De Bono Global (“DBG”) is committed to protecting and respecting your privacy, and takes its obligations under the Privacy Act 1988 (Cth) very seriously.
As a result, DBG has implemented practices, procedures and systems to:
- maintain the confidentiality and security of personal information it collects and holds; and
- manage its systems, practices and procedures in an open and transparent way.
By “personal information”, we mean information or an opinion about an identified individual, or about an individual who is reasonably identifiable from the information.
This Policy sets out how we handle personal information we collect and hold, including in relation to its activities as a media organisation for the purposes of the Privacy Act 1988 (Cth).
For the purposes of this policy, “DBG”, “we”, “our” and “us” refer to De Bono Global Pty Ltd (ABN 47 141 458 808) of Unit 2, 28 Kings Lane Darlinghurst, New South Wales, Australia 2010.
1. What personal information does DBG collect and hold?
The kinds of personal information we may collect and hold are:
- contact details (including email addresses);
- dates of birth;
- answers to log-in questions that may consist of personal information (such as the name of your first pet); and
- details of your visits to our site (including traffic and location information, which pages you visit, weblogs and other
Also, when you visit our site, we may collect information about your computer, including your IP address, operating system and browser type.
We do not keep files containing all of the above information on all people who contact us, or with whom we deal. In many cases, we may have only one or two pieces of data relating to any particular person.
2. Why does DBG collect and hold personal information?
We collect and hold personal information for a variety of purposes – and different kinds of personal information are used for different purposes.
In each case, however, the personal information we collect and hold is reasonably necessary for our functions and activities, including in order to provide you with services you would expect from us or that you have subscribed to. These purposes are:
- to provide you with news and information, products or services that you request from us or which we believe may interest you;
- for purposes necessary or incidental to providing you with goods and services (including subscriptions) that you have ordered or requested from us or from our associates and licensees;
- to personalise and customise your experience when using our site (including so that our site is presented in the most effective manner for you and for your computer);
- to communicate with you (including by email, mail or telephone, and including in relation to changes to our products and services);
- to manage and enhance our products and services;
- for system administration (including the provision of support services);
- for network analysis and security;
- to allow you to participate in interactive features of our site that may be available;
- to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are, have been or may be engaged in any unlawful activity; and
- as required or permitted by any law (including privacy legislation).
As part of our commitment to protecting your privacy, however, you will also be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this Policy or in accordance with any additional consent you give, and we will comply with your decision. (You will be able to “opt out”, for example, by clicking on an “unsubscribe” link at the end of an email, or by contacting our Privacy Officer.)
3. How does DBG get the personal information it collects and holds?
DBG only collects personal information by fair and lawful means, including when people:
- order products from us;
- fill in any contact or registration forms on our site;
- post material to our site or to social media that we use (such as Facebook, Twitter, Pinterest and Instagram);
- contact us for assistance or with questions, or to report problems with our site or with a product;
- contact us for a referral to a de Bono Distributor or Master Trainer; and
- contact us other than through our site or social media (for example, if you email us directly, or send us a fax or letter).
We prefer to obtain any personal information we collect directly from you. In some cases, however, it may be unreasonable or impracticable to obtain personal information directly, and we may obtain that information from someone else.
If you are concerned about what personal information we may hold about you, please see below for information on how you can access and (if necessary) correct that information.
4. Can I interact with DBG anonymously or under a pseudonym?
In many cases, you will need to provide your real name when interacting with us. This will particularly be the case when you are purchasing something from us.
You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products or services, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with information, we may not be able to provide you with our products or services, or respond adequately to you.
For clarification on when you must identify yourself, please contact our Privacy Officer. (You may use a pseudonym – or simply not identify yourself – when making such an enquiry.)
5. Who has access to my personal information?
Generally, only our staff will access your personal information, and then only on a “need to know” basis.
