?
- What about information you provide in job applications?
- Is the personal information we hold accurate?
- Links, cookies and use of the Ford website
- How you can access and correct personal information we hold about you
- Queries, comments and complaints about our handling of personal information
- Contact details
1. Introduction
Ford Motor Company of Australia Pty Limited ABN 30 004 116 223 (Ford, we, our and us) is committed to responsible privacy practices and to complying with the Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). Where applicable, we will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act and any other applicable exemptions in the Privacy Act or other legislation.
This Privacy Policy sets out our policies on the management of personal information including how we collect personal information, the purposes for which we use this information, and to whom this information is disclosed.
Authorised Ford Dealers (Dealers) are independent entities and not related to Ford and may have privacy policies which differ from ours. Dealers are responsible for their own privacy policies and privacy practices. Please contact your Dealer directly for further information.
We may change our Privacy Policy from time to time at our discretion. At any time, the latest version of our Privacy Policy is available from our website at www.ford.com.au/privacy or from our Customer Relationship Centre.
If you use the FordPass App, please carefully read the FordPass Terms and Privacy Policy also available in the App itself.
2. What is personal information?
In this Privacy Policy, personal information has the meaning set out in the Privacy Act. Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.
We explain in Section 4 below the types of personal information we collect. One type of information we collect is data transmitted from a Ford Connected Vehicle. Where such data is associated with your vehicle and linked to you, we will treat this as personal information. We explain in Section 3 below how you can check if your vehicle is a Connected Vehicle and how you can manage Connected Vehicle data.
3. Managing Connected Vehicle data
If you drive a Ford Connected Vehicle, your vehicle contains a cellular modem. You can check if the vehicle you drive is a Connected Vehicle here. This section outlines important information about the modem’s three different states (fully activated, partially activated or de-activated), the data transmitted by your modem in each state, and how you can choose the right privacy settings for you.
To begin with, a brief explanation, including a few definitions, describing how a Ford Connected Vehicle works.
FordPass / the FordPass App is an app that you can download onto your mobile device. It can be used in conjunction with a Connected Vehicle.
FordPass Connect modem is a cellular modem containing a SIM card which enables a Ford vehicle to connect to the internet, much like a mobile device with a SIM card. The cellular modem is embedded in the vehicle and just like other parts of a vehicle, is fitted at the factory.
If you have a FordPass Connect modem in your vehicle, you have a Connected Vehicle. To make use of it, you need to download the FordPass App, create an account and, similar to the concept of Bluetooth pairing, link the two together to create a ‘fully activated’ vehicle. Once fully activated, in addition to the standard services offered in the FordPass App, a range of Connected Services are available to you as outlined in the FordPass Terms and Privacy Policy which also outlines the data transmitted by your vehicle in this fully activated state.
The second condition is known as ‘partially activated’ and is the factory default setting. Therefore, your vehicle’s modem is in a ‘partially activated’ state at the time of new vehicle delivery or after completing a Master Reset.
In this state, the modem in your Connected Vehicle is sending certain limited data to Ford, Ford Motor Company (Ford’s parent company in the US) and cloud service providers (based in the USA). The Connected Vehicle data that is transmitted is described in Section 4 and is used for the purposes described in Section 6.
The third condition is that of a de-activated modem. If a FordPass Connect modem is de-activated, the transmission of data and collection of information described ceases. Connected Services cannot operate in this state.
How to identify if a Connected Vehicle is transmitting data
In Connected Vehicles, icons displayed on the SYNC screen indicate that Connected Vehicle data is being transmitted by the vehicle. These appear as:
shows that the modem is activated and that Connected Vehicle data excluding location is being transmitted.
shows that the vehicle’s location is being transmitted.
shows the modem is activated, and that both Connected Vehicle data and the vehicle’s location are being transmitted.
How to control the data that is sent from a Connected Vehicle’s FordPass Connect modem?
You can change the data sent from your FordPass Connect modem or de-activate the modem via the SYNC system in your vehicle. In the Settings menu, select Customer Connectivity Settings and choose the options that are right for you.
The importance of Master Reset if you plan to sell your vehicle or you have just acquired it
If you are the first owner, your modem came in a partially activated state. If you are not the first owner, it may be in one of three states – fully activated, partially activated or de-activated as described above.
