Privacy Policy: Difference between revisions

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* [https://www.airleague.com.au/download/privacy-policy/ Privacy Policy V3 17 FEB 2019]
# '''Introduction'''
## The Australian Air League Inc. ('the League') respects the privacy of its members and understands the importance you place on the protection of personal information in its care.
## Our commitment to protecting your privacy is important to us. You can have full confidence that, when you deal with us, your personal information will not be used in any way that you did not intend it to be used, and that the data will be held securely.
## This Privacy Policy complies with the National Privacy Principles embodied in the new Privacy Act, which came into effect 21 December 2001. It explains how we collect personal information and how we maintain, use and disclose that information. It also outlines your privacy rights along with our general rights and obligations, as well as explaining how you can access the information we keep about members and how you can update your own database records.
## This policy is binding on all members of the League.
# '''Primary Purpose Definition'''
## Personal information is collected and retained on past and present adult members, as well as youth members and their parents/guardians, for the primary purpose of operating the League.
## All information collected is directly applicable to the functions and activities of the League and to the health, well-being and protection of its members.
## This information is entered and stored in centralised database/s located at the State and National Levels. Any Unit of the organisation to which the individual member belongs may also retain data in electronic or hardcopy format.
# '''Collection of Data'''
## We will only collect personal information in a fair and lawful manner, and then only that information which we require to manage and promote the organisation and the health, well-being and protection of its members.
## When you apply for membership, the application form includes statements about privacy and requests for consent. These privacy statements refer you to this policy where more detail is available on how any information about you may be used and disclosed in relation to your membership of The League.
## When you apply for membership, you consent to us collecting, maintaining, using and disclosing personal information about you and provided by you or by another person in accordance with this policy.
# '''Identifiers'''
## When you apply to become a member of the League you are assigned a computer-generated number to uniquely identify you for the purposes of the organisation's operations. This number has no relationship to any identifier assigned by any other agency.
# '''Type of Data Collected'''
## Generally, we only collect personal information about you from you, unless it is not reasonable or practical for us to do so, or you consent. For example, the State Office may collect information about you from your local Squadron to whom you have applied to be a member.
## Our membership application forms generally request information that identifies you, such as your full name and date of birth; and information that enables us to contact you such as address, phone and facsimile numbers, as well as e-mail address. We also ask for the name of your school or, if employed, your occupation, position and employer's name and address. We also like to know your hobbies and interests and whether you have any other skills that may be of use to the organisation.
## We also collect from internal sources and from members; information related to events and activities (including photographic/video footage) they attend, training courses, appointments and qualifications related to the League.
## In the case of youth members we also need to know the names and contact details of your parents/guardians in case we have to contact them in an emergency, or to ensure they are informed about League activities, policy issues or other important matters involving their children. We also ask for their occupation/employer details as well as their skills/hobbies and sporting/leisure activities, as our organisation relies on volunteers providing their time and expertise in a variety of areas for the benefit of our youth program. We ask parents/guardians about their willingness to support their children's activities and help out with their local Squadron in whatever capacity they can.
## Some League forms request information about Medicare numbers, hospital insurance cover and other details that significantly affect the League's ability to assist you in an emergency. This type of information can be particularly important when emergency assistance is required away from home - for example during an extended or remote League activity.
# '''Sensitive Data'''
## The League is a voluntary, non-political, non-formal education League for young people, open to all without distinction of origin, race or creed whose aim is to encourage the physical, intellectual, social and spiritual development of young people.
## We do not actively seek to collect sensitive formation (for example health information or information about your racial or ethnic origin or any criminal record), unless it is necessary to satisfy the aims and principles of our organisation, or is for the care and protection of our members.
## The following information, which may be considered to be of a sensitive nature, is collected, but we do so in accordance with the National Privacy Principles:
##* Your religion/denomination/nationality (if applicable) is requested so that we can provide for the needs of members from different religious and cultural backgrounds.
##* Information obtained from the State Police or Government Statutory Authority of criminal record checks on potential adult members is strictly confidential, is not held electronically in any form, and is securely stored and accessed only by the relevant Executive Commissioner, of a State, or the Chief Commissioner.
##* Behavioural files are maintained where appropriate and these are directly under the control of the relevant Executive Commissioner, of a State. Reasonable access by the member involved is available on request.
##* We collect health and medical information, including Medicare and private health fund numbers, about members each time we seek parent/guardian permission for the members to attend a League activity, which provides the opportunity for more up to date data to be supplied. This data provides the organisation with relevant medical information that is essential to the duty of care that we owe the members under our care.
