Privacy Policy

1. Introduction

Your privacy and our obligations to you around our collection and use of your personal information are important to Working Dog Pty Ltd (ACN 076 766 615), Working Dog OD&M Pty Ltd (ACN 678 811 160) and their related entities (together “we”, “us”, “our”, “Working Dog”). We are committed to respecting your rights and to our compliance with the Privacy Act.

This policy explains the purposes for which Working Dog collects, uses and discloses personal information, the types of personal information that we may collect, who information may be collected from and the processes that we have in place to enable individuals to access or update their personal information, or to lodge a complaint.

2. Key definitions

In this document:

"Australian Privacy Principles" or "APPs" means the Australian Privacy Principles set out in the Privacy Act;

"personal information" has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;

"Privacy Act" means the Privacy Act 1988 (Cth); and

"sensitive information" has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person's racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.

3. Why do we collect, use, hold and disclose personal information?

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.

We may use or disclose your personal information:

for the purposes for which we collected it (and related purposes which would be reasonably expected by you);

for other purposes to which you have consented; and

as otherwise authorised or required by law.

The main purposes for which Working Dog typically collects, uses, holds and discloses personal information include:

if you are making a purchase with us:
- to offer and provide you with our goods and services;
- to manage and administer those goods and services, including account keeping procedures;
- to communicate with you, including (but not limited to) emailing you tax invoices, dispatch and tracking information, returns and exchange authorisations;
- to facilitate your participation in competitions, promotions or offers;
- to verify your identity;
- to contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our goods and services;
- to operate, monitor, develop and improve our websites, mobile applications (apps) and our goods and services;
- to optimise and customise the user experience (including content and advertising) for users of the websites, apps and services;
- to address any issues or complaints that we or you have regarding your relationship with us; and
- as otherwise required to manage our business or comply with law.

if you are involved in a production with us:
- to plan, develop, produce, distribute and promote Working Dog's media, television or film productions and to carry out our contractual obligations to financiers, broadcasters, distributors and licensees;
- for use relating to, Working Dog media, television or film productions, including credits and promotional material of any productions;
- to facilitate your involvement with Working Dog productions, including participating in development, production or marketing;
- to facilitate your involvement as an audience member of Working Dog productions, including the administration and record keeping of such events and invitations for future involvement in similar events;
- for direct marketing communications of Working Dog productions;
- to facilitate your entry and participation in any competitions or trade promotions;
- for tax purposes, including for production incentives such as the Producer Offset, and for other production incentives including grants;
- to protect the security, health and safety of our premises, facilities, personnel and visitors;
- to comply with our legal and regulatory obligations;

in connection with the employment and engagement of people in our businesses and productions, including for compliance with workplace health and safety policies; and

as otherwise required to manage our business, to comply with laws and regulations, or in connection with insurances relating to our businesses and productions.

Please note that in parts of Australia, including Victoria, from time to time people in the film industry may be required to provide satisfactory evidence of COVID-19 vaccination status (or medical exemptions) before entering the workplace where they work outside their home, whether they are employees, volunteers or contractors.

4. How do we collect personal information?

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.

We may collect personal information directly from consumers in a variety of ways, including:

when you complete an order form to make such a purchase from us;
when you subscribe to receive information from us;
when you make an inquiry or place an order in relation to goods or services through our websites or apps;
when you register as a user of our websites or apps;
from correspondence (whether in writing or electronically) or when you contact us via telephone, e-mail, social media platforms or other means; and
while conducting customer satisfaction and market research surveys.

We may collect personal information about individuals involved in our productions in a variety of ways, including:

when you submit any project or material or are involved in a project or material being submitted to us (please note that Working Dog does not accept any unsolicited scripts);
when you apply for a job or a role on our productions, including actors, writers, directors, producers, technicians or suppliers of other services and facilities related to the productions;
when you apply to participate in one of our productions in any other way, including, but not limited to, as a studio audience member for test screenings, studio recordings of a program or live event or as an on-screen participant;
when you are otherwise associated with the development, financing, production or marketing of one of our productions;
from correspondence (whether in writing or electronically) or when you contact us via telephone, e-mail, social media platforms or other means;
when you provide feedback about our productions or our other activities;
when you buy our productions and/or related material, such as merchandise or the right to view our production or a special offer related to such production;
when you enter competitions that we run;
if you attend any of our premises, we may record certain contact details so that we can comply with applicable laws, and we may also record your image and/or voice if we have surveillance systems operating at those premises or in the course of filming; and
in administering and performing any contracts with service providers related to the production.

