Sir Bertram Stevens Institute Limited ABN 61 689 577 400 (SBSI, we, us, our) respects the privacy of individuals and is committed to handling personal information in an open, transparent and lawful manner. This Privacy Policy explains how we collect, hold, use, disclose and otherwise manage personal information in connection with our website, publications, campaigns, petitions, memberships, donations, events, research activities, submissions, recruitment, supplier relationships and general operations.
This Privacy Policy operates alongside any collection notice, website terms, event notice, application form, donation form, membership terms and conditions or other notice we provide at or before the time we collect personal information. To the extent of any inconsistency, the more specific notice or terms applying to the relevant interaction will prevail.
We handle personal information in accordance with applicable Australian law, including the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Notifiable Data Breaches scheme, to the extent they apply to us and to the relevant act or practice.
This Privacy Policy does not form part of any contract except to the extent expressly incorporated into separate contractual terms. To the maximum extent permitted by law, it is a statement of our information-handling practices and does not create rights or obligations beyond those imposed by law or by express written agreement.
“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form.
“Sensitive information” includes information such as political opinions, philosophical beliefs, religious beliefs or affiliations, trade union membership, criminal record, health information, biometric information and other categories treated as sensitive information under Australian law.
Depending on the nature of your dealings with us, we may collect and hold:
We may collect personal information:
We may collect, hold, use and disclose personal information for any purpose reasonably necessary for, or directly connected with, our functions and activities, including to:
Where personal information has been collected for a particular purpose, we may also use or disclose it for related secondary purposes that you would reasonably expect, and for other purposes where consent or another lawful basis exists. Sensitive information will only be used or disclosed with consent or as otherwise permitted by law.
Because SBSI operates in policy, civic and public advocacy spaces, individuals may provide sensitive information to us, including political opinions or philosophical views, in submissions, event registrations, surveys, correspondence or applications. We do not seek to collect sensitive information unless it is reasonably necessary for our activities, you consent or the law otherwise permits collection.
If you voluntarily provide sensitive information to us, you consent to our handling of that information for the purposes for which it was provided, any purpose clearly notified to you and any related administrative, compliance or dispute-management purpose. If you do not wish us to handle sensitive information, you should not provide it unless required and specifically requested.
Where lawful and practicable, we may allow you to interact with us anonymously or by pseudonym. However, this will often be impracticable where we need to process payments, register attendance, issue tickets, deliver benefits, consider applications, respond meaningfully, maintain security, comply with law or verify your identity.
You are not generally obliged to provide personal information to us. However, if you do not provide information requested by us, we may be unable to:
We may use your personal information to send you direct marketing and fundraising communications about SBSI and associated matters, including newsletters, event invitations, donation appeals, policy updates, membership offers, campaign material, surveys and other promotional or advocacy communications.
By engaging with us, including by subscribing, donating, registering, joining, attending, corresponding, signing a petition or providing contact details, you acknowledge that we may send you communications of that kind where permitted by law. We may do so by email, SMS, telephone, post, messaging applications, social media, digital advertising or other channels.
You may opt out of direct marketing communications at any time by using the unsubscribe facility, contacting us or following any other opt-out mechanism we provide. We may still send you non-marketing communications that are transactional, administrative, legal, operational or safety-related.
We and our service providers may use cookies, pixels, tags, SDKs, local storage and similar technologies to recognise devices and users, keep our website and systems secure, measure website traffic and user behaviour, track campaign source and performance, understand supporter and donor acquisition, personalise website content and communications, create or refine audience segments, support digital advertising and retargeting and improve user experience and system performance.
We may combine online usage data with other information we hold about you. Some of these tools may involve third-party providers storing or processing information on our behalf, including offshore.
You can usually control cookies through your browser settings and device controls. However, doing so may limit site functionality.
We may disclose personal information to:
We may also disclose personal information where reasonably necessary to protect SBSI’s rights, property, reputation, systems, people or operations, or to investigate suspected misconduct, fraud, abuse, security incidents or legal breaches.
Some of our service providers, contractors and technology platforms may be located outside Australia or may store, access, process, back up or support personal information from overseas. Accordingly, personal information may be disclosed to overseas recipients in countries where our providers, contractors or systems operate.
