Sonic Consulting Group Pty Ltd ABN 13 616 837 542 t/a Sonic Lawyers (Sonic Lawyers, we, us or our) respect the privacy of the individuals we deal with. In our handling of personally identifiable information about individuals, we comply with the requirements of the Australian Privacy Principles (APPs) in the Australian Privacy Act 1988 (Privacy Act).

This Privacy Policy (Policy) describes the types of personal information we collect and explains how we hold, use and disclose that information. The Policy also explains how you can gain access to the personal information we hold about you.

1. What kinds of personal information does Sonic Lawyers collect and hold?

We only collect personal information that we need for one or more of our business activities. Most of the personal information Sonic Lawyers collects relates to individuals in their business or professional capacities, so we only collect this information as an incident of a business relationship with an individual or the organisation they work for. Some examples of this sort of information include:

• contact details of Sonic Lawyers’ clients;
• details of writers (and their songs) and artists (and their recordings) represented by Sonic Lawyers, which we may use for rights administrative purposes; and
• contact details for the people we deal with at other organisations with which Sonic Lawyers has business relationships, such as industry or trade associations, media organisations, government authorities and suppliers of goods and services.

Occasionally, we may collect personal information about individuals in their private capacities, for example where an individual:

• subscribes to receive Sonic Lawyers publications;
• makes an inquiry (e.g by email or telephone);
• makes a complaint;
• makes a comment via our Facebook or Twitter pages, or through other social media and online channels – this is discussed further below (Section 6, Online privacy issues); or
• applies for a job with Sonic Lawyers.

Sonic Lawyers usually does not need to collect any sensitive information (such as information about racial or ethnic origin, political activities or affiliations, memberships of unions or other associations, religion, sexual preferences or practices, criminal record or medical history). If we do collect or hold such information, we will only do so strictly in accordance with the APPs in the Privacy Act.

2. How does Sonic Lawyers collect personal information?

Sonic Lawyers generally collects personal information from the individual. The most common ways in which Sonic Lawyers collects personal information are:

• from contact forms submitted to Sonic Lawyers by individuals via the Sonic Lawyers website;
• when individuals receiving goods or services from Sonic Lawyers make payment for those goods or services;
• when Sonic Lawyers requires bank account details from creditors who receive payment by direct deposit;
• from job applications when individuals apply for jobs at Sonic Lawyers;
• from contributions made via social media (including Twitter and Facebook); or
• from telephone, email, written and in-person enquiries directed to Sonic Lawyers.

However, sometimes Sonic Lawyers needs to collect personal information from a third party, for example, we may collect personal information from the Australasian Mechanical Copyright Owners Society to determine whether persons or organisations may require a licence from rightsholders represented by Sonic Lawyers for the reproduction of those rightsholders’ copyrights.

If we collect personal information about you from a third party and it is unclear whether you have consented to the disclosure of that personal information to us, we will take reasonable steps to contact you and ensure that you are aware of the circumstances surrounding the collection and the purposes for which we have collected your personal information.

3. Why does Sonic Lawyers collect, hold or use personal information?

Generally, we only use personal information for the primary purpose for which we have collected it, or for closely related business purposes. For example, Sonic Lawyers may collect personal information to fulfil its services to rightsholder clients, for the purpose of:

• issuing and administering synchronisation licences;
• managing client’s society memberships;
• managing business relationships;
• reviewing and assessing job applications;
• responding to enquiries and complaints;
• receiving and making various payments; and
• providing information to you regarding events and music industry matters.

In most cases, the primary purpose for which we need personal information will be apparent from the context in which we collect it. If this is not the case, we will take steps to specify our purpose(s) at, or as soon as possible after, the time of collection. We may also use personal information to send you information about our activities, or about goods or services that we believe may be relevant or useful to you. If at any time you do not wish to receive such information, please let us know by contacting our Privacy Officer (see section 9 below).

In other respects, we will only use personal information with your consent, or if we are required or permitted by law to do so (eg. under the APPs in the Privacy Act).

4. To whom does Sonic Lawyers usually disclose personal information?

Sonic Lawyers generally only discloses personal information to other persons or organisations for the primary purpose for which we have collected it, or with your consent (which may be explicit, or may be implied from your conduct or from the circumstances in which the information is collected). We may also disclose personal information if we are required or permitted by law to do so (eg. under the APPs in the Privacy Act).

