Grant Broadcasters is committed to client and listener service and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the 10 National Privacy Principles (NPPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs came into effect on 21 December 2001. The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the National Privacy Principles may be obtained from the website of The Office of the Federal Privacy Commissioner at www.privacy.gov.au.

Part 1: General Privacy Policy

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual.

Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers. This Personal Information is obtained in many ways including interviews, correspondence, by telephone and facsimile, by email, via our network of websites and from third parties. We do use cookies in web browsers simply to save you the trouble of having to log-in every time you hit one of our pages. We don't guarantee website links or policy of authorised third parties, though.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time; all you need to do is let us know.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• for the primary purpose for which it was obtained;
• for a secondary purpose that is directly related to the primary purpose;
• with your consent; orwhere required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take all reasonable steps to ensure that you are made aware of the information provided to us by such third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• third parties where you explicitly consent to the use or disclosure; and where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in database files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

NPP 6 provides you with the right to access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please make out your request to us in writing.

Grant Broadcasters will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing such information.

Maintaining the Quality of your Personal Information

It is an important part of providing our services to you that your Personal Information is up to date. NPP 3 provides that we take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date.

It is important that you advise us at the earliest opportunity of any changes to your Personal Information so that our records can be updated.

Policy Updates

This Policy may change from time to time. The Grant Broadcasters Privacy Policy is available at our office or on our website to anyone who requests it.

Complaints

You can lodge a complaint with us about any breach of our Privacy Policy and our privacy obligations to you by contacting us.

Privacy Policy Enquiries

If you have any queries about our Privacy Policy please contact our Privacy office via web@grantbroadcasters.com.au.

Part 2: Privacy and Journalism

Below is our policy with regard to the Privacy Act and our handling of news and current affairs.

1 - Journalism exemption to the Privacy Act

The Commonwealth Privacy Act seeks to balance the public interest in providing adequate safeguards for the handling of personal information and the public interest in allowing a free flow of information to the public through the media.

The Privacy Act exempts acts done by a media organisation such as Grant Broadcasters in the course of journalism provided that at the time of the act, the media organisation is publicly committed to observe standards that deal with privacy in the context of the activities of the organisation and those standards are published in writing by the organisation or a person or body representing a class of media organisations.

Grant Broadcasters has developed the Journalism Privacy Standards set out in this document and is publicly committed to observe these Standards. Accordingly, Grant Broadcasters is exempt from complying with the National Privacy Principles in respect of its journalism activities.

2 - Definitions

"Personal information" in these Journalism Privacy Standards means information or an opinion (whether true or not and regardless of its source) about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.

"we", "us" and "our" means Grant Broadcasters Pty Ltd (ABN 93 129 643 545) and its related bodies corporate and their respective officers and employees.

3 - Application of the Journalism Privacy Standards

These standards apply to collection, use and disclosure of personal information by us in the course of our journalism activities.

4 - Collection of personal information

• We will collect personal information only where it is in the public interest to do so.
• We will respect an individual's right to protection from unwarranted invasions of privacy.
• Our journalists may collect personal information without revealing their identity where it is in the public interest to do so.
• We will respect the private grief of individuals.

5 - Use of personal information

• Personal information will only be used for the purpose for which it was collected or a directly related and reasonable secondary purpose.
• Personal information obtained by unfair means will not be broadcast or otherwise disclosed unless there are overriding public interest considerations.
• We will not intrude into the privacy of public figures unless the intrusion is related to the individuals' public role or activities or there are overriding public interest considerations.

6 - Quality and accuracy of personal information

• We will take reasonable steps to ensure that personal information we collect, use or disclose is accurate, complete and up-to-date.

7 - Security of personal information

• We will take reasonable steps to protect personal information we hold from misuse and loss and from unauthorised access, modification or disclosure.

8 - Confidential sources

• Where it is lawful to do so, we may refuse to do anything which could reveal the identity of a person who gave us personal information in confidence.
• Where it is lawful to do so and where there are no overriding public interest considerations, we will attempt to ensure that any personal information which we broadcast or otherwise disclose does not identify the source of the information if the information was provided to us in confidence.

9 - Correction

• Where personal information which is materially inaccurate is broadcast or otherwise disclosed, we will take reasonable steps to rectify the disclosure.

10 - Codes of Practice

• The Commercial Radio Codes of Practice registered by the Australian Broadcasting Authority also impose some relevant privacy obligations on us. We are committed to complying with these Codes of Practice.

11 - Privacy Officer

• If you have any concerns, complaints or questions, please contact our Grant Broadcasters Privacy Officer via web@grantbroadcasters.com.au.