Privacy Policy
Kids Under Cover Privacy Policy
Last Updated January 2019
1. Our commitment to you
Kids Under Cover ABN 76 604 592 013 (KUC) provides a range of products and services designed to prevent young people from becoming homeless. Kids Under Cover maintains a relationship with:
- donors and supporters in order to provide opportunities to join in assisting young people at risk;
- young people who use our services, which include housing services, and education scholarships;
- volunteers who support our community activities, and who may provide working with children (WWCC) details; and
- other individuals who interact with KUC on a regular basis.
Kids Under Cover is committed to protecting personal information. When collecting, using and handling personal information, Kids Under Cover complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) set out in that Act. This Policy sets out how we collect, use and manage personal information.
2. What is personal information?
‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether the information or opinion is true or not or recorded in any form or not). Examples of personal information can include your name, postal address, telephone number and email address. When used in this Policy, personal information has the meaning given in the Privacy Act. Personal information also includes ‘sensitive information’ (as defined in the Privacy Act), which can include information about an individual’s health, racial or ethnic origin, sexual orientation, criminal record, political opinions or memberships, religious beliefs or affiliations and philosophical beliefs.
3. What personal information do we collect?
The types of information we collect depends on the circumstances in which it is collected. Some examples of personal information that we regularly collect are set out below. We also collect personal information as otherwise permitted or required by law.
3.1 Donors and supporters The types of personal information we typically collect about our donors and supporters include without limitation:
- contact details such as your name, postal address, email address, phone numbers;
- your date of birth, gender, income, occupation;
- your employer details, if you participate in work place giving;
- a history of your donations, correspondences and other interactions with Kids Under Cover;
- your working with children (WWCC) number, expiry date, photo and copy of your card;
- your interests and opinions;
- your Kids Under Cover supporter number;
- credit card or bank account details; and
- your Kids Under Cover website username and password and activities performed when you login to a Kids Under Cover related website.
We also maintain details of the Kids Under Cover products and services that you use such as:
- Regular Giving;
- Appeal donations;
- Donate Your Car;
- Event invitation and attendance;
- Volunteering;
- Kids Under Cover electronic and printed newsletters;
- Undercover magazine;
- Scholarships; and
- Housing.
3.2 Our clients If you are one of our clients (that is, a young person who uses our services) we may collect information regarding your:
- house ownership;
- house occupants;
- ethnicity or race;
- social welfare circumstances;
- disability type (if any);
- relevant health information; and
- family history and background.
3.3 Our personnel If you apply for position with us as an employee, volunteer or independent contractor, we may collect information for the purpose of considering your application and, if you are successful, administering your position with us.
The types of information we may collect during the application process may include your qualifications and resume, as well as reference information from your nominated referees, background check results, bank details, feedback from supervisors and training records.
We may also collect information from publicly available sources, for example through LinkedIn or other social media websites or other publicly available search tools.
3.4 Dealing with us anonymously where it is practicable to do so, you may choose to remain anonymous or deal with us using a pseudonym.
However, if you choose not to provide your personal information, we may not be able to process your donation or provide you with the Kids Under Cover products or services you request. For example, if you are a young person who wishes to use our services we may not be able to provide you with certain services unless you provide certain information about yourself.
4. How we collect your personal information
Kids Under Cover collects personal information in a number of ways, including:
- directly from you, when you provide information by phone, SMS, in person, via our website or in application forms;
- from your school or other agencies (if you are a young person who uses our services);
- from third parties who organise fundraising activities on our behalf;
- from a third party who makes a donation on your behalf or nominates you as the recipient of a gift or other communication regarding that donation;
- from some third parties to whom you have given permission to share your personal information (e.g. your nominated referees when you apply for a position with KUC);
- from our suppliers, service providers and other organisations with whom we do business;
- from publicly available sources;
- from our own records of how you use our products and services;
- from your use of our Internet websites or social media; and
- as otherwise permitted or required by law.
When we collect personal information, we take reasonable steps to ensure that you are aware of certain matters relating to the collection of personal information, for example by providing a ‘collection statement’ at the time your personal information is collected. We may also require you to provide consent at the point of collection, if consent is required under the Privacy Act or other applicable laws. Where we collect your personal information from third parties, we take steps (in accordance with the requirements of the Privacy Act) to require the third party to assure us that it has obtained your consent to share the information or is otherwise authorised to provide us with that information. When you provide us with personal information about other individuals, we rely upon you to:
- make them aware of this Policy and any relevant collection statement;
- make them aware that you have provided us with that information; and
- obtain their consent or ensure that you are otherwise authorised to provide us with that information.
If Kids Under Cover receives unsolicited personal information that could not have been lawfully collected under the APPs, we will destroy or de-identify such information as soon as practicable (except where it would be unlawful or unreasonable to do so). Where Kids Under Cover could lawfully have collected such information, the information will be protected and handled in accordance with this Policy.
