1. Introduction

RGM Artists Pty Ltd ABN 78 163 055 972 (we, our, us) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information. We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Privacy Act’s requirements in relation to the collection, management and disclosure of your personal information.

2. What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, personal information is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation, amongst other things. If the information we collect personally identifies you, or you can be reasonably identified from it, the information will be regarded as personal information.

3. What personal information do we collect and hold?

We may collect the following types of personal information about you:

• your name;
• your mailing or street address;
• your email address;
• your telephone number(s); and
• your age or birth date.

If you are a client of ours, we may also collect additional personal information from you to assist us to perform our role as your agent or representative, including the following additional types of information; 

• your professional name or pseudonym;
• your gender;
• your dietary requirements and allergies (if any);
• your measurements/shoe sizing;
• your medical information;
• your passport details;
• your union membership or professional association/guild membership;
• your criminal record (if any);
• your travel and accommodation requirements;
• your earnings and royalties;
• your taxation and superannuation details;
• details of your past work history and work engagements; and
• any other information you provide to any of our personnel from time to time.

If you are an employee or contractor of ours or you apply for a position with us, we may collect additional personal information about you to manage our employment or contracting relationship with you, including your superannuation and taxation details, an emergency contact for you and documents detailing your right to work in Australia. 

4. How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• if you are a client of ours, in the course of our relationship with you as your agent or representative;
• through your access and use of our website;
• during conversations between you and our personnel;
• if you are a client of ours, when you complete a client representative agreement with us; and
• if you are an employee or contractor of ours, when you apply for a position with us or send a résumé or curriculum vitae to us or when you complete a new starter form or other employment-related form. 

Where relevant, we may also collect personal information from third parties including:

• if you are a client of ours, from any other representative, agent or professional advisor (such as your lawyer or accountant) that you have engaged;
• in relation to our employees and contractors, from recruitment agencies that we deal with or which you have engaged or from your former employer(s) or any referees that you provide; or
• from third parties such as credit reporting bodies, law enforcement agencies and other government entities.

We generally do not collect sensitive information about you, unless you have consented to the collection of this information by us or we are required by law to collect this information. “Sensitive information” includes health information, racial or ethnic background, sexual orientation or practices, criminal record, biometric information, religious, political or philosophical beliefs and membership of a union or political or professional association. Where you are a client of ours, we may need to collect some sensitive information about you in order to assist us to act as your agent or representative. This may include health information about you and details of any criminal record that you might have. 

5. What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide our services to you or act as your agent or representative, either to the same standard or at all;
•  we may not be able to provide you with certain types of assistance that we would normally be able to provide (such as booking travel or accommodation for you); or
• if you are an employee or contractor of ours or you apply for a position with us, we may not be able to consider your application for employment or engagement as a contractor or provide you with any benefits or otherwise administer our employment or contracting relationship with you. 

6. For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of service to you. We collect, hold, use and disclose your personal information for the following purposes:

• to provide our services to you and to communicate with you, including in our role as your agent or representative (if applicable);
• to engage with entertainment industry representatives and professionals both in Australia, and (where applicable) internationally, on your behalf in our role as your agent or representative;
• to liaise with any international representatives appointed by you or any other professional advisor appointed by you;
• to discuss and negotiate terms and conditions of work engagements with third parties;
• to administer arrangements relating to payments due to you from third parties including any royalty and/or residual payments;
• for business administration purposes (including human resources, client management and debtor management) and for administrative purposes (including in connection with our role as your agent or representative, if applicable);
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties on your behalf;
• if you are an employee or contractor of ours or you apply for a position with us, to consider your application for employment or engagement, to manage your employment or contracting relationship with us (including to pay you any salary, fees or benefits), to administer any training or education that you may require as part of your role and to assess your performance and provide you with performance feedback, including to undertake disciplinary action if necessary;
• to provide your updated personal information to our related bodies corporate, contractors or service providers (and to your other representatives and advisors, if applicable);
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.

Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy. 

7. Our website

Our privacy policy also applies to our website at www.rgm.com.au

Cookies
When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of services you view so that, if you consent, we can send you news about those services. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer our website, track users movements and gather broad demographic information.

Security
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

8. Who do we disclose your information to?

If you are a client of ours, we may disclose your personal information to:

• our employees, related bodies corporate, contractors, service providers and other third parties in connection with our role as your agent or representative, including to seek and secure work opportunities for you, to arrange travel and accommodation for you, to collect and remit income and royalties owed to you and to otherwise assist you while acting as your agent or representative;
• third parties that provide services to us or to you (such as any other representatives or professional advisors that you have engaged) or who we engage to provide services on your behalf;
• our related bodies corporate, contractors, agents and service providers (to the extent necessary in connection with our role as your agent or representatives), as well as to government bodies and regulatory authorities, where required or authorised by law;
• other third parties that we deal with in connection with our business, including web hosting providers, IT service providers, couriers, payment processors, debt collectors and other suppliers, as well as professional advisors such as accountants, solicitors, business advisors and consultants; and
• any other third party for any authorised purpose or otherwise with your express consent.

If you are an employee or contractor of ours, we may disclose your personal information to third parties that we deal with as part of our business in connection with your role with us, including to our clients and to other third parties that you are required to deal with as part of your role. 

9. Do we hold or disclose your personal information to anyone outside Australia?

We may disclose personal information to third parties located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach applicable privacy obligations relating to your personal information.

We may disclose your personal information to the following entities located outside of Australia:

• if you are a client of ours, to any relevant third party located in any country where you are seeking or undertaking a work engagement (including your international representative or agent, any travel or accommodation providers and any organisations that you are undertaking a work engagement for or from which you are seeking a work engagement);
• our data hosting and other IT service providers, both within Australia and overseas; and
• other third parties located in including the US, Britain, Ireland, Scotland, Malaysia, Singapore, Laos, New Zealand, Canada and countries within the UAE and EU.

10. Security and data quality

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Our computerised information technology systems are protected from unauthorised access through the use of a hardware firewall and password protection for all access methods into the network. All computers and servers have antivirus protection with automated virus definition updates. To prevent loss of data, Servers are protected with hourly backups and transferred off-site to a secured backup facility on a daily basis, with all backups encrypted by password. Certain parts of our database containing personal information require an additional layer of encryption security, requiring a separate password to access.

We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the later).

11. How can you access and correct your personal information?

You may request access to any personal information that we hold about you at any time by contacting us (using the details in the ‘Contacting us’ section below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by posting or emailing a copy to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information that we hold about you. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we correct it. We will consider if the information requires correction. If we do not agree that there are grounds for correcting your personal information, then we will add a note to the personal information stating that you disagree with it. 

12. What is the process for complaining about a breach of privacy?

If you believe that we have breached your privacy, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and that your complaint is resolved within a reasonable time (and in any event within the time required by the Privacy Act, if applicable). 

If our response to your complaint does not address your concerns to your satisfaction, you have the right to make a complaint to the Office of the Australian Information Commissioner.

The contact details for the Office of the Australian Information Commissioner are:
Phone: 1300 363 992
TTY: Call 133 677 then ask for 1300 363 992
Email: enquiries@oaic.gov.au
Fax: +61 2 9284 9666
Post: GPO Box 5218 
Sydney NSW 2001

13. Contacting us

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact our Head of Finance using the details set out below. If you are an employee or contractor of ours, you may also contact your human resources representative with any privacy queries that you may have. 

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.

Please contact our Head of Finance at:
Post: Head of Finance
RGM Artists Pty Ltd
PO Box 128 
Surry Hills NSW 2010
Australia
Tel: +61 2 9281 3911 
Email: info@rgm.com.au 

14. Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website and will be effective from the date of posting.

This privacy policy was last updated on 12 July 2017.