Albert Group Services Pty Ltd, Boomerang Associates Pty Ltd and their related bodies corporate (collectively, Alberts, we, us or our) respect the privacy of the individuals we deal with. In our handling of personally identifiable information about individuals, we comply with the requirements of the Australian Privacy Principles (APPs) in the Federal Privacy Act 1988 (Privacy Act).
What kinds of personal information does Alberts collect and hold
We only collect personal information that we need for one or more of our business activities. Most of the personal information Alberts collects relates to individuals in their business or professional capacities, so we only collect this information as an incident of a business or potential business relationship with an individual or the organisation they work for. Some examples of this sort of information include:
- contact details of individuals or organisations seeking funding or investment;
- contact details of Alberts’ royalty clients;
- details of Alberts’ writers (and their songs) and artists (and their recordings), which we may use for marketing, promotional and rights administrative purposes;
- contact details for the people we deal with at other organisations, philanthropic associations and foundations with which Alberts has business relationships, such as industry or trade associations, media organisations, government authorities and suppliers of goods and services;
- contact details and information provided to us by the people and organisations Alberts engage to represent Alberts’ copyrights; and
- contact details and information for Alberts’ officers, employees and contractors.
Occasionally, we may collect personal information about individuals in their private capacities, for example where an individual:
- subscribes to receive Alberts’ publications;
- makes an inquiry (e.g by email or telephone);
- makes a complaint;
- makes a comment via our Facebook or LinkedIn pages, or through other social media and online channels – this is discussed further below (Section 6, Online privacy issues); or
- applies for a job with Alberts.
Alberts usually does not need to collect any sensitive information (such as information about racial or ethnic origin, political activities or affiliations, memberships of unions or other associations, religion, sexual preferences or practices, criminal record or medical history). If we do collect or hold such information, we will only do so strictly in accordance with the APPs in the Privacy Act.
- How does Alberts collect personal information
Alberts generally collects personal information from the individual. The most common ways in which Alberts collects personal information are:
- from networking and business meetings;
- from contact forms submitted to Alberts by individuals via the Alberts website;
- when individuals receiving goods or services from Alberts make payment for those goods or services;
- from grantees receiving philanthropic grants in order to process donations;
- when Alberts requires bank account details from royaltors and other creditors who receive payment by direct deposit;
- from job applications when individuals apply for jobs at Alberts;
- from contributions made via social media (including LinkedIn and Facebook); or
- from telephone, email, written and in-person enquiries directed to Alberts.
However, sometimes Alberts needs to collect personal information from a third party, for example, we may collect personal information from the Australasian Mechanical Copyright Owners Society (AMCOS) to determine whether persons or organisations may require a licence from Alberts or its administrators for the reproduction of Alberts’ copyrights.
If we collect personal information about you from a third party and it is unclear whether you have consented to the disclosure of that personal information to us, we will take reasonable steps to contact you and ensure that you are aware of the circumstances surrounding the collection and the purposes for which we have collected your personal information.
- Why does Alberts collect, hold or use personal information
Generally, we only use personal information for the primary purpose for which we have collected it, or for closely related business purposes. For example, Alberts collects personal information to fulfil its role as an investor, a funder, a lessor and a music rights manager, for the purpose of:
- assessing and managing investment opportunities;
- assessing and managing grant opportunities;
- managing commercial leases;
- issuing and administering synchronisation licences;
- managing Alberts’ memberships;
- managing business relationships;
- reviewing and assessing job applications;
- responding to enquiries and complaints;
- receiving and making various payments;
- providing information to you regarding events and industry matters; and
- performing our related administrative and organisational functions and tasks and to communicate with you about the services we offer.
In most cases, the primary purpose for which we need personal information will be apparent from the context in which we collect it. If this is not the case, we will take steps to specify our purpose(s) at, or as soon as possible after, the time of collection. We may also use personal information to send you information about our activities, or about goods or services that we believe may be relevant or useful to you. If at any time you do not wish to receive such information, please let us know by contacting our Privacy Officer (see section 9 below).
In other respects, we will only use personal information with your consent, or if we are required or permitted by law to do so (eg. under the APPs in the Privacy Act).
- To whom does Alberts usually disclose personal information
Alberts generally only discloses personal information to other persons or organisations for the primary purpose for which we have collected it, or with your consent (which may be explicit, or may be implied from your conduct or from the circumstances in which the information is collected). We may also disclose personal information if we are required or permitted by law to do so (eg. under the APPs in the Privacy Act).
