Privacy Policy

SEC Newgate PTY LTD (ACN 162 366 056) (SEC Newgate, we, our or us), recognises and respects the importance of your privacy and understands your concerns about the security of the personal information which is provided to us.

We are sensitive to privacy issues and take seriously the ongoing trust our business associates have placed in us.

We are committed to compliance with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), which detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to, or make complaints about, the personal information held about them in Australia.

We are also committed to compliance with Regulation (EU) 2016/679 (General Data Protection Regulation) (the GDPR) so far as it affects Australian businesses and the collection, use, disclosure of personal information of EU residents.

SEC Newgate is part of a larger global group, whose ultimate group holding company is SEC Newgate S.p.A. We are a communications and marketing business and work cooperatively with our group members in providing our services to you. Any disclosures from or to group members are in accordance with this Privacy Policy, the Privacy Act and in so far as it may apply to us, the GDPR.

SEC Newgate Research, a division of SEC Newgate conducts market and social research activities in accordance at all times with the Privacy Act and more specifically the Privacy (Market and Social Research) Code 2014 (the Code).

For the purposes of this Privacy Policy:

Personal information is defined in the Privacy Act as information or an opinion about an identified individual, or about an individual who is reasonably identifiable.

Personal data, as defined in the GDPR, is “any information relating to an identified or identifiable natural person (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Sensitive information, a sub-set of personal information, is information or an opinion about an individual’s racial or ethnic origin, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices or criminal record, and includes health information and genetic information.

All references in this Privacy Policy to Personal information will also apply to Personal data for the purposes of the GDPR.

This Privacy Policy details how we manage personal information we collect, use and hold. It lets you know what personal information of yours we hold, what we do with it, who we will disclose it to and how you can access the Personal information we hold about you. You can also find out here how to change inaccurate Personal information and how to opt out of receiving communications from us.

What personal information we collect and hold

We provide strategic solutions for individuals and businesses with communications and marketing (the Business Services).

The kinds of personal information we collect from you or about you depend on your engagement with us, the Business Services you or your organisation have contracted us to provide or any part of them, and the Business Services you or your organisation are interested in and visit our website www.newgatecomms.com.au (Website) in relation to.

Generally, we collect and hold the following types of Personal information in the course of providing the Business Services. At all times, we collect and use information that is necessary for the provision of our Business Services.

The Personal information we, for the purposes of the GDPR ‘process’ or otherwise collect includes:

  • your name;
  • work address, email address and/or phone number;
  • your job title, information about your job role;
  • your age, ethnicity, gender or nationality;
  • your occupation, place of employment and work history; and
  • any other information that you may have provided us with or is in the public domain.

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

The information SEC Newgate Research collects may also include your life stage, makeup of your household, whether you own or rent your home, and opinion and feedback in relation to a number of ideas, products, proposals or issues.

 

In providing the Business Services, we may collect and hold Sensitive information from time to time. Depending on the nature of the research conducted by SEC Newgate Research, we may also collect Sensitive information from you, including your political opinion, income level and cultural background in the course of conducting social and market research. Sensitive information will only be collected with your prior consent and only if it is directly related to, or reasonably necessary for our Business Services and any research undertaken.

 

Cookies

When you browse our Website, contact us electronically, or engage with us on social media, we may also record geographical tagging, cookies, your IP address and statistical data from your activity. We may use your Personal information to customise and improve your user experience on our Website and other social media platforms. By using our Website, you agree that we can record this information from your device and access them when you visit the site in the future.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

 

Third Party Sites

Our Website may contain links to other websites you may find of interest which are owned or operated by third parties separate from SEC Newgate or the group of which SEC Newgate is a member. Once you use these links to leave our Website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to any website in question before disclosing or otherwise providing any Personal information.

 

How we collect and hold personal information

We aim to collect personal information only directly from you as a consumer or business customer, unless it is unreasonable or impracticable for us to do so. For example, we may collect Personal information from you through telephone calls and other interactions with our employees, contractors and consultants (Representatives), your emails and other correspondence to us or our Representatives, account set up for the Website, enquiries and contracts for use of our Business Services.

