The Conversation Media Group Ltd ACN 142 923 653 is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act).
This policy sets out how we handle Personal Information, including the Personal Information of our authors, commenters and readers (users), in accordance with the Privacy Act, and how you can exercise your rights under the Privacy Act.
We are a media organisation within the definition used in the Privacy Act. As such, for all our dealings with Personal Information in the course of journalism we may rely on the exemption contained in section 7B(4) of the Privacy Act.
‘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 (including names, addresses, birth dates, or email addresses).
‘Related Body Corporate’ has the same meaning as ‘Related Body Corporate’ under section 50 of the Corporations Act 2001 (Cth).
3. How do we collect your Personal Information and what types of Personal Information do we collect?
We collect your Personal Information directly from you. The types of Personal Information we collect depends on the circumstances in which the information is collected. For example, we may collect Personal Information when you create an account for, or publish an article or comment on The Conversation, which may include:
- information required to create an account:
- user name;
- login details including email address or, if you login using an existing social media account (such as Facebook, Twitter, Google+, or LinkedIn), limited information about that account;
- optional information:
- job title;
- for contributors, other contact details including phone number;
- information that you may include in your account profile, for example, profile pictures, contact details, professional history, expertise or interests; and
- comments that you may make on articles published by The Conversation.
We collect Personal Information when you donate to us online or over the phone. The types of Personal Information we collect from donors includes contact information and bank or credit card details.
We also collect your Personal Information from third parties. For example, if you create an account for The Conversation using a social media account, we may collect Personal Information, including your name and email address, from your social media account.
We also collect website analytics – anonymised statistics about how people use The Conversation. These statistics help us understand how our users, as a group, use The Conversation, and aren’t linked to specific individuals.
4. Why do we collect, use and disclose your Personal Information?
The purposes for which we use, collect and disclose your Personal Information will depend on the circumstances in which we collect it. Whenever practicable 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 permitted or required by law.
Some of the specific purposes for which we commonly collect, use and disclose your Personal Information include:
- to sign you up as a contributor or create your profile on The Conversation;
- to allow you to comment on articles published by The Conversation;
- to allow other media outlets to republish and attribute articles you have written;
- if you have requested notifications, to deliver email notifications to you;
- if you are a donor, to contact you regarding your donation or to deliver direct marketing to you (where you have consented to us doing so, or it is otherwise permitted by law);
- to allow you to participate in surveys or provide feedback to The Conversation; or
- if you have subscribed to one or more of our newsletters, to deliver email newsletters to you.
5. How do we use and disclose your Personal Information?
If you sign up to The Conversation, we will publish your author/user profile on The Conversation. Your profile will contain your name and you may choose to include additional information. Author profiles generally contain information about professional experience and expertise.
If you comment on an article published by The Conversation, we will publish your comment together with your name, which is linked to your profile.
Beyond those circumstances, we generally don’t publically disclose user Personal Information. We don’t sell our users’ Personal Information.
We may be required to disclose your Personal Information; for example, where required by law or a court order or to third parties which assist the operation of The Conversation. This may include disclosing your Personal Information to the following types of third parties (depending on the purposes for which we have collected your Personal Information):
- our Related Bodies Corporate;
- our licensees who operate overseas editions of The Conversation;
- our contractors and other third parties that provide goods and services to us including:
- website and data hosting providers;
- analytics, marketing and profiling service providers; and
- our accountants, insurers, lawyers, auditors and other professional advisors and agents;
- if you are an individual contractor to us or a prospective employee, to HR related service providers (e.g. for outsourced payroll processing, background checks);
- any third parties to whom you have directed or permitted us to disclose your Personal Information (e.g. referees); and
- otherwise as permitted or required by law.
Where we disclose your Personal Information to third parties we will use reasonable efforts to ensure that such third parties which assist with the operation of The Conversation only use your Personal Information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the APPs.
If you post information to public parts of our websites or to our social media pages, you acknowledge that such information (including your Personal Information) may be available to be viewed by the public. You should use discretion in deciding what information you post.
6. Does your Personal Information leave Australia?
Our head office is located in Australia, but we also have offices operated by licensees in the UK, the USA, France, Canada, South Africa and Indonesia. Staff in those countries have access to user Personal Information.
The systems we use to provide The Conversation are located in Australia, the United States and the UK.
Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the APPs.
7. Security of your Personal Information
We store Personal Information on computer databases and/or in hard copy and will take reasonable physical and electronic security measures to protect any records that we hold which contains Personal Information. We destroy or permanently de-identify Personal Information in a secure manner when we no longer need it. We do not store bank details or credit card information.
8. How can you access your Personal Information?
Under the Privacy Act, you have the right to access the Personal Information that we hold about you.
We handle any access request in accordance with the Privacy Act. The Privacy Act provides some exemptions to access requests. We may require that you provide proof of your identity in order to grant your access request.
It is free to make an access request. However, depending on the scope of your request, we may charge an administration fee for the time we spend locating, compiling and explaining the information you ask for. If we need to charge a fee, we will let you know up front and confirm that you would like us to proceed.
If you would like to request access to your Personal Information, please contact us at firstname.lastname@example.org.
We take reasonable steps to maintain the accuracy of your Personal Information.
Under the Privacy Act, you also have the right to ask us to correct any Personal
Information we hold about you. We encourage you to contact us if you become aware that the Personal Information we hold about you is incorrect or to notify us of a change in your Personal Information.
We handle any correction request in accordance with the Privacy Act. The Privacy Act provides some exemptions to correction requests.
If you would like to request a correction to the information that we hold about you, please contact us at email@example.com.
If you make a complaint, we will assess your complaint and respond within 30 days.
If you aren’t satisfied with the way in which we handle your complaint, you can complain to the Australian privacy regulator, the Office of the Australian Information Commissioner.
If you have any other questions or concerns, please email us at firstname.lastname@example.org.