1. Our commitment to privacy
Compassion Australia is committed to managing your personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 and other applicable laws.
This policy explains our practices for the collection, use and protection of your personal information.
In this policy, “we”, “our” and “us” refers to Compassion Australia and “you” and “your” refers to any person about whom we collect personal information.
2. Key definitions
For the purposes of this policy –
Personal information is information or an opinion about you, or which reasonably identifies you.
Sensitive information includes personal information about your health, your philosophical beliefs, your religious beliefs or affiliations, or criminal record.
3. What personal information might we collect about you?
We will only collect personal information (not being sensitive information) about you if it is reasonably necessary for one or more of our functions or activities, or where the collection is otherwise required or permitted by law.
We will only collect sensitive information about you –
- if the information is reasonably necessary for, or directly related to, our activities, and you provide the information to us or consent to its collection, or it is otherwise required or permitted by law, or
- if the information relates to our activities and you have regular contact with us in connection with those activities.
The types of personal information (including sensitive information) we may collect about you depends on the nature of your interaction with us. The main types of personal information are as follows-
TYPE OF PERSONAL INFORMATION
Information about a supporter, a potential supporter, or a person who makes an enquiry or participates in an event we conduct or are involved in.
WHAT PERSONAL INFORMATION WE MIGHT COLLECT
- your name, email, postal address, telephone number and other contact details,
- information about your gender, date or year of birth or other demographic information, and information about your church membership,
- information about your web browsing, email, text messaging, social or other electronic interaction, including your username and social media profile (for more information see section 7 below),
- records of your dealings with us, including by telephone or electronic means (which may include, with your prior consent, a recording of a conversation) or email, and your interactions with us via social media,
- your preferences about how we communicate with you, and the nature of the information we send you,
- your responses to any surveys or questionnaires we ask you to complete,
- your financial payment details and donation and other supporter history,
- our opinions about the likelihood of you supporting a program or appeal, based on modelling and analysis.
TYPE OF PERSONAL INFORMATION
Information about a person who is undertaking a trip or visit or proposes undertaking a trip or visit (a “traveller”). Information about the emergency contact of a traveller.
WHAT PERSONAL INFORMATION WE MIGHT COLLECT
- your name, email, postal address, telephone number and other contact details,
- information about your gender, date of birth or other demographic information, and your church membership,
- your passport and visa information,
- your dietary requirements,
- your medical information, to the extent required to effect travel insurance or manage health issues which may arise during the trip or visit,
- your financial payment details and payment history,
- reference information, such as the results of a criminal record check or information about your Working with Children Check (or like check),
- if you are the emergency contact of a traveller - your name, email, postal address, telephone number and other contact details, and relationship to the traveller.
TYPE OF PERSONAL INFORMATION
Information about an applicant for a position with us (whether as an employee or volunteer). Information about a referee of an applicant for a position with us.
WHAT PERSONAL INFORMATION WE MIGHT COLLECT
- your name and contact details,
- your resume and educational and work history,
- your membership of a professional organisation,
- your responses to screening questions,
- information about your salary expectations,
- information provided to us at an interview or by a referee,
- if you are a referee – your name, email, telephone number and other contact details.
TYPE OF PERSONAL INFORMATION
Information about a person who leaves us with a bequest or lets us know they intend to do so.
WHAT PERSONAL INFORMATION WE MIGHT COLLECT
Details of the bequest including –
- the relevant terms of your will or other testamentary disposition,
- your executor or administrator, other beneficiaries and family members,
- the details of any relevant dispute in relation to your estate.
We may collect personal information about children (for example, when children contact us or participate in an event we conduct or are involved with). Where children do not have sufficient maturity and understanding to consent to our collection of their personal information, we will require their parents or guardians to consent on their behalf.
