Adelaide Airport Ltd ABN 78 075 176 653 and its related companies (AAL, we, us or our) are committed to protecting the privacy of your personal information. “Personal information” is information or an opinion about you as an identified (or reasonably identifiable) individual. “Sensitive information” is a sub-set of personal information that includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health information and biometric information.
AAL is required to comply with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).
What personal information is collected?
The kinds of personal information we collect and hold about you, and our use of that information, depends on our dealings with you. Generally, this personal information may include (but is not limited to) your name, address, telephone number, email address, details of the products or services you have enquired about and your payment and delivery details.
We may also collect additional information from you, for example:
- if you attend the AAL terminal or AAL premises, we may collect surveillance footage of you via Closed Circuit Television Surveillance (CCTV);
- if you use our valet, online booking or other parking services, we may collect your driver’s licence details, licence plate registration number, credit card and flight details;
- in limited circumstances we may collect sensitive information about you, for example if you become ill or are injured in or en route to the AAL terminal, if you borrow a wheelchair during your time in the AAL terminal or require other special needs assistance;
- if you or an entity you are associated with are enquiring about leasing retail premises at the AAL terminal, we may collect a range of personal information for the purpose of assessing the tenancy application, including your business experience, qualifications, referees and credit-related personal information;
- if you or an entity you are associated with are providing services to AAL or its tenants (for example, as a contractor), we may collect a range of personal information for the purpose of assessing the potential engagement, carrying out induction and work, health and safety training;
- if you register your interest using the AAL website for receiving communications and media alerts;
- if you use any of our online platforms, then we may collect information about how you use those platforms (including your location, pages visited, MAC addresses, IP addresses, operating system and browser being used);
- if you are applying for a position with AAL then we will collect personal information about you related to our recruitment processes (for example, your resume, qualifications, skills, work history, residency status and sensitive information from health records, Work Cover claims and pre-engagement health and medical assessments);
- if you visit the AAL premises, use our car-parking facilities or use our wi-fi facilities, we may collect information about the types of goods and services you use (including the amount spent on such products or services), how often you visit AAL or use our products or services, the purpose and frequency of your travel plans and in some circumstances this may extend to monitoring your behaviour and movement whilst on AAL premises (through use of our CCTV facilities and other data you provide to us when using electronic devices); and
- information to comply with our obligations under or the requirements of legislation, including but not limited to the Airports Act 1996 (Cth), the Civil Aviation Act 1988, Civil Aviation Regulations 1988 and the Competition and Consumer Act 2010 (Cth), or as otherwise authorised by law.
Remaining anonymous or using a psudonym
You will have the right to remain anonymous or adopt a pseudonym when dealing with us. However, if some or all of the above personal information is not collected by us we may not be able to provide goods, services or information to you, or be able to provide them to the same standard as if we had the information requested.
How is personal information collected?
We generally collect your personal information directly from you unless it is impracticable or unreasonable to do so. For example, this may include in forms that you provide to us, through other forms of communication such as email, over the phone and in person and through CCTV.
We may also collect personal information about you from third parties or other sources (for example, from public records, law enforcement agencies, government agencies (such as CASA or Department of Immigration), our contractors, tenants and licensees).
Generally, if we are unable to collect the personal information we require we may not be able to provide you with the products and services you seek. If the information provided is incorrect or incomplete, this may also prevent, limit or otherwise affect our ability to provide products or services to you.
Collection of information about third parties
Purposes for which personal information is collected, held, used and disclosed
We will use and disclose your personal information for the purposes for which we collected it, and for other related purposes that you would reasonably expect. We may also use and disclose your personal information with your consent and as otherwise required or permitted by law.
Generally, we collect your personal information to respond to your enquiries, provide you with products and services, obtain your feedback on your customer experience, conduct direct marketing and other promotional activities and for our general business operations. Our general business operations include a range of activities, such as maintenance of our business records, compliance with our legal and insurance obligations, statistical analysis and planning purposes, investigating and responding to incidents or occurrences on AAL’s premises, managing and defending claims involving AAL, undertaking targeted online advertising, data and audience matching, analytics and research.
