1. General policy
Audio-Visual Copyright Society Limited trading as Screenrights of Level 1, 140 Myrtle Street, Chippendale, NSW 2008 (ABN 76 003 912 310) (Screenrights) understands the importance of privacy to the public, including its members, users of the Screenrights website at www.screenrights.org, the MyScreenrights Portal at https://my.screenrights.org and any other websites (each a Website, collectively the Websites), products and services that Screenrights operates (each a Service, collectively the Services).
2. Collection of your Personal Information
Screenrights collects Personal Information relating to rightsholders, licensees, media industry professionals and participants and Website and other Service users as part of the normal course of its business.
Generally, where possible, Screenrights will collect Personal Information directly from you or from persons you have authorised to provide information to us about you. Should you wish to remain completely anonymous, do not log into a Website as you will have identified yourself in doing so and do not provide us with any information that may identify you. Where possible, Screenrights will allow you to use a pseudonym when contributing to our Websites.
In general, the Personal Information that Screenrights collects includes (but is not limited to) names, contact details (including phone numbers and postal and email addresses), financial information (including bank account details for electronic funds transfer payments), lists of registered programs and related entitlement information, details of other relevant memberships or associations and details of relevant licence schemes. Such information may be collected in the process of membership and Service enquiries, membership and Service applications, Website user enquiries, Website user registrations, use of Websites, email correspondence, notes taken by Screenrights staff of telephone and face-to-face meetings and surveys undertaken by Screenrights or a third party on its behalf for the purposes of gathering user experience information in order to improve our Services and through your interactions with Screenrights which may include entering competitions and through social media.
Screenrights only collects Personal Information for purposes that are related to Screenrights’ business purposes and only when it is necessary for or directly related to such purposes, which include (without limitation):
- Providing and administering the Services;
- Collecting and distributing payments for use of copyright materials;
- Identifying and locating rightsholders;
- Confirming payment share entitlements;
- Assisting members to resolve disputes over entitlements to Screenrights’ royalties;
- Providing information on the use of copyright material to rightsholders and licensees; and
- Collecting and distributing funds as a disbursement administration service.
3. Information logged and cookies
Apart from any Personal Information that you provide to Screenrights, servers used in Screenrights’ operations may gather information provided by your browser when you visit the Websites. This may include:
- The date and time of your visit;
- The pages you access;
- The content, including videos and documents that you view or download;
- Browser type;
- Searches you perform on the Websites;
- Your server’s Internet Protocol (IP) address; and
- If you have been referred to the Websites from another website, the address of the referring website.
In relation to the information logged and cookies referred to above, Screenrights gathers such information to monitor usage of our Websites and to understand the Websites’ use and relevance. This enables us to improve and enhance the Websites, to make the Websites more user-friendly and to make the Websites more relevant to users.
From time to time, Screenrights engages independent contractors to perform analytics and related services and in such cases will make all reasonable efforts to ensure that contracts with such independent contractors include an obligation to comply with Australian privacy laws or apply privacy standards that meet or exceed requirements of Australian law.
Additionally, Screenrights may use also use suppliers who also set cookies on our Websites on our behalf in order to deliver the services that they are providing. For example, if Screenrights embeds photos and video content from third party content platforms on the Websites, those third parties may have set cookies relating to that content. If you then share that content, another third party cookie may be set by the service you have chosen to share content through. Screenrights does not control these cookies, and does not block cookies set by third parties in these ways.
4. Use and disclosure
Screenrights will only use Personal Information for the purposes for which it was given to us, or for purposes that are directly related to one of our functions or activities.
Screenrights may use and disclose your Personal Information in order to provide Services to you and to improve the Services that it offers generally and may use your Personal Information to contact you for these purposes, including to advise you of any issues relating to programs in which you have or may have a copyright or payment interest and to inform you of upcoming events and other sites or publications which we reasonably believe may be of interest to you.
Screenrights may also use and disclose your Personal Information to help it assess and survey the ways in which users use the Services. To the extent that it is reasonably practicable, this information will be de-identified so that you are not personally identifiable in the results of any such assessment or survey.
