PRIVACY POLICY
Aim of this policy
Community Spirit Foundation (ACN 125 810 568) (CSF) has obligations concerning the use, disclosure and storage of personal information. These obligations are set out in the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act), and other applicable State and Territory privacy laws.
In this Privacy Policy, references to "we", "us" and "our" are to CSF.
You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy. We will review and may update this Privacy Policy from time to time. The current version will always be available on this website.
We encourage supporters and visitors to our website to check this page regularly for any updates.
What is personal information?
“Personal information” is information or an opinion about an identified individual or reasonably identifiable individual, whether true or not or whether recorded in material form or not.
Whose personal information do we collect?
The personal information that we collect and hold may include an individual's:
• name;
• contact details (residential address, phone number, fax, email address);
• date of birth;
• gender;
• bank account or credit card details if provided;
• donation history;
• technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, usage data, language and operating system; and
• information from or in connection with your resume or job application if you apply for a position with us.
What is Sensitive information
“Sensitive information” is a sub-category of personal information which includes information about an individual’s racial or ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health information, genetic or certain biometric information.
What sensitive information do we collect and hold?
CSF may also collect sensitive information when you attend one of our camps, including information about:
• your Medicare number;
• current medication;
• medical conditions; and
• your health records.
How do we collect and hold personal information?
We may collect personal information from the individual concerned or from a third party.
We may collect this information when you:
• communicate with us through our website, by telephone, by e-mail or through a written application;
• make a donation to CSF;
• become an employee or volunteer for CSF or apply to become an employee or volunteer;
• participate in any program, activity, competition or event organised by CSF; or
• otherwise voluntarily provide your details to CSF.
We may also collect personal information about you if it is publicly available.
CSF has processes in place to ensure that our records remain accurate, complete and up to date, including by verifying the information with you each time you use our services or from other sources.
These records are retained for time periods permitted or required by law.
If the information is no longer required by us for any purpose for which it was collected and is no longer required by law to be retained by us, we will destroy or de-identify the information.
Can I remain anonymous?
You can always choose to deal with us anonymously or by using a pseudonym.
However, please note that if you choose to remain anonymous, this may affect your ability to access or use certain functions of our website or services. If you choose not to provide us with your contact details when you send a gift to CSF, we cannot send you an official tax-deductible receipt and letter of thanks.
If you wish to remain anonymous when dealing with us via a telephone call, please advise the call operator assisting you. Providing your personal details enables us to provide you with a contact record reference number which allows you, and other authorised persons, to retrieve information about that call at a later date.
What about personal information provided by other people?
In some circumstances, CSF may receive personal information about an individual from a third party. CSF will only collect information from a third party where you have given your express or implied consent for us to do so.
How do we use your personal information?
We may collect, hold, use and disclose personal information for the following purposes:
• to process any donations you may send to us;
• to enable you to access and use our website and services;
• to manage our relationship and communicate with you;
• to engage in and send information about CSF including newsletters, updates and information on appeals or other information that has been requested or which may be of interest to you (including marketing and promotional messages);
• to run our general business activities, and to operate, improve and optimise our website and services and yours and other users' experience;
• to comply with our legal obligations; and
• to insert other general descriptions of uses required by CSF.
If you do not wish to receive further communication from us, please contact us on +61 3 9686 4813.
Disclosing your personal information
In using your personal information for the purposes set out above, CSF may disclose your personal information to a range of individuals and organisations which provide services to CSF and include, but are not limited to:
• mail-out and email distribution service providers;
• telecommunication and telemarketing service providers;
• marketing analysis service providers;
• fundraising services providers;
• your financial institution in the case of direct debit or some credit card transactions;
• CSF’s professional advisers, including accountants, auditors and lawyers;
• CSF’s insurers; and
• other companies that CSF engages to carry out functions and activities on behalf of CSF.
When we disclose personal information to third parties, we make all reasonable efforts to ensure that we disclose only relevant information and that it is accurate, complete and up to date and that the third party will comply with the Privacy Act in relation to that information.
We may disclose personal information in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by the Privacy Act.
These other disclosures may include where:
• You would reasonably expect the disclosure to occur (for example, quality assurance purposes or training);
• We are required, authorised or compelled by law to disclose;
• it is requested by an enforcement body when reasonably necessary;
• it will lessen or prevent a serious threat to an individual's life, health or safety or a public health or safety;
• it is necessary as part of the establishment or defence of a legal claim; or
• it is a necessary part of an investigation following a complaint or incident.
