OSCA Privacy Policy

PURPOSE

The purpose of this document is to describe the management of personal information that is collected, used or disclosed by the Old Scotch Collegians’ Association (OSCA or the Association).

OSCA is committed to meeting the standards of the Australian Privacy Principles (APPs) provided in the Privacy Act 1988 (Cth) when collecting, storing, using and disclosing personal information.

In interpreting this policy it is useful to understand that OSCA is an alumni organisation affiliated to Scotch College (the College), which operates in the context of a network with and between the College and OSCA affiliated alumni clubs and associations. In order to effectively operate as an alumni organisation of the College and within that network, there is at times an exchange or sharing of staff, facilities, data and information between those entities, which in doing so, OSCA will endeavour to meet the standards of the APPs and this policy.

SCOPE

This policy applies to OSCA and its officers and agents in relation to the collection, use and disclosure of personal information collected by OSCA in the course of its functions and activities. OSCA typically collects personal information to assist its activities in:

    • promoting the welfare and advancement of the College through the activities of Old Collegians, and present and former Staff Members of the College;
    • providing a means for Old Collegians to keep in touch with each other, to promote unity among them, and to foster and develop in them a desire to assist in the welfare and advancement of the College;
    • raising, aiding or contributing to the raising of funds for the use and benefit of the College, whether for endowment, building, embellishment, improvement, educational, recreational or any other purposes considered to be advantageous to the College;
    • establishing and encouraging, aiding, assisting and taking part in the establishment of funds, exhibitions, scholarships, bursaries and prizes for students or Old Collegians of the College;
    • contributing or undertaking to contribute to any fund or assist in attaining any object established or designed to foster friendly relationships with the Associated Public Schools of Victoria or other similar schools;
    • taking or accepting any gift of property for any one or more of the objects of the Association, and to undertake and execute any trust for the purpose of directly or indirectly carrying out the objects of the Association;
    • promoting sport, wellbeing, entertainment and education among Old Collegians, encouraging social interaction between Members of the Association, and promoting the formation of affiliated clubs for any such purpose, on terms determined by the Council from time to time;

     

    THE KINDS OF PERSONAL INFORMATION OSCA COLLECTS AND HOLDS

    The kind of personal information that OSCA collects and holds includes names, addresses and emails and telephone contact details of:

    • Members and prospective Members of OSCA, along with date of birth, occupation, qualifications, family relatives, marital status, gender, photographic images, personal interests, and, where necessary to facilitate a transaction with a Member, bank account or credit card details for processing purposes only;
    • prospective employees, along with marital status and next of kin, identity documents, photographs, Working with Children Checks, National Police Record checks, health information, personal references, employment history and qualifications of such persons;
    • volunteers and contractors, along with personal references, Working with Children Checks, and employment history and qualifications of such persons;
    • other persons who come in contact with OSCA, along with such other information necessary in the circumstances of that person’s contact with OSCA.

    OSCA will collect sensitive information and health information only where it is reasonably necessary for, or directly related to, its functions and activities and either:

    • the individual has consented; or
    • it is consistent with the scope of the APPs, or if OSCA is required or authorised by or under law to collect such information.

    In some cases where OSCA requests personal information about you, if the information is not obtained or provided, OSCA may not be able to process or accept your application for membership, provide you with services or opportunities that OSCA generally provides to its Members or keep you informed of news concerning OSCA and its activities.

    HOW OSCA ACCESSES, COLLECTS AND/OR HOLDS PERSONAL INFORMATION

    OSCA collects personal information in a number of ways including:

    • directly from you, including when you enter your personal details on our website (e.g. OSCAconnect and OSCAnet), such as when registering as a member or using or applying to use our services;
    • when you provide personal information by phone, email, or in documentation, such as our membership application form;
    • from third parties, including the College;
    • from publicly available sources of information.

    You can unsubscribe from our communications at any time by following the ‘unsubscribe’ option which will be included the emails we send, or by following the contact details provided in this policy.

    OSCA requires that its officers, staff, agents and volunteers respect the confidentiality of personal information held by OSCA.

    OSCA will take reasonable steps to protect the personal information it holds from misuse, loss, unauthorised access, modification or disclosure by use of various methods.

    In the event of an “eligible data breach”, in accordance with the Privacy Act and Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth), OSCA will investigate and notify you and the Office of the Australian Information Commissioner, in accordance with a required “data breach procedure and response plan.”

    If personal information is passed to external organisations acting on behalf of OSCA, OSCA will endeavour to ensure appropriate privacy safeguards are put in place before the release of the information.