5. How we use and disclose your personal information
5.1 General The purposes for which we collect, hold, use and disclose your personal information will depend on the circumstances in which we collect it and the nature of your relationship with us.
Kids Under Cover collects, holds, uses and discloses your personal information primarily to enable us to provide and improve our products and services. For example, we collect, hold, use and disclose personal information for the following purposes:
- providing our services and administering our programs for young people who are at risk of homelessness;
- managing and processing donations and providing receipts;
- sending you information about your donation and about Kids Under Cover’s activities;
- confirming your identity when you make enquiries, answering your queries and addressing any feedback you may have;
- if you are a donor, providing you with new opportunities to assist young people at risk of homelessness (for example, by sharing your details with like-minded organisations in Australia and overseas);
- conducting analysis and research so that we can better meet your needs;
- considering you for a position with us (whether as an employee, volunteer or independent contractor) or in the context of other relationships with us;
training our personnel; and - any other specific purposes for which it was requested, or otherwise as permitted or required by law.
If you are a young person who wishes to use our services we may also share information with your support agencies in order to provide you with assistance.
5.2 Third party service providers We may disclose your personal information to third parties that assist Kids Under Cover by providing the following services:
- mail-out services;
- email distribution services;
- information technology services;
- telecommunication and telemarketing services;
- marketing analysis and research services;
- benchmarking and data analysis services;
- website usage analysis;
- call centre operations;
- fundraising; and
- process donations and payments.
Kids Under Cover takes reasonable steps (in accordance with the requirements of the Privacy Act) to ensure that the third parties providing these services are contractually bound by privacy and confidentiality obligations in relation to their use of your personal information and that they only use your personal information for the specific purpose(s) for which we supply it.
5.3 Direct marketing Kids Under Cover does not rent or sell your information. However, if you are a donor or supporter we may use and disclose your personal information for direct marketing by us and carefully selected third party organisations where you have:
- consented to us doing so; or
- where we are otherwise permitted to do so by law.
Some of the main ways in which we conduct direct marketing are described below:
Kids Under Cover may send you offers relating to other causes, products and services that may be of interest to you. We may also re-connect with past supporters by sending information about Kids Under Cover and its current activities. If you no longer wish to receive marketing or promotional material from Kids Under Cover at all or in any particular form, you may contact us with your request on the details provided in Item 8 (“Accessing or correcting your personal information”) below. We will comply with your request as soon as practicable. Where we send you messages for direct marketing purposes, each message will explain how you can opt out of receiving such messages in the future.
Kids Under Cover may also send you offers relating to the products and services of third parties that also provide financial support to Kids Under Cover. We do not disclose your personal information to these organisations. If you accept any offer from a third party organisation that is sent to you by Kids Under Cover, your relationship is with that third party organisation and they may seek your consent to send offers to you.
In order for us to find new supporters, like-minded organisations both in Australia and overseas may allow us to contact their mailing list. In return we allow these organisations to mail our supporters with information we believe may be of interest to you. If you prefer not to receive such communications please let us know using the contact details provided in Item 8 (“Accessing or correcting your personal information”) below.
5.4 Disclosure to recipients overseas We do not regularly disclose personal information to recipients outside of Australia in the ordinary course of business.
However, from time to time, we may disclose personal information to recipients outside Australia on a case by case basis. For example, we may disclose your personal information to like-minded organisations located in other countries, as set out in item 5 (“How we use and disclose your personal information”) above. The countries in which these third parties are located will depend on the circumstances. Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Principles in the Privacy Act in relation to such information.
6. How we handle and retain your personal information
Kids Under Cover holds personal information in secure hardcopy files and in electronic databases. Our information systems and files are protected from misuse, interference and loss and 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. Kids Under Cover believes that the relationship you have with us is one that should be comfortable and appropriate to your needs. To maintain our on-going relationship with you, it is important for us to retain a basic electronic record of your personal information in order to:
- if you are a young person who uses our services, manage our programs and services effectively;
- if you are a supporter, keep a record of your generosity in case you want to reference it in the future;
- if you are an employee, independent contractor or volunteer, administer and manage your position with us;
- if you or your organisation do business with us, facilitate that business relationship;
- respond to any enquiries that could arise in relation to our child protection obligations;
- manage our legacies program effectively; and
- re-connect with past supporters that may be interested in supporting Kids Under Cover’s current activities.
Where your information is no longer needed for any purpose for which it may be used or disclosed, Kids Under Cover will take reasonable steps (in accordance with privacy, tax or other relevant legislation) to ensure that it is archived or otherwise flagged as a non-current record.
Kids Under Cover takes reasonable steps to ensure that the personal information we hold is accurate, complete, up-to-date and relevant. We recommend that you let us know if there are any errors in, or changes to, your personal information by contacting us using the details provided in Item 8 (“Accessing or correcting your personal information”) below.
