The South Australian Tourism Commission (SATC) is committed to protecting the privacy of any personal information it collects about you. This Privacy Statement describes SATC’s general privacy practices that apply to personal information that we collect, use and share about consumers and individuals we deal with.
The SATC operates in compliance with the Government of South Australia's Information Privacy Principles Instruction (IPPS), a copy of which can be obtained here.
This policy statement has been updated to reflect the enactment of the European Union’s (EU) General Data Protection Regulation (GDPR). The SATC has representation and undertakes activity in many countries, including countries in the European Union and therefore the GDPR applies to the SATC when data is collected from EU residents.
WHAT IS PERSONAL INFORMATION
The IPPS set down by the Government of South Australia defines personal information as “information or an opinion, whether true or not, relating to a natural person or the affairs of a natural person whose identity is apparent, or can reasonably be ascertained, from the information or opinion”.
In addition to IPPS’ definition of personal information, the GDPR defines personal information as “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.”
WHY AND HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
The SATC will collect the personal information that it needs to carry out specific functions. We may collect your personal information as an individual for various purposes, including the following:
Access and use of websites and other online services
When accessing one of our websites, we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site such as IP address and browser settings. We also collect information about your activities during your visit in order to personalise your website experience. This information will be collected based on consent, when you first visit an SATC website, you will be provided with the choice to “opt in”.
The cookies on SATC websites do not store personal details such as your name, address, telephone number or payment information, but may include your IP address, referring site and pages visited on SATC websites. IP addresses are logged to track a user’s visit while the user remains anonymous. The SATC analyses this data for certain trends and statistics, such as which parts of SATC websites users are visiting and for how long. The SATC does not link your IP address to anything that identifies you.
The SATC uses Adobe and Google Analytics to analyse the use of our website. Both analytics platforms gather information about website use by means of cookies which collect anonymous data. The information gathered relating to the SATC’s website is used to create reports about the use of our website.
The SATC uses advertising cookies and technologies including Adobe, Facebook and Google for the purposes of analytics and online behavioural advertising. This enables the SATC and its partners to serve you with advertising content that is more relevant to your interests. Privacy policies for Adobe, Facebook and Google are also available online.
Anonymous data from advertising cookies including browsing history and practices may be provided to third parties for the purposes of promoting tourism in South Australia via online advertising.
Although the SATC has relationships with other suppliers, we select those relationships very carefully and constantly monitor them. These suppliers may also set their own cookies during your visit to show you products or services based on what you seem to be looking for.
For more information about online targeting and advertising cookies, as well as instructions on how to opt out, visit one of the following online advertising regulatory groups:
• Australian Digital Advertising Alliance (ADAA)
• Digital Advertising Alliance (DAA)
• European Digital Advertising Alliance (EDAA)
• Network Advertising Initiative (NAI)
In order to cater for guests at SATC events or on familiarisation visits, the SATC may collect relevant information on guests including names, phone numbers, addresses, dietary requirements and/or medical conditions. This information will be collected from you for vital interests and may be shared with a third party (eg tour operator or caterer) but only for the purpose of catering for your visit.
Correspondence that has been addressed to the Chief Executive or the SATC is saved on SATC’s online document management system (Sharepoint) and referred to the relevant areas within the SATC for consideration and preparation of advice and responses. The correspondence includes personal information which might arise in any subject matter related to the SATC’s functions. Examples include but are not limited to names, addresses, personal opinions about tourism related matters, complaints and grievances and any other matter that the correspondent wishes to convey to the SATC.
Financial Management and Contractual Records
Financial records are used to process and account for expenditure and revenue. Generally, these records contain the name, address and Australian Business Number of the service provider and the goods or services supplied. This information is collected on a legal basis. Contractual Records include personal information relating to consultants and other contractors who provide goods and services to the SATC. In accordance with the South Australian Government’s Disclosure Policy, information relating to contracts entered into by the SATC may be published on the SA Government website. Financial and contractual information is stored in the Finance and Business Services Unit and is accessed by staff and auditors of the SATC.