Where it is reasonably practical to do so, we will collect your personal information directly from you. However, in certain cases we may also collect your personal information from publicly available sources and third parties, such as:

our suppliers, contractors, clients, business partners, advertisers and promotional partners;
participants in or contributors to our productions;
parents and guardians (in the case of minors) and schools (in the case of minors involved in our productions);
your employers;
recruitment agencies, referees and past employers (in the case of applicants for a job or role);
individuals, companies and agencies relating to pre-employment checks including Working With Children checks and police checks;
casting and talent agents and managers;
contractors that supply services to our productions; and
funding bodies, financiers, broadcasters and licensees associated with the production.

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

You do have the right to contact us and deal with us anonymously or by using a pseudonym, however, in some such situations it may be impractical for us to deal with you or provide you with the assistance you request.

5. What personal information do we collect?

The types of personal information we collect about you depends upon the reason the information is collected. Typically, the types of personal information we collect about you may include (but are not limited to) your name, address, telephone number, email address, work or other contact details, gender, and date of birth.

If you enter into a contract with us, request or receive goods or services from us or have any other commercial dealings with us, we may collect your signature, credit card and/or banking details, and billing information.

If we need to confirm your identity, we may collect a copy of appropriate identification.

If you call us via telephone, we may monitor and in some cases record such telephone conversations for staff training, quality assurance and record-keeping purposes.

If you attend a premises we operate or manage, we may:

collect certain contact details that you provide to us (which may be via digital check-in apps), including the date and time of attendance, including for safety and security reasons and so that we can comply with applicable laws (such as public health directives). If we collect such information to comply with a particular law, we will only use and disclose it in accordance with applicable laws; and
record your image and/or voice through the use of Closed-Circuit Television (CCTV) systems for the purposes of managing security of the premises and health and safety of occupants and the public generally.

If you are an employee or an individual contractor in connection with a Working Dog production, please refer to 'Employees and individual contractors' at section 13 below as this outlines some additional personal information that we may be collect about you.

We will only collect personal information about you if that information is reasonably necessary for our functions or activities.

We may collect sensitive information about you with your consent or otherwise in accordance with the Privacy Act. This may include information about a health condition, injury or disability you have. If you do provide sensitive information to us for any reason, you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.

6. Holding and storage of personal information

We seek to keep your personal information safe and secure, whether it be as hardcopy records, in electronic format on our intranet system, in cloud storage, and in some cases, records on third party servers, some of which may be located overseas. Information kept at our offices is protected by a security system for our premises. We also use a range of security procedures and tools to protect data stored electronically. We make all our staff aware of the need for protecting personal information and adherence to this Policy and the Australian Privacy Principles.

We will destroy or de-identify personal information once it is no longer required by us for a valid purpose or required to be kept by law. We may need to retain records containing personal information to comply with record keeping obligations and for other legitimate business purposes (such as quality assurance).

7. Who do we disclose personal information to?

Working Dog will not disclose your personal information to third parties except (i) as set out in this Policy; or (ii) for the particular purpose for which the personal information was collected; or (iii) with your consent; or (iv) where disclosure is authorised, permitted, compelled or required by law.

We may disclose your personal information to the following types of third parties:

service providers, suppliers, contractors and organisations that provide us with technical and support services or who manage some of our business functions;
our related entities (who may use and disclose the information in the same manner we can);
our accountants, insurers, lawyers, auditors and other professional advisers;
any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors; and
debt collection agencies.

If we disclose information to a third party who is handling it on our behalf, we generally require that the third party protect your information to the same extent that we do.

