1. Our commitment to you
Plan International Australia ACN 004 875 807 (Plan) provides a range of products and services designed to assist children around the world to reach their full potential. Plan works together with you to make a just world for children and equality for girls.
Plan International is committed to protecting personal information. The purpose of this Privacy Policy is to inform you of how Plan manages your Personal Information in compliance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) set out in the Act.
Plan recognises the trust and responsibility that you place with us when providing us with our Personal Information. When collecting your Personal Information, Plan will:
- tell you the purpose for the collection;
- tell you how the information collected will be used;
- not share that information with anyone else, unless it has your consent or is required to by law or legal direction;
- only hold the information so long as it needs to, to achieve the purpose and then it will safely dispose and delete the information;
- provide you with access to update or amend your information; and
- maintain security measures and processes to protect the information in its possession.
2. Scope of this Statement
This Policy applies to any personal information that we collect from individuals who may engage with us: in person, through our website or other direct marketing; or indirectly, through third party fundraising partners or other means. It sets out what, how, and why we collect, use, hold and disclose your personal information during the ordinary course of our operations.
Plan requires its staff to comply with this policy in relation to any personal information they handle. Plan also requires contractors, suppliers and service providers Plan engages from time to time to comply with these obligations with respect to any personal information held by Plan to which they may have access, or which may be disclosed to them.
If you do not agree with the terms of this Policy, please do not submit your Personal Information to us. By not providing us with your Personal Information you still have the opportunity to contribute to some of our programs or campaigns anonymously or with a pseudonym, but we may not be able to provide you with the full range of information or access that may otherwise be available.
3. What is Personal Information?
Personal Information is information or an opinion (whether the information or opinion is true or not) held by an organisation that identifies, or can reasonably identify an individual for example name, contact details, date of birth, gender identity, photographs or voice recordings.
Personal Information includes Sensitive Information, which can include information about an individual’s racial or ethnic origin, political opinions or memberships, sexual orientation or practises, religious beliefs or affiliations and philosophical beliefs.
4. Consent
Plan will only collect and hold your Personal Information with your informed consent, this means that we will notify you at the time of collection, for example by using a ‘Collection Notice’ on the website, or in person when you complete a hardcopy form.
However, when you expressly provide Personal Information to us, whether through the
website, via email or other methods, it is implied that you consent to:
- us collecting your Personal Information for the express purpose that we have requested it; and
- us handling the collected Personal Information in accordance with this Privacy Policy and applicable privacy and data laws in the applicable jurisdiction.
In all other cases we will not use your Personal Information without your express consent for any other purposes than those disclosed to you at the time of collection.
Plan will not collect Personal Information from individuals who do not have the legal capacity to consent.
5. What Personal Information do we collect?
The types of Personal Information that we typically collect and maintain are:
- contact details such as your name, postal address, email address, phone numbers;
- your date of birth, gender, income or occupation;
- your communication preferences;
- employer details, if you participate in workplace giving;
- Sensitive Information (primarily in connection with research projects);
- payment information (direct debit or credit card details) for donations, and a history of your donations;
- correspondences and other interactions with Plan, including conversations by phone or email with our staff and volunteers;
- information generated by your engagement with Plan products and services, such as:
- your Plan supporter number (if you have one);
- your Plan account username and password;
- details of the Plan products and services that you have used;
- your consumer-based interests and opinions (based on your support for our work eg. signing a petition, and other areas of our work or campaigns that you might be interested in supporting);
- IP address and cookie preferences.
- background security checks, such as National Police Checks, Working with Children Check (for volunteers or sponsorship visits).
For some of our products and services, you may choose to remain anonymous or engage with us using a pseudonym. However, this may reduce your ability to engage with our programs or campaigns to their full extent. Please note that Plan may be required by Australian law, or an order of a court or tribunal, to disclose details of accounts that have not identified themselves.
6. How we collection Personal Information?
Plan collects Personal Information in a number of ways, including:
- directly from you, for example by phone, SMS, in person, via our website, surveys, or applicable forms;
- indirectly from you, for example from our own records of how you use our products and services, and your use of our websites, or when another person makes contribution on your behalf;
- from third parties we engage or partner with to whom you have given consent to share your information and we require the third party to provide evidence of this consent;
- from publicly available sources; and
- authorised government agencies, where applicable (security and police checks).
7. Why do we collect Personal Information?
Plan collects Personal Information for a number of reasons, the specific purpose will be disclosed to you at the time of collection, however generally we will collect Personal Information in connection with the following purposes:
- collecting donations and sponsorships;
- your participation in campaigns or research organised by Plan;
- when we are legally required to do so, such as security and police checks if you wish to sponsor a child, or visit your sponsored child;
- to verify your identity in response to:
- a request to access and/or correct Personal Information Plan holds about you;
- a complaints-handling process.
