Privacy Policy

1. Policy Statement

1.1 Camp Quality respects and is committed to protecting the privacy of the individuals whose personal information it collects. We are bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth).
1.2 This policy lists the personal information we collect from various individuals, how we collect, why we need the information and to whom we disclose the information. It details how stakeholders can make a complaint regarding any privacy issue or concern.
1.3 This policy is available and easily accessible on the Camp Quality website at https://www.campquality.org.au/Privacy-Collection_Statement

2. Definitions

2.1 Government related identifiers: are identifiers assigned by an agency, State or Territory authority, an agent of an agency or authority, or a contracted service provider for a Commonwealth or State contract.
2.2 Involved person: an individual connected to Camp Quality operations, activities and events - including employees, donors, research study participants, recipients of support services including individuals attending our camps, participants in advocacy campaigns or health promotion projects such as our puppet shows, suppliers, volunteers and service providers.
2.3 Personal information: information or an opinion about an individual who is identified by the information, or whose identity can be easily ascertained from the information. Examples of Personal Information we may collect include name, address, tax file number, credit information or any information from social media, and online data collection.
2.4 Sensitive Information: includes information which may not identify an individual but includes important details, such as specific health or medical information, a person's race, religion, political opinions, affiliations, philosophy, memberships or genetic information.
2.5 Use: all activities involving Personal Information such as collecting, recording, disclosure, organisation, retrieval, processing, aligning, combining, or deleting of Personal Information.

3. Responsibilities

3.1 General Managers
1. 3.1.1 Final review and approval of policies
2. 3.1.2 Ensuring legislative and legal requirements have been adequately addressed
3. 3.1.3 Dissemination and communication of approved policies using approved policy format
4. 3.1.4 Organisational support to ensure successful implementation of policies
5. 3.1.5 Request managers or employees to review or develop policies as appropriate
6. 3.1.6 Seeking expert advice policy matters as require
7. 3.1.7 Maintaining and implementing the Policy Review Schedule
8. 3.1.8 Conduct themselves in line with Camp Quality polices

3.2 Managers
1. 3.2.1 Review policies and provide input as requested
2. 3.2.2 Consult with employees or volunteers regarding policies as required
3. 3.2.3 Conduct themselves in line with Camp Quality polices
4. 3.2.4 Ensure employees and volunteers are aware of and understand policies

3.3 Employees and volunteers
1. 3.3.1 Review policies and provide input as requested
2. 3.3.2 Consult with volunteers regarding policies as required
3. 3.3.3 Conduct themselves in line with Camp Quality policies

3.4 Privacy Officer
1. 3.4.1 Role held by the Compliance Manager.
2. 3.4.2 Responds to complaints lodged by individuals.
3. 3.4.3 Act as Data Breach Review Team Coordinator pursuant to the Data Breach Policy.

4. Policy Practice and Procedure

4.1 Collecting personal information of involved persons
1. 4.1.1 Where possible Camp Quality collects personal information directly from involved persons, in person, on the telephone, via mail, email or online.
2. 4.1.2 Some information is also collected from third parties such as contractors, health professionals, government bodies and social services.
3. 4.1.3 In circumstances where information has been collected from third parties, and it is not clear whether we have permission from the individual to disclose the information, Camp Quality takes reasonable steps to obtain such permission and ensures the purposes for which information is collected is made clear. Camp Quality collects information for several purposes, including but not limited to:
  - marketing;
  - fundraising;
  - providing services and programs; and
  - health promotion.

