Girl Guides Australia and State Girl Guides Organisations (referred to in this document as Girl Guides, we, us or our) recognises that your privacy is very important and we are committed to protecting the personal information we collect from you. The Privacy Act 1988 (Cth) (Privacy Act), and the Australian Privacy Principles (APPs) govern the way in which we must manage your personal information.
This policy sets out how we collect, use, disclose and otherwise manage personal information about members (and prospective members), family members of members, donors, members of the public and Girl Guide’s workers (including volunteers, employees, board, candidates for volunteer work, and prospective employees).
In addition, if you are resident in New South Wales, the Health Records and Information Privacy Act 2002 (NSW) will apply to health information collected and handled. If you are resident in Victoria, the Health Records Act 2001 (Vic) will apply to health information collected and handled.
The handling of some personal information by Girl Guides is exempt from certain obligations under the Privacy Act where it directly relates to a current or former employment relationship, and an employee record held by us (where ‘employee record’ means a record of personal information relating to the employee’s employment). This will not apply to all Girl Guide workers, as not all workers are employees.
Types of information collected
We may collect and hold personal information about you, that is, information that can identify you, and is relevant to providing you with the goods and services you are seeking.
The kinds of information we collect from you depends on our relationship with you. Generally, however, we may collect your name, contact details, and other information relevant to providing you with the information, goods and services you are, or someone else you know is, seeking.
If you are a member or applicant, we will also generally collect your date of birth, age, gender, personal and emergency contact information, interests and hobbies, skills, and name of your school. We may also collect photographs, videos, and other recordings of you where those assist us in providing you with member services. We are also likely to collect sensitive information about you during your application or involvement with us, including your racial or ethnic background, health and medical information (including Medicare number and health fund details), religious beliefs or affiliations, political opinions, and sexual orientation. If you are an adult member, we may collect information on your criminal history.
If you are a parent/guardian of a member or applicant, we will also generally collect information on your occupation, interests and hobbies, and skills, and whether you are available to support or volunteer with us. We are also likely to collect sensitive information about you during you and the member’s/applicant’s involvement with us, including your racial or ethnic background, health and medical information, religious beliefs or affiliations, political opinions, and sexual orientation.
If you are an attendee of an event, we will also generally collect health or medical information in the form of dietary, capabilities and accessibility requirements.
If you are a donor, you may choose to provide us with demographic data, such as your date of birth, gender, income, and areas of interest. We use this information to help understand who engages with us.
If you are a Worker, we will also generally collect your date of birth, personal information contained within an application and CV/resume, employment history, personal information derived from a reference, personal information derived from an interview, personal information derived through testing (including psychometric or aptitude testing), licences and other certificates and qualifications, and information included in a passport, birth certificate, visa or other documentation demonstrating a worker’s right to work in Australia. If you are a current employee or volunteer, we will also generally collect information during the engagement and on-boarding process, bank account and superannuation fund information, tax file number, wage and entitlement information and other payroll information, drivers licence number, emergency contact information, information relating to your performance or conduct, information relating to your employment, training, disciplining, and resignation/termination, the terms and conditions applicable to you, and photographs, videos, and other recordings. In addition, we are likely to collect and hold sensitive information about you during your employment, including health and medical information, racial or ethnic background, sexual orientation or practices, criminal record and other information provided in a police check, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, biometric information, and biometric templates.
We only collect sensitive information you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions and activities. Consent may be implied by the circumstances existing at the time of collection. There may also be circumstances under which we may collect sensitive information without your consent, as required or authorised by law.
We may also collect information through the use of our website and digital platforms, including user preferences, ‘cookie’ information, and geographical location.
Method of collection
Personal information will generally be collected directly from you through the use of any of our standard forms, our assessment procedures for members, our volunteer and employment application process, registration and attendance at our events, when making donations or purchases, via emails or other communications, via phone, in person, via our surveys (where applicable), via our website (including online registration and contact forms), and social media accounts.
For example, we may collect personal information about members or applicants for membership from a parent or guardian, and we may collect personal information about workers from referees when they provided references, academic institutions or training and certification providers, providers of licence and background-checking services, recruiters and other service providers who assist in the engagement process, and other publicly available sources such as social media platforms.
We will usually notify you about instances of collection from third parties in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
If we receive unsolicited information about you that we do not ask for or which is not directly related to our functions or activities, we may be required to destroy or de-identify that information, provided it is lawful and reasonable to do so.
