CCI Giving is strongly committed to protecting your privacy and those individuals on whose behalf you may seek a grant. We want to provide a safe and secure environment for you and will only collect information that is necessary for us to provide services to you, or where it is required by law.

The purpose of this Privacy Policy is to tell you what kind of information we may gather about you or your client, how we may use that information, and whether we will disclose it to anyone else. It also explains how we store the information you provide to us, how you may access or correct it, and how you can contact us.

In this Privacy Policy the terms "we", "our" and "us" refers to CCI GF Pty Ltd ACN 619941874 (CCI Giving). CCI Giving is committed to collecting and handling personal information in accordance with the privacy law obligations contained in the Privacy Act 1988 (Cth). We are committed to ensuring that all of our business dealings comply with the 13 Australian Privacy Principles (APPs) and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) and acknowledge the importance of safeguarding your personal details. The principles that relate to the protection of personal information are:

  • Open and transparent management of personal information.
  • Anonymity and pseudonymity.
  • Collection of solicited personal information.
  • Dealing with unsolicited personal information.
  • Notification of the collection of personal information.
  • Use or disclosure of personal information.
  • Direct marketing.
  • Cross-border disclosure of personal information.
  • Adoption, use or disclosure of government related identifiers.
  • Quality of personal information.
  • Security of personal information.
  • Access to personal information.
  • Correction of personal information.

The adoption of the APPs supports our management philosophy that promotes mutual trust, respect, equity and fair treatment of all our clients. CCI Giving supports:

  • fair and open information collection practices,
  • processes that ensure personal information kept by us is accurate, complete and current, and
  • the right to access and where necessary, correct information held by us.

What kind of personal information does CCI Giving collect and hold?

CCI Giving may collect two types of information:

  • personal information that can be used to identify individuals on whose behalf you may seek a small grant; and
  • sensitive information.

We will only collect information by lawful and fair means, and not in an unreasonable or intrusive way.

Personal information means information we collect and hold from which the identity of an individual is either apparent or can be reasonably determined. This may include:

  • an individual’s name, date of birth, gender,
  • contact details such as an individual’s address, telephone number, email address, and
  • in some instances, we may have collected sensitive personal information such as medical or personal circumstances information provided in support of a grant application.

You do not have to provide us with your client’s or clients’ personal information.

Sensitive Information

CCI Giving will not collect sensitive personal information revealing racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs, trade-union membership, sexual preferences, criminal record or details of health or medical information unless you have consented, or the collection is required or specifically authorised by law. In addition to any stated purposes for which it was collected the personal information you provide may be used to:

  • respond to your queries, feedback or complaints
  • communicate with you about your application, and
  • any related purposes.

CCI Giving may supplement the information we collect with information from other commercially available sources, business partners, or related and affiliated companies overseas.

If you do not want us to communicate with you about activities other than the one(s) you have directly engaged in, please contact us as outlined in the Contact section.

We are committed to only collecting personal information that is relevant to your application, we will only collect personal information directly from you. Where we collect information about you from someone else we will, wherever possible, make sure you know we have done this. You may be required to verify your identity such as providing your full name and date of birth.

The purposes for which your personal information is collected, held, used and disclosed

If CCI Giving has collected personal information, we will manage it in accordance with the APPs and the Privacy Act. We use personal information only for purposes consistent with the reason you provided it, or for a directly related purpose, such as to assess grant applications

We may collect your personal information from, and in some instances we may be required to disclose your personal information to:

  • Australian Philanthropic Services (APS), a not-for-profit entity that provides administrative and accounting services on behalf of CCI Giving,
  • third party suppliers such as IT vendors and/or consultants (but only for the strictly limited purpose of carrying out the relevant services),
  • external auditors,
  • regulatory authorities (if requested) including but not limited to the Office of the Australian Information Commissioner (OAIC), Australian Prudential Regulation Authority (APRA), the Australian Securities and Investments Commission (ASIC), AUSTRAC, the Australian Taxation Office (ATO), and the Australian Financial Complaints Authority (AFCA)
  • as required by a court/tribunal order, or
  • other parties as required by Australian law.

At CCI Giving we take reasonable steps to protect the personal information we hold about you from misuse or loss, and from unauthorised access, modification or disclosure. Where practicable we will always gain your consent before disclosing your personal information. We will endeavour to maintain control over your personal information even though it may be stored with, or is accessible to third parties.

Quality of personal information

We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and current. From time to time we may contact you and request that you notify us if your contact details have changed.

If you believe personal information we currently hold is incorrect or incomplete please contact CCI Giving as outlined in the Contact section.

