Australia’s South West operates within the Western Australian legal jurisdiction and is bound by the laws of that jurisdiction. Australia’s South West recognises the importance of protecting the privacy of personal information and sensitive information collected in a number of ways including:
• from publicly available sources of information
• when you visit Australia’s South West websites and / or via software, such as cookies and web or tracking pixels;
• from you directly;
• from third parties;
• from records at Australia’s South West; and
• when legally required to do so.
PERSONAL INFORMATION AND SENSITIVE INFORMATION
In this document the term personal information refers to information or an opinion about an identified individual or an individual who is reasonably identifiable. Other legislation may define “personal information” differently and where that is the case, that definition applies.
Sensitive information refers to information or an opinion about an individual’s personal preferences and characteristics (such as race, ethnicity, political opinions, memberships, religious or philosophical beliefs and sexual preference), health information about an individual, genetic information and/or biometric information.
KINDS OF INFORMATION HELD AND COLLECTED BY AUSTRALIA’S SOUTH WEST
Australia’s South West is bound by the State Records Act 2000 (WA) (the State Records Act) and the Australia’s South West State Records Plan (the Australia’s South West SRP) which is made pursuant to that legislation. The State Records Act and the SRP Plan apply to all records generated by Australia’s South West.
Australia’s South West only collects (and holds) personal information when knowingly and voluntarily submitted by you. When you register your interest or otherwise in the course of us providing services to you, Australia’s South West may need to collect personal information which may include your name, address, telephone/mobile phone number, e-mail address, credit card details, your business name, your user ID or password.
Australia’s South West only collects (and holds) sensitive information when knowingly and voluntarily submitted by you. Although Australia’s South West will rarely hold and/or collect this kind of information, the information Australia’s South West may hold includes your racial or ethnic background, your family status and/or financial information about you, such as your tax file number. Subject to any legal constraints or obligations, Australia’s South West will, at all times, take reasonable steps to obtain your express consent where Australia’s South West proposes to handle your sensitive information.
Generally:
• Australia’s South West will tell you why information is being collected and how it will be used or these things will be obvious when the information is collected; and
• Australia’s South West will only use your personal information when Australia’s South West needs to contact you.
For example, Australia’s South West may need to collect such information to provide you with further services or to answer or forward any requests or enquiries. It is Australia’s South West’s intention that our practices will ensure that your personal information is dealt with in accordance with the applicable legislation in Western Australia and consistent with applicable privacy laws in Australia.
If you choose not to provide personal information to us, Australia’s South West may not be able to provide you with access to the parts of Australia’s South West websites or to certain content, products and services available on or from Australia’s South West websites or generally from Australia’s South West.
USE OF INFORMATION
Australia’s South West use your information to provide services to you or to fulfil administrative functions associated with these services. Personal information is used only for the purpose for which it is submitted or for such other secondary purposes that are related to that purpose, unless Australia’s South West discloses other uses in this Privacy Statement or at the time of collection.
Primary purpose refers to the particular purpose for which the information in question was collected. For example, if Australia’s South West provided you with a newsletter and asked for your address, the primary purpose for the collection for your address would be to send the newsletter to you at your address.
Secondary purpose is any purpose other than the primary purpose for which Australia’s South West has collected your personal information. Personal information will only be disclosed or used for a secondary purpose where:
• you have consented to the use or disclosure;
• you would reasonably expect Australia’s South West to use or disclose the information for that secondary purpose; such as targeting you with relevant information about Western Australia
• the use of disclosure is required by or under a law of Western Australia, an Australian law or a court/tribunal order;
• a ‘permitted general situation’ exists, such as lessening or preventing a serious threat to life, health or safety, locating a missing person or to undertake a confidential alternative dispute resolution process; and
• Australia’s South West reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conduct by or behalf of an enforcement body.
Australia’s South West usually collects personal information such as your name, address, telephone number, and in some instances, some of your business details. When you are on Australia’s South West websites, Australia’s South West may collect information regarding the pages within Australia’s South West’s network that you visited, what you clicked on and your IP address.
If you subscribe to receive promotional or other material from us or are registered for any services, then your personal information that you provide will be recorded. Your email address will only be used for the purpose for which you have provided it (which may include receiving destination information from Australia’s South West, being added to Australia’s South West’s mailing list, and in the instance when Australia’s South West is delivering a project in partnership with another company it may also include being added to the partner’s mailing list for that particular project) but otherwise it will not be added to any other mailing lists.
Generally, your personal information will only be accessed by Australia’s South West staff and officers when and where it is appropriate or necessary. However, your personal information may also be accessed, from time to time, by:
• Australia’s South West contractors;
• Australia’s South West project partners; and
• Australia’s South West suppliers.
