Privacy Policy

References to “us”, “we”, “Business First Travel” and/or “our” in these booking terms and conditions shall mean KTC Worldwide Pty Ltd t/a Business First Travel. We understand the importance of, and is committed to, protecting the privacy and confidentiality of your personal information. We comply with the Privacy Act 1988 (Privacy Act). We are bound by the Australian Privacy Principles (APPs), which regulate how we may collect, use, disclose and store personal information and how our customers (individuals for whom we arrange travel products and services) may access and correct personal information we hold about you.

Information We May Collect and Hold

The kinds of personal information we collect from you may vary depending upon the nature of the travel services you have engaged us to provide. We collect information about you that we reasonably need for our business functions and activities and which is required by law. Generally, we will collect the following kinds of personal information concerning an individual:

  1. a)Your name, address and contact details
  2. b)Company details if applicable
  3. c)Your date of birth
  4. d)Your gender
  5. e)Your nationality
  6. f) Your financial and credit information for payment purposes
  7. g)Travel related details including passport details, frequent flyer details, driver licence, travel preferences and other similar information
  8. h) Your employment details including in some cases superannuation information (in case of group travel packages facilitated by your employer)
  9. i) Personal identification documents such as your driver’s licence or birth certificate
  10. j) Your passport details
  11. k)Information concerning your visa status or informational reasonably required to assist you in obtaining a visa in a jurisdiction other than Australia
  12. l) Where you or your representative have engaged us to assist in obtaining travel insurance or other similar services, we may also collect and hold sensitive information regarding your personal health and medical history. Pursuant to our obligations arising under the Privacy Act 1988 we will only obtain such information if we are required to by law or with your express prior consent.

How We Collect and Hold your Personal Information

We will collect the majority of personal information from you directly, usually via telephone, email or face to face communication, through your completion of a form, subscription to a mailing list, or any combination of these. We may also obtain your personal information from:

  1. a)Your employer or colleagues where a travel package is being booked by them on your behalf
  2. b)Couriers
  3. c)In the case of prospective employees, recruitment agents
  4. d)Third parties who hold mailing lists to which you have subscribed
  5. e)Third party service providers such as airlines or accommodation providers where your booking is required to be made or amended by us on your behalf
  6. f) Our service providers may provide us with your personal information from websites, social media sites, mobile and other technology based sources

We will obtain your consent before contacting any third party for the purposes of collecting your personal information.

The Purposes for which we Collect, Hold, Use and Disclose your Personal Information

  1. a)Providing travel, accommodation and event services to you, your business or your employees
  2. b)Providing you with information about other services that we, our related entities and other organisations that we have affiliations with, offer that may be of interest to you
  3. c)Facilitating our internal business operations, including the fulfilment of any legal requirements
  4. d)Documenting our relationship with current and prospective employees
  5. e)Analysing our services and client needs with the view of developing new or improved services

How you may Access or Seek the Correction of Personal Information Held by Us

You may access or seek the correction of any personal information held by us by contacting the Travel Manager acting on your behalf in any of your current booking with us. Alternatively, you may contact our head office using the contact details available at our websitewww.businessfirst.travel .

We will deal with your request for such access within a reasonable time. If we refuse access, we will provide you with a written notice which sets out the reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. We may recover reasonable costs in relation to a request for access to personal information.

How you may Complain about a Breach of the APPs by Us

If at any stage you feel we have breached the APPs in our collection, use, disclosure, storage, security, management or disposal of your personal information, you may lodge a complaint with Remy Koh, Company Director – remy@businessfirst.travel

We are committed to protecting your privacy and as such we treat all complaints very seriously. Our Company Director(s) will contact you to ensure you are satisfied with our proposed resolution. If we do not respond to you within 30 days or you are not satisfied with our response, you are entitled to lodge a “Privacy Complaint Form” with the office of the Australian Information Commissioner. Copies of this form and details relating to lodgement are available atwww.oaic.gov.au/privacy/making-a-privacy-complaint.

Our Disclosure of Your Personal Information

We will not sue or disclose your personal information for a purpose other than:

  1. a)A purpose set out in this privacy policy (primary or secondary purpose above)
  2. b)A purpose you would reasonably expect
  3. c)A purpose required or permitted by law
  4. d)A purpose otherwise disclosed to you to which you have consented

Depending on the circumstances, we may disclose your personal information to other people including one or more of the following:

  1. a)Service providers including travel providers, agents, contractors, IT, security, legal, accounting, researchers, credit providers, credit reporting bodies, marketers, insurers, financial institutions and others
  2. b)Our affiliates and related companies
  3. c)Government, regulatory and law enforcement authorities, where we are required to or permitted to, by law
  4. d)Your employer if you are an employee of our business client
  5. e)To prevent or investigate any fraud or crime (or a suspected fraud or crime)

We take reasonable steps to ensure that these organisations are bound by confidentiality, privacy and security obligations with respect to the protection of your personal information.