4. How might we collect your personal information?
We collect personal information directly from you unless it is unreasonable or impractical for us to do so. The main ways we collect personal information are as follows –
WAY WE COLLECT
You give it to us
HOW COLLECTION MIGHT OCCUR
Collection might occur when you –
- contact or meet with us,
- donate to us or support one of our programs,
- attend one of our events (either in person or on-line),
- participate in a field trip or visit,
- apply to work with us.
WAY WE COLLECT
We collect it ourselves or another person collects it on our behalf
HOW COLLECTION MIGHT OCCUR
Collection might occur when –
- you interact with us in person or via our supporter engagement centre, our website, your MyAccount, or our social or digital pages,
- you interact with our external service provider, such as through recruitment, travel or fundraising platforms hosted on the website of such a provider,
- we collect opinions about you that are the result of our own research and analysis, or research and analysis by an external service provider on our behalf, such as opinions about the likelihood of you supporting a program or appeal.
WAY WE COLLECT
We obtain it from another person
HOW COLLECTION MIGHT OCCUR
Collection might occur if we obtain the information from –
- a person you have authorised to deal with us on your behalf,
- if you are a child – from your parent or guardian,
- if a participant on a field trip or visit identifies you as their emergency contact – from the participant,
- if an applicant for work with us identifies you as a referee – from the applicant,
- a referee or former employer, such as if you apply to work with us,
- the provider of national criminal record checks or an authority which issues Working with Children Checks (or like checks),
- an external service provider who is providing advice to us about fundraising and who is authorised to provide us with your information,
- publicly available social media accounts,
- other publicly available sources or commercial information providers.
5. Why do we collect personal information and how might we use it?
We collect your personal information and use it to enable us to deal with you more efficiently and effectively and meet your needs. We also collect your personal information to improve what we do and meet other organisational requirements.
Specifically, depending on the nature of our interaction with you, we may use your personal information for one or more of the following purposes –
- to verify your identity when you contact us,
- to send you important information, such as information about a child or program you support,
- to process your donations or other payments and send you receipts,
- to plan, promote and administer our activities, appeals and events, and send you information about them and invite you to participate or contribute to them,
- to invite you to our events or other activities,
- to invite you to participate in a field trip or visit, and to organise your itinerary, flights, accommodation and meals and manage your security,
- to ensure that children who participate in one of our events, or at a frontline partner church, are not at risk of harm,
- to respond to your requests for information and other general enquiries,
- to receive and manage any complaint you may make,
- to gather your feedback about the services we provide and how they can be improved,
- to undertake research, and develop and expand our services,
- to perform research and analysis to help us fundraise, now and in the future,
- to monitor and manage any bequest left to us, or intended to be left,
- to teach and train our staff, volunteers, contractors or other workers,
- to recruit staff (including volunteers),
- to implement and manage proper governance processes such as risk management, incident management, compliance monitoring or external audit,
- to enable us to satisfy our legal obligations, comply with applicable laws and meet the requirements of relevant regulators and accrediting bodies, and
- for such other purposes as we may advise you in writing from time to time.
As referred to in paragraph (d) above, we may use your personal information to send you information about our activities, appeals and events and invite you to participate or contribute to them. That information may be sent to you by way of advertisement on an external platform such as Google or Facebook, using tools which enable us to target activities, appeals and events which may be of specific interest to you. The use of those tools requires that we send personal information (such as your name, email address, phone number, IP address and browser ID) to the external third party which operates that platform, such as Google or Meta. Information such as your name, email address and phone number is tokenised and can only be recognised by the third party if you have an account on the platform they operate. Other information, such as your IP address and browser ID may not be tokenised.
Artificial Intelligence may be used in connection with such purposes (see section 8 below).
6. Do I have to provide my personal information?
You can choose not to provide us with your personal information and remain anonymous or use a pseudonym in your dealings with us.
However, generally, it is not practicable for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, the main consequences are that we may be unable to -
- communicate with you, or communicate effectively with you,
- process your donations or payments or issue a receipt to you,
- invite you to attend our events,
- invite you to participate in a field trip or visit,
- consider you for, or offer you, employment, a volunteer role or other role with us.