If you are involved in a Working Dog production as an employee or independent contractor, we may also disclose your personal information to the following third parties:

third party contractors engaged on a Working Dog production, including (but not limited to) casting agents, travel agents and payroll;
our business partners, including television networks, investors, financiers;
our insurers; including completion bond companies;
our sales agents, distributors, broadcasters and other third party as reasonably necessary for us to carry out our functions or activities;
businesses we engage to manage live audience participation or other production or marketing services;
your name and position may also be included on the credits of the production and in associated marketing materials;
government funding departments and agencies may require aggregated details relating to a production, including your name, nationality, residence and contract details, including any payments and other benefits; and
the Media Entertainment and Arts Alliance (MEAA), including for the purpose of calculating and paying residuals to on-camera talent.

Some of the third parties to whom we disclose personal information may be located outside Australia. The countries in which such third-party recipients are located depend on the circumstances. For example, in the ordinary course of business, we commonly disclose personal information in the credits of a Working Dog production, which may be viewed overseas.

From time to time we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

Whenever we transfer your personal information outside of Australia, we will do so in accordance with the requirements of applicable privacy and data protection laws. We may disclose your personal information to overseas recipient without your consent where permitted by the Privacy Act (and, in such circumstances, we will comply with the applicable requirements of the Privacy Act in doing so).

8. Direct marketing and advertising

Like most businesses, marketing and advertising is important to our continued success. We therefore like to stay in touch with customers and let them know about new offers and opportunities.

We may provide you with information and advertisements about products, services and promotions either from us, or from third parties which may be of interest to you, where you have asked us to (or have otherwise consented to us doing so) or where otherwise permitted by law. We conduct direct marketing through various channels, including by e-mail and social media.

If you would like us to stop sending you direct marketing communications, you can request this by contacting our Privacy Officer (see contact details below at section 17). Please note that there are certain types of communications that you may not be able to opt-out from, such as communications that we are required or permitted by law to send you.

We also use e-mail analytics to track and measure the success of our e-mail newsletters, fundraising e-mails and other e-mail campaigns. We use technologies (such as tracking pixels) to collect information such as: which of our emails you have opened, which links you have clicked, which email client you are using, whether you opened our e-mail on a computer or mobile device, and the geolocation of your IP address. We use this data to analyse and improve the performance of our e-mail campaigns.

9. Social media

We use social media platforms such as Facebook, Instagram, X (formerly Twitter), TikTok, Google (YouTube) and LinkedIn to communicate with the public about our services and businesses. We may collect the personal information that you choose to share with us through these platforms, including photos, videos and comments and posts.

These social media platforms have their own privacy policies, and may handle your personal information for their own purposes. You can access the privacy policies for these social media platforms on their websites.

If you choose to use these social media platforms to communicate with us, please be mindful that certain pages within these platforms may be publicly available. We encourage you to use the privacy settings available on each platform.

10. Internet advertising

We may also use your personal information in connection with online targeted advertising services that help our ads to reach you (and other people who may be interested in our products and services) on websites, apps and social media platforms across the Internet. These online targeted advertising services are operated by third party vendors. The advertising service providers that we currently use include Facebook, Instagram, X (formerly Twitter), TikTok, Google (YouTube) and LinkedIn.

Some of these services work by using non-identifying data about your behaviour and demographics that has been collected through cookies and other tracking technologies (such as pixels and device identifiers) when you use the Internet, including when you move between different websites and apps and use different devices. For example, third-party vendors, such as Google, may use cookies and/or device identifiers to serve ads based on your past visits to our websites. Your browser or device may provide you with the option to disable or opt-out of some of these cookies and other tracking technologies (such as device identifiers).

Other services require us to use limited amounts of your personal information. For example, we may include your information in a customer list that we provide to selected online advertising service providers (such as Facebook, Instagram, X (formerly Twitter), TikTok, Google (YouTube) and LinkedIn) so that we can conduct audience-based advertising. This allows us to show our ads to you (if you also use those platforms) and to other users of those platforms who share similar characteristics with you. The customer list is usually hashed (to improve security and confidentiality) before it’s processed by the service provider to target and serve our ads.