We may, however, also disclose your personal information:
- to people who work for us or for one of our suppliers, who may be engaged in, among other things, filling orders, processing payments and mail-outs, marketing, research and providing support services;
- to de Bono Master Trainers and de Bono Distributors, and to other licensees and sub-licensees, in order to assist you with your enquiries, or to follow-up on issues you have raised with us;
- to protect the rights, property, health or safety of DBG or its staff, customers or others (including exchanging information with other companies and organisations to protect against fraud and to reduce credit risk);
- to our agents, business affiliates, joint venture entities and other partners (including any holding company or subsidiary, our ultimate holding company, and its holding companies and subsidiaries, as defined in section 50 of the Corporations Act 2001 (Cth));
- to sponsors and promoters of any competition that we conduct or promote;
- as part of a sale (or proposed sale) of all or part of our business;
- to anyone else that you specifically authorise us to receive information held by us; and/or
- as otherwise required or permitted by law (including under privacy legislation).
6. How can I access (and, if necessary, correct) personal information that DBG collects and holds about me?
If you want to review (and, if necessary, correct) personal information that DBG may have collected and holds on you, please contact our Privacy Officer.
We will respond to your requests to access and to correct your personal information as soon as possible (but in any case within a reasonable period).
7. How can I complain about DBG if it breaches any applicable privacy principles or any registered code that binds it?
Contact our Privacy Officer if you have any complaints about breaches by DBG of any applicable privacy principles or of any binding registered code.
8. How will DBG deal with complaints I might have about breaches of applicable privacy legislation or any relevant registered code?
We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously, and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.
9. What steps does DBG take to secure personal information?
We take all reasonable steps to ensure that your personal information is treated securely and in accordance with this Policy and is not subject to misuse, interference or loss, or to unauthorised access, modification or disclosure. For example, apart from using secure servers, we implement firewalls and password access and, where relevant, impose limits on who can access personal information.
While we use Secure Sockets Layer (SSL) encryption software for security, please also note that the transmission of information (including over the Internet) is never completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information – particularly while it is being transmitted to us – so any transmission is at your own risk and we cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
If we have given you (or where you have chosen) a password which enables you to access our services or parts of our websites, you are responsible for keeping this password confidential. You must not share a password with anyone who is not entitled to that password (for example, under a subscription).
10. Does DBG disclose personal information to people or organisations outside Australia?
DBG holds personal information securely on servers located in Australia.
Many de Bono Master Trainers and de Bono Distributors, as well as other DBG licensees or sub-licensees (such as publishers) are located outside Australia and, DBG may disclose personal information to these people and organisations (for example, if to do so is, in DBG’s opinion, reasonable in the circumstances).
We will not, however, otherwise transfer your personal information overseas to a country that is not subject to a comparable privacy scheme or to an organisation that does not implement privacy obligations at least comparable to the obligations that apply in Australia.
Please contact our Privacy Officer if you have any questions, comments or requests in relation to this Policy.
12. Who do I contact at DBG about privacy issues?
Contact our Privacy Officer at firstname.lastname@example.org or care of de Bono Global Pty Ltd, 2/28 Kings Lane Darlinghurst NSW 2010, Australia if you have any concerns about privacy issues, including in relation to:
- how DBG is dealing with your personal information; or
- how it is being held.
Please also contact our Privacy Officer if you want to review and/or correct any personal information we hold about you, or if you receive communications purporting to be connected with DBG or our services that you believe have been sent other than in accordance with this Policy or in breach of any law.
DBG’s privacy standards relating to its activities as a media organisation
The Private Sector amendments to the Commonwealth The Privacy Act 1988 (Cth) exempts from its ambit acts and practices by media organisations in the course of journalism when the organisation is publicly committed to observing a set of privacy standards. Accordingly, The DBG Group Pty Limited has developed such a set of standards. These standards apply to all activities of DBG involved in the collection, preparation and dissemination of the following material for the purpose of making it available to the public: – news, current affairs and information; and – material consisting of commentary or opinion on, or analysis of, news, current affairs or information.
These standards apply to all such activities undertaken by DBG. Complaints arising from such activities can be made by contacting DBG’s Privacy Officer at email@example.com.