Likely countries include United States of America, Canada, New Zealand, United Kingdom of Great Britain and Northern Ireland, the Republic of Austria, the Kingdom of Belgium, the Republic of Bulgaria, the Republic of Croatia, the Republic of Cyprus, the Czech Republic, the Kingdom of Denmark, the Republic of Estonia, the Republic of Finland, the French Republic, the Federal Republic of Germany, the Hellenic Republic, Hungary, Ireland, the Italian Republic, the Republic of Latvia, the Republic of Lithuania, the Grand Duchy of Luxembourg, the Republic of Malta, the Kingdom of the Netherlands, the Republic of Poland, the Portuguese Republic, Romania, the Slovak Republic, the Republic of Slovenia, the Kingdom of Spain and the Kingdom of Sweden.
Before disclosing personal information overseas, where required we will take reasonable steps to ensure the overseas recipient handles the information in a manner consistent with applicable Australian privacy requirements, unless an exception applies. However, overseas processing may still expose information to foreign laws and regulators, and the privacy protections in those jurisdictions may differ from those in Australia.
If you provide a submission, article, paper, comment, testimonial, endorsement, biography, photograph, video, audio recording or similar material to us, you acknowledge that:
If you require anonymity or have a genuine objection to publication or recording, you should notify us in advance. We do not guarantee that all material can be withdrawn, anonymised or retrospectively edited once published, distributed, archived or shared.
We may collect and use government-related identifiers and identity documents where reasonably necessary to verify identity, prevent fraud, satisfy legal obligations, manage security or otherwise as permitted by law. We will not adopt a government-related identifier as our own identifier of you except as permitted by law.
We take reasonable steps in the circumstances to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Those steps may include access controls, password management, segregation of duties, contractual controls, staff training, secure destruction processes, monitoring, backups and encryption where appropriate.
However, no information-handling environment is completely secure. To the maximum extent permitted by law, we do not warrant or guarantee the security of any information transmitted to us or stored by us, and you provide information at your own risk to that extent.
We retain personal information for as long as reasonably necessary for our functions and activities, and for any longer period required or permitted by law, regulation, taxation, accounting, insurance, governance, dispute, enforcement, archival, backup or legitimate operational requirements.
When personal information is no longer required, and we are not required or authorised to retain it, we may destroy it or de-identify it. De-identified, aggregated or anonymised information may be retained and used indefinitely for any lawful purpose. Deletion from active systems does not necessarily mean immediate deletion from backups, archives, disaster recovery systems or legal hold repositories.
You may request access to personal information we hold about you by contacting us using the details below. We may require you to verify your identity before providing access.
We will respond within a reasonable time. Where permitted by law, we may refuse access in whole or in part. If we refuse access, we will generally provide written reasons and information about available complaint mechanisms, unless the law allows otherwise. We do not charge for making an access request, but where lawful we may charge a non-excessive fee for providing access.
If you believe personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request correction. We may require evidence reasonably necessary to assess and act on the request.
If we refuse to correct information, we will generally give written reasons and explain available complaint mechanisms.
If you believe we have handled your personal information in breach of applicable law, you may make a complaint by contacting our Privacy Officer using the details below. Your complaint should identify the relevant facts and the outcome you seek.
We will assess the complaint and respond within a reasonable period, usually within 30 days where practicable. We may request further information from you to investigate and resolve the complaint.
If you are dissatisfied with our response, you may be able to complain to the Office of the Australian Information Commissioner.
If a suspected data breach occurs, we may investigate, contain, remediate and notify affected persons, regulators and other parties as required or considered appropriate. Where the Notifiable Data Breaches scheme applies and the breach is likely to result in serious harm, notification may be required to affected individuals and the Office of the Australian Information Commissioner.
This Privacy Policy applies to personal information collected during recruitment and engagement processes. However, to the extent permitted by law, it does not necessarily apply to acts or practices directly related to current or former employment relationships and employee records where an applicable exemption operates.
Our website, emails and communications may contain links to third-party websites, payment portals, social media platforms or external services. We are not responsible for the privacy practices of those third parties. You should review their privacy policies before providing information to them.
We may amend this Privacy Policy at any time by publishing an updated version on our website or otherwise making it available. The updated version takes effect from the date of publication unless stated otherwise. Your continued dealings with us after publication of an updated version constitute acceptance of the updated policy to the extent permitted by law.
Privacy Officer
Sir Bertram Stevens Institute Limited
ABN 61 689 577 400
Email: contact@sbsi.com.au
Post: PO Box 1013, Newcastle, NSW 2300
Website: www.sbsi.com.au