MelbourneEast Arts is committed to maintaining the privacy and confidentiality of its staff, volunteers, associated performing and visual artists, supporters and attendees of MelbourneEast Arts events.
MelbourneEast Arts undertakes to comply with the Information Privacy Act 2000 (Vic) and the Privacy Act 1988 (Cth) as amended including the thirteen Australian Privacy Principles (APPs).
APP 1 – Open and transparent management of personal information
MelbourneEast Arts collects and retains information for a range of purposes, including but not limited to:
- Presenting arts events;
- Promoting arts events;
- Conducting internal business functions and activities; and
- Meeting personal and organisational requirements.
The following types of personal information may be collected as needed:
- Contact details;
- Demographic Information relevant to cultural artistic performances and presentations;
- Billing information for bookings or payments.
For staff, contract employees and artists presenting, the following types of sensitive information may also be collected and held:
- Identity details;
- Employee details & HR information;
- Complaint or issue information;
- Disability status & other individual needs;
- Background checks, such as Criminal Checks or Working with Children checks;
- Copies of licences
How personal information is collected
MelbourneEast Arts will usually collect information directly from the individual. This may include the use of forms (such as booking forms or contact forms for event marketing) and the use of web-based systems (such as online enquiry forms or web portals).
How personal information is held
MelbourneEast Arts will use robust storage and security measures at all times. Information on collection is:
- As soon as practical, converted to electronic means;
- Stored in secure, password-protected systems; and
- Monitored for appropriate authorised use at all times.
Virus protection, backup procedures and ongoing access monitoring procedures are in place.
Accessing and seeking correction of personal information
MelbourneEast Arts confirms all individuals have a right to request access to their personal information held and to request its correction at any time. In order to request access to personal records, individuals are to make contact with:
The Contacts Coordinator
MelbourneEast Arts will not provide personal information to any third party without the prior written consent of the individual concerned. The sole exception is where a government authority requests information for valid purposes. In such cases, the party requesting access to personal information is robustly identified and vetted.
If an individual feels that MelbourneEast Arts may have breached one of the APPs or a binding registered APP Privacy Complaints Procedure in the first instance contact:
The Contacts Coordinator
Review and update of this Privacy and Confidentiality Policy
MelbourneEast Arts reviews this Privacy and Confidentiality Policy:
- On an ongoing basis, as suggestions or issues are raised and addressed, or as government-required changes are identified; and
- As a component of each complaint investigation process where the complaint is related to a privacy matter.
Whenever this policy is updated, changes to the policy are widely communicated through staff communications, meetings and documentation, and externally through publishing of the policy on the MelbourneEast Arts website and other relevant documentation for clients.
APP 2 – Anonymity and pseudonymity
MelbourneEast Arts provides individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us in relation to a particular matter, whenever practical. This includes providing options for anonymous dealings in cases of general event enquiries or other situations in which an individuals’ information is not required to complete a request.
Individuals may deal with us by using a name, term or descriptor that is different to the individual’s actual name wherever possible. This includes using a generic email address that does not contain an individual’s actual name or generic user names when individuals may access a public component of our website or enquiry forms.
MelbourneEast Arts only stores and links pseudonyms to individual personal information in cases where this is required for service delivery or once the individual’s consent has been received.
Circumstances requiring identification
MelbourneEast Arts must require and confirm identification where this is a legal requirement for staff, contractors or artists, as noted earlier in this policy.
APP 3 – Collection of solicited personal information
MelbourneEast Arts only collects personal information that is reasonably necessary for our arts activities. All information is collected only by lawful and fair means. MelbourneEast Arts only collects solicited information directly from the individual concerned.
APP 4 – Dealing with unsolicited personal information
MelbourneEast Arts may from time to time receive unsolicited personal information. Where this occurs we promptly review the information to decide whether or not we could have collected the information for the purpose of our arts activities. Where this is the case, we may hold, use and disclose the information appropriately as per the practices outlined in this policy.
Where we could not have collected this information by law or for a valid business purpose we immediately destroy or de-identify the information unless it would be unlawful to do so.
APP 5 – Notification of the collection of personal information
Whenever MelbourneEast Arts collects personal information about an individual, we take reasonable steps to notify the individual of the details of the information collection or otherwise ensure the individual is aware of those matters. This notification occurs at or before the time of collection, or as soon as practicable afterwards.
Our notifications to individuals on information collected include:
- MelbourneEast Arts’ identity and contact details;
- The purpose of collection;
- If the collection is required or authorised by law, the name of the Australian law or other legal agreement requiring the collection; and
- A link to this Privacy and Confidentiality Policy on our website.
Where possible, we ensure that the individual confirms their understanding of these details, such as through signed declarations at staff induction, website form acceptance of details or in person through questioning.
