The Centre for Books, Writing and Ideas (ACN 134 682 189) trading as The Wheeler Centre (Wheeler Centre, we, us or our) exists to drive the development and celebration of literature in Melbourne and beyond, and to foster broad public engagement in books, writing and ideas. We engage with audiences online, via newsletter and in person at our function and event space located at 176 Little Lonsdale Street Melbourne.
This Policy explains how we collect, use, store and share the personal information that we collect from you.
Personal Information is any information or an opinion about you where your identity is apparent, or can reasonably be ascertained (Personal Information), whether true or not. Sensitive Information is a subset of Personal Information and includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, philosophical beliefs, membership of a trade union, sexual orientation, criminal record, and health, genetic or biometric information (Sensitive Information).
By using the website located at www.wheelercentre.com (Website), including to submit applications to us, you are consenting to the Wheeler Centre making use of the information we collect from you, including your Personal Information, in accordance with this Policy.
1. What this policy is about
This Policy explains the key measures we have taken to implement the requirements of the Privacy Act 1988. It aims to answer the questions you might have about how we collect, use and disclose the information we collect from you, including your Personal Information. If you have any further questions about the Wheeler Centre’s privacy practices, please contact us (firstname.lastname@example.org).
2. What information we collect from you
We collect Personal Information:
- directly from you when you apply for a program or scheme at the Wheeler Centre, such as the Hot Desk program or The Next Chapter scheme;
- directly and indirectly from you when you visit or use the Website; or
- indirectly from you via any third-party sites or platforms through which you access our products and services, or interact with us (Third Party Sites).
This information may include:
- information provided in registering to use the Website and Third Party Sites – for example, your name, email address, contact details and, if provided, your credit card details;
- information provided directly by you as a participant on the Website and Third Party Sites, such as information you disclose in our forms, on our blogs, in sending messages or emails us, or any other spaces where you are able to make comments;
- information provided directly by you to us, such as in applications for Wheeler Centre programs, correspondence, phone calls and other direct means of communication; and
- information provided indirectly by you as a result of your use of the Website and Third Party Sites – for example, the frequency with which and the times at which you use the Website and Third Party Sites and information about your preferences and interests.
Third Party Sites
Health and Sensitive Information
You may elect to disclose health or Sensitive Information to us when applying for programs or schemes offered by the Wheeler Centre. This is most likely to occur where our schemes have the objective of increasing diversity in the writers’ community – such as the Next Chapter scheme – and you may wish to share Sensitive Information about yourself to demonstrate how you fit with the scheme’s objectives.
Where we solicit this information from you, we will use that information only for the purpose of assessing your application and for our own internal reporting mechanisms. We may also de-identify the data and use if for our external reporting obligations, such as reporting to our funding bodies on our audience reach or diversity. We will not retain the sensitive information in a manner which identifies you once your participation in the scheme has finished.
When you submit an application to us via the Website, the application will be stored on reputable third-party servers based overseas, as disclosed below under the heading ‘Security’. If you are concerned about the transfer of your data overseas or the effect this has on your rights and remedies, please contact us at email@example.com and we will work with you to find an alternative solution in accordance with our obligations under the Privacy Act 1988.
If you provide us with unsolicited health or Sensitive Information, please advise us and we will take steps to delete such information in accordance with our obligations under the Privacy Act 1988.
Information collected indirectly from you from the Website
We wish to provide the Website’s users with a positive user experience. To assist us in doing this, we may collect visitor information related to browser and operating systems.
Most web browsers automatically accept cookies but you can disable this function by changing your browser settings if you so wish.
3. What we do with this information
We collect information to improve and expand our audience’s engagement with the Wheeler Centre and the world of writing, books and ideas. We also collect information to provide you with your use of the Website.
We may also use information we collect about you and your Personal Information for related purposes such as:
- communicating with you, including advising you of upcoming releases of new programs, schemes, features or events;
- to record information about our users’ usage, preferences and behaviour in relation to the Website and Third Party Sites, as well as any site feedback you share with us;
- to perform statistical analyses of user behaviour;
- maintaining our relationship with you, including responding to your questions;
- helping us to identify and inform you about other products or services that are likely to be of interest to you;
- providing targeted third-party advertising to you on the Website;
- performing internal accounting and administration, including for reporting purposes;
- protecting you and the Wheeler Centre from fraud; and
- any other use for which we obtain your permission.
We may share overall visitor trends and other generic information collected on this Website with our sponsors, advertisers and other third parties, but we do not pass on any Personal Information except for in accordance with this Policy.
