SEW INC.’S COMMITMENT TO PRIVACY
SEW Inc. ABN 50 403 962 056 (SEW Inc.) is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws to the extent these laws apply to us.
ABOUT SEW INC.
SEW Inc. is an incorporated association and registered charity with the Australian Charities and Not-for-profits Commission, with DGR status. It is a social enterprise, working in partnership with HIV+ women in Tanzania.
WHAT INFORMATION DOES SEW INC. COLLECT ABOUT YOU?
Customers and donors
When you enquire about our enterprise, place an order for products or make a donation, a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection, but will typically include:
- your name, e-mail, postal address and other contact details;
- [personal details, including date of birth];
- financial information [such as credit card], bank account or other payment details; and
- any additional personal information you provide to us, or authorise us to collect, as part of your interaction with SEW Inc.
SEW Inc. may collect personal information about other individuals who are not donors or customers of SEW Inc. This includes service providers and contractors and any other individuals who interact with SEW Inc.. The kinds of personal information we collect will depend on the capacity in which you are dealing with SEW Inc. Generally, it would include your name and contact details.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
In limited circumstances, SEW Inc. may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by SEW Inc., we may collect health information about you in an emergency or otherwise with your consent.
We may collect personal information about children (for example, when children participate in events we are involved with). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.
You can always decline to give SEW Inc. any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
Visitors to our websites
The way in which we handle the personal information of visitors to our websites is discussed below.
HOW AND WHY DOES SEW INC. COLLECT AND USE YOUR PERSONAL INFORMATION?[Note: this section needs to be carefully reviewed and tailored to what happens in practice. Please confirm whether any personal information will be shared with any third parties – i.e. third party service providers (e.g. for processing payments). Under privacy laws you can only use personal information for the purpose it is collected and limited secondary purposes (such as administration). You should ensure that you are not sharing personal information with other organisations for unrelated purposes unless you have received a specific consent (such as an ‘opt in’ “yes I am happy for SEW Inc to share my information with XYZ”. In fact we don’t generally recommend you do this at all ].
SEW Inc. collects personal information reasonably necessary to carry out its enterprise and to raise funds for HIV+ women in Tanzania. We may also collect information to fulfil administrative functions associated with these purposes.
The purposes for which SEW Inc. usually collects and uses personal information depends on the nature of your interaction with us, but may include:
- responding to requests for information and other general inquiries;
- processing donations;
- completing financial transactions, including issuing receipts;
- fundraising activities and events and keeping you informed of our latest news, campaigns, appeals and projects – we may send you fundraising information by post, email or phone;
- responding to complaints; and
- reporting on our activities, including producing our annual report and reporting to government bodies.
SEW Inc. generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet (via our website) or social media, or in person. We may also collect personal information about you from other sources, for example:
- our affiliated associations; and
- third party suppliers and contractors who assist us to operate our enterprise.
SEW Inc. also collects and uses personal information for market research purposes and to innovate our delivery of products and services.
HOW DOES SEW INC. INTERACT WITH YOU VIA THE INTERNET?[Note: this section needs to be carefully reviewed and tailored to what happens in practice. It assumes that no personal information is being collected via cookies].
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
SEW Inc.’s website may contain links to third-party websites. SEW Inc. is not responsible for the content or privacy practices of websites that are linked to our website. [Note: how are payments processed? Are they processed by a third party service provider? See previous comments re PCI DSS compliance].
CAN YOU DEAL WITH SEW INC. ANONYMOUSLY?
SEW Inc. will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is not practicable for SEW Inc. to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.
HOW DOES SEW INC. HOLD INFORMATION?
SEW Inc. stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia [##and overseas – list countries here]). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
SEW Inc. maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our website does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our website are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
DOES SEW INC. USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
SEW Inc. may use or disclose your personal information for the purpose of informing you about our upcoming fundraising activities and events, new projects and any other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, SEW Inc. may still contact you in relation to its ongoing relationship with you.
HOW DOES SEW INC. USE AND DISCLOSE PERSONAL INFORMATION?
For customers and participants
If you are a customer or participant/supporter in an event, we may disclose your personal information to the venue where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur. [Note: While we have included this, we generally recommend you seek express permission if an individual is going to be significantly featured in anything more than social media posts (for example print advertising and promotion) this is especially the case for celebrities or other high profile individuals.]
Disclosure to volunteers, contractors and other service providers
SEW Inc. may disclose information to its volunteers and any third parties it engages, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
Personal information may also be shared between affiliated entities of SEW Inc., located overseas (if any).
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Use and disclosure for administration and management
SEW Inc. will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
- financial reporting;
- planning, managing, monitoring and evaluating our fundraising;
- statistical analysis and reporting;
- training staff, contractors, other workers and volunteers;
- risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
- responding to enquiries and complaints;
- obtaining advice from consultants and other professional advisers; and
- responding to subpoenas and other legal orders and obligations.
Other uses and disclosures
DOES SEW INC. DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?
SEW Inc. works with entities and sponsors across the globe. It is likely that your personal information will be disclosed to overseas recipients.
Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
SEW Inc. has affiliates in Tanzania. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which SEW Inc. and its affiliates operate.
HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You are entitled to access your personal information held by SEW Inc. on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that SEW Inc. may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au. The Office of the Australian Information Commissioner can only deal with complaints in circumstances where the Australian Privacy Principles or the Privacy Act applies to us.
HOW CAN YOU CONTACT SEW INC.?
The contact details for SEW Inc. are:
Privacy Officer[postal address]