Plan International Australia - Privacy Statement (2018)
Plan International Australia (Plan) – ABN 49 004 875 807
1. Our commitment to you
Plan International Australia ACN 004 875 807 (Plan) provides a range of products and services designed to assist children around the world to reach their full potential. Plan works together with you to make a just world for children and equality for girls.
Plan is committed to protecting personal information. When collecting, using and handling personal information, Plan must comply with the Privacy Act 1988 (Cth) (Privacy Act) and is bound by the Australian Privacy Principles (APPs) set out in that Act. Plan also takes reasonable steps to protect personal information from breach and includes processes to handle any actual or suspected data breach.
This Statement sets out how we collect, use and manage personal information.
2. Scope of this Statement?
Plan requires its staff comply with this Statement in relation to any personal information they handle. Plan also uses its best endeavours to ensure that contractors, suppliers and service providers Plan engages from time to time comply with similar obligations with respect to any personal information held by Plan to which they may have access, or which may be disclosed to them.
The Statement outlined here sets out, in general terms, how Plan will handle and protect the personal information of any individual which Plan collects or which is disclosed or made available to Plan in the course of Plan undertaking its usual business functions and activities.
3. What is personal information?
Under the Privacy Act 'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether the information or opinion is true or not or recorded in any form or not).
Examples of personal information include your name, postal address, telephone number and email address. Plan outlines below the typical types of personal information Plan collects from individuals. Generally, Plan collects personal information only if it is reasonably related to any of Plan’s functions or activities, and only by lawful and fair means.
When referenced in this statement, personal information should be taken to include sensitive information, which can include information about an individual's racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations and philosophical beliefs.
4. What personal information do we collect and maintain?
The personal information we typically collect and maintain is:
- contact details such as your name, postal address, email address, phone numbers;
- your date of birth, gender, income, occupation;
- your employer details, if you participate in work place giving;
- a history of your donations, correspondences and other interactions with Plan;
- your interests and opinions;
- your Plan supporter number;
- credit card or bank account details; and
- your Plan website username and password and activities performed when you login to a Plan related website.
We also maintain details of your Plan products and services.
Where it is practicable to do so in relation to a particular matter, you may choose to remain anonymous or deal with us using a pseudonym. However, if Plan is required or authorised by or under an Australian law or a court or tribunal order, to deal with individuals who have identified themselves concerning that matter, the foregoing would not apply in relation to that matter.
Further, Plan reserves the right to verify your identity as part of Plan’s response to a request to access and/or correct personal information Plan holds about you, or as part of Plan’s complaints-handling process. If Plan is unable to verify your identity, or you continue to engage with Plan in an anonymous or pseudonymous basis, then Plan may be unable to satisfy your request or complete our complaints-handling process.
5. How we collect your personal information
Generally, Plan endeavours to collect personal information about an individual directly from that individual. However, this may not always be possible.
Additionally, Plan generally only collects personal information when it specifically requests that information, except in circumstances where personal information is volunteered to Plan or otherwise supplied to Plan without Plan asking for such information or otherwise taking active steps to collect the personal information.
This section outlines how Plan collects your personal information.
Plan collects personal information from a variety of sources using a number of ways, including:
- directly from you, when you provide information by phone, SMS, in person, via our website or in application forms
- from third parties who organise fundraising activities on our behalf
- from a third party who makes a donation on your behalf or nominates you as the recipient of a gift or other communication regarding that donation;
- from some third parties to whom you have given permission to share your personal information;
- from publicly available sources
- from our own records of how you use our products and services
- from your use of our Internet websites
We may also collect personal information when we are legally required to do so, such as security and police checks if you wish to visit your sponsored child in an overseas country.
When we collect personal information, we are required to take reasonable steps to ensure that you are aware of certain matters relating to the collection of personal information. Plan does this by ensuring that a 'collection statement' is provided at the time your personal information is collected, at which point you grant consent for the collection.
Where we collect your personal information indirectly from third parties, we generally require the third party to assure us that it has obtained your consent to share the information or is otherwise authorised to provide us with that information.
When you provide us with personal information about other individuals, we rely upon you to:
- make them aware of this Statement
- make them aware that you have provided us with that information
- obtain their consent or ensure that you are otherwise authorised to provide us with that information.
If Plan receives unsolicited personal information that could not have been collected under the APPs, we will destroy or de-identify such information as soon as practicable (except where it would be unlawful or unreasonable to do so). Where Plan could have collected such information, the information will be protected and handled in accordance with this Statement.6. How we use and disclose your personal information/p>
As a general principle, and in accordance with Plan’s statutory obligations, Plan generally uses personal information only for the primary purpose(s) for which Plan collected the information, or any secondary purpose that is related to the primary purpose for which you would reasonably expect Plan to use the collected information, or as otherwise permitted or required by law.
Plan will take reasonable steps to make you aware of the purpose(s) for which the personal information collected may be used at or before the time of collection.
