The Caulfield Grammarians’ Association (CGA) is bound by the Australian Privacy Principles, which are part of the Privacy Act 1988 (Cth) (Privacy Act).
CGA recognises and acknowledges that the protection of individuals’ privacy is important and required under the relevant legislation.
By using CGA’s online communities and/or by submitting personal information, you agree to the processing of your personal information in the manner provided in this policy. If you do not agree with this policy, please do not use our online communities or provide us with your personal information.
- CGA protects the privacy of personal information which CGA collects and uses;
- CGA may use such information and to whom such information may be disclosed; and
- Individuals can access their personal information, correct any personal information which CGA holds, lodge complaints in relation to alleged breaches of privacy or make any related enquiry.
Personal information may be collected from any individual with whom CGA may have contact, including current and past students and their parents/guardians, alumni, job applicants, volunteers, contractors, past employees and other individuals who come into contact with CGA.
Types of information CGA collects and holds:
CGA collects a range of personal information about an individual, including but not limited to an individual’s name, address, telephone number, email address, age and date of birth. CGA may also collect information about individuals when individuals access CGA’s website for statistical purposes. Information CGA collects from visits to its website is generally anonymous and CGA does not use such information to identify individuals. However, due to the nature of internet protocols, such information may contain details which may identify a particular individual, such as the IP address of the computer accessing CGA’s website, the internet service provider used by the individual, the web-page directing the individual to CGA’s website and the individual’s activity on CGA’s website.
How CGA collects personal information:
- CGA may collect personal information from an individual from a variety of sources, including:
- a form that is completed and submitted to CGA;
- a telephone, email or in-person inquiry or discussion about CGA and the services that CGA provides;
- mail correspondence, emails and other electronic means (including by accessing CGA’s website and use of the “contact us” form);
- publicly available sources of information;
- reference from an affiliate organisation about an individual
CGA will usually collect personal information directly from the individual, unless it is unreasonable or impracticable to do so. Additionally, CGA will usually only collect personal information when CGA asks for that personal information. However, CGA may from time to time receive unsolicited personal information about an individual. Where CGA determines that CGA could not have collected such personal information lawfully, then CGA will promptly destroy or de-identify such information.
CGA may collect data from its website using various technologies, including “cookies”. A “cookie” is a text file that CGA’ website sends to an individual’s browser which is stored on the individual’s computer as an anonymous tag identifying the individual’s computer (but not the individual) to CGA. A browser can be configured to disable cookies; however, parts of CGA may not function properly (or at all) if cookies are disabled.
From time to time, CGA may seek consent of individuals to use their name, image and likeness in materials produced or published by CGA, including newsletters, magazines, posters and other advertising materials to promote CGA and its services. Where individuals do not consent to their name, image and likeness being used by CGA in this manner, CGA will refrain from using their name, image and likeness. Additionally, individuals may at any time withdraw their consent and CGA will promptly remove their name, image and likeness from the materials produced or published.
How CGS uses personal information it collects:
CGA generally only uses personal information for the primary purpose for which personal information is collected or a secondary purpose when permitted by the Privacy Act.
To the extent that CGA collects “sensitive information” (as the Privacy Act defines the term), then CGA would only use such information for the primary purpose of collection and for any secondary purposes which are directly related to the primary purpose and you would reasonably expect CGA to use or disclose the information for the secondary purpose.
CGA may use or disclose personal information (including sensitive information) for a purpose other than the primary purpose of collection if authorised or required by law.
CGA collects personal information for the purposes of:
- facilitating its ability to function as an alumni organisation;
- other administrative functions, including assessing job applicants and managing volunteers;
- fulfilling its duty of care to its alumni;
- complying with its legal obligations;
- addressing queries or resolving complaints and other customer service activities;
- running competitions;
- organising events
- keeping members informed on matters relating to the CGA through correspondence, newsletters, magazines and reports;
- assessing applications for scholarships and awarding and administering scholarships; and
- seeking and administering donations and bequests made to CGA.
CGA may also disclose personal information it collects from individuals to third parties, such as CGA’s bankers, professional advisers, courts, tribunals, regulatory authorities, other companies and individuals for the purpose of:
- complying with its obligations owed to an individual under any contract between CGA and the individual, or as required by law;
- enabling those third parties to perform services on behalf of CGA; and
- recovering debts where amounts owed to CGA in consideration for services CGA provides remain due and outstanding beyond the payment terms.
Third parties CGA engages from time to time may have access to personal information held by CGA about individuals, but CGA will not authorise them to use such information for any other purpose.
CGA may disclose personal information (including sensitive information) held about an individual to government departments (where CGA must disclose such information for the purpose of CGA complying with its legal obligations), service providers, recipients of CGA publications (such as newsletters and magazines), and past parents and staff.
