Introduction:
For those who may have a specific question relating to privacy on any individual event we conduct, this first section of the page is for you. We’ll explain the most common issues in plain English to help everyone meet on the same page (figuratively). Of course the main thing we’re all about is keeping the young people who come celebrate with us safe, to the extent that’s possible and within realistically achievable “real-world” scenarios. We’re nationally renowned for going far further than anyone else in our quest for perfect safety. That includes…
Having stated all of that, we recognise (and so should any reasonable person) that no system is perfect because it involves humans, and humans are a little fuzzy around the edges when it comes to perception, interpretation and behaviour. That’s why it’s always going to be a work in progress, and that comes with help from you, in terms of giving us your thoughts & ideas, and seeing how things unfold in the process so we can always apply new found knowledge and experience towards that desired, albeit elusive, perfection.
So let’s address the common questions about what’s OK and what’s NOT OK with how we handle privacy in the most common scenarios with people attending our events.
Privacy of Personal Data:
The Privacy Act, like all acts and regulations, speaks to the “Spirit” and “Intent” of the idea behind the document. The act specifies that information such as phone numbers, email addresses, residential addresses, biometric data such as facial images, fingerprints, DNA etc are considered to be “sensitive” information, only when combined with a person’s name (a name alone not being enough to warrant application of “privacy” by itself) is something that may constitute a “breach” of privacy because when those 2 or more pieces of data combine to actually single out one individual person to a large number of unrelated strangers, it’s possible that some bad actor with nefarious intent might seek to do that specific person harm.
There’s also some weight that must be given to the fact that our events are not open to the public. They’re by invitation only and eligible guests who buy tickets have to be vetted by the organisers as people permitted within the social circle of the group being catered for. What we’re basically talking about here is that the vast majority of people who attend our events are school friends from the same year group and under those circumstances, they’re all well known to each other already. In such an environment there’s no reasonable expectation of privacy with regard to people’s names so as long as we’re not making those names completely public, and we’re also not sharing any additional specific data about any of the individuals with anyone outside the known group, then there’s no threat to privacy.
One of the most common things we come across relates to who comes to our events and what kind of data we have to collect about them. Under state law, we have to keep an accurate register of the details of every person who attends our events. That’s because they’re classed under Licensing Regulations as “Minor’s Functions” and that comes with a plethora of state-imposed regulations. Those records have to be kept and made available to government authorities upon request. For that reason, we have to collect people’s names, contact details, email addresses and so on. We can’t accept that someone is a guest of another ticket-holder and just be satisfied with “Partner” or “Plus 1” because the law demands that we dig further to gather the proper information on everyone, regardless of their age.
Another issue we sometimes see relates to people’s specific dietary restrictions. This can be a life-threatening issue when it comes to catering and we take very seriously the responsibility of gathering data, checking it, and re-checking it through a variety of protocols to ensure to the very best of our abilities that nobody who is allergic or intolerant to any food would have their health (or life) threatened by the very food our venues serve. This is also an area of some “human fuzziness” because we’re all different. Dietary intolerances and allergies are a spectrum like many other things so we have to be as vigilant as possible. Of course we can only deliver the quality of care based on the quality of data we receive. We always contact every attendee and corresponding parent anytime we see dietary issues. In days gone by we might see 2 or 3 Vegetarians among a guest list of 300 teenagers, however today the averages of the full range of dietary needs are closer to 1/3 of the whole guest list. Therefore it’s neither reasonable, nor efficient, to transmit relevant data about what’s safe for certain people to eat to each guest one at a time. The only practical way may be to create a one page list of dietary warnings and send it to groups of people together, as they share much of the same information and need the same answers. Again, this is within the confines of the school year group and parents and nothing more than their names are listed alongside the food warnings. This is not considered personal, sensitive data, when seen via this context, and therefore doesn’t qualify as a breach of privacy, considering that it’s deemed to be essential for safety.
What we NEVER do is share ANY data publicly, or with anyone or any organisation outside our immediate business operations. Within the scope of what we need to provide to our business partners (like venue chefs for catering etc) there’s no data shared beyond that which is necessary to conduct whatever the service requires, such as name and seating allocation in the case of dietary needs, as an example.
The next most common question relates to pictures, images, video, audio etc that may be recorded at the event. Yes, we do share that in public forums such as web sites or social media platforms, however, we get permission first. If you buy a ticket to one of our events, it’s very clearly stated that any images we gather at the event will be used in this way, and that condition has to be ticked and agreed before the ticket purchase can be finalised. One additional fact that some people may not be aware of is that anyone over the age of 16 has complete autonomy to decide if they want to share their likeness publicly or not, without the need to gain any kind of approval from a parent or guardian. For that reason we also have signs really clearly placed on areas such as photo booths and media walls that alert people to the fact that these images may be made public. They have the right to refuse to have their photo taken at the event, and we’ll respect that if and when it happens.
As with all legislative acts and regulation, the “Spirit”, “Essence” or “Intent” of the act or regulation is worded in such a way that people may be required to “take all reasonable steps to ensure” that something happens or doesn’t happen in one way or another. That’s because the wisdom of government also recognises the “fuzzy” side of applying “absolutes” to humans. We already go far further than “reasonable” when it comes to the protection of our guests. It’s at the core of who we are and what we do.
Below this line is the comprehensive and standard statement of policy with regard to general information and general uses.