Plan uses and discloses your personal information primarily to enable us to work together with you to make a just world for children and equality for girls. For example, we use and disclose personal information for the following purposes:
- to provide Plan’s products and/or services to you or to a third party you nominated to Plan;
- to process transactions and to administer accounts;
- to address queries and to resolve complaints;
- managing and processing donations and providing receipts;
- sending you information about your donation and about Plan’s activities;
- confirming your identity when you make enquiries, answering your queries and addressing any feedback you may have;
- notifying you about human and child rights situations around the world;
- notifying you about our other causes, products and services that may be of interest to you;
- providing you with new opportunities to assist children and their communities living in poverty;
- conducting analysis and research so that we can better meet your needs;
- training our personnel;
- to comply with any obligations under any law or statute that binds Plan;
- to comply with obligations or to enforce rights under a contract into which Plan has entered;
- to assess the suitability of an individual applying for a job or to volunteer with Plan;
- to assess and to manage the supply of goods and/or services to Plan by a contractor or service provider; and
- any other specific purposes for which it was requested.
Plan will not disclose your personal information for a purpose that is not related to your relationship with us without your prior consent, except as Plan is permitted or required to do so by law or court or tribunal order. In order to communicate with you in relation to the activities of Plan, we may securely disclose your personal information to third parties. These third parties assist Plan by providing the following services:
- mail-out services
- email distribution services
- information technology services
- telecommunication and telemarketing services
- marketing analysis and research services
- benchmarking and data analysis services
- website usage analysis
- call centre operations
- process donations and payments.
Plan may disclose personal information to recipients in any of the following groups:
- Plan’s agents, suppliers and contractors (including, for example but without limitation, to Plan’s agents, suppliers and contractors in order to enable them to perform services under contract with Plan which may directly or indirectly benefit the individual from whom the information was collected);
- to Plan’s customers, sponsors and donors, when Plan is required to disclose personal information under contracts Plan has entered into with any of its customers, sponsors and donors;
- marketing providers, to facilitate the provision of marketing of Plan, its products and/or its services;
- professional advisers, to facilitate their provision of advice and other services to Plan;
- Government departments and agencies, for the purpose of Plan complying with its statutory obligations.
Plan takes reasonable steps to ensure that the third parties providing these services are contractually bound by privacy obligations in relation to their use of your personal information and that they only use your personal information for the specific purpose(s) for which we supply it.
When you sponsor a child, your contact details (such as your address and telephone number) are not disclosed to Plan's overseas offices or your sponsored child. However, details such as your supporter number, name, gender and country of origin are provided to your sponsored child.
Plan may otherwise use personal information collected about individuals in order to protect its legal rights and interests, or to enforce its rights against a third party in the event the third party is engaged in conduct which is prejudicial or harmful to Plan or to its interests, or to those to whom Plan provides products and/or services.
Plan works with service providers and partner organisations that store personal information in the Cloud. In these cases, Plan complies with the APPs by:
- taking reasonable steps to ensure that the service provider/partner organisation is subject to a law, or binding scheme, that is at least substantially similar to the APPs and that individuals can enforce that protection; OR
- entering into a contract with the service provider/partner organisation which imposes an obligation on them to comply with the APPs, establish a complaints handling process, and implement a data breach response plan with notification mechanisms of any actual or suspected breach.
Without limiting the foregoing, Plan does not authorise those third parties to use or to disclose any personal information Plan may disclose or allow the third parties to access except for purposes related to their provision of services to Plan and to otherwise complete their obligations they owe to Plan.
Plan may send you offers relating to other causes, products and services that may be of interest to you. We may also re-connect with past supporters by sending information about Plan and its current activities. If you no longer wish to receive marketing or promotional material from Plan at all or in any particular form, you may contact us with your request on the details provided below. We will comply with your request as soon as practicable. Where we send you electronic messages for direct marketing purposes, each message will contain a functional means for you to opt out of receiving such messages.
Plan may also send you offers relating to the products and services of third parties that also provide financial support to Plan. We do not disclose your personal information to these organisations. If you accept any offer from a third-party organisation, communicated to you by Plan, you become their customer and they may send offers to you.
From time to time, Plan may be required to disclose personal information collected from or about you within Plan International federated organisations in other countries. By providing us with personal information, you consent to Plan having the discretion to take reasonable steps to ensure that the recipients do not breach the APPs in relation to the disclosed information.
Plan may directly market the work it does to assist children around the world to reach their full potential, the products and services Plan offers, and the work undertaken to make a just world for children and equality for girls. Plan may do this in order to seek donations and support from you or from organisations with whom you are affiliated.
Plan may engage in direct marketing campaigns to you on the basis that you would reasonably expect Plan to do so, where Plan has already collected your personal information directly from you.
Where Plan collected information about you from a party other than you, then we will not use that information to directly market to you unless you consent to receiving such communications (such consent may be expressed or implied).
Indirectly marketing Plan’s products and services, Plan will comply with all laws relevant to marketing, including the Spam Act 2003 (Cth), and the Competition and Consumer Act 2010 (Cth), including the Australian Consumer Law.
All direct marketing communications which Plan sends will include an opt-out procedure if at any time you wish for Plan to stop sending you direct communications.