Trans-Border Information Disclosure:

We may disclose your personal information to overseas service provider for example, a travel provider, a travel product or service provider, or a customer information call centre. Our overseas travel service providers may be located in any country that you travel to. We may also store your personal information on servers or data centres located in overseas countries.

If it is not practicable or reasonable for us to gain your consent to disclose your personal information to an overseas service provider, we will take reasonable steps to notify you of the specific countries where we disclose your personal information. We will take reasonable steps to ensure that the overseas services provider is bound by privacy, confidentiality and security obligations. If you have any specific questions about where or to whom your personal information will be sent, please contact us.

Countries in which Overseas Recipients Likely to be Located

Given the nature of our business, we disclose personal information to a broad array of international destinations. We will only disclose your personal information to third parties in the country or countries to which you will be travelling during your booking made by us on your behalf. If we intend to disclose your personal information to parties outside of this jurisdiction or their jurisdictions, we will obtain your consent prior to such disclosure.

Our Websites

We collect website activity statistics such as the number of visitors, pages visited, time and date of visit and where you accessed our website from, so that we can make informed decisions relating to improving our website and the services we deliver. This information is anonymous and does not identify a person.

When you visit our website, a cookie is placed on your computer. The cookie does not contain personal information that can identify you, but may contain information about the page you visited on our website. If you do not wish for this to occur, you can remove cookies from your computer by following the standard procedures applicable to your internet browser.

Information Security

We hold your personal information in both paper based and electronic file. We will take reasonable steps to ensure that your personal information which is held by us is protected from loss and misuse and from unauthorised access, modification, disclosure and interference.

We maintain various physical, electronic and managerial security systems and procedures to protect your personal information and regularly review these systems and procedures.

Copies of this Policy are available free of charge upon request.






Complaints handling policy.

It is a requirement of AFTA and our ATAS accreditation that a complaints handling policy is published on our website. However, we believe there should never be a circumstance where one of our valued clients would need to visit this page. 

And if you’ve gone this far, please immediately contact our Executive Director, Remy Koh on 0416 178 361 or remy@businessfirst.travel .





Business First Travel - Complaints Handling Policy and Procedures

  1. Objective of the policy

As a responsible travel agent, weseek to maintain and enhance our reputation of providing you with high quality products and services. We value complaints as they assist us to improve our products, services and customer service.

We are committed to being responsive to the needs and concerns of our customers or potential customers and to resolving your complaint as quickly as possible.

This policy has been designed to provide guidance to both our customers and staff on the manner in which wereceive and manage your complaint. We are committed to being consistent, fair and impartial when managing your complaint.

The objective of this policy is to ensure:

  • You are aware of our complaint lodgement and handling processes;
  • Both you and our staff understand our complaints management process;
  • Your complaint is investigated impartially with a balanced view of all information and evidence;
  • We take reasonable steps to actively protect your personal information; and
  • Your complaint is considered on its merits taking into account individual circumstances and needs.
  1. Definition of a complaint

In this policy a complaint means an expression of dissatisfaction by a customer relating to a travel service provided by us.

  1. How a complaint can be made

If you are dissatisfied with a travel service provided by us, you should in the first instance consider speaking directly with the staff member/s you have been dealing with. If you are uncomfortable with this or consider the relevant staff member is unable to address your concerns you can lodge a complaint with us in one of the following ways:

  • By emailing the Director, Remy Koh – remy@businessfirst.travel
  • By telephoning the Director – 0416 178 361

If we receive your complaint verbally and we consider it appropriate, we may ask you to put your complaint in writing.

Our complaints management process is free of charge.

  1. The information you will need to tell us

When we are investigating your complaint, we will be relying on information provided by you and information we may already be holding. We may need to contact you to clarify details or request additional information where necessary. To help us investigate your complaint quickly and efficiently we will ask you for the following information:

  • Your name and contact details;
  • The name of the person you have been dealing with about your travel service;
  • The nature of the complaint;
  • Details of any steps you have already taken to resolve the compliant;
  • Details of conversations you may have had with us that may be relevant to your complaint, and
  • Copies of any documentation which supports your complaint.
  1. Help when making a complaint

The person receiving or managing your complaint should provide you with any assistance you may need to make your complaint. However, if you consider you need further assistance please inform us of this at the time you are lodging your complaint.