A Master Reset will reset both SYNC and modem to factory settings.
For the modem, this means returning it to a partially activated state. This will delete all authorised FordPass users, removing access to the Connected Vehicle via any linked FordPass account.
For the SYNC system, this means erasing all mobile phone and navigation data imported from all mobile devices that had been previously linked to your vehicle via Bluetooth. It also includes the deletion of addresses entered manually into the SYNC navigation system.
Completing this process is particularly important if you are not the first owner. Likewise, please don’t forget to do a Master Reset if you ever sell your vehicle. It is much like wiping your smart phone memory when you upgrade to a new device.
To perform a Master Reset, in SYNC select Settings and navigate to select Master Reset.
If you are not the first owner, we recommend that you contact Ford to let us know you are the new owner of your vehicle and we recommend you immediately Master Reset your vehicle, as described above.
Sharing your Connected Vehicle, or driving a shared vehicle
You can choose to share access to your Connected Vehicle to other users by authorising them in FordPass (only in fully activated state). This offers ultimate flexibility, particularly in a household setting where multiple members use the same vehicle. However, it is important to understand how the data moves in this situation.
If you are driving a Connected Vehicle, with a FordPass App account connected to it, the user(s) of the FordPass App may, depending on the connectivity settings selected in the vehicle, have access to:
- the vehicle's location;
- services which allow the vehicle to be remotely started, locked and unlocked;
- services which show information about the vehicle's status (for example, its fuel level); and
- notifications such as service reminders or useful tips.
More than one FordPass App account can be connected to a single vehicle. If you are driving a vehicle with more than one FordPass App account connected to it, depending on the connectivity settings selected in the vehicle, the user(s) of each account will have access to the information and services outlined above.
If you choose to connect your FordPass App account to a vehicle which has already been connected to another FordPass App account, your name and the fact that you have requested this connection will be shared, via the FordPass App, with user(s) who connected to the vehicle before you. This user or users will be given the opportunity to allow or refuse your connection to the vehicle.
If you share your Connected Vehicle with others, please tell them about your connectivity settings. For example, let them know where they can find the information needed to turn off location and other data sharing in the Settings menu in SYNC. You are responsible for ensuring that anyone you share your vehicle with is aware of the connectivity settings and our collection and use of data.
Your vehicle may tell a new driver that it is sharing data via pop-up notifications in-vehicle to alert drivers of data sharing settings. Drivers without a mobile device or with an unrecognised mobile device will see a pop-up displayed in-vehicle alerting them to the current vehicle data or location sharing settings. A mobile device is “recognised” if it has been paired with the SYNC system. This way if someone is new to your vehicle, or not driving it enough to pair their mobile device, the vehicle will notify them of its current connectivity settings.
So don’t forget, when putting back your seat position or adjusting your mirrors, you might also need to check your connectivity settings. Please note that disconnecting the vehicle, or changing data sharing settings, may impact the availability of certain Connected Services.
As mentioned previously, where Connected Vehicle data is associated with your vehicle and linked to you, we will manage this as personal information.
4. What types of personal information do we collect?
The types of personal information we collect from you depends on the circumstances in which the information is collected.
We may collect contact details including your name, address, email address and phone numbers.
Where relevant, we may also collect your driver’s licence and registration details, date of birth or age group, occupation, gender, information about your vehicle (including its number plate and vehicle identification number), answers you provide to questions we ask and other information in relation to your dealings with Ford or Dealers (such as types of vehicle purchased and replaced and repair/service history).
If you are an employee or individual contractor to Ford, in addition to the information referred to above, we may collect information relevant to your engagement with Ford including qualifications, length of engagement, resume, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of Ford equipment (e.g. phones, computers and vehicles). A reference to an individual contractor in this document includes those individuals who perform work for Ford under a ‘purchased service’ arrangement or as a contract worker placed with Ford. If you are employed by or contracted to a Dealer, we may also collect and maintain training records about you.
If you attend Ford premises to work or as a visitor, we may collect your image through our use of a closed-circuit television (CCTV) system with fixed security cameras. Please refer to our CCTV Personal Information Collection Notice (located on our website) for more information.
If you drive a Ford Connected Vehicle and the vehicle is partially activated (as described in Section 3), the modem in your vehicle is sending certain limited data to Ford, Ford Motor Company (Ford’s parent company in the US) and cloud service providers (based in the USA). Data sent comprises vehicle diagnostic data (including diagnostic trouble codes when detected), vehicle maintenance data (such as fuel and fluid levels, engine temperature and odometer information), the electronic serial number of your FordPass Connect modem (ESN), the SIM serial number (ICCID) and the vehicle identification number (VIN). Where Connected Vehicle data is associated with your vehicle and linked to you, we will manage this as personal information.
Note, if you drive a Ford Connected Vehicle and the vehicle is fully activated (as described in Section 3), as previously mentioned, the data transmitted by your vehicle’s modem is outlined in the FordPass Terms and Privacy Policy. You will have accepted these terms when you created your FordPass account.
When using the Ford website, we or our third-party service providers may collect web site usage information such as the IP address you are using, the name of your Internet service provider, your browser version, the web site that referred you to us and the next website you go to, the pages you request, the date and time of those requests and the country you are in. Except where you provide it to us via the website, we do not collect personal information such as your name, mailing address, email address or phone number when you are browsing our website.
We do not generally require customers to disclose any sensitive information (e.g. details of race, religious beliefs, sexual orientation, health information etc.) to us. In limited circumstances, we may require prospective employees, employees, individual contractors and Dealer personnel to provide us with certain health information.
If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
Occasionally, sensitive information in relation to an individual’s membership of a trade or similar association may be provided to us but we do not actively seek this information. We will only use and disclose that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
In addition to the types of personal information identified above, Ford may collect personal information as otherwise permitted or required by law.
5. How do we collect your personal information?
We collect personal information in a number of ways. The most common ways we collect your personal information are:
- directly from you when you provide it to us or our agents or contractors (e.g. via our Customer Relationship Centre);
- via Dealers from which you purchase Ford related goods or services;
- via the FordPass App when you create an account;
- via our website or when you deal with us online (including through social media);
- via our market research agencies;
- when you enter a competition or promotion;
- if you are an individual contractor to Ford, from your employer or recruitment agency;
- if you are employed by or contracted to a Dealer, from that Dealer;
- via in-vehicle technologies (e.g. Connected Vehicle data and analytics sharing, SYNC system analytics and diagnostics features);
- via CCTV security cameras located on Ford premises;
- from publicly available sources;
- from our related companies; and
- from third parties (for example, from referees if you apply for a position as an employee or contractor with us).
6. For what purposes do we collect, use and disclose your personal information?
The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
We may use or disclose your personal information:
- for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
- for other purposes to which you have consented; and
- as otherwise authorised or required by law.
In general, we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.
Some of the specific purposes for which we collect, use and disclose personal information are as follows:
- to fulfil your requests and deal with your enquiries;
- to record and maintain the details of your purchase of a Ford vehicle, product or service for warranty and administration purposes;
- to keep track of the repairs and servicing of your Ford vehicle by Dealers;
- to create and administer your web and FordPass accounts;
- to allow you to control certain vehicle features and to provide you with Connected Services (where relevant);
- to facilitate the provision of roadside assistance and other services you acquire from us, Dealers or our agents or contractors;
- to inform you in the event of a field service action, for example a recall, affecting your Ford vehicle;
- to personalise your experience and the communications you receive, such as timely service reminders;
- for troubleshooting purposes;
- to carry out remote diagnostics activities;
- to provide software updates to your vehicle;
- to contact you (directly or through our service providers and market research agencies) to obtain your feedback and to find out your level of satisfaction with our products, services and Dealers through surveys;
- to assess the quality of the services we and our dealers provide, and the services our suppliers provide to us or on our behalf;
- to develop new or revised products, services, and business and marketing strategies;
- to predict which Ford products or services could be of interest to you;
- to address any issues or complaints that we or you have regarding our relationship;
- to verify your identity;
- to facilitate your entry and participation in a competition or trade promotion;
- to consider you for a job at Ford (whether as an employee or contractor) or other relationships with us;
- to facilitate and manage your relationship with us;
- to provide goods or services to you or to receive goods or services from you;
- to comply with legal requirements or requests from public authorities; and
- to detect, prevent, or otherwise address fraud, security, safety, or privacy issues.
