Privacy Policy

Introduction

Australian Marist Solidarity (AMS) is the international development arm of the Marist Brothers Star of the Sea

Province and the Marist Association of St Marcellin Champagnat. It has a particular focus on empowering young

people to transform their Jives and community. Promoting the dignity of the human person, as safeguarded by

internationally recognised human rights conventions, is a core value of AMS.

Australian Marist Solidarity (AMS) is committed to protecting the privacy of personal information which the

organisation collects, uses, holds, discloses, administers, keeps secure and gives access to. AMS is bound by the

Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs) and which regulates

the way AMS collects, uses, holds, discloses, administers, keeps secure, and gives access to, personal information.

AMS recognises the essential right of individuals to have their information administered in ways which they would

reasonably expect - protected on one hand and made accessible to them on the other. These privacy values are

reflected in this policy, which is compliant with the Privacy Act.

Definition of personal information

Information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and

• whether the information or opinion is recorded in a material form or not.

Purpose

The purpose of this policy is to provide a framework for AMS in dealing with the privacy, confidentiality and data

security considerations of organisational stakeholders. Stakehofders include AMS donors, Board members,

volunteers, staff members, contractors, consultants and project partners of AMS.

This policy applies to the information AMS collects and the manner in which AMS collects, uses, discloses, keeps

secure, stores and gives access to, the personal information obtained through the AMS website and social media, at

AMS-associated events, or participation in an AMS program.

Scope

This policy applies to all Board members, staff members, contractors, external consultants, agencies, volunteers and

project partners of or who work with AMS.

If any person provides us with their personal information, or the personal information of a child where that person

is the child's parent or guardian, then that person agrees to the information being collected, held, used and disclosed

as set out in this Privacy Policy.

Changes to this policy

AMS may update and revise this Privacy Policy from time to time. The current version of the Privacy Policy can be

accessed free of charge on our website, www.australianmaristsolidarity.org.au, or by contacting the AMS Chief

Executive Officer on the details below. The AMS Privacy Policy is reviewed annually.

What kind of personal information does AMS collect and hold?

AMS will only collect personal information from its stakeholders for the purposes outlined in the "Purposes for

collection and holding of personal information" section of the policy below. Accordingly, AMS may collect the

following information about a stakeholder:

• full name, date of birth and contact details (including residential address, e-mail address, and telephone

number);

• financial information to facilitate monetary donations and refunds, such as credit card and bank account

details.

How AMS will collect and hold information

• AMS will only collect and hold personal information when it is provided on a voluntary basis; personal

information obtained through visiting the AMS website, making a donation, signing up to the AMS newsletter,

or provided by any other means will be collected, held, used and disclosed as set out in this Privacy Policy.

• AMS uses a third-party cloud-based software platform, external CRM, to collect and store personal information

for access by AMS. There are security measures in place that enable AMS to restrict external CRM's access to

its database to times when it requires technical support. Further, external CRM also complies with the Payment

Card Industry Data Security Standards.

• AMS will only collect and hold personal information when it is received from stakeholders directly, including:

o through the stakeholder's use of AMS' website which includes external CRM;

o from communications between the stakeholders and AMS and its employees and representatives

(including communications conducted in person, over the phone, by email, by postal mail or otherwise);

and

o from promotional and marketing activities undertaken by AMS, in which AMS requests or otherwise

receives personal information from the stakeholder.

• AMS will only collect and hold pe rsonal information in relation to a child where that information has been

verified by the child's parent or guardian, unless specific circumstances require that the information

collection be made directly from the relevant child. (Refer to the AMS Safeguarding Policy for more

information.)

• In the event that AMS receives personal information that was not solicited by the entity, AMS will either

lawfully destroy said information or de-identify it as soon as is reasonably possible.

Use of AMS' website

AMS may use "cookies" to assist AMS aggregate statistical information about site usage. "Cookies" contain no

personally identifiable information but are small alphanumeric text files.

Storage and security

All personal information AMS collects will be held securely and in accordance with this Privacy Policy. AMS will

take all reasonable steps to protect any personal information collected and stored against misuse, loss,

unauthorised access and modification through the use of secure passwords, user logins, or other security

procedures, including firewalls and anti-virus technology.

AMS will also conduct regular audits to ensure the integrity of the AMS' information and communication

technology systems.

All AMS employees are made aware of their obligations under the Privacy Act during the induction stage of their

employment. Ongoing training is provided to ensure that AMS adheres to our established security practices.

However, AMS cannot provide any assurance regarding the security of information transmitted to AMS online, as

the internet is inherently insecure. Nor can AMS guarantee that the supply of information to AMS from a

stakeholder will not be intercepted. Information a stakeholder transmits to AMS online is at the stakeholder's own

risk.

Purposes for collection and holding of personal information

Use of personal information

• AMS will only use or disclose information for the primary purpose for which it was collected or a directly

related secondary purpose.