    THE PURPOSES FOR WHICH OSCA COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

    In addition to the purpose disclosed at the time of collection, OSCA may use and disclose the personal information it collects and holds about its Members or prospective Members for the following purposes:

    • identifying Members and potential Members to assist them to access OSCA’s services more readily;
    • providing the ordinary services that OSCA provides to its Members;
    • administering and managing the services it provides, including charging, billing and collecting payment for those services;
    • gaining an understanding of the service needs of its Members in order to provide better, more personalised services that are tailored to the Members’ needs;
    • informing you of the ways the services provided by OSCA could be improved;
    • researching and developing of services that OSCA could provide;
    • maintaining and developing OSCA’s business systems and infrastructure, including testing and upgrading its systems;
    • providing your details to the College for the general purpose of keeping records consistent, reducing your need to inform two organisations, and informing you of events and activities, including those relating to fundraising.

    In relation to personal information about job applicants, contractors and volunteers, OSCA’s primary purpose of collection is to assess and (if successful) to engage the applicant, contractor or volunteer, as the case may be.

    The purposes for which OSCA uses personal information about job applicants, contractors and volunteers include:

    • to assess applications and suitability for employment, contracting work or volunteer work with OSCA;
    • in administering an individual’s work as a volunteer or contractor;
    • insurance purposes
    • to satisfy OSCA’s legal requirements.

    In some cases where OSCA requests personal information about you as a prospective employee, contractor or volunteer, if the information requested is not obtained, OSCA may not be able to fully assess your suitability for employment, contract work or volunteer work (as the case may be) or be able to employ or engage you.

    Unless noted at the time of collection, OSCA will not disclose personal information about an individual to recipients outside Australia without:

    • obtaining the consent of the individual (in some cases this consent will be implied), and/or
    • otherwise complying with the APPs.

     

  • ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

    Broadly, an individual may request access to any personal information which OSCA holds about them, and access will be provided within a reasonable time. Consistent with the APPs, there are, however, some exceptions where OSCA may refuse you access to your personal information, including to the extent that:

    • giving access would have an unreasonable impact on the privacy of others;
    • giving access would be unlawful;
    • denying access is required or authorised by or under an Australian law or a court or tribunal order;
    • giving access would be likely to prejudice an activity conducted by an enforcement body, such as Victoria police.

    OSCA endeavours to ensure that the personal information it holds is current, accurate, complete, and not misleading. You may seek to update your personal information that OSCA holds. Once notified, OSCA will then take such steps (if any) as are reasonable in the circumstances to ensure that, having regard to the purpose for which the information is held, it is updated and correct. However, if OSCA refuses to correct your personal information as requested by you, it will give you a written notice providing reasons for the refusal and mechanisms available for appeal.

    To make a request to access any information OSCA holds about you, or to have any information corrected, please contact:

    Executive Director

    Old Scotch Collegians’ Association
    1 Morrison Street
    Hawthorn   Vic   3121
    scott.montgomery@scotch.vic.edu.au
    +61 3 9810 4359

    DEFINITIONS

    In this policy document, unless otherwise noted within, capitalised terms have the meaning set out in the Association’s Constitution and as set out below:

    Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable:

    • whether the information or opinion is true or not; and
    • whether the information or opinion is recorded in a material form or not.

    Personal information also includes sensitive information and health information.

    Sensitive information is personal information that includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a professional, trade or political association or union, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices or criminal record.

    Health information is information or an opinion about the health or disability of an individual, the individual’s expressed wishes about the future provision of health services, or a health service provided to the individual, currently or in the future.

    COMPLAINTS

    You may make a complaint to OSCA if you consider that it has interfered with your privacy because of an alleged breach of any of the APPs in relation to personal information held about you.

    A complaint can be made in writing addressed to the Executive Director (per details noted above).

    The procedure for a complaint is:

    • The complaint must be forwarded to the Executive Director and must specify details of the alleged breach.
    • The Executive Director or such other person nominated by OSCA will ensure that the complaint is assessed and investigated.
    • A response will be provided as soon as practicable, with OSCA endeavouring to reply by no later than within 30 days of receiving the complaint.

    If OSCA determines that there has been a breach of the APPs, it will advise you of any action it intends to take to remedy the breach.

    The Executive Director will maintain a record of all complaints and determinations together with a record of any action taken in response to each complaint.

    RESOURCES

    Further information on the privacy legislation is available on www.oaic.gov.au or by contacting:

    Office of the Australian Information Commissioner
    GPO Box 5218
    Sydney  NSW  2001
    Privacy Hotline: 1300 363 992
    enquiries@oaic.gov.au

    OTHER

    OSCA may change its security and privacy policies at any time by publishing the new version of the policy on its website. OSCA recommends you visit this page occasionally to review policy updates.

    This policy was last updated in May 2020.

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