4. How long we will you keep your Personal Information
We will keep your Personal Information for as long as it is required to provide you with our services and to comply with our legal requirements.
If we no longer require your Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify your Personal Information in accordance with our obligations under the Privacy Act 1988.
5. Sharing your information with others
The Wheeler Centre recognises the trust you place in us when you give us your Personal Information. Other than disclosure to service providers (explained below) or as required by law (for example, disclosure to various Government departments or to courts), our policy is that we do not give your Personal Information to other organisations unless we have disclosed the use in this policy or you have given us your consent to do so.
The service providers we may share your Personal Information with are the providers of the electronic systems we use to collect and store your Personal Information; banks and financial institutions you use to make payments to us; and other service providers we use to help us run aspects of our business efficiently. Occasionally the Wheeler Centre might also use your Personal Information for other purposes or share your information with another organisation because:
- we believe it is necessary to provide you with a service which you have requested;
- we believe it is necessary to protect the rights, property or personal safety of another Website user;
- we believe it is necessary to do so to prevent or help detect fraud or serious credit infringements - for example, we may share information with law enforcement agencies and fraud prevention units;
- we believe it is necessary to protect the interests of The Wheeler Centre – for example, disclosure to a court in the event of legal action to which the Wheeler Centre is a party; or
- the assets and operations of the Wheeler Centre’s business are being transferred to another party as a going concern.
When we share information with other organisations and service providers as set out above, we do so in accordance with this Policy. To the extent that these organisations and service providers gain access to your Personal Information, their use is governed by the rules set out in the Privacy Act 1998.
6. Accessing information we keep about you
You can access the Personal Information we hold about you at any time. Simply contact us to make your request.
We will always endeavour to meet your request for access. However, in some circumstances we may decline a request for access. This includes the following circumstances:
- we no longer hold or use the information;
- providing access would have an unreasonable impact on the privacy of other persons;
- the request is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
- providing access would be unlawful;
- providing access would be likely to prejudice the detection, prevention, investigation and prosecution of possible unlawful activity; and
- the information would reveal our commercially sensitive decision-making processes.
If we decline your request for access, we will give you reasons for our decision when we respond to your request.
We reserve the right to charge you a reasonable fee for access to some types of information. These charges will be limited to the cost of recouping our expenses for providing you with information, such as document retrieval, photocopying, labour and delivery.
7. Changing or deleting the information
To provide you with the best possible service and to comply with our obligations under the Privacy Act 1988 it is important that the information we hold about you is accurate. We will take reasonable steps to ensure that your Personal Information is accurate, complete and up-to-date at the time of collecting, using or disclosing the information.
If you believe that any information we hold about you is inaccurate, incomplete or out-of-date, you should notify us. We will do our best to correct it or delete it, unless we need to keep if for legal reasons.
The Wheeler Centre endeavours to take all reasonable steps to keep your Personal Information secure.
Data collected from the Website
The data collected directly and indirectly from you via our Website is stored on reputable third-party platforms. These platforms utilise Amazon servers based in the United States and/or in undisclosed locations and accordingly the Wheeler Centre may, in some circumstances, transfer personal information or information collected from individuals to overseas servers operated by third-party organisations.
If you proceed with providing information to us via the Website you need to be aware that this means that:
- The Wheeler Centre will not be accountable under the Privacy Act for the disclosure of this personal information to an overseas recipient;
- You will not be able to seek redress under the Privacy Act;
- The overseas recipient may not be subject to any privacy obligations or to any principles similar to those found under Australian law;
- You may not be entitled to seek redress in the overseas jurisdiction; and
- The overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
Data stored in emails and internal documents
The Wheeler Centre is not responsible for any third-party access to your Personal Information as a result of:
- interception while it is in transit over the internet;
- spyware or viruses on the device (such as a computer or phone) from which you access the Website, nor
- as a result of your failure to adequately protect your user names or passwords;
nor for any losses, expenses, damages and costs, including legal fees, resulting from such access.
9. Providing information on Third Party Sites
10. What to do if you have a problem, question or complaint
If you have any further queries relating to this Policy, please contact the Wheeler Centre. If the Wheeler Centre becomes aware of any ongoing concerns or problems with customer information, we will take these issues seriously and work to address these concerns.
11. Changes to this Policy
From time to time, our policies will be reviewed and may be revised. The Wheeler Centre reserves the right to change this Policy at any time and notify you by posting an updated version of the Policy on the Website. Before providing us with Personal Information, please check this Policy on the Website for any changes.
This Policy was last updated in May 2018 and is currently under further review.