This is the privacy policy of Broughton Publishing Pty Ltd as trustee for the Broughton Publishing Trust (ABN 65 964 133 851) referred to as ‘we’, ‘us’ or ‘our’. The purpose of this privacy policy is to provide information about how we deal with and manage personal information. We take the protection of personal information seriously, and comply with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles, and the General Data Protection Regulation (GDRP) to the extent it applies.
Personal information
Personal information is defined in the Privacy Act as:
information or an opinion about an identified individual, or an individual who is reasonably identifiable;
whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this privacy policy, and any other arrangements that apply between us. We may change our privacy policy from time to time by publishing changes on our website. We encourage you to check our privacy policy periodically to ensure that you are aware of our current privacy policy.
Why do we collect personal information?
We collect personal information where it is reasonably necessary for our functions or activities. In addition to our core business activity of publishing books and other material, including but not limited to The Anglican Church of Australia Directory (Directory) and epray, our functions and activities include:
- marketing and selling the Directory and our other publications and our business generally;
- undertaking research to improve the Directory and our other publications and our business;
- obtaining or providing goods and services (e.g., printing services, design services, database management, etc.) from or to other businesses;
- engaging with enquiries received;
- employing staff; and
- complying with legal and regulatory obligations.
Some common examples of personal information that we may collect include an individual’s name, contact details, and details of products and services that they obtain from us. We may also collect personal information through our website located at https://www.broughtonpublishing.com.au (Website).
The kind of personal information we collect will depend on who you are (e.g., an individual, employee or third party service provider) and the nature of your interaction with us.
The Privacy Act recognises certain types of personal information as sensitive information. Examples of sensitive information about an individual include information about the individual’s:
- health;
- racial or ethnic origin;
- political opinions;
- membership of a political association, professional or trade association or trade union;
- religious beliefs or affiliations;
- philosophical beliefs;
- sexual orientation or practices; and
- criminal record.
Any sensitive information which we collect will either be collected with the individual’s consent or as permitted by law.
How do we collect and keep personal information?
We receive personal information in different ways and through a number of different media including:
- via online sources (including email);
- by telephone;
- through face to face communications; and
- by hard copy correspondence and documentation.
We keep different types of records that include personal information. These include records stored electronically on databases and also hard copy files.
When do we use or disclose personal information?
To fulfil the purposes for which we collect personal information, we may disclose, or otherwise provide access to, the personal information to the other businesses referred to above, and, in relation to the personal information collected for inclusion in the Directory, to Anglican Diocesan offices across Australia, the General Synod Office of the Anglican Church of Australia, technology service providers, our distributors, our mailing house and our subcontractors. We agree to only use data processors who provide sufficient guarantees that they will implement appropriate technical and organisational measures that ensure compliance with the GDPR and protect the rights of the data subject, and only to third parties who agree to comply with this privacy policy.
By giving us your personal information you are consenting to our using your personal information for the purpose of writing to you to inform you about ourselves, and about our products and services (including by electronic mail), and where required, to enforce our agreement with you. You can tell us at any time that you do not wish to receive any further materials of this nature. If you do, we will stop sending you those materials.
If you are a third-party service provider, we will use your Personal Information to email you to accept your offer to provide Services, correspond with you in relation to the provision of Services and to pay your invoices.
If we collect personal information for a particular purpose, we may use or disclose that personal information for that purpose. For example, if a customer obtains a product or service from us, we may use and/or disclose their personal information for the purpose of providing the product or service to them.
We may also use or disclose personal information for other secondary purposes including the following:
- where you have consented to the use or disclosure for the secondary purpose;
- the secondary purpose is related to (or in the case of sensitive information directly related to) the purpose for which the personal information was collected and you would reasonably expect us to use or disclose the information – for example providing marketing information to existing customers (unless the customer has requested not to receive marketing information from us);
- the use or disclosure is required or authorised under an Australian law or a court or tribunal order;
- a permitted general or health situation exists as defined in the Privacy Act; or
- we reasonably believe that the use or disclosure of the personal information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
Any personal information we disclose in the Directory may be accessed by individuals located outside of Australia who subscribe to the Directory.
Cookies
We may use ‘cookies’; technology to store data on your computer using the functionality of your browser. Many Websites do this because cookies allow the Website publisher to do useful things like find out whether the computer visited a Website before.
You can modify your browser to prevent cookie use – but if you do this our service (and our Website) may not work properly. The information stored in the cookie is used to identify you. This enables us to operate an efficient service and to track the patterns of behaviour of visitors to our Website.
In the course of serving advertisements to our Website (if any), third-party advertisers or ad servers may place or recognise a unique cookie on your browser. The use of cookies by such third-party advertisers or ad servers is not subject to this Privacy Policy, but is subject to their own respective privacy policies.
Google Analytics
Our website uses Google Analytics, a service which transmits website traffic data to Google Servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
How can you access your personal information that we hold?
You may request access to your personal information held by us by emailing us at Broughton Publishing accounts, accounts@broughtonpublishing.com.au. We will provide access where we are required to do so under law. In other cases, we reserve our right not to provide access. We also reserve the right to recover our reasonable costs of providing you with access to your personal information held by us.
The right to erasure (which encompasses the ‘right to be forgotten’) gives you a right to require us to delete your Personal Information in certain circumstances, and/or to return it to you including, but not limited to where your information is no longer necessary for the purpose for which it was collected, or where you withdraw your consent and there is no other legal ground for processing your data. If you wish to have your information erased and/or returned to you please notify us by emailing accounts@broughtonpublishing.com.au.
What should you do if you believe we hold personal information about you that is wrong or you wish to complain about how we have handled your personal information?
If you believe that we hold personal information about you that is wrong (which includes inaccurate, out of date, incomplete, irrelevant or misleading), or you wish to complain about how we have handled your personal information, you should contact us at Broughton Publishing accounts, accounts@broughtonpublishing.com.au.
If you have complained to us about how we have handled your personal information, and you believe that we have not satisfactorily resolved your complaint, you may wish to contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au/
For further information on your privacy rights go to http://www.privacy.gov.au
For further information on the GDPR go to https://ec.europa.eu/info/law/law-topic/data-protection_en