In the event that Plan receives Unsolicited Personal Information we will destroy or de-identify such information as soon as practicable (except where it would be unlawful or unreasonable to do so) and in any event, will not use that information for any purpose. Any Unsolicited Personal Information held by Plan, will be treated as confidential and will be protected and handled in accordance with this Policy.
8. How do we use your Personal Information?
Plan will use your Personal Information for the purpose that was disclosed to you at the time of collection, and in accordance with this Policy. Plan will not disclose your Personal Information for any other purpose without your consent, except as set out in this Policy, or to the extent that Plan is permitted or required to do so by law or court or tribunal order.
With your consent, Plan uses your Personal Information to:
- communicate with you about activities, products and services provided by Plan (see also Direct Marketing);
- provide Plan’s products and/or services to you, or to a third party you have nominated (with that third party’s consent);
- process transactions and to administer accounts;
- address queries and to resolve complaints;
- manage and process donations and provide receipts;
- verify your identity when you make enquiries, answering your queries and addressing any feedback you may have;
- conducting analysis and research so that we can better meet your needs;
- training our personnel;
- to comply with any of our obligations under any law or statute;
- to comply with obligations or to enforce rights under a contract into which Plan has entered; and
- to assess the suitability of an individual applying to sponsor a child, seek employment, or to volunteer with Plan.
9. When Plan may disclose your information to third parties
Subject to obligations of Confidentiality and compliance with this Policy or equivalent, Plan may disclose Personal Information to third parties from any of the following groups:
- other Plan International federated organisations in other countries;
- third party services providers to facilitate communications, Direct Marketing and research on behalf of Plan, including but not limited to:
- mail-out (postal and email) services;
- information technology services;
- telecommunication, telemarketing services, and call centre operations;
- marketing, benchmarking, and data analysis and research services; and
- website analysis.
- Plan’s professional advisors, agents, suppliers and contractors in the ordinary course of receiving services or providing the organisation’s services, programs and products;
- to Plan’s customers, sponsors and donors, pursuant to specific contractual obligations Plan has entered into with them;
- Government departments and agencies, for the purpose of Plan complying with its statutory obligations.
When you sponsor a child, details such as your supporter number, name, gender and country of origin are provided to your sponsored child. Plan may otherwise use Personal Information collected about individuals in order to protect its legal rights and interests, or to enforce its rights against a third party in the event the third party is engaged in conduct which is prejudicial or harmful to Plan or to its interests, or to those to whom Plan provides products and services.
10. Direct Marketing
Plan may directly market the work it does to assist children around the world to reach their full potential, the products and services Plan offers and to seek donations and support from you, or from organisations with whom you are affiliated.
Plan may send you offers relating to the products and services of third parties that also provide financial support to Plan. We do not disclose your Personal Information to these organisations.
If you accept any offer from a third-party organisation, communicated to you by Plan, you become the third party’s customer and it may send offers to you.
We will not use Personal Information to market to you directly unless you expressly consent to receiving such communications. Plan complies with all laws relevant to marketing, including the Spam Act 2003 (Cth) and the Australian Consumer Law contained within the Competition and Consumer Act 2010 (Cth).
You may ‘opt out’ or ‘opt in’ to receiving direct marketing communications or any other goods or services from Plan at any time you wish by clinking ‘unsubscribe’ within a direct marketing communication (i.e. email) by updating your communication preferences via your Plan online account, or by contacting Plan directly via the details provided at the end of this Policy.
11. How we handle and retain your Personal Information
Plan stores the majority of Personal information that it collects within a cloud based Customer Relationship Management (CRM) with appropriate cyber security features.
Plan further ensures the security of your Personal Information that it shares with, or is stored by third party suppliers by ensuring that they:
- are only provided with access to the information required to perform the services they are engaged to perform;
- are strictly limited in the ways they are authorised to use or share information shared with them;
- are subject to, and contractually bound to comply with, the Privacy Laws, or bound by substantially equivalent laws or binding scheme in its jurisdiction to Australian Privacy Laws, and that individuals can enforce that protection; and
- establish and maintain an adequate complaints handling process, and implement a data breach response plan with notification mechanisms of any actual or suspected breach.
Plan also conducts regular review, testing and audits to ensure the information is kept securely and protected from threats, misuse, interference and loss from unauthorised access, modification and disclosure by maintaining up-to-date physical, computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of Personal Information.
