The Privacy Act 1988 (Privacy Act) (amended 20 December 2018) regulates the handling of personal information about individuals. Palms Australia is obliged to be compliant with this legislation.
This document details Palms Australia’s policy with respect to the collection, holding and disclosure of personal information supplied to Palms Australia. This policy is informed by the Australian Privacy Principles (APP) which outline how Australian not-for-profit organisations must handle, use and manage personal information. When personal information such as name, address, or health details are collected, we are bound to follow these principles.
Important: Palms Australia provides personal information to overseas entities for the purposes of recruitment and arranging travel. These overseas entities are not bound by the Privacy Act (1988) and APP and Palms Australia is not responsible for personal information held by these overseas entities.
- Application of this policy
This Policy applies to personal information of international program applicants, international program participants, travellers, members, office staff and volunteers, donors, and subscribers.
‘International program applicants’ refers to individuals who have submitted information for the purposes of applying for a long-term international placement. ‘International program participants’ refers to individuals who have been accepted into Palms Australia’s global mentoring program, prior to departure, during their term overseas, and upon their return to Australia. ‘Travellers’ refers to individuals who are registered on a Palms Australia Encounter tour.
‘Personal information’ is information or an opinion about an identified individual, or an individual who is reasonably identifiable.
- Collection of information
Palms Australia collects personal information for the effective provision of our international programs, tours and domestic activities. Palms Australia collects personal information through:
- Online enquiry, application, and registration forms
- Information provided at events or in-person interactions
- Through publicly available publications (e.g. contact information provided on websites and published registers)
- Provision by a third party individual for the purposes of registering next of kin or program dependents.
Palms Australia will attempt to make clear the purpose of the inclusion of any sensitive information collected in application and registration forms. Individuals may choose not to disclose such information.
Palms Australia does not purchase or seek registers of personal information from third party entities for the purpose of marketing or communication.
- Holding of information
Personal information provided to Palms Australia is kept in a secure database. This information is accessible by Palms Australia staff and office volunteers.
Sensitive information is stored independently of this database and is accessible only to designated staff members. Any access of this sensitive information for purposes other than those for which it was provided is prohibited.
Individuals have the right to access personal information held and the right to request that the information held on file is correct, complete & up-to-date. Individuals may, at any time, request their personal information be updated by contacting a Palms Australia representative.
- Disclosure of information
Palms Australia will not disclose personal information to a third party or to a platform which may reasonably be considered public without the express consent of the individual, with the exception of sensitive information disclosed for the purposes of providing emergency medical care (See ‘6. Sensitive Information’ below). Consent will be sought from international program applicants, participants, and travellers to disclose their name and relevant information to overseas third parties for the purposes of securing an international placement or for necessary travel arrangements.
Information and opinions provided to Palms Australia for the purposes of distribution through Palms Australia’s website and online platforms must have the consent of all parties represented in accompanying images. By providing an article for publication, the individual agrees for the information therein to be publically available until such a time as Palms Australia removes it from the platform(s). Requests to remove personal information from Palms Australia’s public materials (online or in print) can be made to a Palms Australia representative.
Individuals will be notified of any request by a third party organisation or individual to access their personal information.
- Deletion of information
Any individual may request, at any time, for their information to be entirely and permanently deleted from Palms Australia’s records. An exception exists for records of electronic payments made to Palms Australia, the records of which must be available to Palms Australia for tax purposes.
To request that information is changed or deleted, an individual must contact a Palms Australia representative. Any requests for changes to, or deletion of, information must be made within three working days of receiving the request.
For individuals whose personal information is held for the purposes of their being registered as next of kin for international program participant or traveller, the international program participant or the traveller will be notified of this request for deletion and will be required to provide Palms Australia with details for a new next of kin.
The opportunity to unsubscribe from Palms Australia e-newsletter correspondence is made available in each instance of correspondence. Note that unsubscribing from this mailing list does not remove an individual’s record from Palms Australia’s database.
- Sensitive information
Sensitive information is a type of personal information and includes information about an individual’s:
- health (including predictive genetic information)
- racial or ethnic origin
- political opinions
- membership of a political association, professional or trade association or trade union
- religious beliefs or affiliations
- philosophical beliefs
- sexual orientation or practices
- criminal record
- biometric information that is to be used for certain purposes
- biometric templates.
Palms Australia will not disclose sensitive information of an individual without prior, express consent from the individual. An exception may be made for sensitive information of international program participants or traveller in cases of medical emergencies.
- Information held overseas
Personal information of international program applicants, participants and travellers may be provided to overseas entities for the purposes of recruitment or organising travel arrangements. By applying for an international program placement or an Encounter tour, individuals give consent for Palms Australia to share non-sensitive information with an overseas entity. Sensitive information will only be shared with the express consent of the individual.
Palms Australia is not responsible for personal information held by overseas entities.
- Reporting of data breaches
Palms Australia is obligated to report any data breeches or suspected data breeches. Notification of a breech or suspected breech will be made to the Office of the Australian Information Commissioner and affected individuals will be notified of the breech and any necessary steps to be taken to protect their personal information.
This policy may be revised in response to relevant amendments to the Privacy Act (1988) or legislation pertaining to digital data storage. However, the passage of new legislation does not negate this document. This document will remain in effect until such a time as it is reviewed and amended by Palms Australia.