The Fund is required by the Privacy Act 1988 (Cth) (Privacy Act) to comply with the Australian Privacy Principles (APP) (subject to other provisions of the Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal. The Fund is also required to comply with the Spam Act 2003 (Cth) (Spam Act) and the Do Not Call Register Act 2006 (Cth) (Do Not Call Register Act).
1.1 What is personal information?
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; and whether the information or opinion is recorded in a material form or not. Special provisions apply to the collection of personal information which is sensitive information. Sensitive information includes (for example) information about a person’s membership of a professional or trade association. The Fund does not collect sensitive information (as defined by the Privacy Act) without consent.
The kinds of personal information the Fund collects and holds
1.2 Collection of personal information by the Fund
To the extent required by the Privacy Act:
The Fund will not collect personal information about you unless that information is necessary for one or more of our functions or activities, for example:
When the Fund collects personal information directly from you, we will take reasonable steps at or before the time of collection to ensure that you are aware of certain key matters, such as the purpose for which we are collecting the information, the organisations (or types of organisations) to which we would normally disclose information of that kind, the fact that you are able to access the information and how to contact us.
Where the Fund collects information about you from a third party, we will take reasonable steps to ensure that you have consented or have been made aware of the details as set out above.
Similarly, the Fund may be required to provide your contact details to third party suppliers of services which you would reasonably expect the Fund to do in order to provide its services. The Fund provides the opportunity to opt-out of such third party arrangements.
The Fund acknowledges that there is no obligation for an individual to provide it with personal information. However, if an individual chooses not to provide the Fund with personal details, the Fund may not be able to provide the individual with the services reasonably expected to be provided.
1.3 Why does the Fund collect personal information?
The Fund collects personal information from you that is necessary for it to perform its functions. The types of personal information the Fund collects, and the purposes of collecting that information, include:
Generally, we collect information directly from the relevant individual. Sometimes, we may need to collect information about an individual from third parties including other third party information sources. We will do this if the individual has consented for us to collect, use or disclose the information in this way, or where it is not reasonable or practical for us to collect this information directly from the individual.
Provision of your personal details is the most effective method for the Fund to communicate with you, and to assist in the efficient delivery of services.
From time to time, the Fund may survey its contacts on a range of issues. These surveys help us to identify and analyse the ongoing needs of our stakeholders and the quality of our products and services. If you do not wish to participate in these surveys, please let us know.
1.4 Use and disclosure of personal information by the Fund
If the Fund uses or discloses your personal information for a purpose (secondary purpose) other than the main reason for which it was originally collected (primary purpose) to the extent required by the Privacy Act, we will ensure that:
1.5 How might we contact you?
We may contact you in a variety of ways, including by post, email, SMS, social media, mobile devices or apps, telephone call or facsimile.
We will not send you any commercial electronic messages such as SMSs or emails unless this is permitted by the Spam Act. Any commercial electronic message that we send will identify the Fund as the sender and will include our contact details. This message will also provide an unsubscribe facility. If you do not wish to receive commercial electronic messages from us, please let us know.
Do Not Call Register
We will not call you on a number listed on the Do Not Call Register unless this is permitted under Do Not Call Register Act. If you do not wish us to call you on a particular number, please let us know.
Website or mobile device activity
The Fund system requires that the web browser accept cookies, which are used to make logging-in possible. These cookies are not used to collect, store, track or monitor any personal information. As would reasonably be expected, the Fund may collect website and mobile device (e.g. apps) statistics (which includes pages accessed and search terms used) but this information is not identifiable (i.e. the Fund cannot tell who you are).
1.6 When does the Fund disclose personal information to third parties?
In performing our functions and activities (such as for conferences, presentations, and events as outlined above), we may need to disclose personal information to third parties where you may reasonably expect the Fund to use or disclose the personal information for a specific purpose. Third parties with whom the Fund may share your personal information include, where appropriate:
1.7 Data quality and security
All personal information collected by the Fund will be retained as part of a database, which will be securely monitored and maintained by the Fund or an approved host, which to the best of our knowledge is based in Australia. If the Fund stores personal information with a “cloud” service provider, the provider may be situated outside Australia. Subject to paragraph 1.6, the data will not be made available to a third party, unless it is legally required and verified, without the authority of the individual who provided the personal information. The Fund will take all reasonable steps to protect the security of the personal information that it holds. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy. Where information held by the Fund is no longer required to be held, and the retention is not required by law, then the Fund will de-identify or destroy such personal information by a secure means.
1.8 Access and correction of your personal information
The Fund will make available for inspection, free of charge, all personal information, based on the information supplied by the individual that it holds in relation to an individual, provided reasonable notice is given. In the event that such a request is made, the Fund will review our records to determine what personal information is held and endeavour to respond to your request as soon as possible. Please note that the Fund will request that identification is provided before personal information is released. In the event that any part of the personal information that the individual inspects is determined to be incorrect and requires alteration then the Fund will make such alteration in compliance with the corrected advice provided by the individual.
In some circumstances, the Fund may not permit access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision.
Please contact the Fund if you have any queries about the personal information that the Fund holds about or the way we handle that personal information. Contact details for privacy queries are outlined below.
Attention: Privacy Officer
The Crawford Fund Ltd
PO Box 4477
Kingston ACT 2604
Via email at: [email protected]
Telephone: 02 6188 4370
If you want to obtain additional information about your privacy rights and how you can enforce them, you can visit the website of the Office of the Australian Information Commissioner at: https://www.privacy.gov.au or https://www.oaic.gov.au/.
Policy creation date: April 2014
Policy review date: June 2014
Current version: 1
Owner: Privacy Officer
Next review date: June 2016