Privacy Policy

This Policy applies to The Council for Christian Education in Schools Ltd (ABN 59 004 240 779) (referred to as ‘Korus Connect’, ‘we’, ‘our’, ‘us’) and extends to and covers all operations and functions of that organisation.

All clients that have access to or use personal information collected and held by Korus Connect must abide by this Privacy Policy. Korus Connect makes this Policy available free of charge and can be downloaded from its website here.

This Policy outlines Korus Connect’ obligations to manage and protect personal information. Korus Connect is bound by the Australian Privacy Principles ('APPs') and the Privacy Act 1988 ('Privacy Act'). This Policy also outlines Korus Connect’ practices, procedures and systems that ensure compliance with the Privacy Act and the APPs.

In this Privacy Policy:

• ‘Clients’ means customers, potential customers, service providers or suppliers, prospective employees, employees and contractors, relevant parties with whom we come into contact, volunteers, donors, supporters and stakeholders;
• ‘Disclosing’ information means providing information to persons outside Korus Connect;
• ‘Individual’ means any person whose personal information we collect, use or disclose;
• ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
• ‘Privacy Officer’ means the contact person within Korus Connect for questions or complaints regarding Korus Connect’ handling of personal information;
• ‘Sensitive information’ is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
• ‘Use’ of information means use of information within Korus Connect.

We collect and hold the following kinds of personal information about individuals:

• name
• address
• phone numbers
• email addresses
• occupation
• bank account details
• drivers’ licence details
• any other information that is relevant to the services that we provide.

We generally collect personal information directly from the individual. For example, personal information will be collected when an individual opens an account with us, visits our website, or sends us correspondence. Sometimes we may collect personal information about the individual from a third party. When we are provided with personal information from a third party, we will take reasonable steps to ensure that the individual is or has been made aware of the matters set out in this Privacy Policy.

Korus Connect will not collect sensitive information unless the individual has consented or an exemption under the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If the personal information we request is not provided, we may not be able to provide customers with the benefit of our services, or meet an individual’s needs appropriately.

Korus Connect does not give individuals the option of dealing with them anonymously, or under a pseudonym. This is because it is impractical for Korus Connect to deal with individuals who are not identified.

Korus Connect may receive unsolicited personal information about individuals. Korus Connect’ employees are required to notify the Privacy Officer of all unsolicited personal information received by them. We destroy or de-identify all unsolicited personal information, unless the personal information is relevant to Korus Connect’ purposes for collecting personal information.

The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals

• customers;
• potential customers;
• service providers or suppliers;
• prospective employees, employees and contractors;
• other third parties with whom we come into contact;
• volunteers;
• donors, stakeholders and supporters.

We collect personal information from our web site (www.korusconnect.org.au) when we receive emails and online forms. We may also use third parties to analyse traffic at that web site, which may involve the use of cookies. Information collected through such analysis is anonymous. Our website privacy policy can be accessed by clicking on the privacy button on our website.

We may use and disclose the information we collect about an individual for the following purposes:

• to assist Korus Connect in providing a product or service to an individual;
• to consider and assess an individual’s request for a product or service;
• to provide an individual with information about a product or service and invite an individual to marketing events;
• to protect our business and other customers from fraudulent or unlawful activity;
• to conduct our business and perform other management and administration tasks
• to consider any concerns or complaints an individual may have;
• to manage any legal actions involving Korus Connect;
• to comply with relevant laws, regulations and other legal obligations; and
• to help us improve the products and services offered to our customers, and to enhance our overall business.

Korus Connect may use and disclose personal information for the primary purposes for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.

We use and disclose personal information for the purposes outlined in section 7 above. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g. if required by law).

We engage other people to perform services for us, which may involve them handling personal information we hold. In these situations, we prohibit them from using personal information about the individual except for the specific purpose for which we supply it. We prohibit them from using your information for the purposes of direct marketing their products or services.

In relation to sensitive information held by us, wherever possible, Korus Connect will attempt to deidentify the information. We also undertake to take reasonable steps to delete all personal information about an individual when it is no longer needed.

We may disclose personal information to:

• a related entity of Korus Connect;
• an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors, mailing houses, or other advisors;
• organisations involved in a transfer or sale of all or part of our assets or business;
• organisations involved in managing our payments, payment merchants and other financial institutions such as banks;
• regulatory bodies, government agencies, law enforcement bodies and courts; and
• anyone else to whom the individual authorises us to disclose it or as required by law. We may also collect personal information from these organisations and individuals, and will deal with that information in accordance with this Policy.

We will not disclose personal information to recipients outside of Australia unless:

• we have taken reasonable steps to ensure that the recipient does not breach the Act, or the APPs;
• the recipient is subject to an information privacy scheme similar to the Privacy Act; or
• the individual has consented to the disclosure.

