ISCAST Privacy Policy - ISCAST

The purpose of this policy is to ensure that in the course of ISCAST’s activities, we manage and protect personal information in accordance with the Privacy Act 1988 (Privacy Act) and the 13 Australian Privacy Principles (APPs). Whilst ISCAST is not bound by the Privacy Act, ISCAST works to voluntarily conform to the requirements of the Privacy Act to provide assurance to all who deal with ISCAST that we take privacy seriously.

Scope of policy
- This policy outlines the circumstances in which we obtain personal information, how we use that information and how we manage requests to access and/or change that information.
- This policy applies to all staff, volunteers and contractors of ISCAST and its related bodies.
What is personal information and how do we collect it?
- Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from the individual in their capacity as a member, fellow, contractor, volunteer, supporter, stakeholder, job applicant or in some other capacity.
- We may collect and hold:
  - Personal information including names, addresses and other contact details; dates of birth; and financial information
  - Sensitive information including government identifiers (such as TFN), nationality, country of birth, professional memberships, and current and past employers
  - Health information including medical records, disabilities, immunisation details and psychological reports.
  - Academic qualifications, list of publications and citations
- In addition, as part of our recruitment processes for employees, contractors and volunteers, we may collect and hold:
  - Personal information including names, addresses and other contact details, dates of birth, financial information, citizenship, employment references, regulatory accreditation, media, directorships, property ownership and driver’s licence information
  - Sensitive information including government identifiers (such as TFN), nationality, country of birth, professional memberships, family court orders and criminal records
  - Health information including medical records, disabilities, immunisation details and psychological reports.
- Generally, we will seek consent from the individual in writing before we collect their sensitive information (including health information).
- Employee records are not covered by the APPs or the Health Privacy Principles where they relate to current or former employment relations between ISCAST and the employee. However, a current or former employee’s health records are covered by the Victorian Health Privacy Principles.
Collection of personal information
- The collection of personal information depends on the circumstances in which ISCAST is collecting it. If it is reasonable and practical to do so, we collect personal information directly from the individual.
Solicited information
- ISCAST has, where possible, attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms). However, given the nature of our operations we often also receive personal information by email, letters, notes, via our website, over the telephone, in face-to-face meetings and through financial transactions.
- We may also collect personal information from other people (e.g. a third-party administrator, referees for prospective employees) or independent sources. However, we will only do so where it is not reasonable and practical to collect the personal information from the individual directly.
- We may collect information based on how individuals use our website. We use ‘’cookies’’ and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyse and improve our website, marketing campaigns and to record statistics on web traffic. We do not use this information to personally identify individuals.
Unsolicited information
- ISCAST may be provided with personal information without having sought it through our normal means of collection. This is known as “unsolicited information” and is often collected by:
  - Misdirected postal mail – Letters, Notes, Documents
  - Misdirected electronic mail – Emails, electronic messages
  - Employment applications sent to us that are not in response to an advertised vacancy
  - Additional information provided to us which was not requested.
- Unsolicited information obtained by ISCAST will only be held, used and or disclosed if it is considered as personal information that could have been collected by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the personal information as appropriate.
Collection and use of sensitive information
- We only collect sensitive information:
  - If it is reasonably necessary for one or more of the functions, services or activities we deliver, and we have the individual’s consent
  - If we have a reasonable belief that it is necessary to lessen or prevent a serious threat to life, health or safety and it is unreasonable or impracticable to obtain consent
  - In another permitted general situation
  - In another permitted health situation.