Be aware that under our Whistleblower Policy, you can communicate anonymously with us to report a matter to which that policy applies. If you provide personal information in connection with a report, you are entitled to the protections set out in that policy.
7. How do we interact with you via the internet?
Visiting our website
You can visit our website (www.compassion.com.au) without identifying yourself. However, our website may contain cookies, pixels and scripts which may collect certain information such as your device type, browser type, IP address, pages you have accessed on our website and on third-party websites.
If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to us will be managed in accordance with this policy.
MyAccount
You may use our website to access and use your MyAccount using your email address and a password (which we will store securely) or other method of authentication. We can determine when you use your MyAccount. In addition, we collect personal information about you through your MyAccount which may be used and disclosed in accordance with this policy.
Use of cookies
Our website uses cookies. A “cookie” is a small file placed into your browser’s application folder stored on your computer, which allows our website to “recognise” you as a unique individual and enable us to –
- customise and improve your experience when you interact with our website,
- gather statistical data on how you use our website so that we can improve it,
- show you relevant material about our programs and appeals.
Cookies by themselves cannot be used to identify you – they identify the computer used to visit our website and help maintain the continuity of your browsing sessions. Cookies do not collect data from your computer.
You can remove cookies from your computer. Also, depending on what type of web browser and browser version you are using, you may be able to change the properties on your cookie file so that cookies are not used or saved. Please check with your browser provider for more information on removing cookies.
However, if you remove cookies or change the properties of your cookie file, you may not be able to access certain pages or content on our website.
Use of pixels
We also use other technologies, such as pixels, which monitor how you have engaged with our website and to help us to monitor our website and marketing campaigns. These technologies, for example, show us popular pages, conversion rates, click throughs and other information which can be used to improve our website.
These technologies also allow us to distribute information through online advertising which may be of interest to you through your digital browsing and social media use.
You can use the settings in your web browser and social media account to control the use of pixels.
Links to third-party websites
Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of third-party websites that are linked to our website.
8. Do we use Artificial Intelligence and how do we use it?
We may use Artificial Intelligence (AI) or related technologies for purposes related to our functions and activities (as to which see section 5 above), which may include –
- researching and analysing a supporter, or potential supporter, including to better understand their needs,
- modelling the likelihood of a person donating to a campaign or appeal or otherwise supporting us,
- enhancing our operational processes or workflow efficiency.
The personal information we hold about you may be used for such purposes, together with other information which is publicly available.
Your personal information may also be disclosed to an external service provider who provides or uses AI and is engaged to assist us for the purposes referred to above, including owners and developers of such technology. Where disclosed, your personal information will only be used by that service provider to provide services to us. However, de-identified information may be used for purposes such as training AI models.
See sections 11 and 12 which contain further information about our controls for the use of external service providers.
9. How do we hold and protect your personal information?
We store personal information in paper-based files or in secure electronic databases (including third-party storage providers based in Australia and overseas - as to which see sections 11 and 12 below). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
We maintain physical security over paper and electronic data bases, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords and other methods of authentication to control access to our computer systems.
If you donate or make another payment via our website or the website of an external service provider, your payment will be processed securely using a trusted payment gateway with industry standard encryption. Reasonable measures are taken to comply with the Payment Card Industry Data Security Standard.
Otherwise, our website or the website of an external service provider does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. You are encouraged to take care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
10. How do I opt out from receiving marketing communications?
As indicated in section 5, we may use or disclose your personal information to inform you about our services, upcoming appeals, our events, or other opportunities that may interest you.
If you do not want to receive marketing communications, you can opt-out at any time by using the opt-out option in the communication we send you, by managing your marketing preferences in your My Account, by contacting us using the contact details below or, in an appropriate case, using the settings in your web browser or social media account to control the use of pixels.
If you opt-out of receiving marketing material from us, we may still contact you about our ongoing relationship with you.