The following paragraphs describe some of the organisations, or types of organisations, to which Sonic Lawyers usually discloses personal information. Wherever personal information is disclosed outside of Sonic Lawyers, we take reasonable steps to ensure that the recipient:

• handles that information in accordance with the APPs in the Privacy Act;
• only uses the information for the specific purpose(s) for which it is provided to them;
• does not disclose the information to any person or organisation except in accordance with directions from Sonic Lawyers; and
• stores the information securely, and either destroys it or returns it to Sonic Lawyers when it is no longer needed.

Occasionally, Sonic Lawyers has to rely on third party contractors to provide services or perform functions on our behalf, and this may involve a disclosure of personal information by Sonic Lawyers to that third party. While these vary from time to time, they may include:

• organisations who provide communication services on our behalf;
• advisers who have been engaged by Sonic Lawyers to provide Sonic Lawyers with legal, administrative, financial or other services;
• debt collection agencies; and
• information technology service providers.

Sonic Lawyers may also disclose information to overseas collecting societies, copyright owners and agents that collect and distribute payments and that have an agreement with Sonic Lawyers. These overseas third parties are located in various countries, for example USA and UK. It may be necessary for Sonic Lawyers to provide personal information to these entities in order to facilitate the licensing activities or the administration and distribution of any royalties which may ultimately be payable to clients. Sonic Lawyers takes steps to ensure that these third parties agree to protect the privacy and security of all personal information, and use it only for the purpose for which it is disclosed.

5. Storage, security and destruction of personal information

Sonic Lawyers takes reasonable steps to ensure that the personal information we hold is protected from risks such as loss or unauthorised access, destruction, use, modification or disclosure.

Your personal information is stored on a password protected database and hard copy files which are secured from unauthorised access. We only allow authorised personnel to access personal information, and it is a condition of employment with Sonic Lawyers that our employees maintain the confidentiality of all information to which they have access.

We only retain personal information for as long as it is needed by us, or for as long as we are legally required to retain the information. When we are no longer required to retain personal information, we ensure that it is disposed of or destroyed in a secure fashion in accordance with our obligations under the APPs in the Privacy Act.

6. Online privacy issues

Sonic Lawyers does not collect personal information about individuals who browse our website (e.g through the use of cookies or tracking technologies that identify individuals). However, this Policy applies to any personal information you choose to provide to us online, for example if you fill out a form on our website or send us an email. Information submitted via our website form transit via the server but are not retained on the server after transit to your inbox.

Social Media
This Policy also applies to the personal information that individuals provide to us via our LinkedIn, Facebook and Twitter pages, or through other social media and online channels. We will generally use and disclose that information only for the purposes of participating in and managing an online conversation (including by responding to individuals’ comments), or otherwise as permitted under this Policy. We will not use or disclose information collected through these channels for marketing purposes unless we make that clear at the time of collecting the information (for example, in the context of a competition or other specific online activity). If an individual decides to communicate or otherwise publish personal information about themselves via our website, LinkedIn, Facebook and Twitter pages or through other social media and online channels, then the individual acknowledges that Sonic Lawyers cannot control the use of such personal information by other users of our website or other online channels.

Links to Third Party Websites
For your convenience, our website and other online channels (including our LinkedIn, Facebook and Twitter pages) may contain links to online services operated by third parties. You should be aware that when you access a third party service, we are not responsible for the privacy practices and policies of that third party. We suggest that you review the privacy policy for each website and online service that you visit, especially if you intend to disclose any personal information.

7. How do I access and correct my personal information?

Under the Privacy Act, you generally have a right to seek access to the personal information that Sonic Lawyers holds about you, although there are some circumstances in which we may be required or permitted by law to withhold access to some or all of that information. You also have the right to ask us to correct personal information about you that you believe is inaccurate, incomplete or out of date.

If you wish to exercise these rights, we ask that you make a request in writing to our Privacy Officer (see section 9 below). You will need to provide some form of identification (e.g a copy of your driver’s licence or passport) so we can verify that you are the individual to whom the personal information relates. You should also include details of how we can contact you in case we need to discuss your request.

8. How can I make a complaint if I believe that Sonic Lawyers has breached the APPs?

If you would like to make a complaint in relation to this Policy or the manner in which we handle your personal information, please contact our Privacy Officer (contact details are set out in section 9). We will endeavour to respond to complaints within 30 days of their receipt.

If you are dissatisfied with our response, you may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au).

9. How do I contact Sonic Lawyers?

If you have any questions or comments about this Policy, or if you wish to access or correct your personal information or make a complaint about our handling of that information, please contact our Privacy Officer by one of the following methods:

By telephone (during business hours): +61 2 9927 0906
By email: privacy@soniclawyers.com
By post: The Privacy Officer
Sonic Lawyers
GPO Box 4899
Sydney NSW 2001
Australia

This Policy was last updated on 3 April 2017.