1. GENERAL POLICY
Southern Community Broadcasters Inc. (henceforth referenced as Southern FM) operates established Melbourne community radio station 88.3 Southern FM. It also operates the main website for the radio station, southernfm.com.au (Website).
2. COLLECTION OF PERSONAL INFORMATION
What kind of personal information do we collect?
Southern FM may collect personal information including (but not limited to) the following: your name, address, email address, telephone numbers, gender, date of birth, photograph and payment details. We may also collect other types of personal information that you share with us in connection with:
(i) an on-air conversation (or possible conversation) with a radio presenter;
(ii) your entry into a competition or trade promotion;
(iii) your feedback (including complaints) in relation to our programs and other services; and
(iv) your use of Southern FM apps, Website and audio streams on the Website.
We also collect other information that is reasonably necessary for, or directly related to, our business functions and activities.
How do we collect your personal information?
We generally collect personal information from you when you communicate with us, or when we communicate with each other. For example, we generally collect personal information via the following means (although there may be others):
(i) Telephone – when you call in to take part in a program, to enter a competition or provide us with feedback;
(ii) Post and email– when you write to us for any reason;
(iii) Website – when you contact us via the Website, register or log in to a user account, enter a competition, and through the use of third-party cookies (flash and non-flash) and web beacons;
(iv) Social media – when you post or like something on our Facebook page, follow/respond to us on Twitter, or Instagram; and
In most instances, we collect personal information directly from you. However, there may be circumstances where we collect information about you from third parties or via other methods.
Why do we collect your personal information?
Where Southern FM collects and holds your personal information, it is collected and held for our business purposes, which are generally to provide services to you and to administer our relationship with you. These purposes include (but are not limited to) the following:
(i) Talkback and other on-air communications – to enable on-air presenters to appropriately address you, know the subject matter of your call and whether you’ve called previously;
(ii) Competitions – to facilitate the conduct of competitions and trade promotions;
(iii) Newsletter and special offers – to provide you with details of events, services of Southern FM, emails and other communications;
(iv) Feedback and complaints – to comply with our obligations under the Community Radio Codes of Practice or the Broadcasting Services Act 1992 (Cth) or to improve our services;
(v) Membership of the organisation – to comply with the Southern FM Constitution, Community Radio Codes of Practice, and Broadcasting Services Act 1992.
3. USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
We generally use and disclose personal information for the purpose for which it was originally collected. We may also use or disclose it for another purpose if you consent to that secondary purpose, or where you would reasonably expect us to use or disclose it for that secondary purpose (and the secondary purpose is related to the purpose for original collection). This includes disclosure as described in the Southern FM Constitution.
In addition, Southern FM may use or disclose personal information:
(a) in response to a legal requirement;
(b) where required or authorised by or under an Australian law (including the Act) or court/tribunal order;
(c) if we reasonably believe that the use or disclosure is:
(i) reasonably necessary for an enforcement related activity conducted by or on behalf of an enforcement body;
(ii) necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(iii) necessary in order to take appropriate action where we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in; or
(iv) reasonably necessary in order to locate a person reported as missing; or
(d) if reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of confidential alternative dispute resolution.
Your personal information may be disclosed to:
(i) external service providers, for example in relation to their storage and management of databases, management of website and email traffic, mailing list management, processing of credit card information and fulfillment of orders from Southern FM online service (including membership sign up/renewal) – this disclosure will always be on a confidential basis and such service providers will be limited in their use of your information to the purpose of Southern FM’s activities only;
(ii) regulatory bodies – which oversee or impact upon Southern FM’s operations, for example the Australian Communication Media Authority (ACMA);
(iii) any other person authorised by you, as specified by you;
(iv) members of the organisation under section 31 of the Southern FM Constitution.
4. HOLDING AND SECURING YOUR PERSONAL INFORMATION
Once collected, we may hold your personal information in a number of different formats, including (but not limited to) software programs (located both onsite and offsite, including in the cloud), databases, filing systems and in offsite backup storage.
Southern FM takes all reasonable steps to protect your personal information from loss, unauthorised access, modification, disclosure, interference or other misuse.
5. SENSITIVE INFORMATION
Southern FM does not generally collect sensitive information, including information relating to your racial or ethnic origin, membership of political bodies, religion or trade unions, sexual preferences or activities, criminal record, state of health or medical history. However, in some instances, such information might be disclosed during the course of your interaction with us, for example during a talkback conversation. If Southern FM holds any sensitive personal information about you, that information will only be used and disclosed by Southern FM if you have consented to such use and disclosure (your provision of that information will be taken to be consent), and will only be used and disclosed for the purpose that it was provided by you.
6. ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
At any time, you may request access to personal information about you that Southern FM holds by contacting our Secretary by email at:
or by mail addressed to:
2 Parliament Street,
Brighton, VIC, 3186
Southern FM will process your request within a reasonable time. If Southern FM is not legally required to provide access to the personal information requested and exercises its discretion not to provide that information, we will let you know our reasons for doing so. We may charge you for the cost of accessing your personal information, but if we do so the charge will not be excessive and will not apply to the making of the request. This charge will not take place if the conditions of Section 31 of the Southern FM Constitution are enacted.
Please notify Southern FM promptly if there are any changes to your personal information. You may ask Southern FM at any time to correct personal information it holds about you by contacting our Secretary using the details above.