Privacy policy

The Conversation Media Group Ltd ACN 142 923 653 (we, our) is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988(Cth) (Privacy Act).

This policy sets out how we handle Personal Information, including the Personal Information of our authors, commenters and readers (users), in accordance with the Privacy Act, and how you can exercise your rights under the Privacy Act.

We may amend this policy from time to time. At any time, the latest version of our Privacy Policy is available from our website at global/privacy-policy.

We are a media organisation within the definition used in the Privacy Act. As such, for all our dealings with Personal Information in the course of journalism we may rely on the exemption contained in section 7B (4) of the Privacy Act. We are committed to observing the Australian Press Council Privacy Principles.

'Personal Information' has the meaning set out in the Privacy Act. Essentially, Personal Information is information or an opinion about an individual who is reasonably identifiable (including names, addresses, birth dates, or email addresses).

'Related Body Corporate' has the same meaning as 'Related Body Corporate' under section 50 of the Corporations Act 2001 (Cth).

We collect your Personal Information directly from you and from third parties. The types of Personal Information we collect depends on the circumstances in which the information is collected. For example, we may collect Personal Information when you create an account for, or publish an article or comment on The Conversation, which may include:

• information required to create an account: user name; and login details including email address or, if you login using an existing social media account (such as Facebook, Twitter, Google+, or LinkedIn), limited information about that account
• optional information: job title; for contributors, other contact details including phone number; information that you may include in your account profile, for example, profile pictures, contact details, professional history, expertise or interests; and comments that you may make on articles published by The Conversation.

We collect Personal Information when you donate to us online or over the phone. The types of Personal Information we collect from donors includes contact information and bank or credit card details. We do not store bank details or credit card information.

We also collect your Personal Information from third parties. For example, if you create an account for The Conversation using a social media account, we may collect Personal Information, including your name and email address, from your social media account.

We also collect website analytics - anonymised statistics about how people use The Conversation. These statistics help us understand how our users, as a group, use The Conversation, and aren't linked to specific individuals.

We use cookies to enable some functions on The Conversation, including login functions, and for website analytics.

The purposes for which we use, collect and disclose your Personal Information will depend on the circumstances in which we collect it. Whenever practicable we endeavour to inform you why we are collecting your Personal Information, how we intend to use that information and to whom we intend to disclose it at the time we collect your Personal Information.

We may use or disclose your Personal Information:

• for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
• for other purposes to which you have consented; and
• as otherwise permitted or required by law.

Some of the specific purposes for which we commonly collect, use and disclose your Personal Information include:

• to sign you up as a contributor or create your profile on The Conversation;
• to allow you to comment on articles published by The Conversation;
• to allow other media outlets to republish and attribute articles you have written;
• if you have requested notifications, to deliver email notifications to you;
• if you are a donor, to contact you regarding your donation or to deliver direct marketing to you (where you have consented to us doing so, or it is otherwise permitted by law);
• to allow you to participate in surveys or provide feedback to The Conversation; or
• if you have subscribed to one or more of our newsletters, to deliver email newsletters to you.

If you sign up to The Conversation, we will publish your author/user profile on The Conversation. Your profile will contain your name and you may choose to include additional information. Author profiles generally contain information about professional experience and expertise.

If you comment on an article published by The Conversation, we will publish your comment together with your name, which is linked to your profile.

Beyond those circumstances, we generally don't publically disclose user Personal Information. We don't sell our users' Personal Information.

We may be required to disclose your Personal Information; for example, where required by law or a court order or to third parties which assist the operation of The Conversation. This may include disclosing your Personal Information to the following types of third parties (depending on the purposes for which we have collected your Personal Information):

• our Related Bodies Corporate;
• our licensees who operate overseas editions of The Conversation;
• our contractors and other third parties that provide goods and services to us including: website and data hosting providers; analytics, marketing and profiling service providers; and our accountants, insurers, lawyers, auditors and other professional advisors and agents;
• if you are an individual contractor to us or a prospective employee, to HR related service providers (e.g. for outsourced payroll processing, background checks);
• any third parties to whom you have directed or permitted us to disclose your Personal Information (e.g. referees); and
• otherwise as permitted or required by law.

Where we disclose your Personal Information to third parties we will use reasonable efforts to ensure that such third parties which assist with the operation of The Conversation only use your Personal Information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the APPs.

If you post information to public parts of our websites or to our social media pages, you acknowledge that such information (including your Personal Information) may be available to be viewed by the public. You should use discretion in deciding what information you post.

Our head office is located in Australia, but we also have offices operated by licensees in the UK, the USA, France, Canada, South Africa, Spain, Brazil and Indonesia. Staff in those countries have access to user Personal Information.

The systems we use to provide The Conversation are located in Australia, the United States and the UK.

Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the APPs.

We store Personal Information on computer databases and/or in hard copy and will take reasonable physical and electronic security measures to protect any records that we hold which contains Personal Information. We destroy or permanently de-identify Personal Information in a secure manner when we no longer need it. We do not store bank details or credit card information.

We are committed to keeping your Personal Information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your Personal Information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

Under the Privacy Act, you have the right to access the Personal Information that we hold about you.

We handle any access request in accordance with the Privacy Act. The Privacy Act provides some exemptions to access requests. We may require that you provide proof of your identity in order to grant your access request.

It is free to make an access request. However, depending on the scope of your request, we may charge an administration fee for the time we spend locating, compiling and explaining the information you ask for. If we need to charge a fee, we will let you know up front and confirm that you would like us to proceed.

If you would like to request access to your Personal Information, please contact us at [email protected].

We take reasonable steps to maintain the accuracy of your Personal Information.

Under the Privacy Act, you also have the right to ask us to correct any Personal Information we hold about you. We encourage you to contact us if you become aware that the Personal Information we hold about you is incorrect or to notify us of a change in your Personal Information.

We handle any correction request in accordance with the Privacy Act. The Privacy Act provides some exemptions to correction requests.

If you would like to request a correction to the information that we hold about you, please contact us at [email protected].

See also: our policy about when we'll remove content

If you have any complaints concerning our privacy policy or the way in which we have dealt with your Personal Information, please email us at [email protected].

If you make a complaint, we will assess your complaint and respond within 30 days.

If you aren't satisfied with the way in which we handle your complaint, you can complain to the Australian privacy regulator, the Office of the Australian Information Commissioner.

If you have any other questions or concerns, please email us at [email protected].

If you would like to delete your user profile please email us at [email protected].

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights set out below, please contact [email protected]. No fee is usually required, but we may charge a reasonable fee for your request, or refuse to comply, if it is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific reasons, of which you will be notified if applicable at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.