Australia’s South West may enter into agreements with commercial partners whereby anonymised data collected by Australia’s South West may also be shared with data management platforms and tools. This anonymised data will be shared with their demand side advertising technologies and data management platforms and tools.
Australia’s South West may also enter into data sharing agreements with third parties whereby some data, excluding personally identifiable data or sensitive information, may be shared with the third party for limited uses. Australia’s South West will ensure that any segmented data which is shared under a data sharing agreement stored in any cookie will be anonymised or encoded so that no reference to the core source or segment can be readily identified as personally identifiable data.
Where a party, other than an employee or officer of Australia’s South West, has access to the personal information of individuals, they will be required to comply with the applicable laws of Western Australia, the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles and, where appropriate, to enter into privacy agreements with Australia’s South West.
Where Australia’s South West makes use of personal information for statistical or marketing purposes, Australia’s South West will endeavour to make use of pseudonyms and/or to make the applicable personal details anonymous.
USE OF AGGREGATE DATA
Australia’s South West may use personal information in aggregate form to improve services and make them more responsive to the needs of customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.
DISCLOSURE
Australia’s South West will be taken to have disclosed personal information when it permits that information to become known outside Australia’s South West and where it releases the information from Australia’s South West’s effective control. For example, Australia’s South West would be said to have ‘disclosed’ your personal information where:
• it shares that your personal information with another entity (other than Australia’s South West contractors, project partners and suppliers as outlined above);
• it publishes your personal information on the internet so that it is accessible by others;
• where one of its staff reveals your personal information in the course of a conversation with a person who does not work for Australia’s South West; or
• where one of its staffs sends a document containing your personal information to someone who is not you.
Apart from the primary and secondary purposes outlined above, personal information may be disclosed in special situations where Australia’s South West have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with Australia’s South West’s rights or property, users, or anyone else who could be harmed by such activities. It may also be used as required by legislation in Western Australia, including the Freedom of Information Act 1992 (WA) (the FOI Act). Finally, Australia’s South West may disclose personal information when it believes in good faith that the law requires disclosure.
PERIOD FOR WHICH RECORDS ARE HELD AND INFORMATION RETENTION AND DESTRUCTION PRACTICES
The State Records Act, the Australia’s South West Record Keeping Plan and the Retention and Disposal Schedule determine when Australia’s South West will retain or destroy records of personal information.
HOLDING PERSONAL AND SENSITIVE INFORMATION AND SECURITY
Australia’s South West strive to ensure the security, integrity and privacy of personal and sensitive information of clients. Australia’s South West use a variety of physical and electronic security measures including restricting physical access to Australia’s South West offices and firewalls and secure databases to keep personal information secure from misuse, loss or unauthorised use or disclosure. In relation to personal information provided through Australia’s South West websites, unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
Unsolicited personal information is information received where the entity has taken no active steps to collect the information. When and where Australia’s South West receives unsolicited information Australia’s South West will need to determine whether the unsolicited information should properly be retained as a record of Australia’s South West. Where Australia’s South West determines that the unsolicited information is not properly a record of Australia’s South West, Australia’s South West will destroy the information as soon as practicable, so long as it is lawful and reasonable to do so.
ACCESSING AND CORRECTING PERSONAL INFORMATION
You can make a request for access to your personal information under the Freedom of Information Act.
You have a right to request the correction and/or amendment of your personal information. Applications to have personal information held by Australia’s South West corrected or amended should be made in accordance with Part 3 of the Freedom of Information Act.
To request access, please contact Australia’s South West’s freedom of information officer as set out at the end of this document.
COOKIES
A cookie is a small text file stored on your computer’s browser. Pixels and Transparent GIF files are tiny graphics with a unique identifier, similar in function to cookies. Many cookies from websites will be visible from your browser. You will usually find information on cookies and how to manage them under “options” or “settings” in your browser. You can choose to see cookies before deleting them and to keep cookies from some websites. Generally, Australia’s South West uses cookies to learn about the way you interact with Australia’s South West’s content and to help us improve your experience when visiting Australia’s South West’s websites.
Australia’s South West may record your visit with cookies and may log the following information for purely statistical purposes:
• your server address;
• your top-level domain name (e.g. .com, .gov, .uk, etc);
• the date and time of your visit to Australia’s South West’s website;
• the pages accessed and documents downloaded by you;
• the previous website(s) visited by you; and
• the type of browser used by you.
If you do not want information collected with cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. You should note that cookies may be necessary to provide you with features and/or functions on this website and on other websites.
Australia’s South West’s websites also makes use of third-party pixels – these are pixels sent by businesses that provide content, such as advertising, on websites that you visit – that is, businesses other than Australia’s South West. Third party pixels are used on Australia’s South West’s websites to enable remarketing and reporting for impression assisted visits, websites conversions, user demographics and user interests.