If your information is to be used or disclosed for additional purposes, we will not do so without your consent.
Disclosure of personal information overseas
Some of the third parties to whom we may disclose personal information may be located overseas. The countries in which those third parties may be located include:
• Canada, USA, UK, New Zealand, Vietnam, Philippines, Austria, Finland, France, Ireland, Netherlands, Hong Kong, Japan, Malaysia, Singapore, South Korea, Brazil, Chile Europe, Israel, Guatemala, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by applicable law.
Where we disclose information outside of Australia, we will take reasonable steps to ensure that any such person to whom personal information is disclosed will deal with that information in a way that is consistent with the APPs.
Do we use your personal information for marketing?
We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
Help us keep your information accurate
CSF aims to ensure that the information we hold about you is accurate, complete and up to date. However, the accuracy of this information is largely dependent on the information you provide. To assist us with this, please contact us if you are aware of any changes required to your personal information.
Security of our personal information
To protect personal information from misuse and loss, and from unauthorised access, modification or disclosure:
• our staff are trained in how to keep your information safe and secure;
• we store your hard copy and electronic records in secure systems; and
• we use trusted contracted service providers (including cloud storage providers).
However, we advise that there are inherent risks in transmitting information across the internet, including the risk that information sent to or from a website may be intercepted, corrupted or modified by third parties. If you have security concerns, or wish to provide personal information by other means (e.g. by telephone or paper), you may contact us using the contact details set out at the bottom of this Privacy Policy.
Generally, the personal information of our employees, systems and third parties we share information with are located in Australia, with some of this personal information stored in secure cloud systems. From time to time, your personal information may be stored in secure could systems overseas including the countries listed in the section titled "Disclosure of personal information overseas".
Cookies
A “cookie” is a small file stored by the web browser software on a computer when you access our website. (An explanation of cookies can be found at the website of the Australian Information Commissioner at www.oaic.gov.au.)
Cookies may be used on our website to monitor web traffic, for security purposes, to improve our website functionality or effectiveness and in connection with a user login. We may also use cookies for other purposes from time to time. You may refuse the use of cookies by selecting the appropriate settings on their browser, however, please note that this may prevent you from using the full functionality of the website. We will deal with any personal information collected by cookies in the same way we handle other personal information under this Privacy Policy.
Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses cookies to help analyse how users use the website. Google Analytics anonymously tracks how users interact with the website, including where they came from, what they did on the website and whether they completed any transactions on the website.
The information generated by the cookie about your use of the website (including their IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of compiling reports on the website activity and providing other services relating to the website and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate a person's IP address with any other data held by Google.
You can opt out of the collection of information via Google Analytics by downloading the Google Analytics Opt-out browser add here.
Clickstream data
When you visit our website, a record is made of your visit, including the following information:
• your server address;
• your top-level domain name;
• the date and time of access to the site;
• pages accessed and documents downloaded;
• the previous site visited; and
• the type of browser software in use.
We analyse this non-identifiable website traffic data (including through the use of thirdparty service providers) on an aggregated basis to improve our services and for statistical purposes.
No attempt will be made to identify users or their browsing activities except in the unlikely event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet Service Provider's log files.
Links
Our sites may have links to other websites not controlled or owned by us. We are not responsible for these sites or any consequence of a person's use of those sites. In particular, we are not responsible for the privacy policies or practices of the operators of other websites. We recommend that you review the privacy policies of those external websites before using them.
You can access your information
We have measures in place to ensure that the information we hold about individuals is accurate, complete and up to date. If you learn that personal information we hold about you is inaccurate, incomplete or not up to date you should contact us so that the information can be updated.
If you wish to see what information we hold about you, you can ask us for a copy.
Sometimes it may not be possible to give you a copy of the information if it was provided anonymously, if it contains details about other people, or if it would be unsafe to provide the information (for instance, if it may lead to harm being done to another person).
If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons.
If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
You will be notified of any likely costs before your request is processed.
How can I make a complaint?
If you have a complaint or concern regarding our handling of your personal information or think that your privacy has been affected, you should contact us as detailed below for an examination of your complaint or concern.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC). See www.oaic.gov.au for further information on making complaints.
Contacting us
Community Spirit Foundation Privacy Officer
Email: admin@communityspiritfoundation.org.au
Phone: +61 3 9686 4813 between the hours of 9am and 5pm, Monday to Friday
Postal address:
Community Spirit Foundation
PO Box 4335
Richmond East, VIC,3121
Last updated: 31 March 2022