PRIVACY POLICY
- Updated Nov, 2023
1. PRIVACY COMMITMENT
In this Privacy Policy, “we” and “us” refers to TNVH and “you” refers to any person about whom we collect personal information. TNVH takes your privacy seriously and is committed to protecting the privacy and personal information of all of its donors, supporters, volunteers and staff. This Privacy Policy represents how TNVH manages your personal information in accordance with the Privacy Act 1988 (Cth) (‘Privacy Act’). Our Privacy Policy seeks to safeguard the privacy of your personal information in accordance with the Australian Privacy Principles (‘APP’s) contained within the Privacy Act.
This Privacy Policy sets out the kind of information we hold and how we collect, hold, use and disclose that information (including personal and sensitive information, which includes health information). This Privacy Policy may be amended or revised at any time. The revised Privacy Policy will take effect when it is uploaded on our website. This Privacy Policy represents the latest version of the Privacy Policy. More information about the privacy provisions can be obtained by calling the Office of the Information Commissioner (‘OIC’) on (07) 3234 7373 or 1800 642 753 or by visiting www.oaic.gov.au.
2. KINDS OF PERSONAL INFORMATION COLLECTED
As a registered charity, TNVH will conduct fundraising activities for families in Brisbane and beyond. Accordingly, TNVH may collect both personal and sensitive information from you. Personal information is any information about you that identifies you or by which your identity may be reasonably determined. The kinds of personal information that may be collected from you includes, but is not limited to your full name, address, phone number, email address, date of birth and payment details.
We may also collect information about family members and/or associates, information about personal and social circumstances, financial information, education information, employment information and other information necessary for the purposes of carrying out our functions. By collecting this personal information, we are able to contact you when necessary, identify and protect your information from unauthorised use and provide the best possible service. Sensitive information is a subset of personal information and includes information about an individual’s race, religion, political or trade association, criminal record or health information about an individual.
Health information is one kind of sensitive information and includes information:
(a) about an individual’s health or disability at any time (that is, past, present or future);
(b) about health services provided, or to be provided, to the individual;
and (c) collected in the course of TNVH’s activities.
3. UNSOLICITED INFORMATION
‘Unsolicited’ information refers to information which is received but which TNVH has taken no active steps to collect.
If TNVH receives unsolicited personal information, we will make an assessment as to whether we could have collected the personal information from you ourselves. If we could not, we will destroy or de-identify it as soon as practicable, unless it is contained in a Commonwealth record or it is unlawful or unreasonable to do so.
4. HOW PERSONAL INFORMATION IS COLLECTED
TNVH collects personal information from a number of sources including the individuals to whom the information relates, family members and associates, other fundraising organisations, community service organisations, and other individuals and/or entities who may have information relevant to TNVH activities.
Where possible, TNVH will always collect personal information directly from you however, at times TNVH will receive personal information from third parties nominating you to benefit from TNVH’s activities.
Collection of your personal information may occur in a number of ways, including:
(a) website or social media interactions;
(b) emails;
(c) telephone conversations;
(d) in person; and
(e) when a complaint is lodged with TNVH.
TNVH must:
(f) only collect health information necessary for its functions or activities;
(g) take reasonable steps, at the time of collecting health information or as soon as practicable afterwards, to make an individual aware of why the information is being collected, who it may be disclosed to, how it can be accessed etc;
and (h) only collect health information with the express or implied consent of the individual concerned, unless collection is required by law or it is necessary to prevent a serious threat to the life or health of any person.
TNVH may also collect information about how visitors use its website and social media accounts. This may happen when you click on a link on the TNVH website or social media accounts or visit the site through advertising.
The information collected in this way is general information collected by cookies. This information may identify site visits but does not identify or give TNVH any identifying information about the visitor as an individual, that is otherwise not publicly available.
5. HOW PERSONAL INFORMATION IS HELD
Personal information is ‘held’ by TNVH where it has possession or control of a record that contains personal information.
TNVH may store your personal information in hard copy or electronic format, physically on our premises, on internal servers and/or with third party data service providers in Australia.
TNVH has policies and procedures in place to protect personal and sensitive information from misuse, interference and loss, unauthorised access, modification or disclosure. These policies and procedures are discussed further in section 12 of this Privacy Policy.
6. PURPOSE OF COLLECTING AND USING PERSONAL INFORMATION
TNVH collects and holds personal information about you in order to provide our services to you or to assist you providing services on behalf of TNVH.
We collect your personal information for purposes including:
(a) to foster relationships for philanthropy purposes;
(b) contacting and communicating with you;
(c) to perform our administrative functions;
(d) to satisfy TNVH’s legal obligations;
and (e) resolving complaints or enquiries.
7. USE AND DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to a person or party outside TNVH:
(a) for the primary purpose for which it was collected;
(b) for directly-related secondary purposes that would have been within the reasonable expectations of the individual at the time;
(c) where necessary in connection with the purpose for which it was collected;
(d) if required by law;
(e) if you consent to the disclosure;
or (f) otherwise as permitted by the Privacy Act.
