This policy applies to MMP Star Pty Ltd and Network Classifieds Pty Ltd, and shall hereinafter for the purpose of this policy be collectively referred to as (“the Company”).
This policy outlines how the Company uses and manages personal information provided to or collected by it with respect to readers, customers, advertisers and other individuals with whom the Company has contact.
This policy has been reviewed and modified to meet the Company’s obligations under amendments to the Privacy Act 1988 that came into effect on 12 March 2014.
Individual privacy is important to the Company and we aim at all times to handle information responsibly. As a media organisation, we handle a very large quantity of personal information and it is critical to the quality of our operation and our position in the community that this information is handled appropriately.
Australian Privacy Principles
The Privacy Amendment (Enhancing Privacy Protection) Act 2012 includes a set of new, harmonised, privacy principles that regulate the handling of personal information by both Australian government agencies and businesses.
These new principles are called the Australian Privacy Principles (APPs) which have replaced the Information Privacy Principles (IPPs) that applied to Australian Government agencies and the National Privacy Principles (NPPs) that applied to businesses. Under the changes, there are now thirteen new APPs.
The information in this policy sets out in general terms how we comply with the requirements of the Privacy Act 1988 and how information should be handled by the Company and refers to some specific situations. Where a particular situation is not covered by this policy, please refer to the Australian Privacy Principles Fact Sheet issued by the Office of the Australian Information Commissioner.
Open and Transparent Management of Personal Information
The Company will ensure we manage your personal information in an open and transparent way at all times. We do collect personal information, for example your name, contact number and email address.
We collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us.
Personal information may be used and disclosed to external organisations that may include international organisations that help us provide our specialised products and services. These organisations are bound by strict confidentiality arrangements.
You may seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please advise us so that we can correct it. The Company, upon your request, and subject to applicable privacy laws, may provide you with access to your personal information that is held by us.
We may collect non-personal information about how people use our website. This information will include website activity (such as the number of users who visit our website, the number of pages viewed, how users have accessed our sites (ie. from a search engine or a link). This information provides us with statistics that can be used to analyse and improve our websites.
The Company is committed to working with its customers and readers. If you have any concerns about privacy please advise us so that we are given the opportunity to improve our processes. You can write to us outlining your concerns addressed to the:
The Privacy Officer
MMP Star Pty Ltd
Unit 6/1-9 Thomsons Road
KEILOR PARK VIC 3042
Anonymity and Pseudonymity
The Company will provide individuals with the option of not identifying themselves or using a pseudonym when dealing with us, such as in contact from readers, unless it is unlawful or impractical to do so.
If you choose to transact with the Company anonymously, you will be advised of the significance of doing so; for example any complaints or concerns may not be able to be actioned.
Information We Collect
The Company will only collect personal information which is reasonably necessary for our business functions and activities. Information will be collected in a way which is lawful, fair and not unreasonably intrusive. The Company will disclose certain information at the time of or before collecting personal information.
The types of personal information that we may collect about you will depend on our relationship with you.
Personal information collected may include:
- Your name, address, gender, date of birth, phone contact numbers and email address;
- Payment details (such as bank account, credit card or PayPal details), to create an account, become a subscriber or an advertiser in connection with the purchase of our products and services.
Use, Collection and Disclosure of Personal Information
The Company may use personal information provided by you to ensure that it continues to provide customers, advertisers and readers with the best possible products and services and to address any questions you may have about our products and services.
We may collect information about you when you:
- use our services or purchase our products;
- fill in a new customer account form;
- enter into an advertising contract;
- deal with us over the telephone;
- email us;
- have contact with us in person;
- register or subscribe to be part of any of our digital products
- engage in social media through any of our platforms ie. Facebook, Twitter or Apps;
- enter into one of our competitions;
- visit our websites;
- provide us with feedback or complete one of our surveys; or
- otherwise interact with us.
As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. These third parties may include:
- third parties that run competitions and other promotions for us or for which we are the sponsor;
- access or log-in to a third party social media service to post comments (information collected may include your user name, comments, likes, tweets, status, profile information and picture(s). Public information, posts and comments are always public and are available to everyone and may be displayed in search results on search engines.
The Company may use your personal information for the following purposes:
- to provide you with our products and services;
- measure and improve our products and services
- to organise marketing or promotional activities for both our print and online digital products and services;
- to deliver our newsletters and any other campaigns, promotions and events;
- to allow service and content providers, including website hosting service providers, data cloud services and debt collection services who support us in delivering and managing our services;
- to publish a letter to the editor, a social media post or a comment, we may publish your name and suburb to identify you as the author of the letter, the post or the comment;
- to allow social sharing; if you log in with or connect a social media service account with the Company, we may share your user name, picture, tweets, likes or comments with other the Company users and with your friends associated with your social media service.
