Privacy Policy - Brave Foundation

Privacy Policy

Introduction

Brave Foundation (we, our or us) is committed to complying with its obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).

We are committed to protecting the privacy of personal information, which we collect, hold and administer. Personal information is information, which directly or indirectly identifies a person.

 Purpose

We are committed to providing support to expecting and parenting teens (clients) and in particular, to assist them in pathways to education, training or workforce participation. This policy explains how we manage and secure your personal information. It also describes the kinds of personal information that we hold and for what purposes, and how that information is collected, held, used and disclosed.

We will:

  • ensure stakeholders are aware of our Privacy Policy and its purposes; and
  • make this information freely available in relevant publications and on our website www.bravefoundation.org.au.

You may request a copy of the policy by contacting us at the contact details in section 12 below.

Please read this policy carefully before you provide us with any personal information.

 Types of personal information that we collect and hold

We may collect and hold the following types of personal information about you:

Personal information

  • your contact details (name, address, telephone number, email address etc.);
  • your bank details and card numbers when you donate to us or purchase our merchandise;
  • information from Working with Vulnerable People, Working with Children and police checks, when you volunteer to help us or are seconded to us from another organisation;
  • online identifiers, including cookie identifiers, internet protocol addresses, device identifiers, client identifiers, mobile carriers, time zone settings and operating systems. Information on cookies may be found in section 4 below; and
  • any other information that we consider to be reasonably necessary.

 

If you participate in the SEPT Program:

  • your contact details (name, address, telephone number, email address etc.);
  • general information about you including your date of birth and relationship status etc.;
  • other information about your life and social support network that will assist with the pathway plan development; and
  • any other information that we consider to be reasonably necessary.

Sensitive information

We may need to collect sensitive information about you. We will only collect sensitive information about you if:

  • you consent to the collection of the information and the information is reasonably necessary for one or more of our functions or activities; or
  • the information relates:
    • to the activities of Brave Foundation; and
    • solely to the members of Brave Foundation, or to individuals who have regular contact with Brave Foundation in connection with its activities; or
  • the collection is otherwise permitted in the Privacy Act.

If you participate in the SEPT Program, the types of sensitive information that we collect and hold about you may include:

  • your ethnicity;
  • any medical conditions, injuries, disabilities; and
  • other health information relevant to your pregnancy or your children.

If you are seconded to us from another organisation, we may collect and hold health information about you including your immunisation history.

Information required by law

We may also collect personal information about you because the collection of the information is required or authorised by law or a court/tribunal order.

Collecting your personal information

We may, if it is reasonable and practical to do so, collect personal information directly from you. We may collect your personal information when you:

  • interact with our representatives and staff; when you access our website;
  • when you volunteer for us or donate to us;
  • when you register for and participate in our services and programs;
  • when you register for and participate in our SEPT Program, information sessions and workshops;
  • when you use our mobile application or complete our online surveys;
  • when your organisation becomes a Brave Village Member Organisation; and
  • when you purchase our merchandise.

On occasion, we may collect personal information about you from other sources where it is necessary to do so or where we have your consent.  Examples of other sources that we may collect personal information from include (but are not limited to) government agencies that conduct Working with Vulnerable People, Working with Children and police checks.

If you do not provide us with your personal information, we may not be able to provide you with certain services.

Unsolicited personal information

If we inadvertently collect personal information about you that we did not ask for, we will check whether we could have collected that information ourselves.  If we could have collected the information, we will handle it in the same way we handle other information we collect from you.  If:

  • we could not have collected the personal information; and
  • the information is not contained in a Commonwealth record,

We will destroy the information or de-identify the information provided if it is lawful and reasonable to do so.

Cookies

We use cookies on our website for analytical purposes and to improve user experience. Cookies are text files placed in your computer’s browser to store your preferences. These cookies collect information on how you and other visitors use our website.

We use Google Analytics, a website analysis service provided by Google LLC, to measure marketing activity and monitor website usage and other online statistical and analytical data. This enables us to generate detailed statistics about traffic to our website, traffic sources and how users interact with our website and third-party websites. We also measure and record sales.  The information collected includes how often users visit our website, what links they click, the user’s IP address, geolocation, browser and operating system and what other sites a user visited before coming to our website.

By using our website, you consent to the processing of your personal information by Google in accordance with Google’s policy which can be found at the following link: www.google.com/policies/privacy/partners/

To opt out of Google Analytics’ use of cookies, an add on is available at the following link:

https://tools.google.com/dlpage/gaoptout

The information collected by Google Analytics is governed by Google Analytics’ Terms of Service, which can be found at the following link:

https://www.google.com/analytics/terms/us.html

Further information about how Google Analytics collects and processes your personal information can be found at the following link:

https://policies.google.com/technologies/partner-sites

 

 

Storing personal information

Personal information is generally held in each client’s file. Information may also be held in our computer database or app.

We treat all personal information as confidential in accordance with our Confidentiality Policy and we will take reasonable steps to:

  • safeguard the information we collect and store against misuse, loss, unauthorised access, modification and disclosure;
  • destroy records in accordance with our Records Management Policy.

Some of the ways we do this are:

  • storing paper files in secure areas;
  • electronic security systems such as through the use of access passwords for computers and phones, and antivirus software;
  • control of access to our buildings;
  • confidentiality agreements for staff and monitoring of staff access to personal information; and
  • encrypted donation portal.
  • If we no longer need your personal information for any purpose, we will take reasonable steps to destroy or permanently de-identify the information, unless:
  • the information is contained in a Commonwealth record; or
  • we are required by law, or a court/tribunal order, to retain the information.

