PRIMARY OBJECTIVE
The primary objective of this policy
is to ensure that PCYC and its Clubs respect the
privacy of its staff, volunteers, donors, Club
members, licensees and contractors in the collection,
management and use of information.
It is also designed to ensure that
each of these parties are aware of and consent
to information being collected about them in the
circumstances and for the purposes set out in
this policy.
POLICY OUTLINE
The elements of the PCYC Privacy
Policy are:
1. PCYC Purpose and
Context
2. Collection of Information and
Type of Information Collected
3. Consent
4. Use and Disclosure of Information
5. Legal Compliance
6. Identifiers
7. Sensitive Information
8. Internet
9. Computer and email services
10. Club Security Surveillance
11. Access & Correction
12. Information Security
13. Complaints
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1. PCYC Purpose
and Context
PCYC provides activities through
community based Clubs that promote the welfare
and development of children and young people,
and, through partnership with NSW Police, programs
that prevent and reduce juvenile crime.
PCYC collects information from its
staff, volunteers, donors, Club members, licensees
and contractors for the following purposes:
· to assist it in delivering
activities, services and programs;
· to ensure it complies with
its legal obligations and those PCYC policies
developed in compliance with PCYC's legal obligations.
In particular, under PCYC's Member/User Protection
Policy it has obligations relating to working
with children (these incorporate obligations under
Children (Care and Protection) Act 1987, Children
Young Persons (Care and Protection) Act 1998 and
Commission for Children and Young People Act 1998)
and its Occupational Health and Safety Policy;
and
· to inform community members
of opportunities to support its work.
2. Collection
of Information and Type of Information Collected
PCYC collects personal information:
· through Club membership
forms: information may include name, age, gender,
contact details, parent/carer/guardian or family
details and contacts, activity interests, health
information including injuries and on-going medical
conditions, special needs relating to language,
religious or cultural background.
· through activity or program
enrolment and consent forms: information may include
name, age, gender, contact details, parent/carer/guardian
or family details and contacts, activity interests,
level of achievement or certification in the activity,
health information including injuries and on-going
medical conditions, health insurance details,
dietary needs/preferences, special needs relating
to language, religious or cultural background.
· through accident and incident
processes and forms: information may include name,
age, gender, contact details, parent/carer/guardian
or family details and contacts, health information
including medical conditions, injuries, harm and
treatment received, behavioural issues and actions
taken. Information may also include material collected
using security surveillance systems. After an
accident has occurred information may also be
collected about an individual from third parties
for the purposes of completing that form.
· through recruitment processes
and forms: information may include, name, age,
gender, contact details, parent/carer/guardian
or family details and contacts, qualifications,
previous work history, referee statements, prohibited
employment declaration, working with children
consent, working with children screening report,
and criminal record report.
· through donation information
forms: information may include name, age, gender,
contact details, PCYC areas of interest and if
relevant credit card details.
· Through third parties such
as telemarketers or mailing houses engaged by
PCYC to promote its activities.
· through Licences or Service
contracts: information may include name, age,
gender, contact details, qualifications, prohibited
employment declaration, working with children
consent, working with children screening report,
and criminal record report
· through individuals accessing
the PCYC web-site as set out in the Internet section
of this policy: the nature of the information
collected will depend on whether the person visiting
the web-site registers when they visit the website
but may include information about that person's
use of PCYC's website such as the time of visit,
duration and the pages visited.
As part of its communication and
donor programs, PCYC may also collect information
through publicly and commercially available information
sources and databases. PCYC only uses such sources
if its collection and use of this information
also complies with the National Privacy Principles
and the Spam Act 2003.
The following Collection Statement
is the approved statement to be used in all PCYC
documentation as required by law:
"PCYC respects the privacy
of its staff, volunteers, donors, club members,
licensees and contractors in the collection, management
and use of information. PCYC collects personal
information from its staff, volunteers, donors
and potential donors, club members, licensees
and contractors (including their employees, subcontractors
and agents) for the purposes of:
· Assisting in the delivery of activities,
services and programs
· Ensuring PCYC complies with its legal
obligations and other policies, in particularly
its obligations under child protection laws in
reporting accidents and injuries and in order
to meet its occupational health and safety obligations,
and
· Notifying people of opportunities to
support PCYC's work which can involve the supply
of information to mailing houses and telemarketers,
· Other functions and activities related
to the above purposes as set out in PCYC's Privacy
Policy
Where an individual choses not to supply personal
information, particularly information relevant
to employment, an activity, a member application
or consent, or a contractual arrangement, PCYC
may not be able to properly consider your application
or enter into a contract with you.