Physical copies of your information, such as donation forms, are kept securely in locked facilities, and destroyed once their purpose has been satisfied.
Plan believes that the relationship you have with Plan is one that should be comfortable and appropriate to your needs. To maintain Plan’s on-going relationship with you, it is important for Plan to retain a basic electronic record of your Personal Information in order to:
- keep a record of your generosity, in case you want to reference it in the future;
- respond to any enquiries that could arise in relation to our international child protection obligations;
- manage our bequest program effectively;
- re-connect with past supporters that may be interested in supporting Plan’s current activities;
- comply with its legal, tax, audit and other obligations.
Plan will destroy or de-identify Personal Information collected from or about you when Plan no longer needs that Personal Information for the purpose(s) for which the information was collected.
12. Privacy and the internet
Plan’s websites, social media, and digital services use Transport Layer Security (TLS) encrypted protocols by default so that your Personal Information is always transferred securely. However, by providing us with your Personal Information, you and accept that no data transmission over the Internet or over mobile data and communications services can be guaranteed to be totally secure.
Plan’s websites contain links to other websites. Other websites may also have links to our websites. In either case this Policy does not apply to, and Plan is not responsible for, the content, privacy practices, or business practices of any website or organisation except our own.
Plan uses various online data sources, such as ‘cookies’, website analytics and third party suppliers, to collect information about:
- how individuals find and use our websites;
- management and display of our online advertising on other websites;
- to inform, optimise and serve ads based on your past visits to our website.
Your personal browser settings can be adjusted to manage our use of cookies on your
devices.
Plan may disclose Personal Information collected from visits to its website or through other online interactions by individuals with Plan (including, but not limited to an individual’s IP address) if Plan deems it necessary to do so in order to comply with relevant laws or pursuant to legal direction.
13. Accessing your Personal Information
Subject to some exceptions provided by law, you have the right to request access, amend or update Personal Information which we hold about you.
Plan takes all reasonable steps to ensure that the Personal Information we hold is accurate, complete and up-to-date, we do this by:
- relying on you to contact us to amend or update your information;
- periodically asking you to inform us if there are any changes to your Personal Information;
- deleting information when we become aware that it is inaccurate.
Requests to access your information can be done in writing (postal or email), via your Plan
Account, or over the phone. When contacting Plan to correct your details, please include your:
- contact details (name, postal address, telephone number); and
- Plan supporter number (if you have one).
Prior to providing you access to, or amending or updating your information, we will verify your identity, or the identity of the person who is authorised to make a request on your behalf. We will not provide access to or make amendments or updates to Personal Information until we have confirmed the identity of the requestor.
Plan will not charge you for lodging a request to access your Personal Information; however, Plan reserves the right to charge a reasonable fee to cover Plan’s costs incurred in procuring the Personal Information requested in accordance with Privacy Laws.
Where Plan does not allow you access to any part of your Personal Information, Plan will tell you the reasons why Plan cannot provide access.
14. Complaints and further information
If you have a privacy complaint, please contact us on the contact details provided below. Our Contact Centre will acknowledge receipt of your complaint and our Privacy Officer will investigate your complaint and work with you for a satisfactory outcome. If your complaint indicates that there has been interference with your privacy by an entity other than Plan, our Privacy Officer may, with your consent, discuss the complaint with that other entity in an attempt to resolve it.
If you are not satisfied with the outcome of your complaint or the way we handle it, you can make a complaint to the Office of the Australian Information Commissioner.
If you would like:
- further information on this Policy;
- want to access your Personal Information held by Plan;
- have any concern about the protection of your Personal Information; or
- wish to make a complaint;
You can contact us by:
Email: [email protected], marking your request “Attention: Privacy Officer”;
Phone: 13 PLAN (13 7526) or +61 3 9672 3600 for callers outside Australia;
Postal mail:
Plan International Australia
Attention: Privacy Officer
GPO Box 2818
Melbourne VIC 3001
15. Updates to this Privacy Policy
Plan reserves the right to modify, amend or to replace this Policy without prior notice. Plan will ensure that the most recent version of the Policy is made available on the website. Hard copies may be requested by contacting the Privacy Officer per the options above
15. Residents outside of Australia
Plan Australia is a proud member of the Plan International global network, and is subject to its Data Processing Agreement which is designed to comply with the requirements of the European Union General Data Protection Regulation (GDPR).
This Policy is compliant with Australian Privacy Laws, if you are concerned that it is not compliant with the privacy laws applicable to your region, we encourage you to contact the Plan entity in your jurisdiction.