This policy has been drafted having regard to UNICEF Australia’s obligations under the Privacy Act 1988 (including the National Privacy Principles) (the Privacy Act).
UNICEF Australia is also a member of the following bodies:
- Australian Direct Marketing Association (ADMA) and we comply with its Code of Practice.
- Australian Council for International Development (ACFID) and we comply with its Code of Conduct.
1.1 UNICEF Australia will only collect Personal Information where the information is necessary for UNICEF Australia to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 UNICEF Australia collects Personal Information about our supporters (financial and non-financial) and members primarily to enable us to maintain accurate records about who donates to us; the purpose, if specified, for which donations are made; and so that we may meet our legal obligations, such as providing donors with official receipts for their donations.
UNICEF Australia also collects and uses Personal Information for secondary purposes including:
- Keeping our supporters informed about UNICEF Australia’s activities, campaigns and appeals
- Keeping our supporters informed about other services, products, campaigns and appeals which may be of interest to you and offer you the opportunity to subscribe to them
- Offering you the opportunity to participate in surveys carried out by UNICEF Australia or its agents.
We may ask for other information to enable us to better understand who our supporters and others who deal with us are, but the provision of that information is purely voluntary.
1.3 UNICEF Australia will notify individuals (including, but not limited to, our supporters) of the matters listed below at the time of collecting any Personal Information:
- the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
- other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
- our identity and how individuals can contact us, if this is not obvious;
- that individuals can access the Personal Information that UNICEF Australia holds about them;
- that individuals should contact UNICEF Australia if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
- the organisations or types of organisations to whom we usually Disclose the Personal Information;
- where applicable, any law that requires the Personal Information to be collected;
- the consequences (if any) for the individual if all or part of the Personal Information is not provided to UNICEF Australia.
1.4 Where it is not practicable for UNICEF Australia to notify its supporters and members of all of the Collection Information before the collection of Personal Information, UNICEF Australia will ensure that individuals are notified of the Collection Information as soon as possible after the collection. UNICEF Australia will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.5 UNICEF Australia will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for UNICEF Australia to collect such information for an activity or function.
1.6 UNICEF Australia will not collect Personal Information secretly or in an underhanded way.
1.7 UNICEF Australia will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.
1.8 If you are under 18 years of age, please make sure that you obtain your parent/guardians permission beforehand whenever you provide personal information. Personal information collected by UNICEF Australia that is identifiable as a young person (under eighteen); for the purpose of sending through educational resources as requested will not be stored.
2.1 UNICEF Australia will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related secondary purpose which would be within the relevant individual’s reasonable expectations.
2.2 UNICEF Australia uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 UNICEF Australia will ensure that:
- individuals are clearly notified of their right to Opt Out from further communications; and
- if the individual Opts Out of all communications the Opt Out will be respected by UNICEF Australia and implemented free of charge.
2.4 UNICEF Australia will not use Sensitive Information for any purpose other than the reasons for which the Information was originally collected.
2.5 UNICEF Australia may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 UNICEF Australia will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3.1 UNICEF Australia may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2 UNICEF Australia may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations. Examples of such functions are mailing services both postal and email, answering supporters questions about activities and programs, fraud prevention services, data analysis to group demographic attributes of supporters and processing credit card payments.
3.3 UNICEF Australia will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.4 In the rare event that UNICEF Australia is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors UNICEF Australia will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
3.5 UNICEF Australia may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.6 Sometimes UNICEF Australia extracts information from our collected records to produce aggregated data. This aggregated data does not identify individuals. UNICEF Australia uses the aggregated data for research purposes and may share the data with third parties.
3.7 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, UNICEF Australia will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
4. Information Quality
4.1 UNICEF Australia will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved. UNICEF Australia may utilise the services of third parties in order to main accurate personal information. Where such disclosure is made, we take reasonable steps to require these organisations comply with the National Privacy Principles.