##* Health and medical information is also sought from adult members attending major activities and events for use in medical situations.
# '''Consent Policy'''
## When you join the League you agree that we may use your contact/personal details to send you information about our organisation and its activities and services that we feel may be of interest to you and to contact you from time to time to obtain your feedback about our activities and services. You also agree to the collection of sensitive data for the purposes disclosed in this policy.
## We will not use your personal information for any purpose that you would not reasonably expect us to use it for. Your information may be used to offer you other products, services and activities that will enhance our relationship with you. You may decide on joining, and at any other time by informing us in writing, that you do not wish to be contacted in this way. It is assumed that existing members have given consent unless they advise us otherwise.
## The personal information obtained by the League may be used by the League to further its relationships and services with third parties of similar interests and requirements.
# '''Use and Disclosure'''
## When you apply to be a Youth Member or an Adult Leader, Parent Helper or Youth Leader, you will be provided with a Privacy Notice that provides you with information about the collection, use and disclosure of your information and which will require your consent to that collection.
## By signing the membership application form you consent to us using your personal information the following way:
##* To maintain a register of our membership
##* To respond to your request or help us process any request for our activities or services
##* To effectively administer all activities and services that we provide to you
##* To communicate with you about the activities and services that we may provide you
##* To inform you of relevant internal or external activities, events, promotions or special offers that may be of interest to you
##* To identify geodemographic details of our membership for the purpose of building membership
##* To ensure the safety, health and well-being of all members while they participate in League activities
##* To carry out research, marketing or development of our products, activities and services including, but not limited to, the surveying of members on their needs and attitudes and the furthering of the League's relationships with any third party.
##* To provide contact information to enable communication between members of the League.
##* To assess the suitability of adult members to be in charge of our youth members
##* To provide personal details of potential adult members to the State Police or Government Statutory Authority for criminal record checks in accordance with various States Child Protection Policies as well as the League's Child Protection Policy.
##* To direct membership inquiries to you if you are the Officer in charge of a Squadron
## If you have chosen to provide us with your email address, we may use that address to advise you of matters of League interest as well as for marketing, planning, new services or research purposes.
## Members have the right to opt out of these additional communications. There is also an opportunity to opt in by joining email subscription lists which will be promoted through emails and the website.
## We may release information about you where there is a duty to the public to disclose that information, or where disclosure is required or authorised for law enforcement or regulatory purposes.
## The League undertakes to give proper and responsible consideration to privacy issues associated with the introduction of new marketing methods or technology.
# '''Data Quality and Integrity'''
## We rely on the accuracy of the information that members or their Squadron provide us. We try to ensure that all information which we collect, use or disclose is accurate, complete and up to date. We conduct periodic internal checking procedures to ensure that as far as is practicable that the data held by us is accurate and current.
## You should promptly notify us if there are any changes to your personal information.
# '''Data Access and Correction'''
## You can request access at any time to personal information we hold about you. We will process your request within a reasonable time, usually 21 days. The first point of contact will normally be the Executive Commissioner in a State.
## There is no fee for requesting access to or updating your information, however, the League reserves the right to charge a reasonable fee (no more than $50) in order to cover any costs associated with providing access to your file. For example, staff will usually be required to assist in maintaining the security and privacy of the files on other members whilst you have access to your file. Any fees charged will be reasonable and in accordance with the conditions of the Privacy Act.
## Before giving access to your records, a member will be required to submit their request in writing (either by letter or fax) and they will be required to provide adequate personal identification (for example a drivers licence or passport).
## In some circumstances, access to your personal record may be denied, or limited to some parts. Such refusal will only occur in accordance with applicable privacy legislation.
## From time to time, for the purposes of data correction, we may provide members or their Squadron with a computer printout of some or all personal data that we hold on a member.
## We also provide a 'Change of Personal Particulars' form (Form 18) to allow members to advise us of amendments.
## The League uses many forms other than the membership application form for various operational purposes. These forms often request personal details from members, which were previously collected from their original membership application. These provide us with further opportunities to ensure our data is accurate and current.
## Any amendments to member's records will be processed as soon as possible after such reports or forms are returned to the State or National Offices.
# '''Access to Data by Members of the League'''
## The League is an organisation that is run by and for its voluntary members. Communication between members is of primary importance for its successful operation. The provision of contact details to members to allow them to make contact with other members is very important.
## The provision of some personal details about members to Officers, whose role is to supervise and in some cases assess the performance of those members, is also essential.
## For these reasons, State and National Offices are authorised to provide limited personal information about a member to another member for bona fide purposes. As a general rule we do not disclose the member's work details.
