1. About this policy
This policy explains how AAWAA collects, holds, uses and discloses personal information, and how individuals can seek access to or correction of that information.
2. Scope
This policy applies to personal information collected by AAWAA through its website, donation forms, membership or supporter records, program participation, volunteer engagement, events, email and telephone enquiries, funding applications, and other dealings with AAWAA. It applies to information collected from members, donors, volunteers, employees, contractors, service users, stakeholders, and other people who interact with AAWAA.
3. Privacy framework
AAWAA seeks to handle personal information in a transparent, secure and lawful manner consistent with the Privacy Act 1988 (Cth) and the Australian Privacy Principles, notwithstanding that AAWAA is not currently required by law to comply with them.
4. What personal information AAWAA may collect
AAWAA may collect personal information that is reasonably necessary for its activities and operations, including:
- name, title and contact details
- postal address, email address and telephone number
- donation history and payment-related records
- membership, subscription or supporter details
- volunteer, employment or contractor application details
- records of communications, enquiries or complaints
- event registration and attendance details
- information relevant to grants, advocacy, service delivery or community engagement
- photographs, recordings or testimonials where consent has been given or collection is otherwise lawful.
5. How AAWAA collects personal information
AAWAA generally collects personal information directly from the individual concerned, for example when a person:
- makes a donation
- subscribes to updates or newsletters
- applies to become a member, volunteer, employee or contractor
- attends an event or participates in a program
- completes a form, survey or application
- contacts AAWAA by email, phone, social media or through the website.
AAWAA may also collect personal information from third parties where this is lawful and reasonable, including from referees, funding bodies, service providers, publicly available sources, or a person authorised to act on the individual’s behalf.
6. Why AAWAA collects personal information
AAWAA may collect, hold, use and disclose personal information for purposes connected with its charitable objects and operations, including to:
- process donations and issue receipts
- maintain supporter, donor, member and stakeholder records
- communicate about campaigns, events, programs, services and advocacy activities
- assess and manage volunteer, employment, contractor or governance applications
- deliver services, supports, education or community activities
- respond to enquiries, feedback and complaints
- comply with legal, accounting, governance and regulatory obligations
- protect the safety, wellbeing and rights of staff, volunteers, participants and the community
- improve AAWAA’s operations, website, communications and service delivery.
AAWAA will take reasonable steps to notify individuals at or before the time of collection about relevant matters, including the purpose of collection and any usual disclosures, consistent with good privacy practice under the Australian Privacy Principles.
7. Disclosure of personal information
AAWAA may disclose personal information where reasonably necessary for the purposes above, including to:
- employees, officers, board members and volunteers who need the information to perform their roles
- professional advisers such as accountants, auditors, lawyers and insurers
- technology, payment, database, email, cloud storage and other service providers
- funding bodies, partner organisations or contractors assisting with AAWAA’s activities
- government, regulatory, law enforcement or safeguarding bodies where required or authorised by law
- other parties where the individual has consented.
AAWAA will not sell personal information. If AAWAA engages third party providers, it will seek to ensure they handle personal information appropriately and consistently with AAWAA’s privacy obligations and expectations.
8. Direct marketing and fundraising communications
AAWAA may use contact details to send updates about its work, appeals, campaigns, events and other matters likely to be of interest to supporters, members and donors where lawful. Individuals may opt out of receiving marketing or fundraising communications at any time by using the unsubscribe function or contacting AAWAA directly. Personal information will be used for the primary purpose for which it was collected unless another lawful basis applies.
9. Website, analytics and cookies
AAWAA’s website is hosted on WordPress.com, a service provided by Automattic Inc. AAWAA’s website uses a website analytics tool provided as part of that hosting service, to understand how the website is used.
This service may collect information such as IP address, browser type, approximate geographic location (such as country, region or city), the pages visited, the length of a visit, and the referring website. The service sets first-party cookies to distinguish visitors and compile these statistics; these cookies may remain on a device for up to two years. AAWAA does not use this tool to identify individual visitors, and the underlying data is held by Automattic Inc. for a limited period as part of its service.
Individuals can adjust their browser settings to block or delete cookies at any time, though this may affect some website functions.
10. Storage and security
AAWAA holds personal information in electronic and physical form and takes reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure. These steps may include access controls, password protection, multi-factor authentication, secure storage systems, staff and volunteer training, confidentiality requirements, secure disposal practices, and review of service providers.
11. Retention and destruction
AAWAA will keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, or for as long as required by law, regulation, taxation, accounting, funding or governance obligations. When personal information is no longer required, AAWAA will take reasonable steps to securely destroy or de-identify it.
12. Overseas disclosure
AAWAA’s website hosting and analytics are provided by Automattic Inc., a company based in the United States. This means some personal information collected through AAWAA’s website, including the information described in section 9, may be stored or processed in the United States, and potentially in other countries where Automattic Inc. or its service providers operate infrastructure.
AAWAA takes reasonable steps to ensure that personal information handled overseas by its service providers is protected in a manner consistent with this policy and applicable privacy obligations. Individuals should be aware that a different privacy protection regime may apply to information held in the United States.
13. Access and correction
A person may request access to personal information AAWAA holds about them, or request correction of information that is inaccurate, out-of-date, incomplete, irrelevant or misleading. AAWAA may need to verify identity before granting access or making corrections. In some circumstances, AAWAA may refuse access or correction where the law permits, but if that occurs AAWAA will provide reasons unless it would be unreasonable to do so.
AAWAA will endeavour to respond to access or correction requests within a reasonable time, ordinarily within 30 days.
14. Anonymity and pseudonyms
Where lawful and practicable, AAWAA will allow individuals to interact anonymously or by using a pseudonym. However, in some cases AAWAA may need identifying information in order to provide services, process donations, issue receipts, respond to concerns, meet safeguarding obligations, or comply with the law.
15. Complaints
A person who believes AAWAA has not handled their personal information appropriately, or has breached this policy, may make a complaint in writing using the contact details below. AAWAA will review the complaint and respond within a reasonable time. If the person is not satisfied with AAWAA’s response, they may raise the matter with the Office of the Australian Information Commissioner (OAIC), although AAWAA notes that, as an organisation currently outside the scope of the Privacy Act, the OAIC’s formal jurisdiction over AAWAA’s handling of personal information may be limited.
16. Contact details
Secretary
AAWAA
admin@womensadvocacy.net
17. Changes to this policy
AAWAA may update this policy from time to time to reflect changes in law, guidance, technology, service providers or AAWAA’s operations. The current version will be made available on AAWAA’s website and otherwise provided on request.