This document sets out the approach which Bruce Downes Ministries (BDM) will take in relation to the treatment of Personal Information. It includes information on how BDM collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how BDM makes the personal information it holds available for access to and correction by the individual.
This policy is a public document and has been prepared in light of APP 1, Open and transparent management of Personal Information.
1.1 BDM will only collect Personal Information where the information is necessary for BDM to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 BDM collects Personal Information primarily to communicate events, campaigns or prayer devotions. BDM also collects and uses Personal Information for secondary purposes including:
- provision of products and services;
- accounting purposes; and
- business planning.
1.3 BDM collects Personal Information in a number of different ways including:
- forms (both paper and online, electronic forms);
- face to face meetings;
- connect cards;
- communications via telephone, email or facsimile;
- interaction with our websites; and
- via our social media accounts.
1.4 BDM will notify individuals of the matters listed below at the time of collecting any Personal Information:the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
our identity and how individuals can contact us, if this is not obvious;
that individuals can access the Personal Information that BDM holds about them;
that individuals should contact BDM if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
the organisations or types of organisations to whom we usually Disclose the Personal Information;
where applicable, any law that requires the Personal Information to be collected;
- the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
- other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
- our identity and how individuals can contact us, if this is not obvious;
- that individuals can access the Personal Information that BDM holds about them;
- that individuals should contact BDM if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
- the organisations or types of organisations to whom we usually Disclose the Personal Information;
- where applicable, any law that requires the Personal Information to be collected;
- the consequences (if any) for the individual if all or part of the Personal Information is not provided to BDM.
1.5 Where it is not practicable for BDM to notify individuals of all of the Collection Information before the collection of Personal Information, BDM will ensure that individuals are notified of the Collection Information as soon as possible after the collection. BDM will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.6 BDM will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for BDM to collect such information for an activity or function.
1.7 BDM will not collect Personal Information secretly or in an underhanded way.
1.8 BDM will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.4.
2.1 BDM will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.
2.2 BDM Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 If BDM relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
- individuals are clearly notified of their right to Opt Out from further Direct Marketing; and
- if the individual Opts Out of all Direct Marketing the Opt Out will be respected by BDM and implemented free of charge.
2.4 BDM will not use Sensitive Information for Direct Marketing.
2.5 BDM may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 BDM will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.7 BDM will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
3.1 BDM may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2 BDM may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
3.3 BDM will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.4 In the rare event that BDM is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors ADMA will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
3.5 BDM may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, BDM will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
4. Information Quality
4.1 BDM will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 BDM will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
5. Information Security
5.1 BDM requires employees and contractors to perform their duties in a manner that is consistent with BDM’ legal responsibilities in relation to privacy.
5.2 BDM will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within BDM who have a genuine “need to know” as well as “right to know”.
5.3 BDM will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Access and Correction
6.1 BDM will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 BDM will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting BDM, as per the details on the end of this document.
6.4 BDM will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 Contact with BDM via phone or web inquiry will be the first point of contact for enquiries about privacy issues.
7.2 Any formal privacy related complaints should be directed in writing to the BDM PO Box 200 Macarthur Square, NSW 2560.
7.3 BDM will endeavour to manage any privacy related complaint efficiently and in a timely manner.
8. Anonymous Transactions
8.1 BDM will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an enquiry or provide a service. BDM may however request visitors to provide Personal Information voluntarily to BDM (for example, as part of a competition or daily video devotion).
8.2 BDM will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
9. Transferring personal information overseas
9.1 BDM generally does not send information overseas.
9.2 If Personal Information must be sent by BDM overseas for sound business reasons, BDM will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the Australian Privacy Principles, preferably as part of the services contract.
Collection Information means the information outlined in 1.5 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of BDM or a Related Body Corporate or those of an independent third party organisation.
Disclosure generally means the release of information outside BDM, including under a contract to carry out an “outsourced function”.
Health Information means:
- information or an opinion about:
- the health or a disability (at any time) of an individual; or
- an individual’s expressed wishes about the future provision of health services to him or her; or
- a health service provided or to be provided to an individual; that is also personal information; or
- other personal information collected to provide or in providing a health service; or
- other personal information about an individual collected in connection with the donation; or intended donation by the individual of his or her body parts or body substances.
Opt-out means an individual’s expressed request not to receive further Direct Marketing.
BDM means The Catholic Guy, including its various brands and related entities.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Privacy Act means the Privacy Act 1988 (Cth) as amended from time to time.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.
Sensitive Information means:
- information or an opinion about an Individual’s:
- racial or ethnic origin; or
- membership of a political association; or
- religious beliefs or affiliations; or
- philosophical beliefs; or
- membership of a professional or trade association; or
- membership of a trade union; or
- sexual preferences or practices; or
- criminal record; that is also personal information; or
- Health Information about an individual; or
Use means the handling of Personal Information within BDM.
Last updated: 1 June 2016
BDM: ABN 46 144 573 259