GCT treats the handling of your personal information very seriously. To that end, GCT has systems and procedures in place to protect your privacy in relation to the handling of your personal information.
GCT abides by the Australian Privacy Principles (“APPs”), which provide a scheme in relation to the collection, disclosure, use and storage of personal information. GCT’s objective is to handle information responsibly and provide you with some control over the way information about you is handled.
The Privacy Act provides for exemptions:
- in relation to employee records (being records relating to a current or former employment relationship between GCT and the individual); and
- from coverage in relation to the journalism activities of GCT (as explained further at section 3).
- Collection of Personal Information
Personal information is information or opinion about an individual, or an individual who is reasonably identifiable (whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form). The nature of personal information collected by GCT generally comprises an individual’s name, address, phone number, fax, e-mail address, birth date and gender, as well as interests and information about your transactions with us and with some of our business partners.
The primary purpose for collecting such information is to arrange, conduct and promote GCT’s media activities (including but not limited to production, broadcasting and publishing) and provide you with requested products and services.
GCT may collect personal information from you in a number of ways. These include, but are not limited to situations in which you set up an account with a company within GCT (for example an online subscription), request to receive products or services from GCT, provide products or services to GCT, enter a competition or voting forum, utilise GCT’s services (including, but not limited to websites, mobile phone apps, blogs and online forums), complete a survey or questionnaire, or when you communicate with GCT by telephone, fax, writing, email, or any other electronic means.
Whilst GCT will attempt to ensure all transfer of data to a third party and use by a third party is secure, GCT cannot be held responsible for the theft of data by a third party, or the consequences resulting from the loss of data where that loss is associated with the technical malfunction, tampering by a third party, viruses, computer bugs, or any action or event beyond the reasonable control of GCT.
GCT does not collect personal information unless it is reasonably necessary for GCT to perform one or more of its functions and activities or supply one or more of its services. On occasion, some of this personal information may be sensitive and GCT will only collect it with your consent or when required or authorised to by law.
GCT or its agents will generally collect personal information from you directly. For example, GCT may collect personal information when you subscribe to one of the GCT’s publications, complete a survey, become a member, attend a function or event, enter a competition, make a purchase, provide a resume or enter an agreement.
You may choose to deal with GCT anonymously or under a pseudonym where lawful and practicable (i.e. provided we are still able to provide the relevant service or do business with you without that information). For example, it might not be practical to deal with you anonymously if we need to process a payment, delivery goods or services or send personalised communications to you.
- Use & Disclosure of Personal Information
Personal information provided to GCT may be shared with related companies within GCT. GCT takes all reasonably practical steps to keep such information strictly confidential.
GCT may use and disclose your personal information for the purpose for which it was initially collected, namely to arrange, conduct and promote GCT’s media activities (including but not limited to production, broadcasting and publishing) and provide you with requested products and services (and renewals thereof), as well as all purposes necessary and incidental to the provision of goods or services by GCT or by anyone on behalf of GCT.
In addition, GCT may use and disclose your personal information for purposes related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes include analysing your personal information for the purpose of identifying and referring you to products and services and/or production and broadcast activities and/or media activities that may be of benefit or interest to you, displaying targeted advertising based on those interests, improving our services, conducting research, contacting you, internal auditing and administration, adding your name to a guest list or invitation list, or assisting GCT to carry out auditing, administration, or product enhancement. Without limiting the foregoing, your personal information may be used to create an anonymous link to additional third party data (for example the data of our business partners) for the purpose of tailoring information you may be more interested in, and that link may be placed in cookies for the purpose of GCT and its business partners sending you targeted advertising when you use websites or other services over the internet, including those supplied to you by GCT as well as by third parties unaffiliated with GCT.
Additionally, in the event of a re-organisation, merger or sale, GCT may transfer any and all personal information we have collected from you to the relevant third party. GCT may also be required to disclose your personal information without your consent if the disclosure is:
- required by an enforcement body for investigative activities; or
- required or authorised by law;
- required in order to investigate an unlawful activity;
- necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.
Generally, GCT will retain your personal information within Australia and not use or disclose it overseas. However, on some occasions the information may need to be transferred to overseas countries in order to perform one of GCT’s functions or activities. In these circumstances, GCT will either obtain your express or implied consent or will use its reasonable endeavours to ensure that the foreign entity to which your personal information is transferred has appropriate measures in place to protect your personal information.
Like most business organisations, GCT performs some of its functions under licence and also contracts out some functions and relies on third party suppliers to conduct specialised activities such as website management, share registry services, mail out services, call centre services, data analysis and processing services, insurance broking, vehicle and petrol supply, supply of equipment, engineering services, security services, financial services, credit reporting services and travel and hospitality services.
Whilst personal information may be provided to these licensors and suppliers in order to enable them to perform the agreed tasks, GCT will make every effort to ensure that the supplier handles the personal information in accordance with the Australian Privacy Principles and confidentiality principles. GCT will require all such suppliers to provide privacy undertakings and enter confidentiality agreements.
- Collection, Use and Disclosure of records collected in the course of journalism
As a media organisation involved in the collection, preparation and dissemination of news, current affairs and information, the journalistic activities and practices of GCT are exempt from the APPs, however GCT is committed to observing standards in relation to privacy in the context of its journalism activities.
- Direct marketing
From time to time GCT may use your personal information to identify programs, products and services that may be of interest to you. GCT may use your personal information to send you information regarding the GCT’s programs, products and services, and those available through GCT’s business partners.
From time to time, GCT may also provide your personal information to carefully selected third parties for the purpose of them providing you with information regarding products and services specific to your needs, and to help GCT conduct product enhancement activities.
If you do not wish to receive direct marketing information from GCT or third parties (as applicable) as outlined in this section, please let GCT know by using the unsubscribe function in the communication you receive.
- Personal Information Security
GCT is committed to keeping your personal information secure, and we will take reasonable precautions to protect your personal information from unauthorised access, loss, release, misuse or alteration.
Your personal information may be stored in hard copy documents, but is generally stored electronically on GCT’s software or systems.
GCT maintains physical security over its paper and electronic data stores, such as locks and security systems. GCT also uses computer and network security technologies such as firewalls, intrusion prevention software, antivirus software, external email filtering and passwords to control and restrict access to authorised staff for approved purposes and to secure personal information from unauthorised access, modification, disclosure, misuse and loss.
Whilst GCT takes all reasonable steps to secure your personal information from loss, misuse and unauthorised access, you acknowledge that all activities in which you intentionally or unintentionally supply information to GCT carries an inherent risk of loss of, misuse of, or unauthorised access to such information. GCT cannot be held responsible for such actions where the security of the personal information is not within the control GCT, or where GCT cannot reasonably prevent such incident.
Additionally, you acknowledge that the collection and use of your personal information by third parties may be subject to separate privacy policies and/or the laws of other jurisdictions.
- Changes to This Policy
GCT may, without notice, change this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes.
If you believe that your privacy has been infringed or a breach of the APPs has occurred, you are entitled to complain. All complaints should initially be in writing and directed to GCT, who will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. GCT will try to resolve the complaint within 30 working days. When this is not possible GCT will contact you to provide an estimate of how long it will take to handle the complaint.
If you believe GCT has not adequately dealt with your complaint, you may complain to the Privacy Commissioner whose contact details are as follows:
Officer of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Email: [email protected]
GPO Box 5218 Sydney NSW 2001