11. Do we disclose your personal information to other people?
We engage third parties to perform a range of administrative, management and operational functions for us. For example, we may engage an external service provider to provide us with services such as –
- data collection (including from publicly available sources),
- data processing,
- data analytics,
- data storage (including cloud storage),
- call-centre services,
- payment processing, including the collection and secure storage of credit card or debit card information,
- communication services,
- marketing services,
- fundraising services, including tele-fundraising services,
- event management and hosting,
- market research services, (including undertaking stakeholder satisfaction surveys, and assessing and analysing the results of market research),
- payroll services,
- recruitment services,
- insurance services,
- transport, accommodation and travel agency services,
- information technology services and support, including website maintenance / development,
- printing, archiving, mail-outs.
In addition, an external service provider may, in turn, engage its own external service providers to enable it to provide us with the services we require. For example, an external service provider we engage to collect your personal information on their platform may, in turn, engage another service provider to store that data (such as in the cloud).
We will only disclose your personal information to an external service provider where needed to enable them to provide services to us. We will take reasonable steps to ensure that our external service providers, and the providers they engage, do not breach the Australian Privacy Principles in relation to your personal information.
In addition, we may also disclose your personal information to another party if required –
- to manage risk, liabilities and claims (for example, liaising with insurers and legal representatives), or
- to obtain advice from consultants and other professional advisers, or
- to meet our legal obligations.
12. Do we disclose your personal information overseas?
By reason of the nature of our ministry and our international affiliations, we work with organisations and external service providers who are located outside Australia.
We may disclose your personal information to affiliated organisations located outside Australia, including affiliated organisations in the United States of America and the countries in which we support development programs or undertake field trips or visits.
We and our external service providers may use services such as overseas or cloud-based data hosting services and overseas call-centre services, which result in personal information being transferred to, used, or stored at a location outside Australia including, but not limited to, Japan, Philippines, Singapore and the United States of America.
Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients or allow an external service provider to disclosure your personal information, where we have taken reasonable steps to ensure that the overseas recipient will not breach the Australian Privacy Principles in relation to your personal information.
13. How can you access or correct your personal information?
Accessing your personal information
You can access the personal information we hold about you in your MyAccount by logging into your account.
You can request to access other personal information by contacting us using the contact details below. If you request to access your personal information we may need to verify your identity before acting on your request.
Correcting your personal information
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. You can help us do this by updating your personal information online via your MyAccount or by letting us know if you notice errors or discrepancies in the information we hold about you or if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading you may request correction of the information.
Responding to a request to access or correct
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
Otherwise, we will act on your request as soon as possible.
Deletion or de-identification of your personal information
If you want to request the deletion of your personal information please contact us using the contact details below. We will delete your personal information (or, in the alternative, de-identify it) if required by the Australian Privacy Principles or, otherwise, in our discretion. We will provide you with written notice about the action taken in response to your request and explain our reasons (if required).
14. What if you have a complaint about how we handle your personal information?
You may contact us at any time if you have any questions or concerns about this policy or about how your personal information has been handled.
You may make a complaint about privacy to us by contacting our Privacy Officer by using the contact details below.
We will first consider your complaint to determine if there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that we may have breached the Australian Privacy Principles or the Privacy Act, you can make a complaint to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
15. How are amendments made to this Privacy Policy?
We may amend this policy from time to time, with or without notice to you. Please visit our website regularly to keep up to date with any changes.
16. How can you contact us?
Our contact details are -
For general questions and requests
Compassion Australia
PO Box 1
HUNTER REGIONAL MAIL CENTRE 2310
Email: compassion@compassion.com.au
Telephone: 1300 224453
For complaints about privacy
The Privacy Officer
Compassion Australia
PO Box 1
HUNTER REGIONAL MAIL CENTRE 2310
Email: privacy@compassion.com.au
Telephone: 1300 224453
Addendum to the Privacy Policy
In connection with our website, we use the CloudFlare Turnstile CAPTCHA system to reduce fraudulent activity. This system collects information as described in Cloudflare's Turnstile Privacy Addendum