We collect and process Personal information of:

  • Business contacts;
  • Clients and individuals associated with clients;
  • Journalists;
  • Suppliers;
  • Employees;
  • Research participants
  • Job applicants
  • Persons who supply us with their information;
  • Shareholders of both our company and that of our clients;
  • Visitors to our offices;
  • Visitors to the Website; and
  • Visitors to the SEC Newgate group companies’ websites.

SEC Newgate will generally collect your Personal information directly from you, or from one of our accredited fieldwork companies or group members, in the course of providing Business Services to you or you participating in our qualitative and/or quantitative research.

In some instances, we may also receive information about you from third parties. As a result of this, SEC Newgate Research may from time to time invite you to participate in research based on information collected about you.

We will record your email address if you send us an email and store this in accordance with this Privacy Policy. We will use this email address for reasonable purposes as outlined in this Privacy Policy and/or in accordance with all applicable laws.

If you choose not to provide your personal information, then we may not be able to provide you with our full range of services.

You can be anonymous or use a pseudonym when dealing with us, unless the use of your true identity is a legal requirement, or it is impracticable for us to deal with you on such basis.

 

Why we collect, hold, use and disclose personal information

We will primarily collect, hold, use and disclose personal information where it is reasonably necessary for us to carry out our Business Services functions and activities and/or where we have a lawful reason for doing so. The lawful basis for processing and/or collecting Personal information by us will be one of the following:

  • The processing and or collecting is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
  • The processing in necessary in order for us to comply with our legal obligations;
  • You have consented to us holding such information for purposes agreed with you; and/or
  • The processing or collection is necessary for the pursuit of our legitimate business interests.

We may also use Personal information for related purposes which you would reasonably expect, such as providing details about other services offered by us or third parties, as well as any promotions, offers or other arrangements or agreements with any third-party suppliers where relevant.

The activities that we may use Personal information for are:

  • Marketing;
  • Informative emails;
  • Invitations to events;
  • Competition entry;
  • Social and Market Research;
  • Human Resource activities;
  • Fund raising;
  • Managing our relationship with you; and
  • Promoting our business or the business of our clients.

SEC Newgate will process Personal data for all the time that it is still lawful and valid to do so. SEC Newgate will store the personal data for varying periods, and this will be reviewed at least annually.

You can opt out of receiving offers or information at any time by notifying us. Opt out procedures are also included on all of our marketing and promotional communications.

In some cases, we disclose personal information to members of our global group with whom we work collaboratively on occasion to provide you the Business Services. We will ensure that any entity to which we disclose your personal information is bound by appropriate confidentiality and non-disclosure agreements, if they are not otherwise required to adhere to the Privacy Act and APPs and/or GDPR.

We may also disclose personal information, collected by us:

(a) where we have sought your specific consent;

(b) in accordance with the Privacy Act or GDPR; or

(c) to third parties where required or permitted by law (including but not limited to government departments and enforcement bodies in any jurisdiction to which we or you are accountable).

 

How we hold, store and keep secure personal information

Your personal information is stored electronically, in the cloud and is encrypted on a server. We have electronic and procedural safeguards in place and take reasonable steps to ensure that your information is protected at all times from misuse, interference and loss, and from unauthorised access, modification and disclosure.

Please be aware that personal information provided by email may not be secure. If you have any concerns regarding the security of your personal information, please provide it in an alternate form, such as facsimile or post.

 

Destruction and de-identification

We will retain personal information collected by us whilst it is required for any of our business functions including but not limited to providing the Business Services or any part of them, or for any other lawful purpose. We will take reasonable steps and use secure methods to destroy or de-identify personal information that is no longer required for any purpose for which the personal information may be used under this Policy or otherwise in accordance with the Privacy Act, APPs and GDPR. Any interview recordings will be stored on an offsite server for six months, after which they will be deleted.

 

Overseas Disclosure

We share your personal information with our business associates (where strictly relevant to provide the Business Services) who are situated in the jurisdiction in which you are based, Australia or otherwise outside of the EEA. Any and all overseas disclosure of Personal information will be strictly in accordance with all applicable privacy laws including but not limited to the Privacy Act and GDPR.

