General Data Protection Regulation

How Plan International Australia applies the GDPR.

This section is intended to add to Plan International’s privacy policy and sets out how we comply with the General Data Protection Regulation (GDPR) with respect to the processing of personal data collected from residents of the European Union. It is not intended to replace Plan International’s Statement that applies to the collection, use and disclosure of personal information from individuals located in Australia.

This section applies whenever you visit this website, including any mobile website from a location within the European Union or when Plan International receives either directly or from a third party the personal data of an EU resident.

Data Controller

For the purposes of the GDPR, Plan International confirms that the data controller of this website is Plan International Australia, a company registered under the laws of Australia, whose registered office is located in Southbank, Victoria.

Where Plan International Australia receives the personal data of an EU resident from a third party, the data controller for such personal data is the third party which supplied the personal data to us. In most situations, the data controller will be Plan International Headquarters (based in the UK).

What personal data does Plan International collect about you and from whom?

When you access, subscribe or sign up to use the website, Plan International Australia may collect a variety of personal data about you. The types of information we collect from individuals (including EU residents) are set out in our Privacy Statement.

In addition, we may from time to time receive personal data from third party data controllers of the types set out in our Privacy Statement.

Use of your personal data

 

Where the GDPR applies to the personal data Plan International collects, we use and process personal data according to the requirements and restrictions of the GDPR. In particular, the organisation will only use and/or disclose your personal data if Plan International has a permitted lawful basis on which to use and/or disclose your personal data.

 

Generally, Plan International collects your personal data because it is necessary for:

  • performing Plan International’s obligations owed to you or to a third party under a contract;
  • the pursuit of Plan International’s legitimate interests (as detailed further below);
  • or complying with Plan International’s legal obligations.

 

Plan International Australia may also rely on your consent to use your personal data, including for marketing purposes. You may withdraw your consent to these activities at any time. If you withdraw your consent, unless another lawful basis applies, we will cease to process the affected data. Please note that withdrawal of consent may result in us being unable to provide you with the products and/or services you have ordered and paid for through the website, or to process your donation or support for Plan International Australia and any of the activities and programs it operates.

 

Plan International Australia may use your personal data for the purpose of performing a contract made between the organisation and you. This includes using your personal data for the purposes outlined in our Privacy Statement.

 

Plan International Australia may use your personal data for its legitimate interests, including those interests outlined in our Privacy Statement. Without limiting Plan International Australia’s Privacy Statement, our legitimate interests include using your personal data:

  • for promoting, marketing and advertising the organisation, the work we do to make a just world for children and equality for girls, and our products and services;
  • for statistical and demographic analysis, in order to understand the behaviour, activities, preferences and needs of Plan International’s customers, its supporters and donors;
  • for improving the website, to improve existing products and services and to develop new products and services;
  • to protect Plan International Australia’s brand, reputation and goodwill in the marketplace, by taking appropriate legal action against third parties who have infringed Plan International’s rights or otherwise are in breach of their legal obligations owed to the organisation;
  • to effectively and efficiently handle and resolve any legal claims or regulatory enforcement proceedings taken against Plan International;
  • for internal business operations and activities; and
    to monitor and to record telephone calls for training purposes.

Additionally, Plan International may also use your personal data for complying with its legal obligations and to enforce its legal rights.

Marketing communications

 

Where you have consented to receiving marketing communications directly from Plan International Australia, you agree that the organisation may use your personal data to contact you by your selected method of communication regarding new products, events, items or related activities which we anticipate you may find useful, together with communications regarding similar products and services Plan International offers.

 

We do not sell, trade or rent your personal data to other companies or partners.

 

You may always revoke your consent at any time by exercising the “unsubscribe” option in any marketing communications which you receive from us.

 

To whom Plan International Australia discloses your personal data

 

Generally, we will use its reasonable endeavours to disclose de-identified data to third parties. However, we may also disclose personal data to third parties. Such disclosures will occur only on an as-needs basis and only in order to facilitate the fulfilment of one or more of the reasons for which your personal data is being processed.

 

Subject to the foregoing, Plan International Australia may disclose your personal data to the categories of recipients outlined in our Privacy Statement.

 

How long does Plan International Australia keep hold of your personal data?

 

Plan International Australia keeps your personal data for as long as it is reasonably necessary to meet the relevant purposes for which the organisation collected your personal data, including for the purpose of satisfying any legal, accounting or reporting requirements.

 

To determine the appropriate length of time for holding your personal data, we take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use and/or disclosure of your personal data, the purpose(s) for which we process your personal data and whether we can achieve those purposes through other means, together with legal requirements imposed on Plan International Australia.

 

As a general rule, we generally retain personal data relating to sponsorships, donations and product purchases for up to seven years following the transaction.

 

Is personal data transferred outside the European Union?

 

As Plan International Australia is located in Australia, all personal data collected from you will be collected and held in Australia. Similarly, the organisation may from time to time receive personal data from its partners located in the European Union, including from Plan International Headquarters.

 

Plan International Australia has implemented appropriate safeguards in connection with the protection of personal data transferred from the European Union into Australia, into our control. Plan International Australia will use its best endeavours to ensure that any third party recipient located outside the European Union will take steps to safeguard the personal data transferred or disclosed by the organisation to the recipient.

 

Further cross-border disclosure or transfer of your personal data will only occur as envisaged in our Privacy Statement.

Security of personal data

 

To the maximum extent permitted by law, Plan International makes no representation or warranty, nor gives any guarantee to you that your access to our website and/or the content accessible on the website will be secure, uninterrupted and error free and that any data transmission over the Internet can be completely secure and, to the maximum extent permitted by law, Plan International cannot give you an absolute assurance or guarantee that the information you provide to us will be secure at all times.

 

Plan International takes reasonable steps to protect the personal data Plan holds from misuse and loss, and from unauthorised access, modification or disclosure. To prevent unauthorised access, to maintain accuracy, and to ensure proper use of personal information, Plan International has deployed physical, electronic and managerial processes to safeguard and to secure the personal data collected.

 

Use of cookies and links to third party websites

 

Please refer to our Privacy Statement with respect to Plan International’s use of cookies and in relation to links from our website to websites operated by third parties.

 

Your rights in respect of your personal data

 

Under certain circumstances, you have certain rights under the GDPR and the Privacy Act in relation to the personal data that Plan International holds about you. Under the GDPR, you can request to:

  • access information held about you, subject to Plan International verifying your identity and subject to our right to charge you a reasonable administrative fee to cover our costs incurred in relation to any repetitive, manifestly unfounded or excessive requests for access – where we refuse your request to exercise this right, we will give you reasons for its refusal and to outline the process by which you can complain about Plan International’s refusal;
  • rectify any incorrect or incomplete data that Plan International holds about you, subject to Plan International verifying your identity;
  • delete, restrict or remove personal data Plan International holds about you, subject to the relevant provisions in the GDPR;
  • transfer any personal data that Plan International holds about you to another party, subject to the relevant provisions in the GDPR;
  • and object to any further processing of your personal data, subject to the relevant provisions in the GDPR;

You can make all such requests to Plan International Australia by sending an email to [email protected], marking your request “Attention: Privacy Officer”; calling our Contact Centre on 13 PLAN (13 7526) or +61 3 9672 3600 for callers outside Australia; or
posting a letter, marking your request “Attention: Privacy Officer”, to the following address:

Plan International Australia
GPO Box 2818
Melbourne VIC 3001

Please note that in respect of all these rights, Plan International reserves the right to refuse your request based on the exemptions set out in the GDPR.

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