We only collect and store personal information that is reasonably necessary for the proper performance of our activities and functions, and we employ reasonable endeavours to protect the security and safe storage of all personal information collected or received by us.
What Kind of Personal or Sensitive Information Do We Collect
‘personal information’ is information or an opinion, in any form (whether true or not), about an identified individual or an individual who is reasonably identifiable.
Personal information may range from contact details (i.e. name, date of birth, address and phone number) to sensitive information.
Collection of Personal or Sensitive Information
We may collect and hold personal and/or sensitive information about you when:
For Program Participants
- You provide information during your participation in the Program;
For Other Website Users:
- You provide information in relation to enquiries about our Program and other services;
Purpose of Holding Personal or Sensitive Information
We collect and hold the abovementioned personal and/or sensitive information for the following use and purposes:
- The delivery of our Programs to you;
- In order to contact you for responding to enquiries and direct marketing to you.
Your privacy is respected, and we do not sell, rent or trade your personal information. As you will note in our Terms of Participation we are committed and demand our clients and consultants to commit to maintaining all confidential information transmitted between us in confidence.
Not providing the information needed to us
You are under no obligation to provide any personal or sensitive information to us, however, if you restrict us from collecting any of this information we may be limited with our capacity to deliver the Program and other services to you.
How your Personal or Sensitive Information is Held
We may store your information in hardcopy and/or in electronic form on computer servers and cloud storage that are located in Australia and outside of Australia. We will on occasion, disclose personal information to overseas recipients. The situations in which we may transfer personal information overseas include:
- the provision of personal information to Peers (other participants accessing the Program from overseas (where consent has been given for this or we are otherwise legally able to provide this information));
- the provision of personal information to recipients using a web-based email account where data is stored on an overseas server; and
- the provision of personal information to foreign governments and law enforcement agencies (in limited circumstances and where authorised by law).
We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Our protection of your personal information includes:
- undertaking employee training to train our employees to respect the confidentiality of personal information provided us;
- using combinations of password-protection, two-factor authentication, and data encryption for data storage;
- software protection including:
- implementing a network firewall which governs internal and external access rights;
- email filtering measures;
- anti-virus software.
When your personal information is collected by us is no longer needed for any purpose for which it may be used or disclosed at such time it will be de-identified or destroyed provided that it is lawful for us to do so.
Disclosure of Personal or Sensitive Information
Your personal or sensitive information may be disclosed to the following third parties:
- Other participants (peers) (who may be outside of Australia);
- our employees, including third parties authorised to work on our behalf;
- Any party with a lawful entitled to obtain this information.
We take reasonable steps to ensure that third parties are bound by privacy obligations in relation to your personal information.
We use personal information from time to time for the following direct marketing purposes:
- whilst you are registered with us, with updates in relation to opportunities, market information and seasonal promotions;
- Subscribers to our email communications
In accordance with anti-spam legislation, whenever we send direct marketing to you, it is only to individuals who have given their express and/or implied consent for such communications to be sent to them since they registered with us and individuals are always given on opt-out or unsubscribe option in relation to such communications to remain compliant with anti-spam legislation. We treat your consent as specific to a certain kind of information, we do not generalise your consent to all communications.
Please note that personal information is not used by or disclosed to any third party for marketing purposes.
Visiting and Browsing The Website
When you visit at our Website, in addition to any personal information you submit, a record of the visit and logs (in server logs) is recorded. The record may include the following information for statistical purposes:
- your server address
- your top level domain name (for example .com, .gov, .org, .au, etc)
- the pages you accessed and documents downloaded;
- the address of any website that linked you directly to our site; and
- the type of browser being used.
We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider’s server logs.
Third Party Websites
Like many companies, we use ‘cookie’ technology on our website. ’Cookies’ are small text files a website can use to recognise repeat users, store registration data, facilitate the user’s ongoing access to and use of the website, allow a website to track usage behaviour and compile aggregate data that will allow content improvements.
Cookies are not programs that come onto your system and damage files. In some cases, cookies may collect and store personal information about you – the same privacy protections are applied to that information as we do to all other personal information we collect about you.
You can disable cookies or be warned when cookies are being used by adjusting your internet browser settings. However, disabling cookies may mean that you are not able to access parts of our website or to take advantage of the improved user experience that cookies can help provide.
Complaints and Contacts
We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, up to date, complete and relevant. If you believe your personal information is not correct you can request that we correct the personal information held about you. We will take steps to correct any information given its reasonable to do so. You may request details of the personal information, and we will generally provide you with access subject to some exceptions permitted by law. For example, if providing this access may disclose information about another person, or may disclose commercially sensitive information, we may need to refuse to grant you access. We may impose a fair charge in providing access.
We endeavour to acknowledge all formal complaints within 10 working days and set out to have resolved any complaints within an additional 30 working days. We will make reasonable endeavours to meet this time commitment except in circumstances where this is not possible due to the particular circumstance.