More details about PCYC's collection and use of
personal information can also be obtained at your
local PCYC Club. You can access personal information
about you held by PCYC. You will need to make
a request in writing to:
Chief
Executive Officer
Police & Community Youth Clubs NSW Limited
PO Box 316
Belmore NSW 2192
PCYC will respond to your request
within 30 days.
3. Consent
All information collected by PCYC
is collected from and with the consent of the
individual involved, or, in the case of children,
their parent/carer/guardian or other person legally
responsible.
The three exceptions to this are:
· Contact details available publicly and
collected to promote support of the PCYC to potential
donor and sponsors
· Information collected from witnesses
to accidents and incidents
· Information collected automatically when
individuals visit the PCYC website.
4. Use and Disclosure
PCYC uses the information collected
for the purposes outlined at the beginning of
this policy and those functions or activities
closely related to those purposes. Those functions
or activities are:
· Administration of membership
systems
· Tailoring of services and
activities to member, user or donor interests
and background
· Assistance to medical or
emergency service providers to deliver care in
an incident or emergency
· Communication to members,
users and donors about PCYC or promoting PCYC
activities or initiatives
· Surveys and analysis to
better target future PCYC activities and to better
promote opportunities to support PCYC activities
· Assessment of suitability
of potential employees and volunteers for work
with children and young people, including transfer
of information provided to NSW Police and Commission
for Children and Young People as part of that
process
· To assess, investigate
and process accidents and incidents and to assist
with insurance claims
· To comply with obligations
under law, such as those relating to Child Protection
All information collected by PCYC
will only be used for the purposes set out in
the policy unless;
· PCYC is required by law to disclose the
information
· PCYC is authorised under the Privacy
Act or the Health Privacy Act to use the information
for another purpose,
· A person consents in writing to PCYC
using information about them for another purpose
not specified in this policy.
PCYC may provide members or supporters
contact information to external partner organisations
such as direct marketing or telemarketers involved
in managing communications and promotions on behalf
of PCYC or in providing goods or services PCYC
believes will be of benefit or interest to its
members and supporters.
PCYC will only deal with such organisations
if they have a Privacy Policy based on the National
Privacy Principles and have formally committed
not to use information provided by PCYC for any
other purpose than that approved by PCYC. Members
will have an opportunity to opt-out of receiving
these communications in the membership form.
PCYC will not sell its information
to an outside organisation.
PCYC may collect information from
unsuccessful applicants for employment or volunteer
work. This information may be retained for future
recruitment purposes but normally such information
is destroyed. Information collected from individuals
appointed as employees or volunteers is retained
as part of a PCYC employee or volunteer record.
5. Legal Compliance
PCYC is aware of and complies with:
· the National Privacy Principles embodied
in the Commonwealth Privacy Act 1988.
· the current form of the Health Records
Information and Privacy Act 2002 NSW (Health Privacy
Act) in relation to PCYC's collection of Health
Information;
· the current form of the Spam Act 2003
where information is collected for the purposes
of informing community members of opportunities
to support its work.
PCYC will also act in a way consistent
with the Australian Direct Marketing Association
(ADMA) Code of Ethics in terms of its communication
and promotion of PCYC activities and initiatives
to Donors
PCYC regularly reviews this policy
to ensure compliance with these Acts.
Police Officers who also work within
PCYC, such as Club Controllers may collect information
concerning individuals in their role as Police
Officers and not on behalf of PCYC. In these circumstances
the Privacy Policy of the NSW Police and not this
policy applies.
6. Identifiers
Club members may be allocated a
membership number for administrative purposes.
Donors may also be allocated a computer-generated
number to identify them for donor administration
purposes. The numbers allocated have no relationship
to any identifier allocated by any other agency.