Effect of non-provision of personal information; anonymity and pseudonymity:
From time to time you may be able to deal with CGA anonymously or by using a pseudonym. For example, without limitation, if you have a general inquiry about us, and/or our services, we may be able to respond to your inquiry on an anonymous or pseudonymous basis.
However, if you do not provide the personal information CGA requests, or you provide the information anonymously or pseudonymously, then CGA may be unable to provide fulfil its functions as an alumni organization or discharge its duty of care.
Further, in some situations, CGA may need to verify your identity as part of CGA’s response to a request to access and/or correct personal information CGA holds about an individual, or as part of CGA’s complaints handling procedure. If CGA cannot verify your identity, or you continue to engage with CGA in an anonymous or pseudonymous basis, then CGA may be unable to complete your request or pursue its complaints-handling procedure.
CGA may directly market its services to you on the basis that you would reasonably expect CGA to do so, where CGA has already collected your personal information. Where CGA collects personal information about you from a third party, CGA will not use that information to directly market to you without your consent. CGA will also comply with other laws relevant to marketing, including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Competition and Consumer Act 2010 (Cth).
All direct marketing communications which CGA sends will include an easy opt-out procedure if at any time you wish CGA to stop sending you information about CGA or its services.
Hyperlinks to other websites:
Our online communities contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies and we urge you to review them. They will govern the use of personal information you submit whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
Cross-border transfer or disclosure of information:
CGA may disclose an individual’s personal information to entities outside Australia from time to time. For example, CGA may be required to disclose the personal information of alumni travelling to overseas reunions to event/venue managers.
In the event CGA engages in cross-border disclosures of information, CGA will ensure that adequate security mechanisms are in place to protect the information disclosed. Wherever reasonably practicable, CGA will first seek your consent to such cross-border disclosure. Where you consent to such disclosure, CGA will be exempt from the requirements of the Privacy Act 1988 (Cth) in relation to such disclosed information. Where it is not reasonably practicable for CGA to obtain your consent, CGA will otherwise comply with the requirements of the Privacy Act 1988 (Cth).
Quality and security of information:
CGA takes reasonable steps to ensure that, having regard to the purpose for which the information is to be used or disclosed by CGA, the personal information CGA collects, uses, holds or discloses is accurate, complete, up-to-date and relevant to CGA’s functions or activities. Additionally, CGA will take reasonable steps to destroy or de-identify personal information it holds about an individual if CGA no longer requires that personal information.
CGA has implemented procedures and adopted technical and security measures to ensure that the security of individuals’ personal information is not compromised.
Personal information collected from CGA’s website, customer relationship management database, and email is stored by CGA on a secure server. All personal information is encrypted and all internet links maintained by CGA have firewalls to ensure a high level of security. Hard copy files and personal information collected from other channels (such as over the phone) is physically secured.
CGA will only retain personal information for the period necessary for the use for which it is submitted to CGA.
Accessing and correcting information:
You are entitled at any time, upon request, to access the personal information CGA holds about you. CGA will respond within a reasonable period of time after CGA receives the request. CGA will give access to the information in the manner you request, unless it is impracticable for CGA to do so. CGA is entitled to charge you a reasonable administrative fee for giving access to the information requested.
CGA may from time to time refuse an individual access to the information CGA holds about that individual, in accordance with the relevant legislation. Where CGA refuses access, CGA will explain the reasons for refusal in writing and, if you wish to lodge a formal complaint about our refusal, CGA will explain the complaint procedure.
CGA reserves the right to verify your identity before granting access to the personal information CGA holds about you.
If at any times you believe that personal information CGA holds is incorrect, incomplete or inaccurate, you may request that we amend such personal information. If CGA refuses the correction request, then CGA will provide written reasons and information about CGA’s complaints-handling process should you not be satisfied with those reasons. Where CGA corrects the personal information held about an individual, CGA will take reasonable steps to notify third parties of the correction.
Lodging a complaint:
If you wish to complain about an alleged breach of the privacy of your personal information, the complaint should be made in writing to the attention of Executive Director of the below address.
CGA will acknowledge receipt of your complaint and CGA will endeavour to deal with your complaint and provide you with a response within a reasonable time following receipt of your complaint (generally 30 days of receipt of your complaint). Where a complaint requires a more detailed investigation it may take longer to resolve. If this is the case, CGA will provide you with progress reports.
CGA will verify your identity and seek, where appropriate, information from you in connection with the complaint. Where required by law, CGA will acknowledge your complaint in writing and provide information in writing on how we will deal with your complaint. Further, if required to do so by law, CGA will provide our determination on your complaint to you in writing.
CGA may refuse to investigate and deal with a complaint if CGA considers it to be vexatious or frivolous.
If you are dissatisfied with the outcome of your complaint, you may seek an internal review of our decision, which will be completed by an officer not previously involved in your complaint. If you remain dissatisfied, you may escalate your complaint to the office of the Australian Information Commissioner.
Caulfield Grammarians’ Association
PO Box 25
Elsternwick, VIC 3185 Australia