  1. Recording complaints

When taking a complaint, we will record your name and contact details. We will also record all details of your complaint including the facts and the cause/s of your complaint, the outcome and any actions taken following the investigation of your complaint. We will also record all dates and times relating to actions taken to resolve the complaint and communications between us.

As part of our on-going improvement plan, complaints will be monitored for any identifying trends by management and rectification/remedial action taken to mitigate any identified issues.

If you lodge a complaint, we will record your personal information solely for the purposes of addressing your complaint. Your personal details will actively be protected from disclosure, unless you expressly consent to its disclosure.

Where a third-party travel supplier such as a tour operator, was involved in your travel services, we may be required to speak with them to fully investigate your complaint.

  1. Feedback to customers

We are committed to resolving your issues at the first point of contact; however, this will not be possible in all circumstances, in which case a more formal complaints process will be followed.

We will acknowledge receipt of your complaint within 2 business days and keep you informed of the progress of your complaint throughout our complaint resolution process.

We are committed to resolving your complaint within 10 business days of you lodging your complaint, however, this may not always be possible on every occasion. Where we have been unable to resolve your complaint within 10 business days, we will inform you of the reason for the delay and specify a date when we will be in a position to finalise your complaint.

During the investigation of your complaint we may need to seek further clarification or documentation from you to assist us in resolving your complaint.

If we have sought clarification or documentation from you and we are waiting on you to provide this information, we may not be able to meet our 14 day finalisation commitment. In such circumstances upon receipt of your clarification or documentation we will indicate to you when we expect to finalise your complaint.

Once we have finalised your complaint, we will advise you of our findings and any action we have taken. We will do this in writing, unless it has been mutually agreed that we can provide it to you verbally.

You have the right to make enquiries about the current status of your complaint at any time by contacting us.

  1. Our six point complaint process
  • We acknowledge – within two business days of receiving your complaint we will acknowledge receipt of your complaint.
  • We review – we undertake an initial review of your complaint and determine what if any additional information or documentation may be required to complete an investigation. We may need to contact you to clarify details or request additional information where necessary.
  • We investigate – within 10 business days of receiving your complaint we will investigate your complaint objectively and impartially, by considering the information you have provided us, our actions in relation to your dealings with us and any other information that could assist us in investigating your complaint.
  • We respond – Following our investigation we will notify you of our findings and any actions we may have taken in regards to your complaint.
  • We take action – where appropriate we amend our business practices or policies.
  • We record - we will record your complaint for continuous improvement process and monitoring through regular review, your personal information will be recorded in accordance with relevant privacy legislation.
  1. When you complain about one of our employees

If you complain about a member of our staff, we will treat your complaint confidentially, impartially and equally (giving equal treatment to all people). We will investigate your complaint thoroughly by finding out the relevant facts, speaking with the relevant people and verifying explanations where possible.

We will also treat our staff member objectively by:

  • informing them of any complaint about their performance;
  • providing them with an opportunity to explain the circumstances;
  • providing them with appropriate support; and
  • Updating them on the complaint investigation and the result.
  1. Complaints under investigation by a regulator or law enforcement agency

If your complaint is currently being investigated by a relevant federal, state or territory consumer protection regulator or law enforcement agency we may cease to take further action in relation to your complaint pending finalisation of their investigation.

We will assist any agency with their investigations.

  1. Our complaint escalation process

Where possible, we will attempt to resolve your complaint at the first point of contact. If we are unable to resolve your complaint at the first point of contact, we will undertake an investigation of your complaint and provide you with our findings.

If you are satisfied with our proposed decision or actions, we will close your complaint and record the findings for our continuous improvement program.

However, if you are not satisfied with our proposed decision or actions, we will record this, and provide you with information on how to escalate your complaint, to the Australian Federation of Travel Agents (AFTA), for external review under their AFTA Travel Accreditation Scheme (ATAS).

ATAS is an industry accreditation scheme that sets the benchmark of quality for the travel industry. ATAS is also responsible for monitoring our compliance with the ATAS Code of Conduct (the Code) and assisting in the resolution of complaints.

The Code sets the standards of good practice that ATAS participants must follow when dealing with their customers. As an ATAS participant we have agreed to be bound by the Code. If you would like to know more about the Code you can visit the ATAS websitewww.atas.com.au.

  1. AFTA Travel Accreditation Scheme (ATAS) 

Should you wish to speak to ATAS about your complaint you can contact them in the following ways:

  • By completing the online complaint form on their website www.atas.com.au
  • By telephoning them on 02 9287 9900
  • By writing to them at Level 31, 31 Market Street, Sydney NSW 2000.
  • By emailing them at compliance@afta.com.au
  1. Your rights under Australian Consumer Law

You reserve the right to refer your complaint to your relevant federal, state or territory consumer protection agency at any time.