The Privacy Act 1988 recognises the need to balance respect for privacy with the public interest in allowing a free flow of information through the media. One way the Privacy Act aims to address this balance is by providing an exemption for acts done, or practices engaged in, by a media organisation in the course of journalism. This exemption will apply if the media organisation is publicly committed to observing standards which deal with privacy in the context of the activities of a media organisation, and those standards have been published in writing either by the organisation or a body representing a class of media organisations.
2. Application of Privacy Standards
These Standards apply to ‘personal information’. This term is defined by the Privacy Act as information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. These Standards recognise the public interest in allowing a free flow of information through the media. For the purposes of these Standards, ‘public interest’ means anything involving a matter capable of affecting people at large so they might be legitimately interested in, or concerned about, what is going on, or what may happen to them, or to others. These Standards apply to ‘personal information’. This term is defined by the Privacy Act as information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. These Standards recognise the public interest in allowing a free flow of information through the media. For the purposes of these Standards, ‘public interest’ means anything involving a matter capable of affecting people at large so they might be legitimately interested in, or concerned about, what is going on, or what may happen to them, or to others.
3. DBG’s Privacy Standards
DBG publicly commits to observe the following standards dealing with privacy in the context of its activities done in the course of journalism as a media organisation:
1. Collection of personal information
When gathering news, current affairs or information, authors should only use personal information in the public interest. In doing so, authors should not unduly intrude on the privacy of individuals and should show respect for the dignity and sensitivity of people encountered in the course of gathering news, current affairs or information. News, current affairs or information obtained by unfair or dishonest means should not be published unless there is an overriding public interest. Generally, authors should identify themselves as such. Public figures necessarily sacrifice their right to privacy, where public scrutiny is in the public interest. However, public figures do not forfeit their right to privacy altogether. Intrusion into their right to privacy must be related to their public duties or activities.
2. Use and disclosure of personal information
Personal information gathered by authors should only be used for the purpose for which it was intended. A person who supplies personal information should have a reasonable expectation that it will be used for the purpose for which it was collected. Some personal information, such as addresses or other identifying details, may enable others to intrude on the privacy and safety of individuals who are the subject of, or referred to in, news coverage or a publication; or the privacy of those individuals’ families. To the extent lawful and practicable, authors should only disclose sufficient personal information to identify the persons being reported in the news, or referred to in a publication, so that these risks can be reasonably avoided.
3. Quality of personal information
DBG should take reasonable steps to ensure that the personal information it collects is accurate, complete and up-to-date.
4. Security of personal information
DBG should take reasonable steps to ensure that the personal information it holds is protected from misuse, loss or unauthorised access.
5. Anonymity of sources
All persons who provide information to media organisations are entitled to seek anonymity. The identity of confidential sources should not be revealed, and where it is lawful and practicable, DBG should ensure that any personal information which it holds derived from such sources does not identify the source.
6. Correction, fairness and balance
Where individuals are singled out for criticism, the publication should ensure fairness and balance in the original published material. Failing that, and provided that DBG in its absolute discretion decides that it is commercially viable to do so, a reasonable opportunity for a balancing response will be provided for those publications which are published periodically.
DBG will take steps to correct any of its records containing personal information which has been published and which is found to be harmfully inaccurate, so as to avoid the harmful inaccuracy being published again.
7. Sensitive personal information
DBG’s publications should not place any gratuitous emphasis on the race, ethnic origin, political opinions, religion, philosophical beliefs or sexual orientation of an individual. Nevertheless, where it is relevant and in the public interest to report and express opinions in these areas, DBG’s publications may do so.
Members of the public caught up in newsworthy events should not be exploited. A victim or bereaved person has the right to refuse or terminate an interview or photographic session at any time.
Unless otherwise restricted by law or court order, open court hearings are matters of public record and can be reported by the media. Such reports need to be fair and balanced. They should not identify relatives or friends of people accused or convicted of crime unless the reference to them is necessary for the full, fair and accurate reporting of the crime or subsequent legal proceedings; or analysis of the legal principles or concepts involved in the matter.