This document sets out the approach which Playable will take in relation to the treatment of Personal Information. It includes information on how Playable collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how Playable makes the personal information it holds available for access to and correction by the individual.
This policy is a public document and has been prepared in light of APP 1, Open and transparent management of Personal Information.
1.1 PLAYABLE will only collect Personal Information where the information is necessary for PLAYABLE to perform one or more of its 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.
1.2 PLAYABLE collects Personal Information primarily to supply organisations and individuals who obtain PLAYABLE products and services directly from PLAYABLE with information and details of it’s products and services. PLAYABLE also collects and uses Personal Information for secondary purposes including:
1. provision of products and services;
2. accounting purposes; and
3. business planning and product development.
1.3 PLAYABLE collects Personal Information in a number of different ways including:
1. forms (both paper and online, electronic forms);
2. face to face meetings;
3. communications via telephone, email or facsimile;
4. interaction with our websites; and
5. via our social media accounts.
1.4 PLAYABLE will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:
1. the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
2. other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
3. our identity and how individuals can contact us, if this is not obvious;
4. that individuals can access the Personal Information that PLAYABLE holds about them;
5. that individuals should contact PLAYABLE if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
6. the organisations or types of organisations to whom we usually Disclose the Personal Information;
7. where applicable, any law that requires the Personal Information to be collected;
8. the consequences (if any) for the individual if all or part of the Personal Information is not provided to PLAYABLE.
1.5 Where it is not practicable for PLAYABLE to notify individuals of all of the Collection Information before the collection of Personal Information, PLAYABLE will ensure that individuals are notified of the Collection Information as soon as possible after the collection. PLAYABLE will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.6 PLAYABLE will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for PLAYABLE to collect such information for an activity or function.
1.7 PLAYABLE will not collect Personal Information secretly or in an underhanded way.
2.1 PLAYABLE will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.
2.2 PLAYABLE Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 If PLAYABLE relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
1. individuals are clearly notified of their right to Opt Out from further Direct Marketing; and
2. if the individual Opts Out of all Direct Marketing the Opt Out will be respected by PLAYABLE and implemented free of charge.
2.4 PLAYABLE will not use Sensitive Information for Direct Marketing.
2.5 PLAYABLE may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 PLAYABLE will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.7 PLAYABLE will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
3.1 PLAYABLE may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2 PLAYABLE may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
3.3 PLAYABLE will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.4 In the rare event that PLAYABLE is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors PLAYABLE will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
3.5 PLAYABLE may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, PLAYABLE will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.7 PLAYABLE does not generally share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved.
4. Information Quality
4.1 PLAYABLE will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 PLAYABLE will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
5. Information Security
5.1 PLAYABLE requires employees and contractors to perform their duties in a manner that is consistent with PLAYABLE’ legal responsibilities in relation to privacy.
5.2 PLAYABLE will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within PLAYABLE who have a genuine “need to know” as well as “right to know”.
5.3 PLAYABLE will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Access and Correction
6.1 PLAYABLE will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 PLAYABLE will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting PLAYABLE, as per the details at the foot of this document.
6.4 PLAYABLE will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 Contact with PLAYABLE via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
7.2 Any formal privacy related complaints should be directed in writing to the PLAYABLE Privacy Officer Level 6 50 Carrington Street Sydney NSW 2000.
7.3 PLAYABLE will endeavour to manage any privacy related complaint efficiently and in a timely manner.
8. Anonymous Transactions
8.1 PLAYABLE will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. PLAYABLE may however request visitors to provide Personal Information voluntarily to PLAYABLE (for example, as part of a competition or questionnaire).
8.2 PLAYABLE will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
9. Transferring personal information overseas
9.1 PLAYABLE may send information overseas.
We sometimes team up with partners to offer our product. We have arrangements in place with our partners that limit their use or disclosure of your personal information.
9.2 If Personal Information must be sent by PLAYABLE overseas for sound business reasons, PLAYABLE maintains effective control of your information at all times, including by ensuring that parties located overseas are subject to strict controls that limit access and subsequent handling of your information to the extent strictly necessary to perform the relevant function and protect your information from unauthorised use and disclosure.
10. Acquisition, Merger or Bankruptcy
In the event Selector, its Parent or any of its Affiliates or Subsidiaries is acquired by another entity, or merges with a third party, the Successor Entity will be bound to respect the provisions of this Policy, with regard to any Personal Information in its possession prior to the acquisition or merger. In the event of bankruptcy, the provisions of applicable law will apply.
Collection Information means the information outlined in 1.5 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of PLAYABLE or a Related Body Corporate or those of an independent third party organisation.
Disclosure generally means the release of information outside PLAYABLE, including under a contract to carry out an “outsourced function”.
Health Information means:
1. information or an opinion about:
• the health or a disability (at any time) of an individual; or
• an individual’s expressed wishes about the future provision of health services to him or her; or
• a health service provided or to be provided to an individual; that is also personal information; or
2. other personal information collected to provide or in providing a health service; or
3. other personal information about an individual collected in connection with the donation; or intended donation by the individual of his or her body parts or body substances.
Opt-out means an individual’s expressed request not to receive further Direct Marketing.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Privacy Act means the Privacy Act 1988 (Cth) as amended from time to time.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.
Sensitive Information means:
1. information or an opinion about an Individual’s:
• racial or ethnic origin; or
• membership of a political association; or
• religious beliefs or affiliations; or
• philosophical beliefs; or
• membership of a professional or trade association; or
• membership of a trade union; or
• sexual preferences or practices; or
• criminal record; that is also personal information; or
2. Health Information about an individual; or
Use means the handling of Personal Information within PLAYABLE.
Last updated: 20th July 2017