Brink Productions Limited Privacy Policy

1.  PURPOSE

This Privacy Policy explains how Brink Productions Limited (“Brink“, “we“, “us“) collects, uses, stores, and discloses personal information.

We are committed to handling personal information responsibly and transparently, in a way that respects the privacy of our artists, audiences, donors, collaborators, contractors and other stakeholders.

This Policy has been adopted as good governance practice. It reflects Brink’s values of integrity, transparency and respect, and our obligations to the people and communities we work with.

2.  SCOPE

This Policy applies to all personal information collected and held by Brink in the course of its activities, including:

• artist engagement, commissioning and contracting,
• audience development and ticketing,
• marketing and communications,
• donations, philanthropy and fundraising,
• auspiced projects and partnerships,
• website and digital interactions,
• grant funding applications, acquittals and reporting, and
• employment and personnel matters, including information relating to the Executive Director, Artistic Director, all staff (whether permanent, fixed-term, casual, contract or volunteer), Board Directors, and Members of the company

For the purposes of this Policy, “personal information” has the meaning given by the Privacy Act 1988 (Cth).

3. LEGAL FRAMEWORK

Brink is a company limited by guarantee and a registered charity incorporated in South Australia. As a not-for-profit organisation with annual turnover less than $3M, Brink is generally exempt from the Privacy Act 1988 (Cth).

However, Brink chooses to apply the principles of the Australian Privacy Principles (APPs) as good governance practice, in recognition of our responsibilities to the artists, communities, and stakeholders we work with.

Brink may also be required to comply with privacy obligations where it:

1. • handles information on behalf of a government agency,
   • enters into funding agreements (including for example with CreateSA or Creative Australia) that require compliance with privacy laws, or
   • operates as an auspice body for independent artists or companies.

When Brink sends commercial electronic messages, the Spam Act 2003 (Cth) applies regardless of turnover.

4. WHAT PERSONAL INFORMATION WE COLLECT

Brink may collect personal information including:

1. • name, email address, phone number and postal address,
   • artist and contractor details, including biographies, resumes, photographs, banking and payment details,
   • employment and personnel records, including engagement terms, payroll and superannuation details, emergency contact information, and performance-related correspondence, for all staff, the Executive Director and Artistic Director, Members, and Board Directors,
   • ticket purchase and event attendance history,
   • donation, membership and payment information,
   • information about grant applications, acquittals and funding reporting, and
   • communications, feedback and survey responses

Brink does not generally collect sensitive information (such as health information or religious beliefs). Where it does (for example, in connection with access requirements or Child Safe Policy obligations) it will only be with consent or where reasonably necessary.

5. HOW WE COLLECT PERSONAL INFORMATION

Brink collects personal information through:

1. • ticketing platforms and event booking systems,

• artist and contractor engagement processes,
• website forms, email subscriptions and digital channels,
• direct communication including email, phone, or in person,
• donor, membership and philanthropy processes,
• auspiced project arrangements, and
• grant applications and funding body reporting processes.

Where reasonable and practicable, Brink collects personal information directly from the individual concerned.

6. WHY WE COLLECT PERSONAL INFORMATION

Brink collects and uses personal information to:

• • manage artist and contractor engagements, including payment and compliance,
  • produce, present and tour theatre works,
  • communicate with audiences, artists and stakeholders,
  • manage auspiced projects on behalf of independent artists and companies,
  • provide marketing, promotional and event information,
  • manage donations, memberships and fundraising activities,
  • meet legal, regulatory and funding obligations, and
  • plan, evaluate and report on Brink’s programming and activities.

7. EMPLOYMENT AND PERSONNEL RECORDS

Brink collects and holds personal information in connection with its employment and governance relationships, including in relation to the Executive Director, Artistic Director, all staff (whether permanent, fixed-term, casual or otherwise), Board Directors, and Members of the Company.

This information may include:

1. • employment contracts, letters of offer, and engagement correspondence,
   • payroll, superannuation, and banking details,
   • emergency contact information,
   • performance management records and related correspondence,
   • board director declarations, conflict of interest disclosures, and governance correspondence, and
   • Members register information held in accordance with Brink’s Constitution and the Corporations Act 2001 (Cth).

This information is:

• collected for the purposes of the employment or governance relationship and Brink’s legal obligations,
• stored securely, with access limited to those with a genuine operational need, and
• not disclosed beyond what is necessary for payroll, compliance, governance, or legal purposes.

