Purpose of Policy
PMG Media Pty Ltd (ABN 12 081 343 259) (PMG) is required and committed to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1998 (Cth) (Privacy Act). The APPs regulate the manner in which PMG, and its affiliates, protects the privacy of personal information throughout its lifecycle, from collection or receipt to use and disclosure, storage, accessibility and disposal.
The purpose of this policy is to set out the open and transparent approach PMG takes in relation to the treatment and management of Personal Information; as well as to outline the measures PMG has implemented to safeguard the privacy of those individuals who voluntarily submit their personal information, whilst complying with it’s obligations under the relevant privacy laws.
The policy includes information on how PMG collects and receives, uses, discloses and keeps secure, individuals’ personal information; it also covers how PMG makes the personal information it holds available for access to and correction by the individual.
PMG is generally exempt from the Privacy Act when it collects and handles employee records; however, PMG’s policy is to protect the personal information of its employees as it does other personal information.
Personal Information: Personal information means information or an opinion (including information or an opinion forming part of a database and whether or not recorded in a material form) about an individual whose identity is apparent or can reasonably be ascertained from the information whether this information or opinion is recorded in material form or not.
- a written record which may include your name, address and other details about you; and
- photographs, images, video or audio footage.
Unsolicited personal information is personal information where no active steps have been taken to collect the information provided (for example, when an employment application is sent to PMG by an individual on their own initiative, rather than in response to a job advertisement).
Disclosure: Disclosure is the action of making new or secret information known.
Direct Marketing: Direct Marketing is a form of advertising in which marketing materials are provided to consumers in order to communicate information about a product or service. Types of direct marketing materials include, but are not limited to:
- short message service (SMS) texts;
- database marketing;
- catalogue distribution; and
- promotional letters
Opt-out: The term opt-out refers to several methods by which individuals can avoid receiving unsolicited product or service information. This ability is usually associated with direct marketing campaigns (such as telemarketing, e-mail marketing or direct mail).
The main purposes for which PMG collects, holds, uses and discloses personal information are primarily to supply employees of member organisations and individuals who obtain PMG products and services directly from PMG, with information and details of its products and services; as well as for campaign management and promotional prize fulfilment. PMG may also collect and use personal information for secondary purposes including, but not limited to, the following:
- provision of products and services;
- accounting purposes; and
- business planning and product development.
PMG will only collect an individual’s personal information where the information is necessary for PMG to perform one or more if it’s functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified. PMG may also collect personal information online for all legal purposes, which includes, but is not limited to the “Get In Touch” feature on its website.
PMG will not make it mandatory for visitors of its website to provide personal information unless such information is required to answer an inquiry or provide a service.
How we may collect, hold and use personal information
The type of personal information PMG may collect and hold about an individual depends on the type of dealings that individual has with PMG. For example, if an individual:
Enters a promotion, we will collect the individuals information through a third-party website or mobile application where the information is processed and then stored on a Comma-separated values (CSV) file, or Excel spreadsheet, which is then stored on PMG’s server;
Get in touch with an enquiry, we will record details about the individual and the nature of the enquiry being made;
Is a supplier of PMG, we will collect contact address details, including, but not limited to, all forms of contact and address, billing information and information about the goods and/or services they supply; and
Applies for a role at PMG, we will collect the information the individual includes in their application for employment, including their cover letter, resume, contact details and referee reports, which are then stored with PMG.
PMG is committed to collecting personal information only by lawful and fair means. We collect personal information in a number of ways, including, but not limited to, the following:
- over the phone;
- through written correspondence (such as faxes, letters and email);
- in person (for example, at job interviews, supplier meetings and client meetings);
- through our website (for example, if an individual submits an inquiry);
- competition entry forms;
- electronic systems such as smartphone and tablet applications; and
- through third parties (such as a direct marketing database).
PMG’s policy is to not use personal information without taking reasonable steps to ensure that the information provided is accurate, complete and up to date; nor will it use sensitive information for the purposes of direct marketing.
PMG will not attempt to match de-identified or anonymous data collected through surveys or online search devices with information identifying an individual, without the consent of the relevant individual.
PMG will take reasonable steps to notify individuals (including, but not limited to, customers, promotional entrants and job applicants) of certain matters at or before the time of collection, or as practicable afterwards. These matters include, but are not limited to, the following:
- the purposes for which we are collecting the information;
- our identity and how to contact us;
- whether the collection is required or authorised by or under an Australian law, court or tribunal order;
- the third-party organisations (or types of third parties) to whom we would disclose personal information;
- whether those third-party organisations are located overseas and, if practicable, to specify the countries in which they are located;
- to provide information on how to access and correct personal information;
- to provide information on how to make privacy complaints, and how PMG will deal with those complaints; and
- the consequences (if any) for the individual if all or part of the individuals personal information is not provided to PMG.
Where individuals have consented to receiving direct marketing communications from PMG or its affiliates, the individuals consent will remain current until the individual advises otherwise; however, the individual may opt-out at any given time pursuant to the terms and conditions of the provider of the direct marketing communication.
When we may disclose personal information
PMG may disclose personal information to third parties where appropriate for the purposes set out in this policy; these third parties include, but are not limited to:
- financial institutions for payment processing;
- prize fulfilment agencies;
- educational service providers;
- government and regulatory bodies (such as Liquor and Gaming NSW, the Australian Taxation Office, Centrelink and Department of Immigration and Citizenship);
- referees whose details are provided to PMG by job applicants; and
- PMG’s contracted service providers.
PMG may disclose personal information to third parties located overseas in situations and analogous situations including, but not limited to, the following:
- data collection (for example, names, training hours and titles for global statistics);
- where cross boarder campaigns require local storing of personal information; and
- where cross boarder suppliers oversee prize fulfilment on behalf of PMG or its affiliates.
PMG is committed to comply with the requirements of the Privacy Act that apply to cross boarder disclosure of personal information, as well as with any legal requirements applicable in the relevant jurisdiction.
PMG may also disclose of personal information (including sensitive information) to avoid an imminent threat to an individual’s life or to public safety; we will also disclose personal information if required by law, including compliance with warrants, subpoenas or other legal process.
In the rare event that PMG is required to disclose personal information to law enforcement agencies, government agencies or external advisors, PMG will do so in accordance with the Privacy Act and will not disclose of government related identifiers (such as a Medicare number or driver’s license number), unless it is required or authorised by or under an Australian law or court/tribunal order.
PMG requires persons and companies to which it discloses personal information to restrict their use of such information to the purposes for which it has been provided by PMG and not to disclose of that information to others.
PMG will take reasonable steps to ensure that its contracts with third-party service providers include requirements for their compliance with this policy and Australia’s Privacy Principles.
Access to and Collection of Personal Information
All individuals have a right to request access to the personal information that PMG holds about them subject to exceptions allowed by law. Individuals wishing to lodge a request to access, correct or update their personal information can do so by contacting PMG.
PMG will also provide access in the manner that has been requested (e.g. by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable to do so. PMG may however charge a fee to cover our reasonable costs to locate the requested information and provide it to the individual lodging the request.
If a request has been lodged by an individual for PMG to update or correct their personal information, or if PMG is satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, PMG will take reasonable steps to correct that information to ensure that the information is accurate, up to date, complete, relevant and not misleading; having regard for the purpose for which it has been collected and held.
PMG will endeavour to respond to lodged requests for access to personal information as soon as practicably possible and will correct the individuals personal information in a practicable timeframe and in accordance with the Privacy Act.
Changes to our Policy
PMG may amend this policy from time to time. The current version will be made available on our website.