7. Sensitive
Information
PCYC is a non-government organisation
open to all who support our work and to all young
people who wish to participate in our activities
and programs or use our facilities. PCYC is committed
to respecting the rights and dignity of each person
with whom we deal and to treating every person
equally.
PCYC does collect information from
Club members ,potential and current employees,
volunteers, licensees, contractors (including
their employees, contractors and agents) that
may be considered sensitive. Such information
is only collected to the extent necessary to ensure
appropriate service to the individuals involved,
to ensure PCYC can fulfil its duty of care including
its duties in relation to working with children,
and to ensure PCYC complies with its legal obligations.
The type of sensitive information
PCYC collects relates to and is collected for
the purposes of:
· Medical conditions, health
insurance details and dietary needs, collected
to prevent medical incident and to assist in care
in emergency situations
· Special needs relating
to language, religious or cultural background
to ensure people from all backgrounds are afforded
every chance to participate in our activities
and to ensure that the conduct of activities are
respectful of different cultural backgrounds
· employment and volunteer
screening, including information obtained from
criminal record checks, to ensure PCYC meets its
obligations in regard to child protection
· Behavioural information
relating to misconduct by, and disciplinary action
against, members, licensees and contractors, collected
as part of PCYC's policy of member protection
and in order for it to manage conduct issues that
may arise.
8. Internet
PCYC's Internet Policy is contained
in the following statement:
This statement sets out PCYC's policies
relating to the collection and use of personal
information as it applies to the use of the PCYC
website and online resources.
Please note that separate privacy
policies may apply to websites made available
through the PCYC site, but not operated or endorsed
in any way by PCYC. Before disclosing personal
information to any third party site, individuals
should read the relevant policy or terms of use.
A. Collecting personal information
from using the PCYC website
There are two ways PCYC collects information about
individuals from its website:
If an individual is not registered
as a subscriber:
Whenever someone visits the PCYC site, the servers
automatically records information about the usage
of the website, such as the time of the visit,
its duration and the pages visited. This helps
PCYC to understand what parts of the site users
enjoy the most, and helps to ensure that content
is most relevant to users' interests. The information
collected remains anonymous, as it is not linked
to any other personal information. Therefore if
an individual has not disclosed his/her identity
on the site, such as by registering, PCYC does
not link a record of the use to the individual
personally.
If an individual does not want PCYC
to retain any information at all, even in an anonymous
form, he/she can use the Preferences on the browser
program to remove all cookies and set the browser
not to accept cookies in the future. For more
information on how to disable cookies, click here
If an individual is registered as
a subscriber:
If an individual registers with PCYC, to receive,
for example, 'Youth', PCYC's regular newsletter,
he/she will be asked for some personal information.
This may be as little as his/her first name and
an email address. If the individual would rather
make up a first name, this is OK. The email address
provided would be the place where the newsletter
would be delivered.
After registering, PCYC may also
collect information from individuals. Any further
collection of personal information will only occur
with consent from the individual. For example,
if an Annual Report or a newsletter is to be sent,
PCYC will need a postal address.
PCYC does not collect information
about individuals from other organisations or
from websites outside of PCYC.
B. Preserving privacy
Surveys show that most internet
users are concerned about their privacy, that
they want to keep control of their personal information,
and do not trust many of the web sites which they
visit. In fact around a third of internet users
give false information online rather than saying
who they really are.
PCYC understands that, even with
this privacy policy, some people still will not
feel comfortable disclosing their personal information
in order to register. If an individual is not
comfortable disclosing his/her real identity,
a pseudonym (a different name) can be used to
register. This way, a new identity (eg. John Smith,
Jane Doe...) is created and that's what PCYC will
call the user. PCYC won't know who the user really
is, but will still be able to find out what he/she
likes on the PCYC site, and send information about
PCYC and its work with young people.
Please note that if there are ever
any commercial advertisers on the PCYC site, those
advertisers or sponsors will never be given information
that identifies individuals (such as names or
email addresses).
C. Use of cookies and applets
by PCYC
Cookies are small pieces of information
that a website transfers to a user's computer
hard disk to make the individual's use of PCYC's
website easier, as it becomes more 'personalised',
in future. Most Web browsers are set to accept
cookies.
