Kambala Old Girls' Union (KOGU) Privacy Policy

Scope of Policy and Source of Obligation

In the course of the Kambala Old Girls' Union's (KOGU's) activities, we manage and protect personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the 13 Australian Privacy Principles (APPs).

This policy outlines the circumstances in which we obtain personal information, how we use and disclose that information and how we manage requests to access and/or change that information.

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 student, alumni, contractor, volunteer, stakeholder, job applicant, visitor or others that come into contact with KOGU.

In the course of providing services we may collect and hold:

Personal Information including names, addresses and other contact details; dates of birth; next of kin details; photographic images; attendance records and financial information.
Health Information including immunisation details.

Generally, we will seek consent from the individual in writing before we collect any sensitive information (including health information).

Collection of Personal Information

The collection of personal information depends on the circumstances in which KOGU is collecting it. If it is reasonable and practical to do so, we collect personal information directly from the individual.

Solicited Information

KOGU has, where possible, attempted to standardise the collection of personal information by using specifically designed forms. However, given the nature of our operations we 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 and the number of pages viewed. 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

KOGU 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 KOGU 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 our functions or activities, and we have the individual's consent
Necessary to lessen or prevent a serious threat to life, health or safety
Another permitted general situation
Another permitted health situation

We may share sensitive information with other entities in our organisation structure, but only if necessary for us to provide our products or services.

How Do We Use Personal Information?

KOGU only uses personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or for an activity or purpose to which you have consented.

Our primary uses of personal information include, but are not limited to:

Marketing, promotional and fundraising activities
Keeping old girls informed as to school community matters through correspondence, newsletters and magazines
Organising reunions and events
Supporting the activities of Kambala
Supporting community based causes and activities, charities and other causes in connection with KOGU's functions or activities
Developing new programs and services
KOGU administration
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 with related bodies corporate, but only if necessary for us to provide our services.

KOGU may disclose information about an individual to overseas recipients only when it is necessary, for example to facilitate an old girl mentoring or internship program. KOGU will not send information about an individual outside of Australia without their consent.

Storage and Security of Personal Information

KOGU 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
Paper based files

KOGU 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:

Restricting access and user privilege of information by staff depending on their role and responsibilities
Ensuring KOGU staff do not share personal passwords
Ensuring hard copy files are stored in lockable filing cabinets in lockable rooms, with access subject to user privilege
Ensuring access to Kambala's premises is secured at all times
Implementing physical security measures around the school buildings and grounds to prevent break-ins
Ensuring our IT and cyber security systems, policies and procedures are implemented and up to date
Ensuring staff comply with internal policies and procedures when handling information
Undertaking due diligence with respect to third party service providers who may have access to personal information, to ensure as far as practicable that they are compliant with the APPs 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 third-party websites outside of KOGU. KOGU 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

KOGU 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.

Disclosure of Personal Information

Personal information is used for the purposes for which it was given to KOGU, or for purposes which are directly related to one or more of our functions or activities.

Personal information may be disclosed to government agencies, other old girls, recipients of school publications, our service providers, agents, contractors, business partners, related entities and other recipients from time to time, if the individual:

Has given consent; or
Would reasonably expect the personal information to be disclosed in that manner

KOGU may disclose personal information without consent 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

Disclosure of 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 stores data outside of Australia.

We will take all reasonable steps not to disclose an individual's personal information to overseas recipients unless:

We have the individual's consent (which may be implied)
We have satisfied ourselves that the overseas recipient is compliant with the APPs, 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 KOGU becomes aware that personal information is incorrect or out of date, we will take reasonable steps to rectify it.

Access and Correction of Personal Information

You 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 your 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

You can make a complaint about how KOGU manages personal information, including a breach of the APPs, 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.

KOGU does not charge a fee for the handling of complaints.

If you are not satisfied with our response, you 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

KOGU can be contacted about this Privacy Policy or about personal information generally by:

Emailing kogu@kambala.nsw.edu.au
Calling 02 9388 6888
Writing to our Privacy Officer at 794 New South Head Road, Rose Bay NSW 2029

If practical, you can contact us anonymously 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.

Changes to Our Privacy and Information Handling Practices

This Privacy Policy is subject to change at any time. Please check our Privacy Policy on our website at kambala.nsw.edu.au regularly for any changes.

This Privacy Policy was last reviewed: January 2021