The following paragraphs describe some of the organisations, or types of organisations, to which Alberts usually discloses personal information. Wherever personal information is disclosed outside of Alberts, we take reasonable steps to ensure that the recipient:
- handles that information in accordance with the APPs in the Privacy Act;
- only uses the information for the specific purpose(s) for which it is provided to them;
- does not disclose the information to any person or organisation except in accordance with directions from Alberts; and
- stores the information securely, and either destroys it or returns it to Alberts when it is no longer needed.
Occasionally, Alberts has to rely on third party contractors to provide services or perform functions on our behalf, and this may involve a disclosure of personal information by Alberts to that third party. While these vary from time to time, they may include:
- organisations that provide communication services on our behalf;
- advisers who have been engaged by Alberts to provide Alberts with legal, regulatory, administrative, financial or other services;
- debt collection agencies;
- our payroll vendor; and
- information technology service providers.
- Storage, security and destruction of personal information
Alberts takes reasonable steps to ensure that the personal information we hold is protected from risks such as loss or unauthorised access, destruction, use, modification or disclosure.
Your personal information is stored on a password protected database, hard copy files and personal devices including laptop computers which are secured from unauthorised access. We only allow authorised personnel to access personal information, and it is a condition of employment with Alberts that our employees maintain the confidentiality of all information to which they have access.
We only retain personal information for as long as it is needed by us, or for as long as we are legally required to retain the information. When we are no longer required to retain personal information, we ensure that it is disposed of or destroyed in a secure fashion in accordance with our obligations under the APPs in the Privacy Act.
- Online privacy issues
We collect data from our users in the form of cookies or contact form submissions. Contact form submissions are used to gather information so that we can stay in contact with you or respond to applications, queries or complaints. Cookies are created to measure your behaviour, improve our website performance or to target relevant content through third party platforms. This Policy applies to any personal information you choose to provide to us online, for example if you fill out a form on our website or send us an email or though cookies when browsing our website.
This Policy also applies to the personal information that individuals provide to us via our Facebook, LinkedIn, Twitter and Instagram pages or through other social media and online channels. We will generally use and disclose that information only for the purposes of participating in and managing an online conversation (including by responding to individuals’ comments), or otherwise as permitted under this Policy. We will not use or disclose information collected through these channels for marketing purposes unless we make that clear at the time of collecting the information (for example, in the context of a competition or other specific online activity). If an individual decides to communicate or otherwise publish personal information about themselves via our website, Facebook and LinkedIn pages or through other social media and online channels, then the individual acknowledges that Alberts cannot control the use of such personal information by other users of our website or other online channels.
Links to Third Party Websites
- How do I access, correct and restrict my personal information
Under the Privacy Act, you generally have a right to seek access to the personal information that Alberts holds about you, although there are some circumstances in which we may be required or permitted by law to withhold access to some or all of that information. You also have the right to ask us to correct personal information about you that you believe is inaccurate, incomplete or out of date.
If you wish to exercise these rights, we ask that you make a request in writing to our Privacy Officer (see section 9 below). You will need to provide some form of identification (e.g a copy of your driver’s licence or passport) so we can verify that you are the individual to whom the personal information relates. You should also include details of how we can contact you in case we need to discuss your request.
You may also request that we restrict the use of your personal information for direct marketing purposes by contacting us via the contact details below. Alternatively, to unsubscribe from our email database or opt out of communications (including marketing communications) you may use the opt-out facilities provided below.
- How can I make a complaint if I believe that Alberts has breached the APPs
If you would like to make a complaint in relation to this Policy or the manner in which we handle your personal information, please contact our Privacy Officer (contact details are set out in section 9). We will endeavour to respond to complaints within 30 days of their receipt.
If you are dissatisfied with our response, you may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au).
- How do I contact Alberts
If you have any questions or comments about this Policy, or if you wish to access or correct your personal information or make a complaint about our handling of that information, please contact our Privacy Officer by one of the following methods:
By telephone (during business hours): +61 2 9232 2144
By email: [email protected]
By post: The Privacy Officer
GPO Box 4899
Sydney NSW 2001
- Changes to our privacy and information handling practices
This Policy was last updated on the 1st October 2019.