• P·ersonal information may be used for the following purposes:

o Maintaining accurate fundraising and donor records;

o Processing donations and issuing tax receipts;

o Acknowledging support, responding to comments, enquiries, suggestions and complaints, and

providing information and updates about AMS programs;

o Improving the quality of our services and for training purposes;

o Issuing AMS publications;

o Processing AMS volunteer program applications;

o Liaising with project partners to facilitate volunteer placements;

o Undertaking administration, marketing or promotional activities for AMS;

o Meeting professional and legal requirements.

• In relation to a seconda1y purpose, AMS will use the personal information only where:

o a secondary purpose is related to the primary purpose and the individual would reasonably have

expected AMS to use it for these purposes;

o court order (including in Family Law matters);

o the person has consented; or

o certain other legal reasons exist, or disclosure is required to prevent serious and imminent threat

to life, health or safety.

• In relation to personal information which has been collected from a person, AMS wi ll only use the

personal information for direct marketing, where that person would reasonably expect it to be used for

this purpose, and AMS has provided an opt out and the opt out has not been taken up. A stakeholder may

opt out at any time using the below contact details.

• For other uses, AMS will obtain consent from the person concerned.

Disclosure of personal information

AMS will:

• Only share personal information within AMS,

• Not share any personal information with third parties, except as provided by civil Privacy legislation.

• Undertake never to trade, sell, lend or rent any personal information to any other third party for any

reason, nor will we provide it to third parties unrelated to the purposes for which AMS may use the

personal information, as outlined above.

• Provide all individuals access to their own personal information, and a child 's personal information

where the person requesting the personal information is the child's parent or guardian, except where

disclosing the personal information may be a threat to life or health or AMS is authorised by law to refuse

to disclose the information.

How a stakeholder can access and correct personal information held by AMS

Stakeholders may request access to any of their personal information held by AMS. Generally, if the personal

information held by AMS about the stakeholder is incorrect, then AMS will correct it at the stakeholder's request.

The stakeholdds right to access is subject to some exceptions allowed by law. AMS will notify the stakeholder of

the basis for any denial of access to their personal information.

Stakeholders may contact the AMS Chief Executive Officer using the below contact details to request access to any

of their personal information held by AMS.

AMS will not charge a stakeholder for making a request for access to personal information, for making a request to

correct the information or making a request to associate a statement regarding accuracy with the personal

information if AMS disagrees with the stakeholder that the information is incorrect.

How a stakeholder can complain about a breach of privacy

If a stakeholder has a complaint about a breach of this Privacy Policy including the manner in which AMS has

collected, held, used, disclosed, kept, or given people access to the stake holder's personal information, then the

stakeholder may make a complaint to AMS using the contact details set out below. The stakeholder will need to

provide AMS with sufficient details regarding their complaint and any supporting evidence.

The stakeholder's complaint will be referred to the AMS Chief Executive Officer who will investigate the issue and

determine the steps AMS will take to resolve the complaint. AMS may ask the stakeholder to provide additional

information.

AMS will notify the stakeholder in writing of its response, generally within 30 days. If for any reason AMS needs

additional time to provide a considered response to the complaint, AMS will contact the stakeholder to explain the

delay and provide the expected timeframe. If the stakeholder is not satisfied with AMS' response, then the

stakeholder can contact AMS to discuss their concerns and if dissatisfied, can refer the complaint to the Office of

the Australian Information Commissioner www.oaic.gov.au.

Is AMS likely to disclose personal information to overseas recipients?

AMS will only disclose the donor's personal information (not including credit card and bank account details) to an

overseas entity where the donor or its authorised representative explicitly authorises the disclosure of their

personal information to the overseas entity for provision of scholarship in that country. Countries in which such

scholarships are usually provided include Timor-Leste.

Right to anonymity and pseudonymity

Stakeholders may choose to withhold their identity ( or to use a pseudonym) when dealing with AMS. However,

this may impact on AMS' ability to respond to the stakeholder or provide them with any necessary or desirable

information.

Request a copy of this privacy policy and further information

A copy of AMS' current Privacy Policy is available from AMS free of charge from our website,

www.australianmaristsolidarity.org.au. Stakeholders can also request a copy of the Privacy Policy to be sent to

them:

• by email, by emailing the request to AMS@marists.org.au.

• by post, by calling 07 3354 0600 ( +61 7 3354 0600 for international callers), or by writing to AMS using

the mail address set out below.

If a stakeholder would like a copy of this Privacy Policy in a particular form then the stakeholder should contact us

using the contact details set out below, and AMS will accommodate any reasonable request.

Contact details

If a stakeholder has any questions, would like to make a complaint about how AMS has managed their personal

information, or would like a copy of AMS' current Privacy Policy, then please contact the AMS Chief Executive

Officer:

Phone: 07 3354 0600

Email: ams@marists.org.au

Mail: PO Box 273, Ashgrove West, QLD 4060