If an individual does not wish to
receive any cookies he/she may set the browser
to refuse cookies. (For more information on disabling
cookies, click here.) This may mean that in future,
the individual will not be able to take full advantage
of some parts of the PCYC site.
Cookies can enhance a user's enjoyment
of what PCYC offers as they help personalise the
experience of the website. They can make it easier
for users to shop online and can ensure that information
provided is most relevant to a user's interests.
Cookies can provide PCYC with aggregated information
on how people use PCYC websites, or, for example,
which advertisements visitors react to. This helps
PCYC to continually improve what users see. PCYC
may also use cookies to operate the registration
system, as they help to identify visitors who
have registered.
Cookies in and of themselves do
not personally identify users, although they do
identify a user's browser. The cookies simply
contain a unique identifier which helps PCYC to
know what customers find interesting and useful
on the website.
PCYC does not collect any personally
identifiable information by the use of cookies
nor is the information ever merged with personal
information otherwise held regarding individuals,
such as name, address or email address, or any
information that is considered sensitive or would
compromise an individual's privacy. PCYC does
not believe that its cookies pose any threat to
privacy, however at any time, a user can still
opt out of having any information on the use of
the PCYC site collected, by switching off cookies.
PCYC also measures and analyses
internet usage. Information on the use of its
website may include:
· The number of page views
(or page impressions) that occur on the site;
· Types of browsers that
visitors use;
· Page errors;
· The number of unique visitors
to the site;
· How long visitors (on average)
spend on the site; and
· Entry and exit points to
the site.
This aggregate, non-personal information
is only used internally, and in consultation with
PCYC's advertising agency - it is never, and will
never be made available outside PCYC.
PCYC does not and will not marry
any data collected in the course of this analysis
with any personal information collected on the
site.
The use of Javascript and/or Java
Applet is determined by the browser that each
individual uses. Internet Explorer users with
Version 4 or above will use Javascript method.
Netscape users, or users whose browser does not
support Javascript 1.1, will use the Java Applet
method.
D. Using and disclosing personal information
PCYC will only use or disclose any
information about an individual for the purposes
outlined in this policy.
E. Spam" (promotional email)
& Surveys
PCYC will not send "spam"
(unsolicited advertising information). PCYC first
asks whether individuals wish to have promotional
information sent to them.
If an individual receives promotional
information and does not wish to receive this
information any longer, he/she may remove his/her
name from PCYC's list either by visiting the website
from which the communication was sent and following
the instructions on how to withdraw information
from that site (where that facility is available),
or emailing PCYC on its privacy feedback form
and asking to be removed from the mailing list.
Seven days should be allowed for this request
to be processed.
From time-to-time, PCYC may request
information from individuals via surveys. Participation
in these surveys is completely voluntary and users
therefore have a choice whether or not to disclose
this information. Information requested may include
contact information (such as name and address),
and demographic information (such as postcode,
age, education). Survey information will be used
for purposes of monitoring or improving the use
and satisfaction of the PCYC site's features.
F. Storage & security of personal information
on the PCYC system
PCYC will take all reasonable steps
to keep secure any information that it holds about
individuals, and to keep this information accurate
and up to date. This information is stored on
secure servers that are protected in controlled
facilities.
PCYC uses a variety of security
measures to ensure the security of personal information
on its systems. User personal information is contained
behind secured networks and is only accessible
by a limited number of employees who have special
access rights to such systems. Any sensitive/credit
information supplied to PCYC is transmitted and
protected via Secure Socket Layer technology ("SSL")
and HTTPS protocol and then secured in the PCYC
database, to be accessed only as stated above.
In addition, PCYC employees and
the contractors who provide services related to
information systems are obliged to respect the
confidentiality of any personal information held.
However, PCYC will not be held responsible for
events arising from unauthorised access to your
personal information.
All credit card related information
provided to PCYC when ordering or downloading
files or other products from the Software and
Service is maintained by PCYC as highly confidential,
and PCYC will not share such credit card related
information to any third parties that are not
directly involved in completing the transactions.
Users can also play an important
role in keeping their personal information secure,
by maintaining the confidentiality of any password
and accounts used.