Our online advertising service providers also help us by measuring the effectiveness of our ad campaigns and providing us with analytics data that we use to inform and optimise our ad campaigns. The analytics data we receive is generally aggregated and non-identifying.

When we use any advertising service that requires us to use or disclose your personal information, we will only do so if we are permitted to do so by applicable privacy laws. You can notify us at any time if you would like us to stop using your personal information for these targeted advertising purposes. Our contact details are set out in section 17 of this Privacy Policy.

You can also:

opt-out of certain online targeted advertising networks directly by visiting the Digital Advertising Alliance’s opt-out portal (http://optout.aboutads.info/) and the Network Advertising Initiative’s opt-out page (https://thenai.org/opt-out/);
use Facebook’s settings you to manage the types of advertising you are shown (https://accountscenter.facebook.com/ad_preferences/);
use Instagram's settings to manage your ad preferences (https://help.instagram.com/2885653514995517/?helpref=uf_share);
use X's settings to manage your ad preferences (https://x.com/settings/ads_preferences);
use TikTok's setting to manage your ad preferences (https://www.tiktok.com/setting);
use Google’s settings to manage your ad preferences and opt-out of Google’s use of cookies and device identifiers (http://www.google.com/settings/ads); and
use LinkedIn's settings to manage your ad preferences and control data collected about you (https://www.linkedin.com/mypreferences/d/categories/ads).

11. Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregated information on how visitors are experiencing our website. This information will help to better adapt our website to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s instructions.

We may use third-party vendors to show our ads on other websites and serve these ads based on a user’s prior visits to our websites and other internet activity. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our websites.

12. Links to third-party websites

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third-party websites are responsible for informing you about their own privacy practices and procedures.

13. Employees and individual contractors

If you are an employee or individual contractor to us or apply for a role with us (including on-camera roles), we collect personal information as part of your application and during the course of your employment or engagement, either from you directly or, in some cases, from third parties such as recruitment agencies, referees, government bodies (e.g. working with children checks or police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications).

The information we collect may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records, and logs of the employee’s usage of our equipment (e.g. phones, computers and vehicles).

We may also obtain additional information such as your citizenship/residency details, appearance and physical characteristics (including photographs) and sensitive information such as details of disabilities, allergies and health issues that may impact your role, or which arise while on our premises or in the performance of your duties, so we can accommodate and otherwise assist you with any related requirements and manage any incidents.

In the case of a current or former employee, personal information may be held, used or disclosed under the Privacy Act in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.

14. Your right to access to personal information and to request corrections

You may request to access or correct personal information that we hold about you by writing to our Privacy Officer (contact details are set out at section 17).

On the rare occasion where we refuse to give you access (which we will only do in accordance with applicable laws), we will provide you with a written notice stating our reasons for refusing access.

You may request corrections to personal information we hold about you if it is inaccurate or out of date. We are not obliged to correct any of your personal information if we do not agree that it requires correction. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing. We will seek to respond to your written request within a reasonable timeframe. Working Dog may charge a fee, as appropriate, in certain circumstances in order to facilitate access to your personal information. No fee is charged to correct personal information.

15. Changes to this Policy

Working Dog reserves the right to change the terms of this Privacy Policy from time to time without notice to you. An up-to-date copy of our Privacy Policy will be available on our websites.

16. If you have a complaint

We encourage you to contact us if you have any questions, concerns or complaints about this Privacy Policy or how we handle your personal information, including if you believe we have breached the APPs, by contacting our Privacy Officer (contact details are set out at section 17).

We take all complaints seriously and will be considered by the Privacy Officer who will endeavour to respond to any complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If the complaint is not satisfactorily resolved, you may contact the Office of the Australian Information Commissioner at the following details:

Office of the Australian Information Commissioner

GPO Box 5218, Sydney NSW 2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

17. Privacy Officer’s Contact Details

Our Privacy Officer's contact details are as follows:

Privacy Officer: Dan Atkins

Telephone Number: +61 3 9826 4344

Postal Address: PO Box 488 South Yarra, Victoria 3141 Australia

Email address: privacy@workingdog.com

The last update to this document was 4 September 2024.