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.
1. PCYC Purpose and Context
2. Collection of Information and Type of Information Collected
4. Use and Disclosure of Information
5. Legal Compliance
7. Sensitive Information
9. Computer and email services
10. Club Security Surveillance
11. Access & Correction
12. Information Security
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,
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:
CEO, Police & Community Youth Clubs NSW Ltd
PO Box 595, Mt Druitt NSW 2770
PCYC will respond to your request within 30 days.
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 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.
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.
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.
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.
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).
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.
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 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.
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
J. Future changes
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.
· 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.
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
Authorised by PCYC Board, 25/3/2004 Issued by PCYC Risk, Compliance & Policy Committee 5/4/2004