G. Individuals can access the information PCYC
keeps about them
As indicated above, if users are
not registered subscribers, PCYC does not collect
information that identifies them personally.
Subscribers will be able to add,
change or delete their personal information at
any time. If an individual wishes to know what
other information is held by PCYC about him/her,
an email may be sent to PCYC via the privacy feedback
form setting out the details of the request. PCYC
will endeavour to respond to all requests within
30 days.
H. PCYC and links to other websites
PCYC provide links to websites outside
of its own. These linked sites are not under the
control of PCYC, and PCYC cannot accept responsibility
for the conduct of companies or organisations
linked to its website.
Before disclosing personal information
on any other website, PCYC advises users to examine
the terms and conditions of using those websites.
I. What users can do if they have a problem
or question
If an individual becomes aware of
any ongoing concerns or problems with pages on
the PCYC website, PCYC will take these issues
seriously and work to address the concerns. Any
further queries relating to the PCYC privacy policy,
or problems or complaints can be pursued by using
the privacy feedback form or as set out in the
complaints section of this policy.
J. Future changes
PCYC's commitment to developing
and promoting a leading Youth Support site means
that it is constantly adding new pages and features
to the site. Because of this, from time to time,
its policies will be reviewed and may be revised.
PCYC reserves the right to change its privacy
policy at any time.
Any updated versions of the policy
will be posted on the PCYC website.
9. Computer and email Services
PCYC computers and email services
are provided to:
· employees for work purposes,
and
· Club members and club attendees who are
not members for educational and recreational purposes.
PCYC may collect information from
employees and club members about their personal
use of the computers and e-mail services. This
information may be used by PCYC to audit the use
of its computers and email services to ensure
compliance with this policy and the law.
10. Club Security
Surveillance
PCYC may establish at its Clubs
security surveillance systems to assist PCYC monitor
and protect the safety of its members. Video based
information collected via such systems is only
retained and used where an incident or accident
requires use of that information. The use of such
systems will be clearly advertised where installed.
11. Access &
Correction
PCYC takes all reasonable steps
to ensure that the information it collects, stores,
uses and discloses is accurate and regularly updated.
Members will be prompted to update any outdated
information in relation to their membership at
the time of annual renewal. PCYC will ensure that
the information collected is provided directly
by the person involved or a parent or guardian
when necessary.
Members, donors, employees and volunteers
may access their own personal information held
by PCYC. Such requests must be made in writing
and will be met within a reasonable time, usually
within 14 days. The "Application for Access
to Personal Information" form (P02-01) may
be obtained from PCYC and used for this purpose.
Access to the information will be
via the office at which the information is held,
usually the local club. There will be no charge
to a person accessing or correcting their information.
Access to personal information about
children under 18 will be permitted only for those
individuals with legal responsibility for the
child in question and where there is no perceived
risk to the child in providing that information.
Details will be forwarded by mail
or email to the recorded addresses or to alternate
addresses subject to the applicant providing proof
of identity (photo licence etc.).
12. Information
Security
PCYC will take every reasonable
step to secure personal information.
PCYC:
· Limits access to information
to authorised staff and volunteers;
· Educates staff and volunteers
in relation to this Policy;
· Ensures systems are in
place for the physical and electronic security
of information;
· De-identifies and/or destroys
information when identifiers are not necessary
and/or when the information is no longer required;
· Holds staff, licensees
and contractors accountable for failure to comply
with this Policy.
13. Complaints
Complaints concerning the use of
personal information or the application of this
policy must be made in writing to the Chief Executive
Officer who will deal with them under PCYC's Complaints
Management Policy.
14. Further
information on privacy
For more information about privacy
issues in Australia and protecting your privacy,
visit the Australian
Federal Privacy Commissioner's website.
RELEVANT LAW & LEGISLATION
· Commonwealth Privacy Act
1988 (Privacy Act).
· Health Records Information and Privacy
Act 2002 NSW
(Health Privacy Act)
· Spam Act 2003
FORMS
1. Application
for Access to Personal Information - (Form
P02-01)
2. Privacy
Feedback Form - (Form P02-02)
Authorised by PCYC Board, 25/3/2004
Issued by PCYC Risk, Compliance & Policy Committee
5/4/2004
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