Working Together
This privacy policy applies to Prom Night Events and its Related Entities’ operations in Australia. This policy explains how Prom Night Events handles personal information and complies with the requirements of the Australian Privacy Act 1988 (Cth) (“Privacy Act”). If you have any further questions in relation to this policy, please contact our Privacy Officer via the “Connect” page.
This policy relates to Prom Night Events collection and handling of personal information that is covered by the Privacy Act. It is not intended to cover categories of personal information that are not covered by the Privacy Act.
Collection of personal information
Prom Night Events collects personal information from clients, customers, employees, contractors and other individuals. We collect this information when it is necessary for business purposes.
The main types of personal information Prom Night Events collects relate to the contact details and organisational roles of our clients, suppliers and other business contacts. Typically, this information includes names, addresses, telephone numbers, e-mail addresses and job titles. In the course of providing professional services to our clients, we may collect more detailed personal information (for instance formal details if we are approached to perform assessment and quotation services).
We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face-to-face meetings, email messages, telephone conversations or by third parties. If you contact us, we may keep a record of that contact.
Use of personal information
The main purposes in collecting personal information about individuals are:
We may use personal information about individuals to market our services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us by writing to The Head Office, Prom Night Events, PO Box 610 Randwick NSW 2031 Australia, or by contacting us through the “Connect” page. Please allow up to 28 days for your request to be processed.
Alternatively, if we have contacted you by email, you may use the unsubscribe function in that email to notify us that you do not want to receive further marketing information from us by email.
If we collect or use personal information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the Privacy Act.
Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by Prom Night Events. For information about our practices relating to employee information, please contact us directly via the “Connect” page.
Disclosure of personal information
Prom Night Events does not routinely disclose personal information to other organisations unless:
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell or trade personal information to third parties, or allow such third parties to use that personal information unless you have permitted us to do so, including by the purchase of tickets and agreeing to the Terms & Conditions agreed during that process, products or services provided by us, or unless permitted by provisions within the Act.
Prom Night Events uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of Prom Night Events will sometimes have access to personal information held by Prom Night Events and may collect or use it from or on behalf of Prom Night Events. This may include, but is not limited to, independent contractors and consultants, travel service providers, mail houses, off-site security storage providers, website hosts, electronic database managers, or event managers, credit managers and debt collecting agencies. We require our service providers to adhere to our privacy guidelines and not to keep this information or use it for any unauthorised purposes.
Transfer of information outside Australia
As part of a global network of Prom Night Events firms, Prom Night Events exchanges information, including personal information, between our offices. As a result, we may transfer personal information outside Australia to countries whose privacy laws do not provide the same level of protection as Australia’s. Prom Night Events may also use overseas facilities to process or back-up its information. As a result, we may transfer your personal information to our overseas facilities for these purposes.
However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.
Privacy on Our Web Sites
This policy also applies to any personal information we collect via our websites, or the web sites of our suppliers or other organisations with whom we do business that are capable of collecting personal information and transmitting it to us. In addition to personal information you provide to us directly (such as where you make a request or complete a registration form), Prom Night Events may also collect personal information from you via its websites.
Cookies may be used on some areas of our websites. A cookie is a small software application which allows a website to recognise a previous user and to observe how a user navigates within a website. Cookies are now used as a standard by many websites. Prom Night Events uses cookies to improve the navigational experience of visitors to our websites and to make them easier to use.
If you are concerned about cookies, most browsers now recognise when a cookie is offered and permit you to opt out of receiving it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your Internet service provider. In most cases, you can refuse a cookie and still fully navigate Prom Night Events websites.
In order to properly manage our websites, we may log certain statistics about the users of the sites, for example the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites present the best possible navigational experience for visitors.
Whenever a registered member (such as a Prom Night Events alumnus) logs in to our websites, they will be identified by their user name and password. The information we collect about members’ use of our websites is used purely for measuring site performance and in assisting to resolve any technical difficulties.
Because Prom Night Events wants your website experience to be as informative and resourceful as possible, we provide a number of links to websites operated by third parties. Prom Night Events is not responsible for the privacy practices or policies of those sites. We encourage you to review each website’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non-Prom Night Events website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.
Security of Personal Information
Depending on the purpose for which we have collected personal information (for example, registration for a Prom Night Events event or a request for particular information or material), we may store some of the information electronically in Prom Night Events customer relationship management system. Some or all of this personal information may be available to partners and authorised staff of Prom Night Events for use in accordance with this policy.
Prom Night Events will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard-copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by Prom Night Events.
Prom Night Events aims to achieve industry best practice in the security of personal information that it holds. It is our policy to destroy personal information once there is no longer a legal or business need for us to retain it.
Access to Information
We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another person’s privacy).
If at any time you want to know what personal information we hold about you, you may contact us by writing to: The National Head Office, Prom Night Events, PO Box 610 Randwick NSW 2031 Australia, or contacting us via the “Connect” page.
Corrections and Concerns
If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us and we will try to resolve those concerns.
If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, auditing or internal risk management reasons).
If Prom Night Events becomes aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our privacy policy, or you have a problem or complaint, please contact our Privacy Officer via the “Connect” Page.
Effect of Policy
Prom Night Events operates in a dynamic business environment. Over time, aspects of our business may change as we respond to changing market conditions. This may require our policies to reviewed and revised. Prom Night Events reserves the right to change its privacy policy at any time and notify you by posting an updated version of the policy on this website.
The amended policy will apply between us whether or not we have given you specific notice of any change.
This policy was last updated in August 2023.
Further information
For information about this policy please contact the privacy officer via our “Connect” page.