1. Collecting personal information
The personal information we may collect will depend on the circumstances of collection, including whether we collect the information from you when you make an enquiry with us or subscribe with us regarding our services (including our educational and social activities), if you wish to make a donation or become a volunteer, employee, contractor or supplier, when you apply for membership, subscribe to services, respond to a survey we conduct or in some other circumstance.
may collect and hold the following kinds of personal information about our members, affiliates and subscribers to our services (including the provision of information and publications, providing support for maintaining the gluten free diet, and organising events for members, affiliates and the general public): name, contact details, date of birth, gender, communications between us, transactional information regarding our services and credit card details, and sensitive information (such as health information including diagnosis of the condition which requires that you maintain a gluten free diet and other associated medical conditions);
may collect and hold the following kinds of personal information about contractors, service providers and suppliers: name, job title, business contact details of company representatives with whom we deal, financial information and banking details; and
in the context of receiving donations, may collect and hold the following kinds of additional personal information: financial details (including banking details);
in the context of our recruitment process for employees, volunteers and contractors, may collect and hold the following kinds of personal information: name, contact details, financial details (including banking details), date of birth, history with us (including communications between us), citizenship, employment references, criminal record checks and the results of working with children checks, driver’s licence information, education, employment history, marital status, membership of a professional or trade association, membership of a trade union and health information.
We will generally collect personal information directly from you (or from parents/guardians in the case of a child). This may be through various contact methods such as by telephone, facsimile, email and mail, or when you (or your parents/guardians) complete forms, questionnaires, transact or request further information about our services through our website. We may also collect personal information from third parties such as your representatives, government agencies or publicly available sources of information.
If someone other than you provides us with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. However, this notice will not be provided if doing so would be a breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.
When contacting us, you have the option to not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way or if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.
3. Social networking services
We use social networking services such as Facebook and Instagram to communicate with the public about our work. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These sites have their own privacy policies.
4. Use and disclosure of information
We collect, hold, use and disclose your personal information for the following purposes:
- to facilitate the provision of membership services to you;
- to maintain, manage and develop our relationship with you;
- to respond to any questions or enquiries from you or to respond to any feedback you have provided about our activities or services;
- to maintain a register of members and affiliates;
- to assist us to conduct statistical research;
- to contact you about our research appeal and other fund-raising activities;
- to send you information about new developments, products, services and special offers;
- to assess and consider applications from prospective job applicants, volunteers, contractors and service providers;
- to manage and administer a volunteer’s, contractor’s or service provider’s relationship and arrangements with us and maintain any records in relation to this relationship;
- to contract out some of our functions to external service providers and suppliers (such as mailing houses, printing companies, IT providers and advertising and marketing services);
- to comply with our legal and regulatory obligations; and such purposes for which we may obtain consent from time to time.
In order to deliver our services to you, we may also disclose your personal information to other organisations but only in relation to facilitate the provision of those services to you. For example, one of our services is to arrange for discounted prices on gluten free products with our sponsors. For that purpose, we will disclose your details to sponsors in order to provide you with a personalised membership discount card.
Only de-identified personal information is disclosed to study groups and then only for research purposes.
If you are a medical or health practitioner and have indicated willingness for us to refer members or affiliates to you for medical advice, we will include your contact details in a list and provide your details to a member or affiliate in response to their request.
5. Disclosure of personal information overseas
We will not usually disclose your personal information to overseas recipients except as outlined in this policy. Some of our data is stored using providers with servers located overseas. Our email service is provided by a third party with servers stored overseas. Our email newsletter is distributed through a third party website which may collect and hold your personal information overseas. When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas. Web traffic information is disclosed to Google Analytics (see below) when you visit our website. Google stores information across multiple countries.
6. Analytic and cookie tools
If you choose, you may be able to configure your computer so that it disables cookies or does not accept them. In relation to Google Analytics, you can opt out of the collection of this information using the Google Analytics Opt-out Browser Add-on.
7. Direct marketing
We may collect, hold, use and disclose personal information about you for the purpose of sending you information about new developments, products, services and special offers by post, telephone or any form of electronic communication.
You may opt out of these communications at any time by contacting us at the details provided below. If you opt out of receiving marketing material, we will still send you information relating to your membership.
8. Accuracy of your information
We take reasonable steps to ensure that the personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us and we will take reasonable steps to correct it.
9. Storage and security
We will use all reasonable endeavours to keep your personal information in a secure environment. Our procedures are designed to prevent your personal information being accessed by unauthorised personnel, lost or misused. We restrict access to your personal information, including through the use of secure storage for hard copy information and password protection for information stored electronically.
Unless you tell us not to, we may retain your contact details after you cease being a member or affiliate to keep you informed of the work of Coeliac Australia, breakthroughs and developments with research into coeliac disease and to let you know about our fundraising and research appeals.
10. Access to information we hold about you
Under the Privacy Act, you have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information.
If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exceptions allowed under the Privacy Act. If you request a correction to your personal information, we will take reasonable steps to correct the information to ensure that it is accurate, up to date, complete, relevant and not misleading. You may request access to your personal information or correction of this information by contacting our Privacy Officer:
Coeliac Australia Limited PO Box 611
Cannon Hill QLD 4170
Or sending an email to us at email@example.com
Or telephoning (02) 9487 5088 or 1300 458 836.
We may charge a reasonable fee for providing you with access to your information.
11. How to make a complaint
If you wish to complain to us about how we have handled your personal information, you should complain in writing to the contact details above.
If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.
If we decide that a complaint should be investigated further, the complaint will usually be handled by a more senior staff member than the person whose actions you may be complaining about.
We will assess and handle complaints in line with our External Dispute Resolution policy.
If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner.