Introduction and application
The Local Independent News Association Ltd. (LINA), ACN 654 806 032, is the peak body for independent and local digital publishers. References to “the LINA”, “we”, “us” and “our” in this Privacy Policy are references to LINA, and our associated entities, agents, staff, subcontractors, or third-party service providers we engage from time to time in the provision of our business and services.
This Privacy Policy discloses our privacy practices and it applies to personal information collected and held by LINA.
In our collection, storage, use and dissemination of personal information, we are bound by the Privacy Act 1988 (Cth) (the Privacy Act), including the Australian Privacy Principles (APPs) and any relevant APP codes registered under the Privacy Act.
“Personal information” includes information or an opinion relating to an identified, or reasonably identifiable, individual. Information or an opinion may be personal information regardless of whether or not it is true.
We may modify this Privacy Policy at any time at our discretion. You can always locate the current version via our website or by contacting us.
Reasons we collect and use personal information
We collect and use your personal information for the purposes of providing our services to you and our broader sector, to meet our legal obligations, for human resources purposes, and for the purpose of marketing our services to you. We may also use your personal information for purposes closely related to our primary purposes, in circumstances where you would reasonably expect such use or disclosure.
The kind of personal information we may gather and hold, depends on the nature of the interaction or activity taking place, including via:
- the course of membership with us, or enquiries or application for membership;
- engagement with us as we keep abreast of our member’s and sector’s needs, and provide our services to our members and sector;
- participation in any kind of electronic or face-to-face meeting or event with us;
- employment with us, or application for employment with us;
- contracting with us in exchange for services with us, or offering to do so;
- our working relationship with the Government agency responsible for regulating the community broadcasting sector, the Australian Communications Media Authority, in this co-regulatory scheme; and
- other related activities.
This means we may collect personal information you provide to us via conversations that take place in person, over the telephone, or in writing, and via all electronic and digital means, including our website/s, cookies, online surveys and forms, webinars, streamed events, social media accounts, and those of our partners and agents.
Information we collect
The information we may collect about you may include:
- your name;
- login details;
- contact details;
- demographic information;
- preferences and interests;
- user generated content;
- IP addresses;
- cookies data;
- research or survey responses, including information about your news organisation; and/or
- payment details.
Personal information that is also sensitive
We will not ask for personal information revealing your racial or ethnic origin, political opinions or membership of a political association, religious or philosophical beliefs, trade union membership, sexual orientation or practices, health information, or disability, unless:
- you consent to providing that information to us; and the information is reasonably necessary for one or more of our functions or activities; or
- as otherwise authorised under law.
What happens if you do not wish to provide your personal information?
You may engage with us without identifying yourself or by using a pseudonym, and we will do our best to accommodate such requests unless it is impractical. However, if you do not provide us with accurate or complete information when we request it, we may not be able to provide you with a proper level of service.
There will also be times when it will be necessary for us to collect certain personal information from you, especially where required by law. We will inform you if such circumstances apply.
We can provide you with information about our legal requirements if you ask us to, or you can refer to the Office of the Information Commissioner (see their contact details below).
Accuracy of information
We are committed to taking reasonable steps to ensure your personal information we hold is accurate. If you believe it is not accurate, please contact us to correct that information (our contact details appear below).
Storage and security of your information
We generally store your personal information via digital/electronic means (including hard drives, servers and cloud storage). Our computer and storage systems are generally password protected, and permission to access your personal information in our systems is limited to our employees and those of our agents and third parties (see “us” in the Introduction above). Where any information is kept in hard copy, it is stored under lock and key. We are committed to taking steps that are reasonable in the circumstances, to protect your information from loss or unauthorised access, interference, modification, disclosure, or misuse.
Disclosure of your information
We will generally only grant permission for others to access your personal information where we believe to do so is necessary to carry on our business and fulfil our responsibilities, or when otherwise required to do so by law (including to the Government), or a court/tribunal order.
Otherwise, we will only disclose your personal information to others if:
- that disclosure is required to give effect to the purposes for which we collected the information, or
- we have your consent to that disclosure; or
- we believe that the disclosure may lessen a risk of harm to your health or safety, or to the health or safety of another person; or
- the disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue; or
- we are sharing data in an anonymous or aggregated form, such as the results of our annual member survey.
International transfers
We may disclose your personal information to third parties, including recipients that are located outside Australia. This may include third-party service providers for data storage or processing, such as cloud-based platforms. Those recipients are likely to be located in the United States.
How you may access your personal information
You may access a copy of the personal information we hold about you, by contacting us. We will use our best efforts to take less than 30 days to respond to your request. We may charge you a reasonable fee for providing access to your personal information.
Contact us – queries and complaints
If you have any queries, comments or complaints with respect to our Privacy Policy, a breach of the Australian Privacy Principles, or registered APP code please contact the LINA as follows:
| Enquiries – May be made by phone (or in writing) | 02 9310 2999 For hearing or speech assistance, contact us through the National Relay Service then ask for 02 9310 2999. For languages other than English, call the Translating and Interpreting Service on 131 450 then ask for 02 9310 2999) |
| Complaints – Please submit in writing if you can, by: | Completing this online enquiry form, or |
| Post, via: CEO LINA PO BOX 564 Alexandria NSW 1435 |
If we take more than 30 days to respond to your privacy complaint, or you are not satisfied with the outcome, you can make a complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner.
Complaints
You may also contact or make a complaint about privacy to the Office of the Australian Information Commissioner (OAIC) as follows:
| Enquiries – May be made by phone 1300 363 992 | For hearing or speech assistance, contact them through the National Relay Service then ask for 1300 363 992. For languages other than English, call the Translating and Interpreting Service on 131 450 then ask for 1300 363 992). |
| Complaints – Must be made in writing, and addressed to: | The Director of Compliance, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001 |
| or complete a complaint form via their website. |