The Company may not use or disclose your personal information for a purpose other than the primary purpose for which it was collected, except only:
- where you have consented to the use and disclosure of the information; or
- where the purpose is related to the primary purpose for which the information was collected, and it would have been reasonable to expect to use or disclose that the information for the secondary purpose would be used in that way; or
- where it is required or authorised by or under an Australian law or a court/tribunal order;
- where it will prevent or lessen a serious and imminent threat to somebody’s health; or
- where the information is used for direct marketing purposes; (subject to certain conditions).
From time to time we may use the personal information we collect from you to identify particular the Company products and services which we believe may be of interest to you. We may then contact you to let you know about these products and services and how they may benefit you. We will only do this with your consent and we will always give you a choice to opt out of receiving such information in the future.
Where we use your personal information to send you marketing information by email (or other electronic means) or by post, we may do so with your implied consent or if this is impracticable, we will ensure that you are provided with an opportunity to “unsubscribe” or “opt out” from receiving future communications. By not choosing a clearly displayed option to “opt out”, we will assume we have your implied consent to receive similar marketing communications in the future.
Where direct marketing takes place by telephone, a member of our call centre team will enquire whether you wish to opt out of receiving any further contact from us.
Personal information (other than sensitive information) that the Company collects about you will not be shared for direct marketing purposes to potential advertisers and any other individuals to whom the Company may provide a service to unless:
- we have collected information from you; and you would reasonably expect the Company to use or disclose information for that purpose; and
- we have provided a simple means by which you may easily choose to ‘opt out’ and not receive direct marketing communications from us; and
- you have not made such a request to the Company.
The Company maintains a register of individuals or businesses who have elected to not receive further direct marketing contact. This register will be referred to upon you contacting us to ensure individuals or businesses are not contacted.
Cross-Border Disclosure of Personal Information
Personal information may be used and disclosed to external organisations, that may include international organisations, that help us provide and manage our specialised products and services.
These trusted organisations must handle any information confidentially and are bound contractually to not disclose any information. The Company takes steps to ensure that all our service providers protect the privacy and security of any personal information transferred outside of Australia at all times.
Adoption, Use or Disclosure with Government Agencies
The Company will not share personal information about you with other government agencies without your permission except in the following situations:
- where it is necessary to provide you with a service that you have requested;
- where you have specifically authorised in writing that the information may be provided to the third party. Where this disclosure has been authorised, the Company will keep a copy of the authorisation.
- where it is required or authorised by or under an Australian law or a court/tribunal order;
- where it will prevent or lessen a serious and imminent threat to somebody’s health;
- where it is reasonably necessary for the Company to verify your identity for the purposes of the Company’s activities or functions; or
- where it is reasonably necessary for the Company to fulfil its obligations to an agency or a State or Territory authority; or
- where the information is provided to a third party for a purpose connected to the primary purpose for which the information was collected, including:
- to recovery agents for the purposes of enforcing unpaid accounts;
- to a distribution agent for the purposes of responding to a reader complaint.
- where the information is required to be provided for other purposes including the following:
- to a legal practitioner for the purposes of conducting legal proceedings;
- where the information is required by a court order to be disclosed;
- where the information is required by the police or other agency for the purposes of investigating a crime.
Security of Personal Information
The Company will take all reasonable steps to prevent information from being misused, lost and from unauthorised access, modification or disclosure. Information which is no longer needed will be destroyed or de-identified.
Security of On-Line Information
The Company takes the security of any information held on-line seriously. We have systems in place to ensure our on-line products and services are as secure as your dealings with us in person, or on the telephone.
When purchasing our products ie. photos, we use the standard encryption, Secured Socket Layer (SSL). The URL in your browser will change to ‘HTTPS’ instead of “HTTP’ when this security feature is enabled and your browser may also display a lock symbol on its bottom taskbar to indicate this security feature is activated.
Except for authorised law enforcement entities, no other attempts are made to identify individual users or their usage habits. Unauthorised misuse of information stored in our systems will be investigated and may result in criminal prosecution.
We may collect non-personal information about how people use our websites. This information will include website activity (such as the number of users who visit our websites, the number of pages viewed, how users have access our sites (ie. from a search engine or a link). This information provides us with statistics that can be used to analyse and improve our web sites.
A ‘cookie’ is a packet of information that allows a server (the computer that houses the website) to identify and interact more effectively with your computer.