Security of information

CCI Giving will use its best endeavours to ensure that your personal information is secure from misuse and loss and from unauthorised access, modification or disclosure. Access to your information will be restricted to those staff who are authorised and are required to access your personal information to carry out business functions (in which case they will require a password when accessing our systems). We take reasonable IT security measures including the use of firewalls, secure log on processes, segregated security level log on, encryption and intrusion monitoring technologies to secure your personal information. Electronic communication of CCI Giving confidential information outside of the organisation will be limited to that required for business operations and only to those with a Confidentiality Agreement in place. Our physical records are stored securely both onsite and offsite, and unauthorised access to our buildings is prevented by strict access protocols.

In line with the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth), we will notify you if we become aware of any unauthorised access to or loss of your personal information.

When personal client information is no longer required it is disposed of securely in designated secure bins, and reasonable steps will be taken by CCI Giving to permanently de-identify your personal information.

Open and transparent management of personal information

On request, we will take reasonable steps to let you know what sort of personal information we hold about you, for what purposes, and how we collect, hold, use and disclose that information.

CCI Giving maintains and reviews our Privacy Policy detailing our management of personal information within our organisation. We may update our Privacy Policy from time to time and will always publish the effective date when the policy is updated on our website.

How you may access your personal information and seek its correction

CCI Giving aims to ensure that your personal information is at all times accurate, up-to-date, complete, relevant and not misleading.

Correction of personal information

CCI Giving will take reasonable steps to correct personal information where we are satisfied it needs to be corrected, or if you request that the personal information of any client on whose behalf you apply requires to be corrected. You may contact us as outlined in the Contact section, and request that we update our records. We will not charge you for asking us to correct your personal information.

How you can access your personal information

On your request, CCI Giving will provide your clients with access to their personal information (including in the manner requested by them if it is reasonable to do so) within 30 days. Where a client has requested the retrieval of their personal information CCI Giving will ensure that the cost of retrieval, copying and sending the information is fair and reasonable. If the requested information is commercially sensitive, we may provide the client with an explanation rather than provide direct access.

In some cases, we may be permitted under the Privacy Act to deny you access to your personal information such as where we reasonably believe that Giving access would have an unreasonable impact on the privacy of other individuals; CCI Giving does not hold the personal information that you wish to correct; that the steps necessary to correct the information as requested are not reasonable in the circumstances; or that the request for access is frivolous or vexatious. If we deny you access to any personal information about you, we will provide you with reasons in writing, and will provide you with your options for complaining about our refusal.

Adoption of Government Related Identifiers

CCI Givingwill not use Government related identifiers (for example, a TFN or your Medicare number) as our own identifier of an individual unless we are required to do so.

We will not use or disclose an identifier assigned by a Government agency, unless the disclosure is required or specifically authorised by law, or is reasonably necessary for us to fulfil our obligations to an agency or State or Territory authority.

Anonymity and pseudonymity

Wherever it is lawful and practicable, we will give the option of not identifying individuals on whose behalf you collect personal information, or of using a pseudonym when dealing with us. However in most circumstances, there will be legal obligations that require identification of the individual when entering into business transactions with CCI Giving.

Disclosure of your personal information to overseas recipients

CCI Giving will generally not transfer information outside Australia. CCI Giving may be required to transfer information outside Australia in circumstances permitted by the Privacy Act, such as where the transfer is necessary for the performance of a contract in your interest between CCI Giving and a third party.

CCI Giving will take reasonable steps to ensure that the information which it has transferred will not be collected, held, used or disclosed by the recipient of the information in a way that is inconsistent with, and does not breach the APPs.

Privacy Complaints

CCI Giving is happy to deal with any concerns regarding your Privacy. If you believe that an act or practice of CCI Giving has interfered with a client’s privacy and potentially breached an APP, you may contact us as outlined in the Contact section, with details of the complaint. CCI Giving will review and respond to your complaint within 30 days. We will not charge for making or investigating a privacy complaint.

In the event that you allege we have breached an individual’s privacy, we will:

  • provide an individual with assistance explaining the internal process and details on how to take a complaint further,
  • respond within a reasonable period of time after the request is made, and
  • give reasons for our decision on the privacy complaint.

How to Contact Us

You may ask us for access to, or request that we correct your personal information by contacting a member of our staff directly, or by writing to us, calling us on

Contact

CCI Giving

GPO Box 180

Melbourne VIC 3001

03 9934 3197

Email

ccigiving@ccinsurance.org.au

If you require further general information about your privacy rights, or wish to make a formal complaint, you may contact the Privacy Commissioner at the Office of the Australian Information Commissioner by using the contact details below:

Mail: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001

Email: enquiries@oaic.gov.au

Visit their website: www.oaic.gov.au

Call their Privacy Hotline: 1300 363 9922

Last updated: 22 February 2018