Privacy Policy
1. Purpose
BBM Ltd is committed to the wellbeing and legacy of our youth migrants and scholars. As part of that commitment, we respect your privacy and work within the privacy laws.
Our Privacy Policy outlines:
the collection, use and disclosure of personal information
governance and accountability
integrity and collection of personal information
the rights of individuals to access their personal information
handling of complaints in relation to privacy
2. Scope
This policy applies to all personal information collected, received, used and held by BBM Ltd.
This policy does not cover personal information we collect or hold about current and former employees.
3. Policy Statement
BBM Ltd is committed to upholding your rights to privacy and this policy has been developed in accordance with the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth) (Privacy Act).
We will uphold our obligation to this policy by:
Ensuring our commitment to confidentiality is resolute
Regularly updating our practices to accommodate changes in legislation, policy and technology
By providing your personal and sensitive information to us directly or indirectly you accept the terms of this Privacy Policy.
4. What personal information do we collect?
Personal information is information, or an opinion about, an identified individual or an individual who is reasonably identifiable. Personal information includes a broad range of information, or an opinion, that could identify a person.
Examples of personal information include; an individual’s name, address, phone number, date of birth, email address, details of Global Footprints Scholarships received (including the category and date), documents you forward to us, details of your date and method of arrival through the Big Brother Movement migration program, business name and type of business. Personal information includes sensitive information.
Sensitive information includes information or an opinion about your; racial or ethnic origin; political opinions or associations; religious or philosophical beliefs; trade union membership or associations; sexual orientation or practices; criminal record; health or genetic information and some aspects of biometric information.
Health information is also sensitive information and includes information about an individuals’ illness, disability or injury. Health information about an individual is governed by the Health Records and Information Privacy Act 2002 (NSW) (the HRIP Act).
When collecting Health Information from you, as this is sensitive information, BBM Ltd will obtain your consent for such collection and explain how this information will be used. Generally, sensitive information has a higher level of protection than personal information.
BBM Ltd will always ask for your consent to collect sensitive information and only collect the information if it is reasonable and necessary. Depending on what the method of contact is and the nature of the contact, BBM Ltd could collect information through contact forms on our website, email, phone, written correspondence and personal conversations.
We may collect sensitive information about you:
when you consent (verbally or in writing)
when the collection is authorised or required by law
the collection is otherwise allowed under the Privacy Act.
5. Why do we collect information?
We collect personal information about you when it is reasonably necessary for, or directly related to, one or more of our functions or activities. The information we collect may be used to:
5.1. Collect historical data:
develop and retain historical records of people who were involved in the Big Brother Movement migration program or the BBM Ltd Global Footprints Scholarship program
provide you and other visitors with information regarding the Big Brother Movement migration program and BBM Ltd
maintain a register and searchable online database of past Big Brother Movement Little Brothers and Global Footprints Scholarship recipients.
5.2. Deliver services:
We may collect your personal information when it is reasonable and necessary for delivering services.
For example, we may collect your personal information to:
confirm your identity
communicate with you, including by SMS or email
provide advice about available support options
verify data provided in relation to claims
manage complaints and feedback
support National Redress Scheme matters
manage and respond to requests for information
administer and provide online services, including various forms of media such as email, Facebook, newsletter, e-newsletter
perform administrative and oversight functions in our data documentation system
tailor our website content to make your experience more valuable
respond to your enquiries or provide you and/or our youth migrants and scholars with assistance as requested
process application forms you have completed either in hardcopy or in electronic form or on our website
provide you with newsletters relevant to the legacy of BBM Ltd (you may unsubscribe from receiving such information at any time);
comply with scholarships intake procedures etc.
6. How do we store personal information?
We take reasonable steps to protect your personal information against misuse, interference, loss, unauthorised access, modification, or disclosure, as follows:
Hardcopy records, where available, are stored securely
Historical information will be sent to the NSW State Archives but we do hold an electronic copy of Personal Record Cards and Shipping Cards
All electronic information described above is stored on restricted access databases
Only access personal information on a need-to-know basis and by authorised employees
Monitor system access which can only be accessed by password
Regularly update and audit our storage and data security systems
Contact IT support immediately if there is any suspicious activity on the BBM or Global Footprints websites, or in relation to any software application, emails or mobile app in use, and follow directions provided.