4.2 UNICEF Australia will take steps to destroy or de-identify Personal Information should UNICEF Australia no longer need the information for any purpose for which the information may be used or disclosed by UNICEF Australia.
5. Information Security
5.1 UNICEF Australia requires employees and contractors to perform their duties in a manner that is consistent with UNICEF Australia’s legal responsibilities in relation to privacy.
5.2 UNICEF Australia will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within UNICEF Australia who have a genuine “need to know” as well as “right to know”.
5.3 UNICEF Australia will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
5.4 No data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, UNICEF Australia cannot ensure or warrant the security of any information you transmit to us over the internet, and you do so at your own risk. Once we receive your transmission, we make our best effort to try and ensure its security both on our systems and while in transit between our systems and the companies who provide us with various services.
6. Access and Correction
6.1 UNICEF Australia will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 UNICEF Australia will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting UNICEF Australia, as per the details included at the bottom of this document.
6.4 UNICEF Australia will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 Contact with UNICEF Australia via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
7.2 Any formal privacy related complaints should be directed in writing to the UNICEF Australia Privacy Officer Level 4 280 Pitt Street Sydney NSW 2000.
7.3 UNICEF Australia will endeavour to manage any privacy related complaint efficiently and in a timely manner.
8. Anonymous Transactions
8.1 UNICEF Australia will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to execute a donation, answer an inquiry or provide a service.
8.2 UNICEF Australia will allow its supporters and members to transact with it anonymously wherever it is lawful, reasonable and practicable to do so.
9. Transferring personal information overseas
9.1 UNICEF Australia generally does not send personal information overseas.
9.2 Some of UNICEF Australia’s third party contractors and service providers may perform certain services overseas. For instance, a third party contractor may utilise a server hosted overseas as a method to send emails to UNICEF Australia’s supporters. Where this occurs, UNICEF Australia takes reasonable steps to ensure that all Personal Information is handled in a manner that is consistent with the National Privacy Principles, preferably as part of the services contract. Third party contractors currently provide a component of their services in Ireland, the United States and the Philippines.
10. Online Privacy
10.3 Third party cookies
To better communicate UNICEF’s work, we sometimes embed photos and video content from websites such as flickr and YouTube. Pages with this embedded content may present cookies from these websites. Similarly, when you use one of the share buttons on our website, a cookie may be set by the service you have chosen to share content through. UNICEF Australia does not control the dissemination of these cookies; you should check the relevant third party website for more information about these.
In addition, if you linked to our websites from a third party website, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
10.4 Secure Online transactions
If you make a purchase through our website, we process your credit/debit card details securely over the Internet using an accredited internet payment security system. With the combination of SSL encryption on our website and a secure browser at your end, we take all reasonable measures to ensure that your credit/debit card and personal information are protected when you donate online. We also recommend that you take appropriate security precautions when accessing the internet via public Wi-Fi networks or shared computers.
10.5 Web browser cookies
If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org
, which contains comprehensive information on how to do this on a wide variety of desktop browsers.
10.6 Social Media
Our website and mobile site may contain links to online forums. Think carefully before you post or publish any Personal Information in these forums as it will be publicly available.
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Communications means the marketing of activities, campaigns, appeals and services by way of written, verbal or electronic means. The activities, campaigns, appeals or services which are marketed may be those of UNICEF Australia or a Related Body Corporate.
Disclosure generally means the release of information outside UNICEF Australia, including under a contract to carry out an “outsourced function”.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be used or disclosed for the particular purpose.
Sensitive Information means information or an opinion about an Individual’s:
- racial or ethnic origin; or
- membership of a political association; or
- religious beliefs or affiliations; or
- philosophical beliefs; or
- membership of a professional or trade association; or
- membership of a trade union; or
- sexual preferences or practices; or
- criminal record; that is also personal information; or
- Health Information about an individual
Use means the handling of Personal Information within UNICEF Australia.
Contacting UNICEF Australia
Telephone: 02 9261 2811
Level 4, 280 Pitt Street, Sydney NSW 2000