The SATC collects personal information from direct and online marketing, online information requests, consumer surveys, interviews, competition entries and promotional media. This information will be collected on the basis of consent which will be requested at the time of collection of the information. The information relates to holiday preferences, tourism product information sources and buying influences. The information collected might include, but is not limited to the following:
• name, age and address of individual concerned
• demographic and lifestyle indicators
• previous holiday locations
• preferred holiday locations and styles
• holiday spending patterns.
The SATC may use this information for marketing purposes, i.e, to keep you informed about events, products and to distribute relevant promotional offers specific to South Australian Tourism. Before we do so, however, the SATC will offer you the opportunity to choose whether or not to have your personal information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you receive, by indicating so when we call you, or by contacting the SATC directly.
Third Party Processors
USE OF PERSONAL INFORMATION
The SATC will only collect personal information if one of the following applies:
• the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which the SATC is subject;
• processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the SATC;
• processing is necessary for the purposes of the legitimate interests pursued by the SATC or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the person which require protection of personal data, in particular where the data subject is a child.
The SATC will not use personal information except for the purpose for which it is collected unless:
• the data subject has expressly consented to the secondary use;
• the SATC believes on reasonable grounds that the use is necessary to prevent or lessen a serious threat to the life, health or safety of the record-subject or of some other person; or
• the use is required by or under law (including pursuant to the Freedom of Information Act 1993 (SA);
If the SATC uses personal information it will take reasonable steps to ensure that, having regard to the purpose for which the information is being used, the information is accurate, complete and up to date.
SHARING OF PERSONAL INFORMATION
The SATC will not disclose personal information to a third party for a purpose that is not the purpose of collection unless:
• you would reasonably expect the agency to disclose the information for a secondary purpose which is directly related to the primary purpose of collection;
• the data subject has expressly consented to the disclosure;
• the SATC believes that the disclosure is necessary to prevent or lessen a serious threat to the life, health or safety of the record-subject or of some other person;
• the disclosure is required or authorised by or under law;
• the disclosure is reasonably necessary for the enforcement of the criminal law, or of a law imposing a pecuniary penalty or for the protection of the public revenue or for the protection of the interests of the government, statutory authority or statutory office-holder as an employer;
• the SATC has reason to suspect that unlawful activity has been, is being or may be engaged in, and discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities.
The SATC’s websites may contain links to websites operated by third parties. The SATC is not responsible for the quality or content of third party websites. The SATC makes no representations or warranties regarding third party website privacy practices. Third party websites are responsible for informing you about their privacy practices.
STORAGE, SECURITY AND RETENTION
The SATC will take such steps as are, in the circumstances, reasonable to ensure that personal information in its possession or under its control is securely stored and is not misused. The SATC takes a risk-based approach to determine appropriate security levels.
The SATC will store personal information as per the mandatory data retention laws pursuant to the State Records Act 1997 (SA), or as otherwise required by law. Information that the SATC deems is no longer necessary to retain will be disposed of in a secure manner.
This statement sets out the SATC’s policies relating to the privacy of your personal information and is to be read in conjunction with the rights claimed by the South Australian Government at http://www.archives.sa.gov.au/alias/privacy.
This site and the data on this site is provided "as is" and without warranties of any kind, whether express or implied. To the fullest extent permissible pursuant to applicable law, the SATC disclaims all warranties, express or implied, including, but not limited to, the site being virus free, implied warranties of merchantability and fitness for a particular purpose and non-infringement.
The SATC reserves the right to delete or archive any material on the site at any time as long as it in compliance with the State Records Act.
Under the IPPS, you can request to access, update or correct your personal information. You also have the right to object to direct marketing.
You may also have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted (erasure) or restricted and ask for portability of your personal information.
To make a request please email the SATC’s Privacy Officer on [email protected]. All requests will be dealt with within required time-frames.
MAKING A PRIVACY COMPLAINT
If you feel that the SATC has not dealt with your personal information in accordance with this privacy statement, the SA Government’s IPPS or the GDPR, please let us know so we may have the opportunity to rectify and resolve the problem. Written complaints should be emailed to [email protected] or sent, with any supporting documentation, to:
South Australian Tourism Commission
GPO Box 1972
ADELAIDE SA 5001
REVIEWS AND UPDATES
From time to time the SATC may update this Privacy Statement, as well as any other specific privacy statement. When making changes to this Privacy Statement, the SATC will add a new date at the top of this Privacy Statement.