7. How do we collect information?
We collect your personal information through a variety of channels. This includes correspondence, email, face to face contact, social media or phone contact.
We use social networking services such as Facebook. When you talk with us through social media, we may collect your personal information to communicate with you and the public. The social networking platform may also handle your personal information for its own purposes.
These services have their own privacy policies. You can access the privacy policies for these services on their websites.
8. Use of disclosure of personal information
BBM Ltd can only use or disclose personal information for a purpose for which it was collected and related to our functions.
For the purposes referred to in this Privacy Policy, we may also disclose your personal information to third parties in order to assist us in providing services including:
contractors and organisations who manage some of the services we offer. In such circumstances steps are taken to ensure that the contactors comply with the APPs when they handle Personal Information and are only authorised to use Personal Information in order to deliver the services or perform the functions required by BBM Ltd. Examples include the work our historian undertakes to share our Youth Migrant stories and the partner organisation our scholars work with and our mentors
other regulatory bodies such as WorkCover and SafeWork
professional advisors, including our accountants, auditors and lawyers
It may be necessary for us to disclose your personal information to our database provider, Salesforce and other software platforms such as Microsoft 365, Zoom and Canva.
Excluding as set out above, BBM Ltd will not disclose an individual’s personal information to a third party unless one of the following applies:
the individual has consented to a secondary use or disclosure
the individual would reasonably expect BBM Ltd to use that information for another purpose related to the purpose for which it was collected (or in the case of sensitive information – directly related to the purpose for which it was collected)
the disclosure is required or authorised by, or under, Australian law or a court/tribunal order
it will prevent or lessen a serious threat to somebody’s life, health or safety or to the public health or safety
it is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities
it is reasonably necessary to establish, exercise or defend a claim at law
it is reasonably necessary for a confidential dispute resolution process
it is reasonably necessary for the enforcement of a law conducted by an enforcement body, in this case BBM Ltd will make a written note of the disclosure
a permitted general situation exists, as defined in s16A of the Privacy Amendment (Enhancing Personal Privacy) Act 2012
a permitted health situation exists as outlined by s16B of the Privacy Amendment (Enhancing Personal Privacy) Act 2012.
Under no circumstances will we disclose your personal information to any person for marketing purposes.
9. Review and Access
Upon your request, we will provide you with details of the information we collect about you. You will have the opportunity to correct, update or modify this information.
Access to information is limited to employees or volunteers who require it to deliver services.
As allowed or required by applicable laws, we may modify our Privacy Policy at any time. We encourage you to check this Privacy Policy often to review any changes. We may, but are not required to, provide you with notice of material changes to this Privacy Policy. If we do send such a notice, we will use the contact information we have on file for you.
We may create links allowing you to access third party websites. BBM Ltd is not responsible for the content that appears on those sites and does not necessarily endorse those sites. Please consult those sites’ individual privacy policies in order to determine how they treat information.
The BBM records from 1925 – 1982 have been transferred to the State Library who have ownership of the historical documents. If you want to access private, historical information the State Library will send the request to BBM for access decision. For further guidance please see attachment A “Privacy guidelines for accessing the Big Brother Movements archive at the State Library”.
10. Handling of complaints in relation to privacy
BBM Ltd are committed to respecting your privacy and we will make every effort to comply with this policy.
If you believe your privacy has been breached, or you would like to discuss any aspects of this policy please contact the CEO, on 02 9233 4005 or via email ceo@bbm.asn.au.
You will need to provide us with details regarding your complaint together with any supporting evidence and we will investigate your complaint and determine the steps that we will undertake to resolve your complaint.
We will contact you if we require any additional information from you and will notify you in writing of the outcome of our investigation.
If you are not satisfied with our determination, at any time you can contact the Australian Privacy Commissioner (see Privacy complaints — OAIC).
11. Contacting our Privacy Officer
Our Privacy Officer is the CEO Ph 02 9233 4005 Email ceo@bbm.asn.au
12. Relevant legislation/legislative instruments
Privacy Act 1988 (Cth)
Health Records and Information Privacy Act 2002 (NSW) Related Documents/Resources
Data breach response procedure
Office of the Australian Information Commissioner (OAIC)
Policy Information
Version: 2
Approved:
Amended:
Reviewed: 11/2023
Review frequency: 12 months
Responsible position: CEO
For more information, you can download a full copy of our Privacy Policy.