4.2 Use of personal information
1. 4.2.1 Camp Quality uses personal information for the purpose for which:
  - it has been provided;
  - it is reasonably related to secondary purposes, which are within the contemplation of the parties (and are directly related, if the information is sensitive information);
  - any other purpose you have consented to; and
  - any other purpose permitted under the Privacy Act 1988 (Cth). This may include:
    - verification of identity;
    - to enable Camp Quality to establish and administer its services;
    - for the purposes of managing relationships with families;
    - handling enquiries
    - to handle communications with individuals, agencies or representatives;
    - to comply with legal and regulatory obligations including any recommendation, request, rule, order or direction of any regulatory, governmental authority, court or tribunal;
    - to conduct marketing activities, including research and analysis in relation to Camp Quality;
    - to provide electronic communications;
    - to conduct recruitment processes, including the assessment of suitability for future roles; and
    - any other purposes related to the above.

4.3 Disclosure of personal information
1. 4.3.1 Camp Quality discloses personal information for the purposes for:
  - which it has been provided;
  - reasonably related secondary purposes which are within the contemplation of the parties (and are directly related if sensitive information);
  - any other purpose you have consented to; and
  - any other purpose permitted under the Privacy Act 1988 (Cth).
2. 4.3.2 Depending on the services, or the relationship to Camp Quality, your personal information may be disclosed to:
  - an employer;
  - a bank or financial institution;
  - to third party suppliers and vendors to the extent necessary for the establishment, provision, and administration of the applicable services
  - an insurer;
  - personnel, agents, contractors and service providers involved in providing managing or administering services;
  - companies who provide information and infrastructure systems to Camp Quality, including cloud storage providers;
  - anyone acting on an individual’s behalf;
  - professional advisors, consultants, accountants, lawyers and auditors;
  - to anyone to whom consent has been provided;
  - where required to do so by law; and
  - for any other purpose related to the above.

4.4 Direct Marketing
1. 4.4.1 Personal information may be used from time to time to distribute current information pertaining to areas including (but not limited to) services and programs, fundraising events and opportunities, and changes to Camp Quality.
2. 4.4.2 By providing personal information, consent is given to receiving such information, including by phone, email, SMS, and social media, until the individual unsubscribes.
3. 4.4.3 Sensitive information will not be disclosed for direct marketing purposes unless consent is provided for that kind of disclosure.

4.5 Cookies, advertising, and tracking
1. 4.5.1 Your IP address is the identifier for your computer when using the internet. Your IP address may be collected for you to interact with Camp Quality’s website.

4.6 Using government related identifiers
1. 4.6.1 Government related identifiers (eg. drivers licence number or tax file number) will not be disclosed other than to the extent required or authorised by law.

4.7 Protecting personal information of involved persons
1. 4.7.1 Camp Quality holds personal information securely, both electronically and in hard copy files.
2. 4.7.2 Camp Quality takes reasonable steps to protect personal information from misuse, interference, and loss and from unauthorised access, modification, and disclosure. These steps include:
  - using Payment Card Industry Data Security Standards (‘PCIDSS’) software and processes; and
  - restrictions on the employees and/or volunteers who have access to personal files.
3. 4.7.3 Camp Quality takes reasonable steps to ensure, when the information is no longer needed, it is destroyed or permanently rendered anonymous.

4.8 Access or correct your personal information
1. 4.8.1 Camp Quality seeks to ensure all personal information collected and stored in its files and database systems is correct and accurate.
2. 4.8.2 Individuals may at any time request access to, or correction of, the personal information Camp Quality holds by contacting the Privacy Officer.
3. 4.8.3 Camp Quality will endeavour to meet or advise of the outcome of such a request within five business days of receipt.
4. 4.8.4 Camp Quality relies on individuals to inform if the information held is inaccurate and / or incomplete.

4.9 Making a Complaint
1. 4.9.1 For any privacy issues or concerns, including a complaint that Camp Quality has breached the Australian Privacy Principles, contact the Privacy Officer. Phone: 02 9876 0500 or email: privacy.officer@campquality.org.au or privacyofficer@campquality.org.au
2. 4.9.2 We may request you make your complaint in writing. Camp Quality will respond to your complaints within a reasonable period (usually 30 days).
3. 4.9.3 An unresolved complaint may be made to the Office of the Australian Information Commissioner (visit oaic.gov.au for further information).