## We also publish a contact list showing limited personal details for a select list of senior adult members.
## This list is provided to all those on the list for contact purposes.
# '''Access to Data by Non-members'''
## Access to personal information by non-members, except custodial parents/guardians, is not permitted. Personally identifiable data is not provided to third parties or non-members other than names and addresses for the purpose of cross-referencing member identity with like Organisations in the furtherance of the League's objectives.
# '''Data Security'''
## We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.
## We have physical, electronic and procedural safeguards to protect your information, which is held by us.
## For example, your personal information in the form of original or copies of paper forms is stored in secured premises at State Offices. Authorised voluntary adult Leaders may also hold forms. These Leaders are accountable for the security and privacy of your data.
## State and National Offices are the locations of the data held in electronic databases. We require all members to maintain the confidentiality of member information.
## The State Offices use secure methods to destroy or de-identify any personal information such as computer reports and completed forms as soon as the information is no longer needed for any purpose. All other Units are expected to ensure that forms no longer required are destroyed using permanent destruction methods. Current policy is that electronic information on the membership database on past members is not removed or archived.
# '''Commercial Use of Data'''
## The League does not make member information available to external organisations for commercial use.
# '''Website On-line Services Policy'''
## The League does not collect any personal information about you via our Internet site (www.airleague.com.au) except when you knowingly provide it.
## It is possible for you to visit this website without telling us who you are.
## If you have elected to be a registered user we may use your e-mail address to send you from time to time various promotional offers, League program information, special events or other marketing communications that may be of interest to you.
## It is our policy to only e-mail members who give us permission to do so. If we send you an e-mail for a commercial purpose, we will give you the option of not receiving further communications of this nature.
## You may also opt in to the e-mail subscription service to receive e-mails about specific subjects and activities.
## Personal information obtained on the site will never be released to a third party without your consent.
## We will use any collected information to improve our service to users, and from time to time may contact registered users about new features and improvements to the website.
## The League undertakes to take reasonable steps necessary to ensure that member information is secure from any unauthorised access or disclosure. In designing the League website, we have incorporated security procedures and practices that we consider are consistent with Australian industry practice. We review our security procedures from time to time and update them when relevant.
## We assume no responsibility for the information practices of third-party sites where a user is able to access their sites through ours. We encourage users to review each site's privacy policy before disclosing any personally identifiable information.
## For statistical purposes we may collect non-personalised information on website activity (such as the number of users who visit the website, the date and time of visits, the number of pages viewed and navigation patterns) through the use of 'cookies' and other tracking technology. In order to collect user statistics we may anonymously log information, and identify categories of users by items such as domains and browser types.
## The League may amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will notify you by posting a prominent announcement on our pages, and via an email to registered users.
## If you have any questions or feedback on our website privacy policy, please send an email to: [mailto:webmaster@airleague.com.au webmaster@airleague.com.au].
# '''Your Rights'''
## You need not give us any of the personal information about you or any other person, which may be requested in our communications with you. However, without that information, we may not be able to process an application, fulfil your request to become a member or provide you with an appropriate level of service.
## You are entitled to ask us for access to your personal information records at any time, or to choose to cancel or opt-out of any service or future mailing. 
## You may elect to advise us that your phone and fax numbers are to be marked as 'silent' in which case we will not release or publish them in any form.
# '''Access Policy'''
## The policy is directed to those individuals whose personal information is being held by the League.
# '''Purpose'''
# The purpose of the Policy is to set our how League will provide access to your personal information. The Policy is part of our [[Privacy Policy]] and our desire to provide for, maintain and give effect to our privacy obligations.
# '''Overriding Principles'''
# At all times the conduct under this Policy will be governed by the following principles:
#* All requests for access will be treated seriously
#* All requests will be dealt with promptly
#* All requests will be dealt with in a confidential manner
#* Your request to access your personal information will not effect your existing obligations between you and the League
# '''Form of Access'''
## The will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that the League holds about you.
## You can make your request in writing by contacting:<br />''Federal Operations Commissioner<br />Australian Air League Inc.<br />PO Box 245<br />RINGWOOD VIC 3034''
## To obtain access you will have to provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.
# '''When will Access be denied?'''
## Access will be denied if:
##* The request does not relate to the personal information of the person making the request;
##* Providing access would create an unreasonable impact on the privacy of others;
##* The request is frivolous and vexatious;
##* The request relates to existing or anticipated legal proceedings
##* Providing access would prejudice negotiations with the individual making the request;
##* Access would be unlawful;
##* Denial of access is authorised or required by law;
##* Access would prejudice law enforcement activities;
##* Access discloses a "commercially sensitive" decision making process or information;
##* Providing access would pose a serious imminent threat to life or health of a person; or
##* Any other reason that is provided for in the National Privacy Principles (NPPs) set out under the Privacy Act.
