1. Policy statement
Trojans Trek Foundation (ABN 12 161 998 232) (‘Trojans Trek’, ‘we’, ‘us’) understands that privacy is important to our community, participants, staff and all people we have dealings with. Trojans Trek is committed to compliance with the laws that protect personal information including the Privacy Act 1988 and the Australian Privacy Principles. Personal Information means information about an individual which identifies the individual or from which the individual is reasonably identifiable. See section 2 below for examples of the types of Personal Information we collect.
We undertake to only collect data which is directly relevant to our interactions, and hold it only for as long as we need to, or you direct us to delete it. This Privacy Policy explains how we may handle your personal information and your privacy rights. The practices outlined in this policy are subject to any rights or obligations we may have to handle Personal Information in accordance with the law.
2. Collection of Personal Information
The types of Personal Information we collect include:
• name;
• contact details (e.g. email address and telephone number);
• identification details;
• payment details (e.g. records of payments made and received);
• information about your service history and preferences relevant to our services
and activities;
• records of communications and activity with our staff members; and
• Medical information relevant to your participation in our activities including
relevant diagnoses and conditions, treatment plans as relevant, allergies and risk
management plans and other information which may be relevant to maintaining
your safety on our activities;
• Names and contact details for Next of Kin and/or Emergency Contacts.
For staff members and volunteers we can also collect information on:
• qualifications, skills, experiences, characters and screening checks
(including health, reference, background, directorship, financial probity,
identity, vocational suitability and criminal record checks);
• we may additionally collect information about training, terms and conditions, staff benefits, emergency contact details, performance, conduct, use of our IT and communications resources, payroll matters, drug/alcohol tests, leave and tax/financial affairs.
Some of the personal information we collect about people who work with us is collected pursuant to laws including the Fair Work Act, Superannuation Guarantee (Administration) Act, the Income Tax Assessment Act and other tax laws, Corporations Act, occupational health and safety acts and workers compensation acts.
We collect Personal Information in a number of ways, such as:
• directly from you, for example when you submit messages or electronic forms via our website or to email addresses displayed on our website, or provide information verbally on the phone;
• from analysis of information we already hold;
• from records of communications and activity, as described above;
• from public sources;
3. What we do with Personal Information
We collect, store use and disclose Personal Information for purposes including the
following:
• to deliver and improve our services to you;
• to respond to your enquiries and requests;
• for recruitment and staff management;
• for identification of collaborative opportunities;
• to operate our website, including to provide IT support or provide particular features (such as where you are required to log in);
• where you have consented to its use or disclosure;
• for purposes related to our record-keeping, research, planning, service development, security and risk management;
• to the extent that we are required or authorised by law to do so, and to defend and exercise our legal rights; and
• to provide you with information on Trojans Trek events or products that you may be interested in and that we believe is relevant to you. You can notify us if you do not wish to receive such information at info@trojanstrek.com
• We may be limited in our ability to do these things without your Personal
Information, for example we may not be able to communicate with you or provide the full range of our services or website features.
4. Who we share Personal Information with
We only share your Personally Identifiable Information (PII) with our volunteers and staff unless otherwise directed for a lawful reason.
From time to time we may be required to make reports to donors and sponsors on our activities. We may use anonymised data to illustrate program outcomes; your data may be aggregated with other participants to demonstrate outcomes.
5. Psychometric testing
All participants are required to undertake a battery of psychometric tests prior to, immediately following and three months following a trek. This data is used to measure the impact of the trek for both individuals and a cohort as a whole.
The administration, reporting and access to these tests is overseen by our Clinical Lead (a board member) to ensure all relevant clinical and ethical standards are met. Access to results and reporting is limited to:
1. Chair
2. Deputy Chair
3. Operations Director
4. Clinical Lead
All testing and reporting conducted using a commercial provider with appropriate security and data protection measures.
6. How we handle email, “Contact us” and “Expression of Interest (EOI) messages PII data which is received via email or website inquiries (including EOI) is managed within our Enterprise Resource Program (ERP). All PII data received via these means is protected by a combination of passwords and restricted access files.
7. Security
We have implemented a number of measures to protect the security and integrity of your Personal Information in physical and electronic form. Some of the measures we use depending on the circumstances, include encryption of data, data access controls, firewalls and backups. We store Personal Information ourselves and with the assistance of service providers.
Some PII and Medical Data will be printed and physical copies taken on various activities. This is to ensure that we have all required data to keep staff and participants safe in remote and locations without internet coverage. In the event that such data is required it will be managed as follows:
1. Printed and secured by the Trek Lead
2. Pertinent information will be briefed to staff on an as required basis
3. All paper records will be destroyed at the end of the trek
Please be aware that no data transmission over the Internet can be guaranteed as completely secure. So, while we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us online and you should do so at your own risk.
If you are a staff member of Trojans Trek, your username and password are essential for you to use the certain restricted-access sections of these website. For your own protection, we require you to keep these confidential in accordance with the Terms of Use.
8. Access to and correction of your information
If you wish to request access to any Personal Information which we hold about you as a result of our information collection practices outlined in this Privacy Policy, please contact us using the “Contact details” set out below. Please provide as much detail as you can about the particular information you seek, in order to help us retrieve it.
You can also request to update and correct your information.
In some circumstances, we may not be required by law to provide you with access or to correction of your Personal Information. In these circumstances, we will provide you with the reason(s) for refusal. If you disagree with our refusal to make a correction, you can request us to take reasonable steps to associate a statement with the information noting your disagreement.
9. Queries and complaints
If you have any questions or feedback about privacy, wish to make a query about your Personal Information or complaint about the way in which we have handled your Personal Information, you may contact us as set out below:
Email: info@trojanstrek.com
Address: Trojans Trek, 12/21 Francis Forde Boulevard, Forde, ACT 2912
If you are making a complaint, we may request additional details from you and may need to engage or consult with other parties in order to investigate and deal with your issue.
We will keep records of your request and any resolution.