Where MelbourneEast Arts collects personal information from another organisation, MelbourneEast Arts will:
- Confirm whether the other organisation has provided the relevant notice above to the individual; or
- Whether the individual was otherwise aware of these details at the time of collection; and
- If this has not occurred, will undertake this notice to ensure the individual is fully informed of the information collection.
APP 6 – Use or disclosure of personal information
MelbourneEast Arts only uses or discloses personal information it holds about an individual for the particular primary purposes for which the information was collected, or secondary purposes in cases where:
- An individual consented to a secondary use or disclosure;
- An individual would reasonably expect the secondary use or disclosure, and it is directly related to the primary purpose of collection; or
- Using or disclosing the information is required or authorised by law.
Requirement to make a written note of use or disclosure for this secondary purpose
If MelbourneEast Arts uses or discloses personal information in accordance with an enforcement-related activity we will make a written note of the use or disclosure, including the following details:
- The date of the use or disclosure;
- Details of the personal information that was used or disclosed;
- The enforcement body conducting the enforcement related activity;
- If the organisation used the information, how the information was used by the organisation;
- The basis for our reasonable belief that we were required to disclose the information.
APP 7 – Direct marketing
MelbourneEast Arts will only use or disclose the personal information that it holds about an individual for the purpose of direct marketing if:
- The personal information has been collected directly from an individual, and the individual would reasonably expect their personal information to be used for the purpose of marketing MelbourneEast Arts events; or
- The personal information has been collected from a third party, but the individual would have a reasonable expectation that their personal information will be used for the purpose of marketing arts events; and
- We provide a simple method for the individual to request not to receive direct marketing communications (also known as ‘opting out’).
On each of our direct marketing communications, MelbourneEast Arts provides a prominent statement that the individual may request to opt out of future communications, and how to do so.
An individual may at any stage request MelbourneEast Arts not to use or disclose their personal information for the purpose of direct marketing, or to facilitate direct marketing by other organisations. We comply with any request by an individual promptly and undertake any required actions for free.
We also, on request, notify an individual of our source of their personal information used or disclosed for the purpose of direct marketing unless it is unreasonable or impracticable to do so.
APP 8 – Cross-border disclosure of personal information
MelbourneEast Arts does not disclose personal information to any overseas recipient. The only contact information provided to overseas service or product providers is organisational email addresses or telephone number.
APP 9 – Adoption, use or disclosure of government related identifiers
MelbourneEast Arts does not adopt, use or disclose a government-related identifier related to an individual except:
- In situations required by Australian law or other legal requirements;
- Where reasonably necessary to verify the identity of the individual;
- Where reasonably necessary to fulfil obligations to a State authority; or
- As prescribed by regulations.
APP 10 – Quality of personal information
MelbourneEast Arts takes reasonable steps to ensure that the personal information it collects is accurate, up-to-date and complete. We also take reasonable steps to ensure that the personal information we use or disclose is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.
Quality measures in place supporting these requirements include:
- Procedures to monitor, identify and correct poor quality personal information (including training staff and volunteers in these procedures);
- Protocols that ensure personal information is collected and recorded in a consistent format, from a primary information source when possible;
- Ensuring updated or new personal information is promptly added to relevant existing records;
- Providing individuals with a simple means to review and update their information;
- Contacting individuals to verify the quality of personal information where appropriate when it is about to used or disclosed, particularly if there has been a lengthy period since collection; and
- Checking that a third party, from whom personal information is collected, has implemented appropriate data quality practices, procedures and systems.
APP 11 – Security of personal information
MelbourneEast Arts takes active measures to consider whether we are able to retain personal information we hold, and also to ensure the security of personal information we hold. This includes reasonable steps to protect the information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
We destroy or de-identify personal information held once the information is no longer needed for any purpose.
Access to the MelbourneEast Arts office is limited to our personnel only – visitors to our premises must be authorised by relevant personnel and are accompanied at all times.
Regular information sessions are conducted with MelbourneEast Arts staff and volunteers. These include information on privacy issues, and how the APPs apply to our practices, procedures and systems.
APP 12 – Access to personal information
Where MelbourneEast Arts holds personal information about an individual, we provide that individual access to the information on their request.
APP 13 – Correction of personal information
MelbourneEast Arts takes reasonable steps to correct personal information we hold, to ensure it is accurate, up-to-date, complete, relevant and not misleading, having regard to the purpose for which it is held.
MelbourneEast Arts will take all reasonable steps to correct personal information in cases where we are satisfied that the personal information held is inaccurate, out-of-date, incomplete, irrelevant or misleading. This awareness may occur through collection of updated information, in notification from third parties or through other means.