## Where possible, the League will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate "intermediary".
## Where there is a dispute about the right or forms of access these will be dealt with in accordance with League's Grievance Policy.
# '''Time'''
## We will take all reasonable steps to provide access within a reasonable time of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will provide information more quickly.
# '''Costs and Charges'''
## The League may impose the following charges inclusive of GST:
##* Photocopying - $2 per page
##* Delivery cost of information stored off-site - where information if stored off-site, the cost of obtaining access to the information - $30 per hour
##* Access to electronic database - $30 per hour
##* Postage Costs
# '''Privacy Complaints: How we handle privacy complaints'''
## ''Introduction''
### The league sees the importance of privacy to the organisation, its customers and other stakeholders. As such the league is committed to protecting the privacy of the personal information that we hold. This is part of our organisations:
###* Legal obligations under the Privacy Act 1988
###* Ethical and business obligations
###* Service to you
## The league places high priority on effectively dealing with any complaints about privacy that you may have.
# '''Overriding Principles'''
## At all times the conduct under this policy will be governed by the following principles:
##* All complaints will be treated seriously
##* All complaints will be dealt with promptly
##* All complaints will be dealt with in a confidential manner
##* Any privacy complaints will not effect your existing obligations or the commercial arrangements that exist between this organisation and you.
# '''Who may complain under this policy?'''
## If you have provided us with personal information you may make a complaint, have it investigated and dealt with under this policy.
# '''What is a privacy complaint?'''
## A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
##* How personal information is collected
##* How personal information is stored
##* How this information is used or disclosed
##* How access is provided
##* How accurate the information is that we hold
# '''What do I do if I have a complaint about privacy practices?'''
## The league resolves grievances at the local level if possible. If you have a complaint about privacy, and it cannot be resolved at a local level, please contact the Federal Operations Commissioner.
## All complaints will be logged on a database/complaints register.
## You may complain in writing to:<br />''Federal Operations Commissioner<br />Australian Air League Inc.<br />PO Box 245<br />RINGWOOD VIC 3034''
## Usually your contact with the league will be the appropriate person to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter will then be referred to the Privacy Officer, (the Federal Operations Commissioner) and then if necessary, the Chief Commissioner and/or the Council of the Australian Air league Inc.
# '''Complaints Resolution'''
## Complaints will be resolved in accordance with the League Dispute Resolution Procedure.
## Complaints should be made in writing or by email.
# '''Dispute Resolution Procedure'''
## The goal of this policy is to achieve an effective resolution of your complaint within the reasonable timeframe.
## Once the complaint has been made, the point of contact can then resolve the matter in a number of ways:
### ''Request further information and investigation:'' your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential.
## A complaint will be investigated. The League will try to do so as soon as possible. It may be necessary to contact others in order to proceed with the investigation.
### ''Discuss Options:'' We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.
### ''Refer to Chief Commissioner and/or Council of Australian Air League Inc.:'' If your complaint is not resolved at the local level or with the Privacy Officer, it will be referred to the Chief Commissioner and/or Council of Australian Air League Inc. The Chief Commissioner and/or Council of Australian Air League Inc. would be provided with the history and may discuss the complaint with the parties that are involved.
### ''Resolution:'' You will be informed of the outcome and the reasons for the decision. If this does not resolve the complaint, the matter will be referred to a mutually agreed intermediary.
## If after the above steps have been followed you are still dissatisfied with the outcome you may refer the complaint to the Office of the Federal Privacy Commissioner.
# '''Records'''
## The league will keep a record of your complaint and the outcome.
# '''Anonymous Complaints'''
## The league is unable to deal with anonymous complaints as we are unable to investigate properly and follow-up such complaints.
## However, in the event that an anonymous complaint is received, the league will note the issues raised and try to resolve them appropriately.
# '''Information'''
## For any further information about this policy please contact the Federal Operations Commissioner at [mailto:privacy.officer@airleague.com.au privacy.officer@airleague.com.au] or<br />''Federal Operations Commissioner<br />Australian Air League Inc.<br />PO Box 245<br />RINGWOOD VIC 3034''
# '''Changes to Our Privacy Policy'''
## This in formation relates to our current privacy standards. We may vary our privacy standards from time to time. We will notify you of these changes by publishing them on our website - we will not separately notify you of these changes.
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Revision as of 19:48, 26 February 2019

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