Purpose of collection
The personal information that we collect and hold about you, depends on your interaction with us. Generally, we will collect, use and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the purposes of:
- providing information, goods and services to you or someone else you know;
- processing your donation or purchase and providing receipts, and communicating with you about how your donation is used;
- facilitating our internal business operations, including
- the fulfilment of any legal requirements;
- establishing our relationship with you;
- maintaining and managing our relationship with you and communicating with you in the ordinary course of that relationship (including responding to feedback or complaints);
- maintaining a register of our membership;
- ensuring the health, safety, and well-being of members and workers;
- establishing suitability of adult members to be in charge of youth members;
- maintaining and managing the engagement of a worker, and terminating that engagement;
- organising and facilitating events;
- accessing, processing and investigating claims made under any insurance products we provide to support the safe and effective roll out of Girl Guiding activities and events;
- analysing our goods and services, membership needs, customer needs, and worker needs with a view to developing new or improved goods and services or business operations; and
- providing you with information about other goods, services, activities, events, promotions, or special offers that we or our related entities and other affiliated organisations offer that may be of interest to you.
Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out above.
Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking. If you are seeking to become a Member, we will not be able to process your application if you do not provide the personal information sought.
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Use and Disclosure
Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above). We may disclose personal information about you to:
- our Workers and other parties who require the information to assist us with facilitating our internal business processes, providing you with goods and services and information, and with establishing, maintaining, managing, or ending our relationship with you;
- to facilitate internal business processes, including directing membership enquiries to the relevant State Girl Guide Organisations;
- third parties to whom you have agreed we may disclose your information or where the information was collected from you (or from an authorised discloser) for the purposes of passing it on to the third party; and
- any other entity as otherwise permitted or required by law, including enforcement and regulatory bodies such as WorkSafe and child protection authorities.
If you are a Member, your personal information may also be disclosed to your parent/guardian, to Leaders and Managers whose role it is to supervise and assess you, and if you consent, to other members. Photographs, videos, and other recordings taken of you as part of providing you with services will only be used by Girl Guiding in Australia and will not be disclosed to third parties without your consent, or where otherwise permitted or required by law.
If you are an Adult Member of the State Leadership team, or a Region or District Manager, your name and contact details will be publicly distributed. Photographs, videos, and other recordings taken of you as part of providing you with services will only be used by Girl Guiding in Australia and will not be disclosed to third parties without your consent, or where otherwise permitted or required by law.
We may expand or reduce our business and this may involve the transfer of control of all or part of our business. Personal information, where it is relevant to any part of the business for transfer, may be disclosed to a proposed new owner or newly controlling entity for their due diligence purposes, and upon completion of a transfer, will be transferred to the new owner or newly controlling party to be used for the purposes for which it was provided.
Sensitive information (including health or medical information) is only used and disclosed for the purposes for which it was collected, unless your further consent is obtained, or otherwise as permitted or required by law. If we use your health information for internal research or statistical purposes, we will de-identify the information first.
Disclosure of Personal Information Overseas
Girl Guides Australia is a Member Organisation of the global organisation the World Association of Girl Guides and Girl Scouts (WAGGGS). For Members travelling overseas and their parent/guardian, your information may be disclosed to other WAGGGS Member Organisations located in the country to which you are travelling.
We are also assisted by a variety of external services providers to operate our business, some of whom may be located overseas. These third parties are too numerous to list, and they change from time to time. Some examples of the types of third parties including technology service providers who may be located in the United States of America, such as Google Analytics and Microsoft Office 365.
You consent to this overseas disclosure and agree that by providing consent, APP 8.1 under the Privacy Act no longer applies, and we are not required to take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to that information.
We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from interference, misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
Personal information we collect is hosted on third party data servers located within Australia. We take reasonable steps to ensure any third-party data storage suppliers we partner with have appropriate cyber and physical security controls in place.
Where personal information we hold is no longer necessary, we delete the information or permanently de-identify it, subject to specific laws in respect of data retention and our obligations to retain information in accordance with the GGA Child Safe Child Friendly framework.
Access and Correction
You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
Subject to our obligations under the Fair Work Act 2009 (Cth) (FW Act),with respect to current and former employees, we may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
Employee records prescribed by the FW Act must be made available to an employee or their representative upon request. These employee records include general employment details, pay records, records relating to leave entitlements, records relating to superannuation contributions, records relating to individual flexibility arrangements, records relating to guarantees of annual earnings, and termination of employment records. Under the Fair Work Regulations 2009 (Cth), we must make a copy of an employee record available in a legible form for inspection and copying on request by an employee or former employee to whom the record relates. If the employee record is kept at the premises at which the employee works or the former employee worked, we will make a copy available at the premises within 3 business days after receiving a request, or will post a copy of the employee record within 14 days after receiving a request. If the employee record is not kept at the premises, we will, as soon as practicable after receiving a request, make a copy available at the premises or post a copy of the employee record to the employee or former employee. This paragraph will not apply to all Workers, as not all Workers are employees.
It is essential that the information contained in our records is accurate, complete, and up to date. If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
Complaints and Feedback
Street address: The Hub, Hyde Park, 223 Liverpool Street, Darlinghurst NSW 2010
Email address: Feedback and Complaints – Girl Guides Australia
Website: Girl Guides Australia
For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.
If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner, Australia. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.
Definitions and Abbreviations
Last Modified: 17/04/23 at 1:15 PM