Any financial information such as bank account details that you provide will be used solely for the purpose for which they are provided, for example making royalty or disbursement payments to you. Screenrights will not sell, share, rent or receive payment for licensing or disclosing your Personal Information.
Screenrights may, from time to time, send marketing material to you that it considers useful including newsletters. Screenrights may also send you material about its activities. If you do not wish to receive this information, you can let Screenrights know by unsubscribing as described below. This does not apply to information that Screenrights is legally required to send or information regarding the rights or obligations of its members.
Generally, Screenrights must get your consent before it discloses any of your Personal Information. You may give your consent expressly or it may be implied by your conduct.
Depending on the Service that you have requested or otherwise engaged with, your Personal Information may be disclosed to:
- External service providers who assist us in providing and administering the Services, competitions, events and promotions, including third party suppliers, contractors and data storage providers;
- Overseas and local collecting societies that collect and distribute royalties for film and related rights and with which Screenrights has reciprocal arrangements;
- Specialist advisers who have been engaged to provide Screenrights with legal, administrative, financial, insurance, research, marketing or other services;
- Other rightsholders, their agents, external mediators or experts for the purpose of resolving or assisting in the resolution of disputes between members in accordance with the Screenrights membership agreement;
- Third party research companies to conduct surveys about Screenrights’ Services to you. Participation in such surveys is optional;
- Independent auditors engaged to audit Screenrights’ operational practices; and
- Any other person authorised by you or specified by you, such as your agent or manager.
There will, of course, be times when it will be necessary for Screenrights to disclose your Personal Information to third parties without your consent. For instance, where it is required or authorised to do so by law, law enforcement bodies or otherwise permitted by law under APP 6.
5. International transfers
6. Storage and Security of your Personal Information
Screenrights takes all reasonable steps to protect your Personal Information from loss, unauthorised access, modification, disclosure or other misuse. This includes: using electronic access restrictions for electronic files that contain Personal Information, securing paper files containing Personal Information and physical access restrictions to files containing Personal Information. Where Screenrights stores your Personal Information with a third party data storage provider, we require them to keep it secure and only use or disclose it for the purpose for which it was provided.
7. Accessing and Updating your Personal Information
Whenever it is possible, Screenrights will provide you with access to the Personal Information that Screenrights holds about you to ensure that is accurate, complete and up to date. If your Personal Information is not accurate, complete or up to date and you cannot access or update your Personal Information, please inform the Screenrights Privacy Officer using the Contact details set out below and Screenrights will take all reasonable steps to correct the information.
8. Direct Marketing Communications and Opting Out
Screenrights may, from time to time, send direct marketing communications to you about its activities and other material that it considers you would find useful. If you do not wish to receive such direct marketing communications, you can contact Screenrights and Screenrights will endeavour to meet your request in a timely manner.
Screenrights Services and communications with you may also contain specific methods to opt out of direct marketing material sent via the particular Service or communication.
If you choose opt out of all direct marketing communications, please note that Screenrights may still contact you for other reasonable purposes, including information that Screenrights is legally required to send and information regarding the rights, benefits or obligations of users of Services.
9. Contact details
Telephone: +61 2 9904 0133
Facsimile: +61 2 9904 0498
Postal Address: The Privacy Officer, Screenrights, PO Box 853, Broadway NSW 2007 Australia
10. Complaints Handling Procedure
Any complaint about handling of Personal Information will be dealt with in accordance with the following Screenrights Privacy Complaints Handling Procedure:
- If you think that an act or practice of Screenrights has interfered with your privacy in relation to Personal Information you may make a complaint to Screenrights.
- The complaint must identify you and be in written form and addressed to the Screenrights Privacy Officer.
- The Screenrights Privacy Officer will investigate your complaint and will endeavour to provide a response setting out Screenrights’ decision in writing within 30 days of receipt of your complaint.
- If Screenrights is unable to satisfactorily resolve your concerns you can contact the Office of the Australian Information Commissioner.
~ March 2014