The third-party pixels used on Australia’s South West’s websites include, but are not limited to, Google Analytics Advertising Features (via the use of Google advertising pixels), pixels from YouTube and the Facebook tracking / web pixel.
Australia’s South West also uses the following companies and technologies:
• Adobe Analytics / Google Analytics to analyse usage statistics on Australia’s South West websites. This analysis is performed using data collected from www.australiassouthwest.com and www.winterdownsouth.com websites and is used to improve the web experience of users. No personally identifiable information is collected by Adobe Analytics / Google Analytics on these websites by the use of cookies, but if you would like to opt-out of Adobe Analytics / Google Analytics anonymous user profiling, you can do so here and here.
If you want to opt out of the operation of third-party cookies – such as those associated with the Google Analytics Advertising Feature – you will need to refer to the privacy policies of the relevant third party website(s).
THIRD PARTY
In relation to use of websites, Australia’s South West may establish relationships with business partners that allow visitors to Australia’s South West websites to link directly to websites operated by these partners. Some of these websites may be “co-branded” with Australia’s South West’s logo; however, these websites may not be operated or maintained by or on Australia’s South West’s behalf. These websites may collect personal information from you that may be shared with us. This Privacy Statement will apply to any personal information Australia’s South West obtains in this manner.
Australia’s South West may also share audience data with these third parties via, amongst others, Google Analytics, Facebook Ad Manager, data management platforms and pixels.
Australia’s South West is not responsible for the content or practices of websites operated by third parties that are linked to Australia’s South West websites. These links are meant for the user’s convenience only. Links to third party websites do not constitute sponsorship, endorsement or approval by us of the content, policies or practices of those third party websites. Once you have left Australia’s South West websites via such a link, you should check the applicable privacy policy of the third party website.
Generally Australia’s South West has taken steps, and will continue to take steps, to ensure that and/or encourage any domestic third parties it has dealings with to comply with the Privacy Act and the Australian Privacy Principles when collecting, holding or using personal information provided to them by Australia’s South West. However, it is not possible for Australia’s South West to compel them to do so.
Australia’s South West will not generally hold third party deterministic or “third party matched” data, such as social media account log-ins and gmail logins. This data will only be acquired within the advertising technologies that Australia’s South West utilises, and in accordance with the Australian advertising industry’s governance processes.
SOCIAL MEDIA
When you browse and make use of Australia’s South West’s social media pages (such as Facebook, Instagram, Twitter and YouTube), you are using an external website and are therefore subject to the privacy policies and practices of that website. If you have any questions or concerns regarding that website’s privacy policies and practices, you should review the privacy policy of the relevant website.
Australia’s South West does not exercise any control over the management of those websites. Australia’s South West does not endorse, and is not accountable for, any views expressed by third parties using that website.
Australia’s South West can view all information posted to its social media pages and can use that information for the purposes of administering the pages, for record keeping, for considering and / or addressing any comments made and for running competitions and campaigns.
OVERSEAS DISCLOSURE
It is not standard practice for Australia’s South West to disclose personal information to overseas recipients. However, there is a possibility that, on occasion, your personal information may be disclosed to an overseas recipient. The location of any potential recipients will vary depending on the project or purpose concerned.
Collected personal information may also be stored on an overseas cloud based computing system provided by a third party data storage provider. Should you have any queries about the potential disclosure of your personal information to an overseas recipient, please contact Australia’s South West.
NOTIFICATION OF CHANGES
If Australia’s South West decides to change this Privacy Statement, Australia’s South West will post those changes to Australia’s South West websites and other places Australia’s South West deems appropriate so users are always aware of what information is collected, how it is used, and under what circumstances, if any, it is disclosed.
QUERIES AND FEEDBACK
If you have any queries relating to this Privacy Statement, or you have and feedback, please contact Australia’s South West:
• by email at [email protected];
• by calling us on +61 8 9791 9197
GENERAL DATA PROTECTION REGULATION (GDPR)
Australia’s South West recognises the importance of your privacy rights, and in turn, the importance of being transparent about how we collect, use, and share information about you, and demonstrates this by complying with applicable privacy and data protection laws such as the European Union General and Data Protection Regulations (GDPR).
With regard to GDPR, it applies to the data processing activities of Australia’s South West in the European Union. Australia’s South West offers goods and services to individuals in the European Union – via our websites and representative offices. Australia’s South West promotes Western Australia as a tourism destination and also holds, from time-to-time, roadshows and famils in the European Union. Detail around what we do with your data, and your privacy rights, and about the purposes for which we use your personal information are detailed in the Privacy Statement.
Under the EU General Data Protection Regulation (EU GDPR), EU residents may exercise their data subjects rights – for example:
• Right of Access
• Right of Erasure
• Right to Rectification
• Right to Object
If you wish to exercise these rights, you may submit a written request using the contact details set out in the Privacy Statement.
Last updated: 04/02/2019