Korus Connect recognises how important the security of personal information is to clients. We will at all times seek to ensure that the personal information we collect and hold is protected from misuse, loss, unauthorised access, modification or disclosure. Korus Connect employees must respect the confidentiality of the personal information we collect.

Personal information is generally held in a computer data base. Information may also be held in paper files which are stored in secure areas. Computer-based information is protected through the use of access passwords.

In relation to our computer-based information, we apply the following guidelines:

• data ownership is clearly defined within Korus Connect;
• passwords are routinely checked;
• we change employees’ access capabilities when they are assigned to a new position;
• employees have restricted access to certain sections of the system;
• the system automatically logs and reviews all unauthorised access attempts;
• the system automatically limits the amount of personal information appearing on any one screen;
• unauthorised employees are barred from updating and editing personal information;
• all personal computers which contain personal information are secured, physically and electronically;
• data is encrypted during transmission over the network;
• print reporting of data containing personal information is limited;
• Korus Connect has created procedures for the disposal of personal information; and
• personal information is overwritten to the extent possible when the information is no longer required. Korus Connect performs all volunteer and employment procedures, including application and termination processes, in a confidential manner. All individual job attributes, such as classification information and salaries, are confidential.

Where we no longer require the personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.

Korus Connect will only use or disclose personal information for the purposes of direct marketing, if the individual has consented to its use or disclosure for direct marketing. Individuals have the right to request to opt out of direct marketing and we must give effect to the request within a reasonable period of time.

In relation to sensitive information, Korus Connect may only use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.

Individuals may also request that Korus Connect provides them with the source of their information. If such a request is made, Korus Connect must notify the individual of the source of the information free of charge within a reasonable period of time.

We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. Korus Connect endeavours to avoid data-matching, being the comparison of data collected and held for two or more separate purposes in order to identify common features in relation to individuals, as a basis for further investigation or action in relation to those individuals

Korus Connect is committed to ensuring that the personal information it collects, uses and discloses is relevant, accurate, complete and up-to-date. We encourage individuals to contact us to update any personal information we hold about them. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless it is agreed otherwise. We do not charge individuals for correcting the information.

Subject to the exceptions set out in the Privacy Act, individuals may gain access to the personal information that we hold about them by contacting the Korus Connect Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal.

An individual’s request for access to his or her personal information will be dealt with by allowing the individual to look at his or her personal information at the offices of Korus Connect. We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.

This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.

It is the responsibility of management to inform employees and other relevant parties about the Korus Connect Privacy Policy. Management must ensure that they advise Korus Connect’ employees and other relevant parties of any changes to the Privacy Policy. It is the responsibility of all employees and other relevant parties to ensure that they understand and comply with this Privacy Policy.

All new employees and volunteers are provided with timely and appropriate access to Korus Connect’ Privacy Policy. All employees and volunteers are provided with opportunities to attend privacy training, which covers Korus Connect’ obligations under the Act and the APPs. Employees must ensure that they understand the Privacy related issues that could adversely affect Korus Connect and its clients if not properly adhered to.

Privacy breaches must be reported to management by employees and other relevant parties. Ignorance of the Korus Connect’ Privacy Policy will not be an acceptable excuse for non-compliance. Employees or other relevant parties who do not comply with Korus Connect’ Privacy Policy may be subject to disciplinary action.

Korus Connect has an effective complaints handling process in place to manage privacy risks and issues.

The complaints handling process involves:

• identifying (and addressing) any systemic/ongoing compliance problems;
• increasing consumer confidence in Korus Connect’ privacy procedures; and
• helping to build and preserve Korus Connect’ reputation and business.

Individuals can make a complaint to Korus Connect about the treatment or handling of their personal information by lodging a complaint with the Privacy Officer.

Korus Connect must ensure that all contractual arrangements with parties adequately address privacy issues. Korus Connect will make relevant parties aware of this Privacy Policy.

Third parties will be required to implement policies in relation to the management of an individual’s personal information in accordance with the Privacy Act. These policies include:

• regulating the collection, use and disclosure of personal and sensitive information;
• de-identifying personal and sensitive information wherever possible;
• ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
• ensuring that the personal and sensitive information is only disclosed to organisations which are approved by Korus Connect.

Korus Connect will conduct periodic privacy audits in order to ensure that it is continuing to comply with its obligations under the APPs.

Any questions about our privacy procedures, or if you wish to make a complaint about how we have dealt with your personal information you may lodge a complaint with us by contacting the Korus Connect Privacy Officer using the details that follow:

The Chief Privacy Officer
Korus Connect
People & Culture Division
Locked Bag 3
SURREY HILLS VIC 3127
enquiries@korusconnect.org.au
(+61) (03) 9811 0999