We may also use and disclose your personal information (and where you own a Connected Vehicle, your Connected Vehicle data) for the purpose of direct marketing to you where:
- you have consented to us doing so; or
- it is otherwise permitted by law.
Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you and to provide you with special offers from Ford or our Dealers. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS. You can unsubscribe from our direct marketing, or change your contact preferences, by contacting us (see Section 16 of this Privacy Policy). If you wish to unsubscribe from direct marketing you have received from a Dealer, please contact that Dealer directly.
7. What happens if you don't provide personal information?
Generally, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information, there may be a consequence, such as us not being able to provide you with the products and services that depend on the collection of that information.
As an example, if we did not collect personal information about your new vehicle purchase, we would be unable to notify you directly of a product recall affecting your vehicle.
8. To whom do we disclose personal information?
We may disclose your personal information to third parties in connection with the purposes described in Section 6 of this Privacy Policy or another purpose of which we notified you when we collected your personal information.
This may include disclosing your personal information to the following types of third parties:
- Dealers;
- our related companies and our affiliates, being the group of companies related to us by common control or ownership;
- our contractors (including mailing houses, marketing agencies, website and data hosting providers and other IT suppliers);
- companies or other organisations who perform services for, or in connection with, us (including to facilitate the delivery of purchases, to provide roadside assistance, to autoclubs, for electronic direct mailing, for credit card payment authorisation, for trend analysis, for market research, for promotions and for the provision of statistical sales information to industry bodies);
- companies who may use your personal information in order to tailor electronic advertising to you (e.g. on a webpage) in relation to our products and services;
- our accountants, insurers (including those that provide extended warranties), lawyers, auditors and other professional advisers;
- if you are an individual contractor to Ford, to your employer or agency in relation to the performance of your work with Ford;
- if you are an individual contractor to Ford or a prospective employee, to our medical service providers for any medical assessments or in relation to any health or safety incidents and to HR related service providers (e.g. for background checks, screening or aptitude testing);
- any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
- in the unlikely event that we or our assets may be acquired or considered for acquisition by a third-party, that third-party and its advisors;
- third parties that require the information for law enforcement or to prevent a serious threat to public safety;
- any law enforcement agency, court, regulator, government authority or other third party where we believe sharing the personal information is necessary for us to comply with our legal or regulatory obligations, or otherwise to protect our rights, the rights of any third party or any individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues; and
- otherwise as permitted or required by law.
Where we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Privacy Principles under the Privacy Act, e.g. by (where commercially practical) including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.
If you post information to certain public parts of our website or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
Your personal information will not be sold by Ford to any other organisation for that organisation's unrelated independent use. If you have opted in to receive marketing materials from us, we may share anonymised (or hashed) data with social media advertising partners, such as Facebook, so that they can create Custom Audiences and deliver advertisements on our behalf to their members. Members are identifiable when the Social Media partner matches our anonymised data to its anonymised data of its users.
9. Does personal information leave Australia?
The parties to whom we disclose personal information include parties located outside Australia. For example, we disclose personal information to our related companies overseas and to our overseas service providers. The countries in which these third parties are located will depend on the circumstances. Personal information is disclosed to Ford Motor Company (our parent company) in the United States of America and to other companies related to us by common control or ownership, including in India and in the United Kingdom. When this occurs, the data is stored in data processing and storage locations including Ford servers and third-party cloud infrastructure. In the ordinary course of business, we also disclose personal information to other parties located in the United States, United Kingdom, Germany, France, Spain, South Africa, Bulgaria, India, Philippines, China, Thailand and Singapore.
Except where an exception applies under the Privacy Act, we will take reasonable steps to ensure that recipients of personal information do not breach the Privacy Principles in the Privacy Act in relation to such information.
10. How do we protect personal information?
We take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth). Please notify us immediately if you become aware of any breach of security.