Brink recognises that employment and personnel records are sensitive and handles them with appropriate discretion. Access to performance-related or disciplinary records is restricted to the Chair, relevant Board Directors, and any engaged professional advisers, as required.

8. ARTIST AND CONTRACTOR INFORMATION

Brink handles significant personal information in relation to the artists and contractors it engages, including biographical information, financial and banking details, and professional correspondence.

This information is:

1. • used solely for the purposes of the engagement and payment;
   • stored securely, with access limited to those with a genuine operational need; and
   • not shared beyond payroll, payment and acquittal purposes without consent.

Banking and financial details provided by artists and contractors are stored securely and accessed only by those required to process payments.

9. AUSPICED PROJECTS

Where Brink acts as an auspice body for independent artists or companies, it may collect and handle personal information on behalf of those parties, including in connection with grant applications, acquittals and project administration.

Brink will ensure that auspiced project participants are made aware of how their personal information is managed, consistent with this Policy and any applicable auspice agreement. Auspice arrangements should be supported by a written agreement that addresses privacy and data handling obligations.

10. CHILDREN AND YOUNG PEOPLE

Brink is committed to the safety and privacy of children and young people. Where Brink’s activities involve children, personal information including images and recordings will be handled with additional care in accordance with Brink’s Child Safe Policy.

11. PHOTOGRAPHY, FILMING AND RECORDING

Brink may photograph, film or record individuals in connection with its productions, events, rehearsals and other activities. This may include:

1. • theatrical performances and public events,
   • rehearsal and development processes,
   • audience and event atmosphere, or
   • promotional, documentation and archival purposes.

Where individuals are identifiable, Brink will:

1. • take reasonable steps to notify participants that photography or recording may occur, and
   • use recordings only for legitimate artistic, promotional or archival purposes.

Where practical, individuals may request not to be photographed or recorded. Where images or recordings include identifiable children or young people, the requirements of Brink’s Child Safe Policy apply.

12. MARKETING AND COMMUNICATIONS

Brink may send communications about its productions, events, programs and opportunities. Individuals can opt out at any time by using the unsubscribe link in emails or by contacting Brink directly. Brink does not sell or provide personal information to third parties for their own marketing purposes.

13. DISCLOSURE OF PERSONAL INFORMATION

Brink may disclose personal information to:

1. • government or regulatory bodies where required by law,
   • funding bodies (including CreateSA and Creative Australia) where required for reporting and acquittal,
   • ticketing and event service providers,
   • IT and digital service providers (such as email platforms and cloud storage),
   • contractors, professional advisers and accountants, and
   • co-producers, touring partners and presenting venues, where relevant to a production.

Brink only shares personal information where reasonably necessary and takes steps to ensure that third-party providers handle data appropriately.

14. DATA STORAGE AND SECURITY

Brink takes reasonable steps to protect personal information from misuse, loss, unauthorised access, modification or disclosure. These steps include:

1. • use of reputable third-party systems for ticketing, donations and cloud storage,
   • password protection and access controls,
   • limiting access to personal information to those who need it, and
   • secure storage of digital and physical records.

Brink’s systems are proportionate to the scale of the organisation. Brink remains vigilant and will update its practices as its operations evolve.

15. DATA RETENTION

Brink retains personal information only for as long as is necessary for operational purposes, and to meet legal or financial record-keeping requirements. When personal information is no longer required, it is securely deleted or de-identified where practicable.

16. OVERSEAS DISCLOSURE

Some of Brink’s service providers (such as digital platforms and cloud storage services) may store data overseas. Where this occurs, Brink takes reasonable steps to ensure that appropriate privacy protections are in place.

17. ACCESS AND CORRECTION

Individuals may request access to personal information Brink holds about them, and request corrections if that information is inaccurate or out of date. Requests can be made by contacting Brink directly (see Contact and Complaints below). Brink will respond within a reasonable timeframe.

18. CONTACT AND COMPLAINTS

For privacy enquiries or complaints, please contact:

Brink Productions Limited

Email: info@brinkproductions.com

We will respond promptly and work to resolve any concerns. If a person is not satisfied with the response, they may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

19. POLICY AVAILABILITY

This Policy is available on Brink’s website and upon request.

20.  REVIEW

This Policy will be reviewed by the Board annually, or earlier if required by changes in legislation, best practice or organisational needs.

21.  ADOPTION

This Policy V1.0 was adopted by resolution of the Board of Brink Productions Limited on 27 April 2026.

Brink Productions Limited | ABN 80 086 516 289 | Privacy Policy