At Corporate Citizen we recognise that your privacy is very important to you – it is to Corporate Citizen as well. We handle personal information provided by and about people every day. By personal information we mean information or an opinion about a person whose identity is apparent or can reasonably be ascertained.
The aim of Corporate Citizen is both to support and to ensure that it complies with the Privacy Act 1988 (Cth) (Privacy Act). Corporate Citizen also seeks to comply with the Spam Act 2003 (Cth) (Spam Act) that is aimed at reducing the number of unsolicited electronic commercial messages that you receive.
The information set out below is largely a summary of our obligations under the Privacy Act, in particular the relevant privacy principles.
We believe that this Policy will address any potential concerns you may have about how personal information you provide Corporate Citizen is collected, held, used, corrected, disclosed and transferred. You can obtain more information on request about the way we manage the personal information we hold. If you seek any further information please contact us in one of the ways set out below.
Collection and Purpose for Collection
In the course of our activities we collect and hold personal information such as details of donors, charities, employer partners for our charity programs and members of the public who make use of Corporate Citizen's services or website. Personal information may also be collected when individuals provide personal information intended for publication on Corporate Citizen's website.
Our main purposes for collecting that personal information include:
We will only collect personal information from you that is necessary for one or more of our functions and activities.
- to process and administer donations made by individuals (either directly to Corporate Citizen or via their employer) to various charities;
- to provide (by electronic means or otherwise) updates and other forms of communication in relation to our services and our business partners, including charities;
- to monitor who is accessing our website or utilising services available on our website;
- to provide you with news on our activities and general promotional material we believe may be useful to you depending on your interactions with Corporate Citizen;
- to deliver and improve services offered by us or our business partners, including charities;
- to regulate the activities of donors and our employer and charity business partners;
- to comply with our legal obligations, including without limitation under the Charitable Fundraising Act 1991 (NSW), the Charitable Fundraising Regulation 2015 (NSW) or equivalent State, Territory or Federal legislation;
- to investigate complaints made in relation to breaches of our Terms and Conditions; and
- to enable Corporate Citizen to respond to queries from third parties, including without limitation charities and employer partners, in relation to amongst other things donation services.
We will collect personal information from you only by lawful and fair means, without being unreasonably intrusive, such as when you complete a donor form (online or hard copy) or questionnaire etc. At or before the time we collect personal information from you we will take reasonable steps to inform you why we are collecting that personal information, who else we might disclose that personal information to and what will happen if you do not provide personal information to us.
Where reasonable and practicable, we will only collect personal information about you, from you. However we may also collect personal information from you from third parties such as employer business partners or charities where you have or are currently participating in any form of donation program offered by Corporate Citizen.
Wherever it is lawful and practicable, we will give you the option of not identifying yourself or not providing personal information when entering transactions with us. However, failure to provide full and complete information we request may mean that we are unable to provide services to you fully and properly.
Once we hold personal information we will take reasonable steps to keep it accurate, complete and up-to-date.
If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Policy. Without limitation this includes our employer and charity business partners.
Use and disclosure
We will only use your personal information for the main purpose we told you it was needed for, except where you consent to us using that personal information for another purpose, where the other purpose is related to the main purpose and you would reasonably expect us to use the personal information for that other purpose, or where it is permitted or required by law, or we reasonably believe it is necessary on health or public safety grounds to use the personal information for another purpose.
Where possible (for example, where not otherwise required by law or regulatory standards), prior to the online publication of personal information we will ensure the de-identification of personal information is undertaken. This enables the value and utility of information published and provided on online resources to be maximised. Corporate Citizen will de-identify personal information by removing or modifying identifying features such as name, address, or date of birth, remove or modify quasi-identifiers such as general, profession or income and /or by suppressing or modifying data with broader categorisations.
In order to fulfil the purposes set out above we may provide access to your personal information to third parties with whom we have a business relationship, for example those who maintain and update our database, who assist with mail-outs, our charity partners and our employer partners.
There are some circumstances where by law we are required to disclose your personal information, including to Courts, Tribunals or law enforcement agencies.
In relation to direct marketing, where practicable we will seek your consent before we use your personal information for this purpose. You may tell us at any time you do not wish to receive any further direct marketing materials – if you do, we will stop sending you such materials.
In accordance with the Spam Act, should you wish to unsubscribe from commercial electronic messages from Corporate Citizen, all future commercial electronic messages from Corporate Citizen will enable you to unsubscribe from that particular type of electronic message from Corporate Citizen and this can be done at any time. If you do not unsubscribe, Corporate Citizen will continue to send you relevant information of the types described above.
Corporate Citizen may also use messaging methods other than email.
Access and correction
If you ask, we will tell you what personal information we hold about you, and what we do with it. We will facilitate access to you by allowing an inspection of your personal information in person, or by providing copies or a summary of relevant documents, depending on what is most appropriate in the circumstances, following receipt of your request. Any charge we make for providing access will be reasonable.
If you can show us that the personal information is inaccurate, we will take reasonable steps to correct it. Note that we need not provide access to personal information in several types of situation, for example where a request is frivolous, or where to provide access would pose a threat to health or public safety, unreasonably interfere with another person’s privacy, or be a breach of the law. If we refuse access we will advise you of our reasons for doing so.
We will protect personal information from misuse and loss, and destroy or permanently de-identify personal information we no longer need. Information may be stored in hard copy or electronic format or in both formats.
When you visit our website or otherwise login to your personal page with Corporate Citizen, details may be recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually (other than details associated with you physically logging into our website).
We will not adopt as our own any identifiers that you may provide to us such as TFNs, Medicare numbers etc.
Third party websites
Overseas disclosure of Personal Information
Whilst not our primary intention at this time, we may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the Asia-Pacific, European Union or the United States of America. We may also use cloud storage and IT servers that are located offshore.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
We are committed to providing donors, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints.
If at any time you have any complaints in relation to privacy, please contact our Compliance Officer at one of the points referred to below. We will seek to address any concerns that you have through our complaints handling processes, but if you wish to take matters further you may refer your concerns to the Office of the Australian Information Commissioner (https://www.oaic.gov.au/).
Changes to this Policy
We are constantly reviewing our statements and policies in an attempt to keep up to date with market expectations and legal developments. Subsequently, we may change this Policy from time to time as the need arises.
If you seek any further information from Corporate Citizen about this Policy or generally please contact our Compliance Officer at one of the reference points below:
Attn Corporate Citizen Compliance Officer
L6, 260 Elizabeth Street
Sydney NSW 2000
Phone +61 2 8114 9770
Further information on privacy in Australia may be obtained by visiting the web site of the Office of the Australian Information Commissioner at www.oaic.gov.au
Updated 8 March 2015