Last Updated: 12 March 2014
RESPECTING YOUR PRIVACY
We run a diverse business with functions and activities that include managing and maintaining an operational airport, security and emergency planning and response, managing and developing ground transport and parking, retail and commercial property management and development, construction of infrastructure and project management.
We carry out those activities in a manner that is respectful of your personal information and manage it in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Principles).
TYPES OF PERSONAL INFORMATION WE COLLECT
We will only ask for personal information that is relevant to our business relationship or other interaction with you.
When you enter Brisbane Airport or use our facilities (e.g. the roads, car parks, retail facilities and terminals including check-in and passing through screening points) we may collect:
- Contact and identification details where relevant e.g. name, postal or email address, telephone numbers, date of birth, driver’s licence details, passport number or Aviation Security Identity Card (ASIC) number;
- Transactional information e.g. credit card details;
- Information from our Electronic Monitoring Systems (as described below);
- A voice recording from calls to our reception numbers and certain operational or security telephone lines and in some search rooms; and
- Travel related information e.g. flight details, destination, visa status and baggage message system status.
Your image, licence plate number, location and movements are collected by the electronic monitoring tools and systems that we have in place at Brisbane Airport.
Our Electronic Monitoring Systems include:
- Closed Circuit Television (CCTV);
- Automatic number plate recognition technology (ANPR);
- Access control systems and electronic keys; and
- Other observational tools and systems such as portable cameras and the baggage message system.
When you participate in our retail offerings, marketing activities, promotions and surveys we may ask you to provide additional information such as:
- Other contact and identification details e.g. social media handles, your photograph;
- Your preferences and opinions about products and services;
- The frequency of your use of certain types of products or services;
- Your method, purpose, frequency of travel and preferred destinations; and
- Your income demographics.
We also collect information (often known as metadata) in relation to our communications with you e.g. the time communications are accessed, the links visited and the device used to access the communication.
Security and operations
Where necessary for matters related to security or airfield operations we collect additional information for security purposes and/or to comply with our legal obligations:
- Place of birth, country of citizenship, gender;
- Your photograph; and
- Residential address history, criminal history, details of any pending prosecutions and the outcome of security assessments, criminal history checks and immigration checks.
Feedback and complaints
We may collect sensitive information (e.g.health information, information about your ethnicity or political opinions) in feedback, complaints, claims or correspondence but only if you give it to us or with your consent.
When you interact with us via our websites, social media channels, mobile applications or wireless internet (Online Platforms), we use Google Analytics to gather statistical information about your use of those Online Platforms e.g. which resources on a website are the most visited. The information we collect includes IP addresses, MAC IDs, geographical location, pages visited and computer information such as the operating system and browser being used. We use this statistical information to help us analyse the usage and performance of our products and to improve our offerings. We do not attempt to re-identify individuals.
REMAINING ANONYMOUS OR USING A PSEUDONYM
We need to know who we are dealing with for most matters, like applying for security access or booking car parking online. However, where it is lawful and practical to do so we will allow you to deal with us anonymously or using a pseudonym, such as when you make a general enquiry or for some marketing activities.
Directly from you
Unless it is unreasonable or impracticable to do so, we will try to collect personal information directly from you when you deal with us. We may do this when you fill out a form with us, make a phone enquiry, enter a promotion run by us, make an application for a security clearance, respond to marketing, use or access any of our products or services or access our websites.
We also collect some information indirectly from you through our Electronic Monitoring Systems as a result of your use of Brisbane Airport’s facilities.
Collection from other sources
We may also collect your personal information from other organisations we deal with when it is necessary to do so (e.g. when issuing access cards, investigating an incident, investigating fraud, responding to a claim, conducting a survey) including:
- Law enforcement agencies e.g. the Australian Federal Police, Queensland Police, Customs;
- Government agencies e.g. the Civil Aviation Safety Authority (CASA), WorkCover;
- Our tenants and licensees e.g. airlines, car park operators, retail outlets;
- Our professional advisers e.g. our insurers, lawyers;
- Our contractors e.g. contracted security, car parking and cleaning companies; and
- Any other organisations conducting activities on our behalf e.g. marketing consultants, project related companies.
CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL INFORMATION
If you do not provide us with your personal information, it may not be possible for us to provide you with the products, services or information you request such as booking car parking or entering a promotion. In some cases it might mean you cannot access certain parts of Brisbane Airport for work or pass through a screening point to fly.
TAKING CARE OF YOUR PERSONAL INFORMATION
Storage and security
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the measures we use include:
- Implementing document storage, information classification and incident notification and management security policies and procedures;
- Applying access restrictions to our systems including network segregation for certain information;
- Protecting electronic security systems by use of firewalls, encryption technology and intrusion detection systems;
- Requiring our employees and contractors to adhere to confidentiality requirements; and
- Controlling physical access to our buildings and instigating further controls to those parts of buildings where sensitive information is held.
We store personal information physically and electronically and sometimes with contracted data storage providers e.g. providing backup storage. If we use a contracted service provider, we use contractual arrangements to ensure that provider takes appropriate measures to protect the personal information.
What happens when we no longer need your information?
We will keep your information for as long as we require it for our business purposes or for as long as any applicable law requires us to keep it. When we no longer require your information or when any period imposed by law expires, we will ensure that your personal information is destroyed in a secure way or that it is de-identified.
WHAT WE DO WITH PERSONAL INFORMATION WE DID NOT ASK FOR
Sometimes people give us personal information we did not seek out (referred to as ‘unsolicited information’) e.g. more information than we asked for. If that occurs, we will check whether that personal information is reasonably necessary for our functions or activities. If it is, then we will handle the unsolicited information in the same way that we handle other personal information we collect from you. Otherwise, we will destroy or de-identify it.