How do we use personal information?
- ISCAST only uses personal information that is reasonably necessary for one or more of our functions, services or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by the individual, or for an activity or purpose to which the individual has consented.
- Our primary uses of personal information include, but are not limited to:
  - Satisfying our legal obligations
  - Keeping members informed as to ISCAST community matters through correspondence, newsletters and magazines
  - Marketing, promotional and fundraising activities
  - Providing speakers for events and schools
  - Helping us to improve our day-to-day operations including training our staff
  - Systems development; developing new programs and services; undertaking planning, research and statistical analysis
  - ISCAST administration including for insurance purposes
  - The employment of staff
  - The engagement of volunteers.
- We will only use or disclose sensitive information for a secondary purpose if you would reasonably expect us to use or disclose the information and the secondary purpose is directly related to the primary purpose.
- We may share personal information to related bodies corporate, but only if necessary for us to provide our services.
- ISCAST may disclose information about an individual to overseas recipients only when it is necessary, for example to facilitate a conference or journal article. ISCAST will not however send information about an individual to an overseas recipient without their consent.
Storage and security of personal information
- ISCAST stores personal information in a variety of formats including, but not limited to:
  - Databases
  - Hard copy files
  - Personal devices, including laptop computers
  - Third party storage providers such as cloud storage facilities
- ISCAST takes all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps include, but are not limited to:
  - Appropriately restricting system and physical access to information based on staff roles and responsibilities
  - Ensuring staff do not share personal passwords
  - Storing hard copy files in lockable filing cabinets / lockable rooms
  - Ensuring access to ISCAST premises are secured at all times
  - Ensuring our IT and IT security systems, policies and procedures are implemented and up to date
  - Ensuring staff comply with internal policies and procedures when handling the information
  - Undertaking due diligence with respect to third party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime
  - The destruction, deletion or de-identification of personal information we hold that is no longer needed, or required to be retained by any other laws.
- Our public website may contain links to other third-party websites outside of ISCAST. ISCAST is not responsible for the information stored, accessed, used or disclosed on such websites and we cannot comment on their privacy policies.
Responding to data breaches
- ISCAST will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).
- If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.
Disclosures of personal information
- Personal information is used for the purposes for which it was given to ISCAST, or for purposes which are directly related to one or more of our functions, services or activities.
- Personal information may be disclosed to government agencies, related entities and other recipients from time to time, if one of the following circumstances is met:
  - The individual has given consent
  - The individual would reasonably expect the personal information to be disclosed in that manner.
- ISCAST may disclose personal information without consent or in a manner which an individual would reasonably expect if:
  - We are required to do so by law
  - The disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety
  - Another permitted general situation applies
  - Disclosure is reasonably necessary for a law enforcement related activity
  - Another permitted health situation exists.
- Staff must not disclose personal information in accordance with clauses 2 and 10.3 above, unless authorised by ISCAST’s Executive Officer.
Disclosure of your personal information to overseas recipients
- Personal information about an individual may be disclosed to an overseas organisation in the course of providing our services, for example when storing information with a cloud service provider which may store data outside of Australia.
- We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless one or more of the following conditions is met:
  - We have the individual’s consent (which may be implied)
  - We have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime
  - We form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety
  - We are taking appropriate action in relation to suspected unlawful activity or serious misconduct.

The quality of personal information
- We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information.
- If we become aware that the personal information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.
Access and correction of personal information
- Individuals may submit a request to us to access the personal information we hold, or request that we change the personal information. Upon receiving such a request, we will take steps to verify the individual’s identity before granting access or correcting the information.
- If we reject the request, you will be notified accordingly. Where appropriate, we will provide the reason/s for our decision. If the rejection relates to a request to change personal information, an individual may make a statement about the requested change and we will attach this to their record.
Complaints
- An individual can make a complaint about how ISCAST manages personal information by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response.
- ISCAST does not charge a fee for the handling of complaints.
- If the individual is not satisfied with our response, they may refer the complaint to the OAIC. A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email.
- A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.
How to contact us
- ISCAST can be contacted about this Privacy Policy or about personal information generally, by:

Emailing contact@iscast.org
Calling 0431 330 380
Writing to our Executive Officer at P.O. Box 40, Forest Hill, Vic. 3131

If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.

Changes to our privacy and information handling practices
- This Privacy Policy is subject to change at any time. Please refer to our website iscast.org for the latest version of the Privacy Policy.