· the kinds of personal information that we collect and hold;
· how we collect and hold that personal information;
· the purposes for which we collect, hold, use and disclose that personal information; who we usually disclose that personal information to;
· the third parties we are likely to disclose that personal information to;
· how you may access the personal information we hold about you, and seek to correct or remove that information; and
· how you may complain to us about a breach of your privacy and how we will deal with such a complaint.
2 WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
The personal information we collect about you may include but may not be limited to:
· personal details (including your name, age, year of birth, gender, social media profile), credit card details, contact details (including phone number, email address, postal address, post code), image (including photo and video recording), Internet Protocol (IP) address and other information reasonably necessary for our activities and functions;
· if you are attending one of our programs or events, the name and contact details of an emergency contact for you and any dietary requirements or restrictions you may have; and
· if you are an employee, contractor or representative of one of our partners, sponsors, collaborators or stakeholders or an educational institution that we deal with, your name and your organisation’s name, your address, contact details and other information necessary to manage and administer our relationship with you and your organisation.
Our cookies may track what kind of visitors we have to our website, their age, gender and interests; what kind of device they are using, the city they are in, how long they spend on the site, what website they linked to us from and what pages they are looking at.
This helps us to understand who our visitors are, what is working on the website and what needs to be improved.
We may also use this information in the future to target any paid marketing campaign.
The data we collect via tracking cookies does not identify individual users.
There are several ways to disable tracking cookies in your browser.
3 HOW DO WE COLLECT PERSONAL INFORMATION?
Wentworth Group collects personal information from you in a number of different ways. We may collect personal information directly from you, or in the course of our dealings with you (or your parent or guardian), for example when you:
· provide personal information to us;
· donate money to us;
· register for any of our initiatives, programs or events;
· apply for a position of employment or to volunteer with us;
· access and use any of our websites, services or social media profiles (including via cookies, see 2.1);
· contact or correspond with us, for example to ask for information, email us, or submit other online forms; and / or;
We may also collect personal information about you from another Wentworth Group entity, initiative or program, from publicly available sources of information, or in some cases, from third-parties including but may not be limited to:
· when you participate in one of our initiatives, programs, events or challenges: from your school or other organisation we are collaborating with to present the initiative, program, event or challenge;
· when you access or use one of our websites or social media profiles from a third party (such as Facebook or Google) when you use express login or post things on our profile pages;
· if you are an employee or contractor of any of our partners, sponsors, collaborators or supporters (including if you attend any of our programs in that capacity): from your employer or another representative of your organisation;
· when you participate in research or evaluation discussions, interviews or focus groups: from a professional research body we have engaged to conduct or assist with those activities; and
· when you apply to work or volunteer with us: from a recruitment consultant, your previous employer(s) and other persons who may be able to provide information to us about your suitability for the position. This may include obtaining information from third-party service providers which provide national police records checks.
Wentworth Group is a registered charity. All personal information collected by us will help us to support our objectives in some way. The purposes for which we collect your information may include:
· to verify your identity (including your age);
· to contact you (including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner)
· to process donations you have made to us;
· to enable you to access and use our websites and social media profiles;
· to help us develop, operate, protect, improve and optimise our services, websites and social media profiles (including to analyse trends and improve functionality) and to obtain feedback;
· to enable you to participate in our initiatives, programs, events or challenges (including competitions and promotions run by us);
· to help us conduct research about challenges facing Australians and evaluate our initiatives, programs, events or challenges (including to obtain your feedback and suggestions on these programs);
· to keep you informed about the work we do (including to let you know about upcoming initiatives, programs, events and challenges);
· to comply with our legal obligations, resolve complaints and enforce our agreements with third parties; and
· to consider your application to work or volunteer with us and to administer your employment, contracting or volunteering arrangement with us.
5 WHAT HAPPENS IF WE ARE UNABLE TO COLLECT PERSONAL INFORMATION?
If we are not able to collect personal information about you:
· we may not be able to provide you with services and assistance to the extent that they require us to collect, use or disclose personal information;
· you may not be able to register to use our websites or participate in our programs;
· we may not be able to keep you informed about the work we do or let you know about upcoming research or programs that you may want to participate in;
· we may be unable to tailor the content of our websites to your preferences and your experience of our websites and social medial profiles may not be as enjoyable or useful.
6 USE AND DISCLOSURE
Wentworth Group may use or disclose your personal information for the purpose for which it was collected. We may also use and disclose your personal information for a secondary purpose that is related to a purpose for which we collected it where you would reasonably expect us to use or disclose your personal information for that secondary purpose.
Other instances when we may use and disclose your personal information include:
· where you have expressly or impliedly consented to the use or disclosure;
· to process donations and payments to Wentworth Group;
· to our advisors and insurers;
· to third parties to improve our services and obtain feedback; and
· where the use or disclosure is authorised or required by or under an Australian law or court/tribunal order.
We may also disclose your personal information to third parties, including:
· to other Wentworth Group entities, initiatives or programs;
· with our advisors and consultants;
· to our employees, volunteers, contractors or third-party service providers we use in conducting our activities, operating our websites, fulfilling requests by you or to otherwise deliver our programs (this may include but may not be limited to web hosting providers, IT system administrators, mailing houses, couriers, network administrators, insurance brokers, banks, data storage services, email filtering, virus scanning and other technology services providers);
· to our partners, sponsors, collaborators, supporters and stakeholders who help us to provide our initiatives.
· if you are under 18, to your parents, guardian, teacher or school for the purposes of you participating in one of our programs;
· to police, fire, medical and other emergency personnel in the event of an emergency involving you;
7 ARE WE LIKELY TO DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
Some of the third parties to whom we disclose your personal information may be located outside Australia. For example, we may disclose your personal information to external national or overseas facilities in the course of operating our websites, social media profiles and in conducting our activities, initiatives, programs, events and challenges, conducting information and data processing, back up or for the purposes of obtaining other services from third parties. We use a number of cloud service providers. These may include Google, Mailchimp, Stripe and Dropbox. The countries in which these third parties are located will depend on the circumstances.
8 INFORMATION ABOUT US
10 STORAGE, SECURITY, AND NOTIFIABLE DATA BREACHES SCHEME
Wentworth Group Limited will take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, Wentworth Group excludes all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security. We may store your information in electronic or hard copy form. These may include Australian or overseas based cloud servers or the servers of third parties within or outside of Australia. When we no longer need your information, we will take reasonable steps to destroy or de-identify it.
In the event of any loss or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will:
· investigate; and
· notify you and the Australian Information Commissioner as soon as practicable,
in accordance with the Privacy Act 1988 (Cth).
12 LINKS TO OTHER WEBSITES
13 THE INFORMATION WE KEEP ABOUT YOU
You may request access to, correction of or removal of your personal information held by us. If you wish to access, correct, update or remove any personal information we may hold about you, please contact us as set out below. We will act on your request within a reasonable time. In most cases, we will be able to give you access to or correct or remove your personal information. If we are unable to do so, we will notify you of the reasons why.
14 HOW TO MAKE A COMPLAINT
However, if you remain dissatisfied, you can also make a formal complaint with the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
· Office of the Australian Information Commissioner (OAIC) Complaints must be made in writing.
· Phone: 1300 363 992
· Mail: Director of Compliance, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001, Australia
· Website: www.oaic.gov.au
16 HOW TO CONTACT US
You can contact us: – by email: firstname.lastname@example.org – via the web: wentworthgroup.org
Dated:19 July 2019