We may periodically ask you to inform us if there are any changes to your personal information. If any of the information we are holding is inaccurate, incomplete, out-of-date or irrelevant, we will take reasonable steps (in accordance with the requirements of the Privacy Act) to correct the information so that it is accurate, complete, up-to-date and relevant.
7. Privacy and the internet
Our websites (which include www.KUC.org.au, www.donateyourcar.org.au) use security encrypted response forms when personal and financial details are required. The security we use between your browser and our website is TLS/SSL with certificate authorities and public key infrastructure. Your web browser will indicate through the use of a padlock icon in the address bar that it supports TLS/SSL security. Click on the padlock icon to verify the security certificate for this website. You can then verify that the certificate is issued to Kids Under Cover, by which authority it was issued and the period of validity for the certificate.
Kids Under Cover’s websites contain links to other websites. Other websites may also have links to our websites. In either case, this Statement does not apply to, and Kids Under Cover is not responsible for, the content, privacy practices or business practices of any website or organisation except our own.
Our online surveys may ask for contact information as well as some demographic information to find out what we can do to better meet your needs. Kids Under Cover collects statistics on visitor traffic to our websites so that we can constantly improve its usefulness. All such statistics are anonymous and do not identify specific visitors. Some of our web traffic reports are created by using website monitoring conducted by Google Analytics. For more information about Google Analytics, including information on their method of collecting information, their Privacy Policy and the ability to opt out, you can visit Google Analytics online. We may anonymously track your visit to our websites by using ‘cookies’ which are provided by a third party. Kids Under Cover also uses third party vendors, including Google, to help manage our online advertising on other websites. These third party vendors also use cookies to serve our advertisements and this enables us to learn which advertisements bring supporters to our websites. They also allow us to customize our website to your needs. Cookies, which are industry standard and are used by most websites, can facilitate a user’s ongoing access to and use of a site. Cookies are data that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies are anonymous and not personally identifiable. It does not contain your name, address, telephone number or email address. If you prefer not to allow the use of ‘cookies’, you may be able to adjust your browser to turn them off or notify you when ‘cookies’ are being used.
However, if you disable cookies, you may not be able to access certain areas or take advantage of certain features or services on our websites. To opt out of our third party vendor’s use of cookies please visit the Network Advertising Initiative opt out page. To opt out of Google’s use of cookies, please visit the Google Opt Out page. As you browse our website, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partners then enable us to present you with retargeting advertising on other sites based on your previous interaction with our website. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number. You can visit this page to opt out of our partners’ targeted advertising. We also use Google advertising programs that use cookies to improve your online experience, including the display of more relevant ads on external websites. Anyone can opt out of these programs at any time by clicking here.
8. Accessing and correcting your personal information
Subject to some exceptions provided by law, you may request access to (and correction of) the personal information which we hold about you. For security purposes, if you would like to access or correct this information, we require you to put your request in writing using the e-mail or postal contact details provided below. We will not charge you for lodging a request to access or correct your personal information (although we may charge an administration fee for granting access to your personal information where permitted by law). Where we do not allow you access to any part of your personal information, we will tell you the reasons why we cannot provide access or correction (unless an exception applies under relevant laws). If you want to access your personal information, correct the information you have previously given us or opt-out of future communications please contact us by:
- sending an email to service@kuc.org.au;
- calling our supporter service centre on 1800 801 633; or
- posting a letter to Kids Under Cover using the address at the end of this policy.
When contacting us to access or correct your details, please include your:
- contact details (name, postal address, telephone number); and
- Kids Under Cover supporter number (if you have one).
Kids Under Cover will periodically review this Policy to ensure that it remains up-to-date. We reserve the right to make changes to this Statement from time to time without notice. The updated policy will be published on this page on our website.
9. Complaints and further information
If you believe your privacy has been interfered with and wish to make a complaint, please contact our Privacy Officer on the contact details provided below. The Privacy Officer will acknowledge our receipt of your complaint, then investigate your complaint and notify you of the outcome. If your complaint indicates that there has been an interference with your privacy by a person other than Kids Under Cover, the Privacy Officer may discuss the complaint with that other person in an attempt to resolve it. If you are not satisfied with the outcome of your complaint or the way we handle it, you may make a complaint to the Office of the Australian Information Commissioner at http://www.oaic.gov.au/privacy/making-a-privacy-complaint. If you would like further information on this Policy, or if you have any concern about the protection of your personal information or wish to make a complaint, please contact us by:
- sending an email to kuc@kuc.org.au, marking your request “Attention: Privacy Officer”;
- calling our supporter service centre on 1800 801 633; or
- posting a letter to Kids Under Cover, marking your request “Attention: Privacy Officer”, to the following address: Kids Under Cover, PO Box 5141 Burnley, VIC 3121