We will take appropriate measures to ensure that any recipient of Personal information protects your Personal information adequately and in accordance with this Privacy Policy. These measures may include but are not limited to those specified in APP 8 (cross border disclosure) and Articles 45 and 46 of the GDPR.

 

Requests for Access and Correction

In most cases, you will be able to gain access to Personal information held about you by us. We may provide you with this information verbally or in writing, as may be appropriate and on reasonable request. In accordance with the Privacy Act and GDPR, under certain circumstances, you have the following rights when we h                     old Personal information about you:

  • the right to ask us to provide you, or a third party, with copies of the Personal information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
  • the right to request erasure, anonymisation or blocking of your Personal information that is processed in breach of the law;
  • the right to object on legitimate grounds to the processing of your Personal information. In certain circumstances we may not be able to stop using your Personal Information, if that is the case, we’ll let you know why; and
  • withdrawal of consent –an individual may withdraw consent at any time (this may apply to processing of special categories of Personal information which may be otherwise classified or deemed Sensitive information and where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership).

To exercise such rights (save from marketing emails – as described above) and if you have any questions about how we collect, store and use Personal information, then please contact us using the details as set out in the “How to Contact Us” section below.

Any of the above requests will be forwarded on should there be a third party involved in the processing of your Personal information.

 

We rely on the Personal information we hold to efficiently provide our services, including but not limited to the Business Services. For this reason, it is very important that the Personal information

we collect is accurate, complete and up-to-date at all times. We will take reasonable steps to amend or correct any Personal information held by us to keep it accurate and up to date provided always that you notify us of any change to Personal information which becomes known to you at any time.

If you would like to discuss any aspect of your personal information, please contact our Privacy Officer using the details provided in this Privacy Policy below.

 

Data Breaches

If we suspect we have suffered a data breach, we will undertake an assessment into the circumstances of the suspected breach within the time period as is required by applicable law including the Privacy Act and, where applicable, the GDPR.

Notification to Australian Information Privacy Commissioner

Where it is determined a breach has actually occurred and where we are required by law to do so (due to a loss in, or unauthorised access to Personal information) we will notify the Privacy Commissioner and affected individuals as soon as reasonably practicable after becoming aware that serious harm is likely to be suffered.

We will also notify the Privacy Commissioner at all other times where we are otherwise required to make a disclosure in accordance with the Privacy Act and specifically the Notifiable Data Breach Scheme, a mandatory data breach notification regime in Australia.

We will make all other required disclosures to the necessary authorities in accordance with the GDPR if any Data Breach concerns the loss or other misuse of Personal information of EU residents.

 

Complaints and Concerns

We have procedures in place for dealing with any complaints and concerns about our practices in relation to the Privacy Act, any alleged breach of this Privacy Policy or any of our other business practices which relate to privacy and data protection. We will respond to your complaint in accordance with the relevant provisions of the Privacy Act and APPs and at all times in good faith. We will respond and advise whether we agree with your complaint or not. If we do not agree, we will provide reasons. If we do agree, we will advise what (if any) action we consider it appropriate to take in response.

Our Privacy Officer can be contacted using the details below to discuss or attempt to resolve any complaints relating to the collection, storage and use of your Personal information.

 

Office of the Australian Information Commissioner

If you are not satisfied after having contacted us in respect to a complaint and concern and having given us a reasonable time to respond, we suggest that you contact the Office of the Australian Information Commissioner: enquiries@oaic.gov.au.

 

Changes to this Privacy Policy

It may be necessary for us to review and revise our Privacy Policy from time to time. An amended version will be posted on our website at www.newgatecomms.com.au. We suggest that you visit our website regularly to keep up to date with any changes.

 

How to Contact Us

Lisa Vo
SEC Newgate Privacy Officer
Level 10, 120 Collins Street, Melbourne VIC 3000
Email: Lisa.Vo@secnewgate.com.au
Tele: 03 9611 1801