11. What about information you provide in job applications?
If you submit a job application to us, we will use the information provided by you to assess your application. We may disclose the information contained in your application to contracted service providers for purposes such as screening, aptitude testing, medical testing and human resources management activities.
As part of the application process or (if you are successful in being employed by Ford) after you commence employment, you may be required to complete a health questionnaire. You may also be asked to undergo a medical assessment. In that case, you will be asked to give specific consent for us to disclose your questionnaire to our service providers for the purposes of the medical assessment and for the relevant service providers to disclose the results of the assessment to us.
If you refuse to provide any of the information requested by us, or to consent to us disclosing your questionnaire to our service providers for the purpose of a medical assessment or to the disclosure of the results of your medical assessment to us, we may be unable to consider your application (or if you have been successful in being employed by Ford, we may not be able to consider you for particular roles or positions within Ford).
We will handle health information in accordance with applicable laws and our Health Information Policy which is available on request.
We may also ask you whether you agree to your personal information being provided to appropriate Ford suppliers so that you may be considered for positions with those suppliers which are relevant to your qualifications and experience.
12. Is the personal information we hold accurate?
We endeavour to maintain your personal information as accurately as reasonably possible. We rely on the accuracy of personal information as provided to us both directly (from you) and indirectly (e.g. from a Ford Dealer).
We encourage you to contact us if the personal information we hold about you is incorrect or to notify us of a change in your personal information. Our contact details are set out in Section 16 of this Privacy Policy.
13. Links, cookies and use of the Ford website
The Ford website contains links to other sites. This Privacy Policy applies to the Ford website and not any linked sites. We encourage you to read the privacy policies of each website that collects your personal information.
Ford and its third-party service providers and / or advertising partners use web tracking and storage technology tools such as web beacons, "cookies", "pixel tags" and java code on Ford websites and in emails you have agreed to receive from us to collect or receive information regarding your activities on the site (e.g. your IP address, page(s) visited, time of day). The use of such technology is an industry standard and helps monitor the effectiveness of advertising and how visitors use websites. A "cookie" is a small data element stored by your web browser on your computer system. If selected by you, the Ford websites will store your username and password in a "cookie" to enable you to be automatically logged in when you return.
We, our third-party service providers, and / or advertising partners use this technology to generate statistics and measure site activity to improve the usefulness of customer visits.
Each time you access Ford websites, we and our third-party service providers and / or advertising partners may deliver certain customised information, including ads, to you based on the data stored in your cookie. Third-party advertising partners may show our ads on sites on the Internet and serve these ads based on information they collected about a user’s prior visits to our website and other Internet activity. We may also use analytics data supplied by third party vendors to inform and optimise our ad campaigns. This practice is commonly referred to as "interest-based advertising".
Opting out of interest-based advertising: You may learn about how to opt-out of this kind of collection and use of information for your browser or device by managing your settings, and for your social media accounts by managing your preferences in your account settings.
Opting out from specific advertisers - Facebook: To learn more about Facebook advertising, go to the Privacy tab on the Facebook website footer, and carefully read the privacy policy and related information.
14. How you can access and correct personal information we hold about you
We encourage you to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate.
You may seek access to personal information which Ford holds about you by contacting us as described in Section 16 of this Privacy Policy. We will provide access to that information in accordance with the Privacy Act, subject to certain exemptions which may apply. We may require that the person requesting access provide suitable identification and where permitted by law we may charge an administration fee for granting access to your personal information.
If you wish to access, correct or update personal information held by a Ford Dealer, or unsubscribe from direct marketing from the Dealer, please contact that Dealer directly.
15. Queries, comments and complaints about our handling of personal information
If you have any questions, concerns or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy or the Privacy Act, please contact us (see Section 16 of this Privacy Policy).
We will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.
16. Contact details
Please address all privacy complaints to:
Attention: Privacy Officer
Ford Motor Company of Australia Pty Limited
Private Mail Bag 5
Campbellfield VIC 3061
OR
foacust1@ford.com
If you wish to seek access to or correct or update any personal information we hold about you, or to unsubscribe from or change your contact preferences in relation to our direct marketing, you can also contact us as follows:
- phone the Ford Customer Relationship Centre on 13FORD (13 36 73); or
- email us at foacust1@ford.com.