When you use one of our websites we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use one of our websites. Cookies do not identify individual users, although they do identify a user’s browser type and your Internet service provider (ISP).
Most browsers automatically accept cookies, however, you can configure your Internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Refer to your browser instructions or help screen to learn more about these functions.
Search terms that you enter when using our search engine are collected, but are not associated with any other information that we collect. We use these search terms for the purpose of aggregated statistical analysis so we can ascertain what our customers and readers are looking for on our websites and to improve the services that we provide.
Access to Personal Information
You may request access to personal information about you that we hold. Where the information requested is routine (for example about contact details), then both the request and the provision of information may occur verbally or in whatever form is most convenient to expedite the provision of information.
Where the information requested is lengthy, complex or time-consuming for the Company to provide, a request must be made in writing. The Company will deal with your request to provide access to your personal information in a reasonable time; usually within 30 days of receipt of your request. The written request must specify the particular information sought with sufficient details to enable the information to be located.
Whilst we will not charge you for lodging such a request, we may recover from you our reasonable costs incurred in supplying you with access to this information. We will inform you at the time of the request of an estimate of the administrative charge and may require that you provide a deposit not exceeding the estimated administrative charge prior to providing the information.
Your right to access your personal information is not absolute. In certain circumstances, the law permits us to refuse your request to provide you with access to your personal information, such as circumstances where:
- access would provide a serious threat to the life or health of any individual;
- access would have an unreasonable impact on the privacy of other individuals;
- the request is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings and would not be required to be disclosed in the course of those proceedings
- the information relates to ongoing negotiations between Independent and the individual or business and would prejudice those negotiations;
- access would be unlawful;
- denying access is required or authorised by law;
- the information is relevant to an investigation of a criminal offence;
- the information relates to a commercially sensitive decision-making process.
Where a request for access to information may fall into one of these categories, the Company will require that the request be made in writing with appropriate details to enable the Company to identify the requested information.
Where we deny access to provide the information after a request, we will inform you of our decision within a reasonable period of time and will outline the reasons for denying access to the information.
Quality and Correction of Personal Information
It is inevitable that some personal information which we hold will become out of date. The Company and its representatives will take all reasonable steps to ensure that processes for the correction of personal information held by the Company is accurate, up to date, complete and relevant upon your request to correct the information.
Maintaining of Personal Information
The Company is required to keep a record of personal information only as long as is necessary or required by law. Where an individual or business has on-going contact with the Company, relevant information and records will be maintained. Where any individual or business has ceased to transact with the Company, information will be retained for a reasonable period as required by law.
Information held by the Company will be subject to regular review and assessment as to whether it is necessary that the Company maintain a record of the information.
Call Centre Monitoring
The Company may monitor and record inbound calls to our Classifieds Call Centre for training purposes. If you do not wish your call to be recorded for training purposes, please let one of our team members know at the time of connecting with us.
Sensitive information will only be collected where you have consented to the collection of personal information or that the collection of personal information is required for legal, safety or public policy reasons.
Where information is provided in an unsolicited form, the Company will treat such information with the utmost sensitivity and confidentiality. We know that when you give us your personal information, it imposes a serious responsibility upon us. We are committed to protecting your personal information and maintaining your trust.
If it is not necessary for the Company to retain the information, it will be destroyed. If it is necessary for the Company to keep a record of the information, it will only be accessible by those who require access to the information.
Information Collected in the Course of Journalism
Information collected in the course of journalism is handled differently from the information that the Company collects for other purposes.
The Company is committed to the highest standards of information management and has pledged to handle information of this type according to the standards of the Australian Press Council’s Statements of Principles and Charter for Free Press.
As soon as practicable at or before the time of collecting personal information, the Company will make available and/or refer you to our Privacy Statement.
If you have a concern about your privacy or you have any query on how your personal information is collected or used please contact us using the details below. We will respond to your query or complaint within a reasonable time.
If you are not satisfied with our response, you may also contact the Office of the Australian Information Commissioner.
Contact Us about Privacy and Information Handling Practices
Where any aspect of this policy is unclear or where a situation arises which is not addressed by this policy, the matter will be referred to the General Manager for further consideration or determination.
The Company is committed to working with its customers and readers. If you have any concerns about your privacy please advise us so that we are given the opportunity to improve our processes.
Phone: 03 8318 5777
Write: The Privacy Officer
MMP Star Pty Ltd
Unit 6/1-9 Thomsons Road
KEILOR PARK VIC 3042
You can also obtain further general information about your privacy rights and privacy law from the Office of the Australian Information Commissioner.
Phone: 1300 363 992
Write: GPO Box 5218
SYDNEY NSW 2001