Financial details, including credit card details and related personal information gathered whilst in the process of conducting an online purchase from our website will be used for credit card authorisation purposes and (in the case of our car park booking service) to allow you to enter and exit the car park. This information will be shared with our payment processing provider in connection with your purchase.
We use the personal information collected by our CCTV surveillance, number plate recognition technology and other monitoring and observational tools, for security, operational, management and car parking related purposes (for example, to manage car park access and charges, traffic flow and access, monitoring emergency situations, conducting investigations, detecting and responding to unlawful activities or inappropriate conduct).
We may use or disclose information collected from CCTV surveillance, number plate recognition technology and other monitoring and observational tools in accordance with this policy and as otherwise required or authorised by law. For more details, please refer to our Surveillance Policy which is available at the following link: Surveillance Policy
By providing us with your personal information, you consent to us using your personal information for these purposes. You can opt-out of marketing and promotional communications at any time by contacting our Privacy Officer via the details shown below.
We may exchange your personal information within the AAL corporate group. We may disclose your personal information to our agents and contractors for the purposes set out above, and for the purposes of those parties providing services to us or performing business services or functions on our behalf (for example, our technology service providers and marketing service providers). We may also, in the event of a sale, transfer or assignment of the whole or part of AAL’s business and/or assets and facilities to a third party, disclose your personal information to that third party for their use in operating the business or assets to be transferred.
We will only collect ‘sensitive information’ with your consent or where otherwise permitted or required by law. We will assume that you have consented to us collecting all information which is provided to us by you for use in accordance with this policy, including any ‘sensitive information’, unless we are told otherwise at the time it is provided to us.
We will only use and/or disclose ‘sensitive information’ for the purpose for which we collected it, for any directly related purpose that you would reasonably expect, for other purposes with your consent or as otherwise permitted or required by law.
Storage and security of your personal information
We may hold your personal information in electronic formats or in hard copy. Generally, we will take reasonable steps to securely store your personal information to ensure it is protected from unauthorised access, modification and disclosure, and from other types of misuse, interference and loss. Generally, we will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes. Your personal information may also be retained in our IT system back-up records.
The transfer of data over the internet is inherently insecure. We cannot guarantee the security, during transmission, of any personal information provided to us via our website. Please bear this in mind when transmitting important information by this means to us.
Overseas disclosure of your personal information
Some of our third party service providers who process personal information on our behalf use data storage services outside of Australia, including in the following countries:
- the EU; and
- the US.
Access and correction of your personal information
You may lodge a request to correct personal information about you that we hold if you believe that your personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading. Such corrections will be made except where we refuse such requests in accordance with the APPs or as otherwise permitted by law. To make a corrections request, please contact our Privacy Officer via the contact details below.
You may request that we provide you with access to the personal information we hold about you. Generally, we will provide you with access, except in limited circumstances where the law permits us to deny access. Any such requests must be made in writing and directed to our Privacy Officer via the details shown below. Please note that no fee will be incurred for requesting access, and if your request for access is accepted we will inform you of the fee (if any) that will be payable for providing access if you proceed with your request.
You may ask us to inform you of the source of any personal information about you that we have collected from a third party. We will provide this at no cost, except in limited circumstances where the APPs or other laws permit us to withhold this information.
Making a complaint
You may lodge a complaint with us in relation to our handling of your personal information. To do so please contact our Privacy Officer via the contact details below. We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response. We will endeavour to respond as quickly as possible, which generally will be within 14 days of receiving your complaint.
If you would like further information about the way we manage your personal information, or if you have a privacy-related complaint, please contact our Privacy Officer at:
Attention: Privacy Officer
Adelaide Airport Limited
1 James Schofield Drive
South Australia 5950
Telephone: +61 8 8308 9211
Fax: +61 8 8308 9311
Email: [email protected]
Office of the Australian Information Commissioner
More information about your rights and our obligations in connection with your personal information are available from the Office of the Australian Information Commissioner at www.oaic.gov.au.