Purpose for collecting, holding, using and disclosing personal information

We collect, hold, use and disclose your personal information for the following purposes:

  • to provide support and assistance to expecting and parenting teens;
  • to comply with any payment systems requirements;
  • for direct marketing (but only with your consent);
  • to comply with any applicable laws, regulations or codes of practice; and
  • for any other purpose for which you have given your consent.

If you are participating in the SEPT Program:

  • to contact you about your participation in the SEPT Program; and
  • to monitor, administer and evaluate the SEPT Program.

 

Use and disclosure of information

We will not use or disclose information which was collected for a particular purpose for another purpose unless the disclosure is:

  • required by law (e.g. the Australian Tax Office has the power to order us to disclose information);
  • authorised by law (e.g. to protect our interests or where we have a duty to the public to disclose);
  • the access, use or disclosure is otherwise permitted under the Privacy Act (e.g. you would reasonably expect us to use or disclose the information for another purpose or the use or disclosure of the information is required or authorised by law or a court/tribunal order); or
  • you have consented to our disclosing the information.

Any personal information provided to us will be only be disclosed to other persons or entities for the purpose it was collected, and related purposes outlined in this policy.

Those persons and entities include (but are not limited to) the following:

  • associated companies and internal divisions of Brave Foundation;
  • external service providers;
  • auditors;
  • other regulatory bodies, law enforcement bodies and courts as required or authorised by law; and
  • any other person or organisation where you have given your consent.

If you participate in the SEPT Program, we will also disclose your personal information to:

  • the Brave Chief Mentor and Stakeholder Manager and SEPT Program Support Co-ordinator as part of the oversight and evaluation of the SEPT Program; and
  • other organisations for the purposes of facilitating your participation in the SEPT Program (as far as such disclosure is necessary for that organisation’s role in the SEPT Program).

If we need to share your personal information with other third parties as part of the SEPT Program we will de-identify your personal information before sharing your de-identified personal information with these third parties. Types of third parties who we will share your de-identified personal information with include (but are not limited to):

  • government agencies and departments (such as the Department of Social Services);
  • academic researchers who are evaluating grant funding; and
  • our IT providers.

In some circumstances we may need to disclose personal information about you to recipients outside Australia, as we may store your personal information in cloud storage or via other types of electronic data storage.  These recipients are likely to be located in the [United States of America]. As data storage can be accessed from various countries via an internet connection, it is not always practicable for us to know what country your personal information may be held in. As such, disclosures may sometimes occur in countries other than those listed above.

Before we disclose your personal information to any overseas recipient, we will take reasonable steps to ensure that the overseas recipient complies with the APPs in relation to the information, unless one of the exemptions in the Privacy Act applies.

Where your personal information is disclosed, we will seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.

We will not sell, rent or trade personal information.

We reserve the right to use general information about our clients in order to understand and inform others as to the services provided and the kinds of clients who have been assisted, but not in any way that would identify a particular client.

Data Quality

We will take reasonable steps to ensure the information we collect is accurate, complete, up to date, and relevant to our functions or activities.

If you believe that your personal information is not accurate, complete or up to date, please contact us at the contact details listed in section 12 below.

Access to personal information

You may, at any time, request access to the personal information we hold about you. We will give you access to that information, unless an exception in the Privacy Act applies.

You can request access to your personal information by contacting us at the contact details listed in section 12 below.

Please note that we may need to verify your identity before we correct your personal information.

Depending on the nature of the request, we may charge you a small fee for granting you access.

We will respond to a request for access within a reasonable time (usually 30 days), and give access in the manner requested by you, if it is reasonable and practicable to do so.

Sometimes, it may not be possible for us to give you access. If we refuse to give you access, we will:

  • take reasonable steps to give you access in a manner that meets our needs as well as yours;
  • provide you with written reasons for our decisions as required by the Privacy Act.

Correcting personal information

If you think that any personal information we hold about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request us to correct the information by contacting us at the contact details listed in section 12 below.

We will take reasonable steps to correct that information and we will respond to a correction request within a reasonable time (usually 30 days).

Please note that we may need to verify your identity before we correct your personal information.

If we correct personal information that we have previously disclosed to another entity, and you ask us to tell the other entity about the correction, we will take reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.

If we refuse to correct the personal information, then we will provide you with reasons for our decision as required by the Privacy Act.

Anonymity

You have the option to remain anonymous, or to use a pseudonym when dealing with us where it is lawful and practical to do so.

We will give you the option of not identifying yourself when completing evaluation forms or opinion surveys.

Complaints or queries

If you:

  • have any issues about the way we handle your personal information after reading this privacy policy;
  • become aware of any breach or potential breach of this privacy policy; or
  • wish to make a privacy complaint,

you should contact us, and request that the complaint be directed to the Board.

Brave Foundation

Email:                   info@bravefoundation.org.au

Telephone:         0448 088 380

Post:                     PO Box 118, Blackmans Bay, Tasmania 7052

If our Board Chair is unable to resolve the matter, it will be escalated (internally or externally) as appropriate to facilitate resolution.

If you are not happy with the outcome of our investigation, then you can raise your concern with the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner

Telephone:         1300 363 992

Email:                   enquiries@oaic.com.au

Mail:                     GPO Box 5218 Sydney NSW 2001

Web:                    www.oaic.gov.au

Changes to this policy

We will review this policy from time to time. We encourage you to check our website regularly for any updates to this policy.

Our Board is responsible for developing, adopting and reviewing this policy.

Our CEO is responsible for the implementation of this policy, for monitoring changes in Privacy legislation, and for advising on the need to review or revise this policy as and when the need arises.

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