Where possible, we will require you to specifically consent to any use or disclosure of your personal information. Your consent will usually be required in writing. However, where necessary, we may accept your verbal consent to disclose particular information in providing our services.
8. NOTICE OF COLLECTION OF PERSONAL INFORMATION
TNVH will take reasonable steps before, or at the time it collects personal information to notify you of the collection of personal information, including the purposes of collection.
If it is not practicable to provide a collection notice before, or at the time personal information is collected, TNVH will take steps as soon as practicable after collection to provide notice, and to ensure that you are aware, as soon as practicable, after the collection.
9. COLLECTING INFORMATION FROM THIRD PARTIES
On occasion, TNVH may collect information from a third party.
For example, TNVH may collect information from the following:
(a) third parties that have nominated you to receive donations;
(b) organisations that TNVH is partnering with for joint fundraising efforts;
(c) agencies that TNVH use to provide products or services and/or to promote a product or service.
10. ACCURACY OF PERSONAL INFORMATION
TNVH will take reasonable steps to ensure that all personal information it holds is accurate, up to date, complete, relevant and not misleading. Individuals may ask TNVH to correct any personal information that TNVH holds.
TNVH will then consider whether or not to change and/or update the information. If TNVH does not change or amend the information as requested, then written reasons for the refusal will be provided.
All requests for amendments or corrections must be sent to hello@thenurturedvillage.org.
11. SECURITY OF PERSONAL INFORMATION
Personal information is stored on secure cloud-based servers which are administered and protected by TNVH. TNVH will take all reasonable steps to protect personal information it holds from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
The steps and strategies implemented by TNVH to ensure the security of personal information include:
(a) educating our staff and volunteers about their obligations in relation to your personal information;
(b) requiring staff to use passwords when accessing our systems;
(c) employing firewalls, intrusion detection systems and virus scanning tools to prevent unauthorised access;
(d) ensuring all TNVH employees, data processes and external parties adhere to strict confidentiality policies and practices;
(e) providing secure storage for physical records;
and (f) destruction and de-identification.
Where TNVH no longer needs personal information for any purpose for which the personal information may be used or disclosed under the APPs, TNVH will take all reasonable steps to securely destroy the information or ensure that it is de-identified, except where:
(g) the personal information is part of a Commonwealth record;
or (h) TNVH is required by law or a court/ tribunal order to retain the personal information.
12. ACCESS TO AND CORRECTION OF INFORMATION
All persons have a right to access their personal information held by TNVH, and to advise TNVH of any inaccuracy. Accessing your personal information is free.
You may access and/or request that your personal information be edited or corrected by contacting the Privacy Officer at TNVH:
Name: Emma Gray
Email: hello@thenurturedvillage.org
Address: 133 Fifth Avenue, Balmoral QLD 4171 Australia
You may be asked to submit your request in writing and for information that identifies you to satisfy TNVH that a request for personal information is made by you personally.
If so, include:
(a) your name and contact details;
(b) the personal information you want to access;
(c) how you’d like access to the personal information (such as receiving a copy by email or post, or if you just want to look at the information);
and (d) if you authorise a person or organisation to access the personal information on your behalf.
There are certain circumstances where TNVH can deny access to personal information - for example where giving access would have adverse and unreasonable implications on the privacy of others, where granting access is unlawful or where denying access is required by law. If TNVH refuses an individual’s access or correction request, TNVH will provide written reasons for the refusal, including information to complain about the refusal. TNVH reserves the right to change its guidelines for providing access.
13. THIRD PARTY WEBSITES
When you leave our website, you may be directed to websites that are beyond our control.
This Privacy Policy does not apply to third party websites and we encourage you to review the privacy policies which apply to third party websites.
14. FEEDBACK
TNVH appreciates the feedback of all its donors, supporters, volunteers and site visitors.
If you would like to provide feedback, please contact us at hello@thenurturedvillage.org
15. COMPLAINTS
If you are unsatisfied with the manner in which we have dealt with your personal information, you may make a complaint by emailing us at hello@thenurturedvillage.org.
When you make a complaint, you should:
(a) identify yourself;
(b) provide a contact address and a contact phone number;
(c) provide a brief description of the matter and why you think TNVH has mishandled your personal information;
(d) let us know what you would like us to do to resolve the matter.
We will, within fourteen days, respond to you and attempt to resolve with you your issues as they relate to your personal information.
If you are still unsatisfied, you may wish to direct your complaint to the OAIC. The OAIC accepts written complaints via its privacy complaint form or via email.
Please refer to the OAIC’s website for further information concerning how to lodge a privacy complaint: https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us
You may also send your complaint to the OAIC by: •
Emailing your complaint to enquiries@oaic.gov.au •
Sending a letter to by post to:
Director of Privacy Case Management
GPO Box 5218 Sydney NSW 2001 •
Faxing your complaint to (02) 9284 9666.