PRIVACY POLICY
Pathways Melbourne Incoporated - Privacy Policy
Pathways Melbourne collects and administers a range of personal information for the purposes of supporting Jewish individuals who wish to question their Orthodox values and identity. The organisation is committed to protecting the privacy of personal information it collects, holds and administers. Pathways stakeholders may include: Jewish Individuals (Pathfinders), Donors, Supporters and Volunteers.
Pathways Melbourne recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – protected on one hand and made accessible to them on the other. These privacy values are reflected in and supported by our core values and philosophies and also reflected in our Privacy Policy, which is compliant with the Privacy Act 1988 (Cth).
Pathways Melbourne is bound by laws which impose specific obligations when it comes to handling, collecting, storing and/or disclosing information. The organisation has adopted the following principles contained as minimum standards in relation to handling personal information.
Pathways Melbourne will:
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Collect only information which the organisation requires for its primary function; Ensure that stakeholders are informed as to why we collect the information and how we administer the information gathered;
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Use and disclose personal information only for our primary functions or a directly related purpose, or for another purpose with the person’s consent;
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Store personal information securely, protecting it from unauthorised access; and
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Provide stakeholders with access to their own information, and the right to seek its correction.
Amendments
We may, at any time and our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our CEO Leah Boulton at info@pathwaysmelbourne.org
Pathways Melbourne Incorporated (ABN 68 546 911 029).
Responsibilities
Pathway Melbourne’s Board is responsible for developing, adopting and reviewing this policy.
The CEO is responsible for the implementation of this policy, for monitoring changes in Privacy legislation, and for advising on the need to review or revise this policy as and when the need arises.
Processes
Collection
Pathways Melbourne will:
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Only collect information that is necessary for the performance and primary function of Pathways Melbourne.
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Collect personal information only by lawful and fair means and not in an unreasonably intrusive way.
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Notify stakeholders about why we collect the information and how it is administered.
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Notify stakeholders that this information is accessible to them.
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Collect personal information from the person themselves wherever possible.
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If collecting personal information from a third party, be able to advise the person whom the information concerns, from whom their personal information has been collected.
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Collect Sensitive information only with the person’s consent or if required by law. (Sensitive information includes health information and information about religious beliefs, race, gender and others).
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Pathways Melbourne will also collect sensitive information about an individual if such collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns:
- is physically or legally incapable of giving consent to the collection; or
- physically cannot communicate consent to the collection; or
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If Pathways Melbourne collects information during the course of the activities of a non-profit organisation—the following conditions must be satisfied:
- The information relates solely to the members of the organisation or to individuals who have regular contact with it in connection with its activities;
- at or before the time of collecting the information, Pathways Melbourne inform the individual whom the information concerns that it will not disclose the information without the individual’s consent; and
- the collection must be necessary for the establishment, exercise or defence of a legal or equitable claim. -
Pathway’s Melbourne will collect health information about an individual if:
- the information is necessary to provide a service to the individual; and
- the information is collected as required or authorised by or under law and in accordance with rules established by competent health or medical bodies that
deal with obligations of professional confidentiality which bind the organisation.
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Determine, where unsolicited information is received, whether the personal information could have collected it in the usual way, and then if it could have, it will be treated normally. (If it could not have been, it must be destroyed, and the person whose personal information has been destroyed will be notified about the receipt and destruction of their personal information).
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Pathways will hold information in accordance with the law.
The types of personal information we may collect about you include:
Your name;
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Images of you;
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Your contact details, including email address, mailing address, street address and/or telephone number;
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Your marital status and/or anniversary;
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Your age and/or date of birth;
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Your credit card details;
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Your demographic information, such as postcode;
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Your preferences and/or opinions;
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Information you provide to us through surveys;
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Details of products and services we have provided to you and/or that you have enquired about, and our response to you;
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Your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
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Information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
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Additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
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Any other personal information requested by us and/or provided by you or a third party.
We may collect these types of personal information directly from you or third parties.
Use and Disclosure
Pathways Melbourne will:
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Only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose including:
- Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- Our employees, contractors and/or related entities;
- Our existing or potential agents or business partners;
- Sponsors or promoters of any competition we run;
- Sponsors and major donors of our organisation;
- Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- Credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
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Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise or defend our legal rights;
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Third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia [including in Israel and New Zealand]
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Third parties to collect and process data, such as Cookies, Web Beacons, Google Analytics, Joyful or Salesforce. This may include parties that store data outside of Australia.
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In the case that international requirements are relevant, appropriate measures will be undertaken on an ad hoc basis.
Storage
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Pathways Melbourne holds its data in Salesforce. All Salesforce-related activities will comply with this Privacy Policy and the law.
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Implement and maintain steps to ensure that personal information is protected from misuse and loss, unauthorized access, interference, unauthorized modification or disclosure.
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Before Pathways Melbourne discloses any personal information to an overseas recipient including a provider of IT services such as servers or cloud services, establish that they are privacy compliant. Pathways Melbourne will have systems which provide sufficient security.
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Ensure that Pathways Melbourne’ data is up to date, accurate and complete.
Destruction and de-identification
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Destroy personal information once is not required to be kept for the purpose for which it was collected in a secure manner
Data Quality
Pathways Melbourne will:
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Take reasonable steps to ensure the information Pathways Melbourne collects is accurate, complete, up to date, and relevant to the functions we perform.
Openness
Pathways Melbourne will:
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Ensure stakeholders are aware of Pathways Melbourne’s Privacy Policy and its purposes.
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Make this information freely available in relevant publications and on the organisation’s website.
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On request by a person, Pathways Melbourne must take reasonable steps to let the person know, generally, what sort of personal information it holds, for what purposes, and how it collects, holds, uses and discloses that information.
Access and Correction
Pathways Melbourne will:
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Ensure individuals have a right to seek access to information held about them and to correct it if it is inaccurate, incomplete, misleading or not up to date.
Making information available to other organisations
Pathways Melbourne can:
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Release information to third parties where it is requested by the person concerned.
Pathways Melbourne is a charitable organisation registered with the Australian Charities and Not for Profits Commission and is endorsed as a Deductible Gift Recipient (DGR). Donations over $2 are tax deductible.
ABN 68 546 911 029