8. How we handle and retain your personal information
Plan holds personal information in secure hardcopy files and in electronic databases. Plan takes reasonable steps to protect its information systems and files from misuse, interference and loss, from unauthorised access, modification and disclosure by maintaining up-to-date physical, computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of personal information.
Plan regularly reviews and updates its physical and data security measures in light of current technologies and threats. Unfortunately, no data transmission over the Internet or over mobile data and communications services can be guaranteed to be totally secure.
In addition, Plan’s employees and contractors who provide services to Plan or who have access to personal information Plan collects and holds are obliged to respect the privacy of any personal information Plan holds.
Plan does everything reasonable within its power and control to prevent unauthorised use or disclosure of personal information Plan collects and holds. However, Plan is not responsible for events arising from unauthorised use of or access to personal information except to the extent that such unauthorised use or access is as a result of Plan’s failure to comply with its legal obligations concerning the steps taken to secure the personal information Plan collects and holds.
Plan believes that the relationship you have with Plan is one that should be comfortable and appropriate to your needs. To maintain Plan’s on-going relationship with you, it is important for Plan to retain a basic electronic record of your personal information in order to:
- keep a record of your generosity, in case you want to reference it in the future;
- respond to any enquiries that could arise in relation to our international child protection obligations;
- manage our legacies program effectively;
- re-connect with past supporters that may be interested in supporting Plan's current activities;
- comply with its legal, tax, audit and other obligations.
Plan will take reasonable steps to destroy or to de-identify personal information collected from or about you when Plan no longer needs that personal information for the purpose(s) for which the information was collected.
Plan takes reasonable steps to ensure that the personal information we hold is accurate, complete and up-to-date. We recommend that you let us know if there are any errors in, or changes to, your personal information by contacting us using the details provided below.
As the accuracy of the information Plan holds largely depends on the accuracy of the information supplied to Plan or which Plan collects, Plan may periodically ask you to inform us if there are any changes to your personal information.
If any of the information we are holding is inaccurate, incomplete or out-of-date, please contact Plan in order to correct the information. Plan will take all reasonable steps to correct the information so that it is accurate, complete and up-to-date and to notify the third parties to whom Plan has disclosed the relevant corrected information of the correction.
9. Privacy and the Internet
Plan’s websites, social media, and digital services use TLS encrypted security by default so that your personal information is always transferred securely.
Plan's websites contain links to other websites. Other websites may also have links to our websites. In either case this Statement does not apply to, and Plan is not responsible for, the content, privacy practices, or business practices of any website or organisation except our own.
Plan may disclose personal information collected from visits to its website or through other online interactions by individuals with Plan (including, but not limited to an individual’s IP address) if Plan deems it necessary to do so in order to comply with relevant laws.10. Accessing your personal information
Subject to some exceptions provided by law, you have the right to request access to the personal information which we hold about you. For security purposes, if you would like to access this information, we require you to put your request in writing using the contact details provided below. Plan will not charge you for lodging a request to access your personal information; however, Plan reserves the right to charge a reasonable fee to cover Plan’s costs incurred in procuring the personal information requested.
Where Plan does not allow you access to any part of your personal information, Plan will tell you the reasons why Plan cannot provide access.
Plan supporters can also access and update some of their personal details online at any time via MyPlan (https://my.plan.org.au).
If you want to access your personal information, correct the information you have previously given us, opt-out of future communications or withdraw your consent for us to hold your personal information, then please contact Plan using the contact methods included at the end of this Privacy Statement.
When contacting Plan to correct your details, please include your:
- contact details (name, postal address, telephone number); and
- Plan supporter number (if you have one).
11. Complaints and further information
If you have a privacy complaint, please contact us on the contact details provided below. Our Contact Centre will acknowledge receipt of your complaint and our Privacy Officer will investigate your complaint and work with you for an outcome. If your complaint indicates that there has been interference with your privacy by an entity other than Plan, our Privacy Officer may discuss the complaint with that other entity in an attempt to resolve it.
If you are not satisfied with the outcome of your complaint or the way we handle it, you can make a complaint to the Office of the Australian Information Commissioner: http://www.oaic.gov.au/
If you would like further information on this Statement, if you want to access your personal information held by Plan, if you have any concern about the protection of your personal information, or wish to make a complaint please contact us by:
- sending an email to firstname.lastname@example.org, marking your request "Attention: Privacy Officer";
- calling our Contact Centre on 13 PLAN (13 7526) or +61 3 9672 3600 for callers outside Australia;
- posting a letter to Plan, marking your request "Attention: Privacy Officer", to the following address:
Plan International Australia
GPO Box 2818
Melbourne VIC 3001
12. Updates to this Privacy Statement
Plan reserves the right (at its discretion) to modify, amend or to replace this Statement from time to time. Plan will post the modified, amended or new Statement to its website in place of the superseded Statement. Plan will use its reasonable endeavours to notify you of the modified, amended or new Statement the first time you visit Plan’s website following the publication of the current Statement. Nonetheless, Plan recommends that you regularly check its Statement to ensure that you are familiar with the most-up-to-date version of its Statement.
European Union residents can click here to access additional information about Plan’s application of the General Data Protection Regulation (“GDPR”)