HOW WE USE YOUR PERSONAL INFORMATION
The main reasons
Generally, the reasons we use personal information include to:
- Develop, improve, manage and administer our products and services;
- Keep in contact with you at your request e.g. deal with any feedback or complaints, return any lost property;
- Maintain any business relationship we have with you;
- Maintaining records that are required for insurance, tax, other claims or legal purposes e.g. claims management, enforcement of contracts, requirements of law;
Allow us to run our business and perform administrative and operational tasks like:
- training staff;
- risk management;
- systems development and testing, including our websites and other online channels;
- undertaking planning, research and statistical analysis; and
- Carry out any purpose for which you have given consent.
We may use the personal information collected by our Electronic Monitoring Systems (e.g. CCTV, ANPR, access systems) for Safety, Operations, Emergency and Security purposes including:
- Monitoring and maintaining airport security;
- Monitoring and managing airport operations such as traffic flow, passenger and aircraft facilitation and access to our facilities and infrastructure e.g. roads, car parks, terminals and retail facilities;
- Detecting, deterring and responding to criminal or unlawful activity or suspicious, inappropriate or unauthorised activity on Brisbane Airport;
- Monitoring and managing the safety and security of airport operations including in relation to airport users and staff and conducting investigations; and
- Monitoring emergencies and incidents to manage response, recovery and investigation activities.
When you participate in our marketing activities such as our promotions, subscribe to e-newsletters or purchase a product or service like car parking, you consent to us using your personal information (like your name, email address and preferences) for further marketing.
We will use your information to let you know about services, special offers, promotions, opportunities, products or benefits that are being offered by us, any of our strategic alliance partners, customer airlines, tenants or associated airlines, in which you may be interested. We may also wish to obtain your opinion about those offerings or information about how you use them via research or surveys. We promote our business and Brisbane Airport and undertake analysis to provide you with targeted products or services.
We may conduct these marketing activities via direct mail, email, telephone, SMS or any other electronic means. We may also market our products or services to you through third party channels (such as social networking sites) or based on your use of our products or programs.
We will always let you know that you can opt out from receiving our marketing offers e.g. you will be given the option to unsubscribe from e-newsletters and other marketing or promotional material sent by us. Where practical you will be able to choose to opt out of particular marketing or all of it. We will process your ‘opt out’ request as soon as we can after we receive it.
We will not sell your personal information to any other organisation.
Security and operations
The security and operational purposes we might use your personal information for include:
- Issuing and maintaining airport authorities, licenses, passes, and permits e.g. Authority to Drive Airside, ASICs, other access cards;
- Maintaining records that are required for security and aviation purposes e.g. audits conducted by CASA or the Office of Transport Security;
- Recording, investigating and analysing any emergencies and actual or potential incidents or occurrences that occur on Brisbane Airport; and
- Maintaining and managing airport operations, safety and security e.g. passenger identification, screening of passengers, reviewing access to secure areas.
We only disclose your personal information to other persons or organisations for the purpose for which we collected it or with your consent.
On that basis we disclose your personal information to those involved in providing, managing or administering the product or service we provide to you, such as:
- Organisations that participate with us in payments systems including merchants, payment organisations, tolling organisations;
- Other organisations involved in our normal business practices, including our agents and contractors e.g. security, car parking and cleaning contractors; those involved in debt collecting;
- Organisations with whom we have alliances or arrangements for the purposes of promoting our respective products or services e.g. airlines, charities;
- Organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
- Our tenants and licensees e.g. airlines, transport operators; and
- Our accountants, auditors, insurers, lawyers and other external advisers.
We also provide information to various organisations where authorised under the Privacy Principles such as:
- Enforcement bodies e.g. the Australian Federal Police, Queensland Police, Customs; and
- Entities or regulatory bodies conducting audits, investigations or managing claims or disputes e.g. CASA, WorkCover; the law courts.
Disclosures to overseas recipients
Although we run our business in Australia sometimes we may disclose personal information to entities located overseas e.g. to a contracted service provider providing technology services. Some of our contracted service providers are located in Singapore.
You have a right to request access to your personal information and/or to request that it be corrected. To protect your personal information we will always confirm your identity before giving access or making any change.
There are circumstances when we might not give you access to the personal information we hold about you, e.g. if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety. If that occurs, we will tell you why in writing. If you have concerns you can let us know by contacting us.
There is generally no cost for accessing the personal information we hold about you, unless the request is complex, resource intensive or we incur third party costs in providing you with access. If there is a charge, it will be reasonable and we will let you know what it is going to be so that you can agree to it before we proceed.
Contact us with your complaint
If you have a complaint about how we have dealt with your personal information, we would like to hear from you.
All formal privacy complaints must be in writing however you are welcome to contact us by phone in the first instance if you prefer:
- Call +61 7 3406 3000 and request to speak with our Privacy Officer.
To put a privacy complaint in writing please contact us by:
- Emailing our Privacy Officer at email at email@example.com; or
- Submitting an enquiry form and selecting “Send us your Feedback” via our website at www.bne.com.au/help.
We will acknowledge receipt of your written complaint within 3 working days after we receive it. We need a reasonable time to conduct enquiries and so we will provide you with a formal response within 30 days of receiving your written privacy complaint. If the circumstances of your complaint are complex and we need additional time to provide you with a formal response, we will contact you to let you know. Our Privacy Officer will provide you with our formal response.
Need more help?
If you still feel your issue has not been resolved then you can raise your concern with the Office of the Australian Privacy Commissioner:
- Online: www.oaic.gov.au/privacy/making-a-privacy-complaint
- Phone: 1300 363 992 or (if outside Australia) +61 2 9284 9749
- Email: firstname.lastname@example.org
- Fax: +61 2 9284 9666
- Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601.