On-line Privacy Statement
This statement declares the undertakings by the Woolcock Institute of Medical Research in relation to its handling of Your information. The Woolcock takes the privacy of users of its web-sites seriously and seeks to comply with all elements of the National Privacy Principles in its on-line conduct.
Information Collection
The Woolcock Institute of Medical Research (hereafter referred to as “The Woolcock”) undertakes to collect Your information by means that are fair, legal, and transparent.
About the collection of web-site traffic data: The Woolcock’s web-site www.woolcock.org.au uses www.statcounter.com to collect visitor data and analyse traffic on our web-site. This information helps us understand visitor interests and helps us improve our web-site. Statcounter does not sell, give, or trade the statistics they store to any third parties for data-mining or marketing purposes. Please visit www.statcounter.com/privacy.html for their privacy policy.
If you visit The Woolcock’s web-site, your web-browser automatically discloses, and our web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in ‘cookies’ and submits them each time you request a web-page within a particular domain (such as www.woolcock.org.au). This data may or may not be sufficient to identify you.
About “cookies”: When you visit our site, the pages that you look at, and a short text file called a cookie, are downloaded to your computer. A cookie is used to store small amounts of information. This information is collected for traffic analysis only. The cookie does not contain personal details.
Overall, cookies help us provide you with a better web-site, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Depending on the browser that you use, you can set your preferences to block/ refuse cookies, and/ or notify you before they are placed. This may prevent you from taking full advantage of the web-site.
Links to other web-sites: This privacy policy does not apply to parties that may be linked or associated with The Woolcock’s web-site. Those web-site owners are responsible for the privacy of the information they collect and should be contacted directly for details of their privacy policies.
Our web-site may contain links to other web-sites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other web-site. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the web-site in question.
If you disclose personal data to The Woolcock in conjunction with an identifier such as your name or your credit-card details, The Woolcock will collect Your information. Moreover, any data that becomes available to The Woolcock through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your information.
Controlling your personal information: You may choose to restrict the collection or use of your personal information in the following ways:
• whenever you are asked to fill in a form on the web-site, look for the box or field that you can tick or un-tick to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at breathless@woolcock.org.au.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
Subject to the qualifications immediately below, The Woolcock undertakes to collect Your information from you and not from other parties. This undertaking is qualified as follows:
• where The Woolcock reasonably considers that the protection of its financial interests requires that it gather Your information from other sources, or from additional sources. This applies in particular where The Woolcock has a lending exposure to you, and seeks information about your creditworthiness;
• where The Woolcock reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your information from other sources. This applies in particular to consumer profile data.
Where The Woolcock collects Your information from sources other than you, it undertakes:
• to do so only by legal means;
• to do so only with your Consent; and
• to declare to you what sources it uses, and under what circumstances.
The Woolcock undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as ‘to support our operations’.
Information Security
The Woolcock undertakes to store Your information in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
The Woolcock undertakes to transmit Your information in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
The Woolcock undertakes to implement appropriate measures to ensure security of Your information against inappropriate behaviour by The Woolcock’s staff-members and contractors. These include:
• training for staff in relation to privacy;
• access control, to limit access to Your information to those staff and contractors who have legitimate reasons to access it;
• particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
• reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
• declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
• clear communication of policies and sanctions; and
• processes to audit, to investigate and to impose sanctions.
Information Use
Use refers to the application of Your information by any part of The Woolcock, or any staff-member or contractor of The Woolcock in the course of their work.
The Woolcock undertakes to use Your information only for:
• the purposes for which it was collected;
• such other purposes as are subsequently agreed between The Woolcock and You;
• such additional purposes as may be required by law. In these circumstances, The Woolcock will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
• such additional purposes as are authorised by law (in particular to protect The Woolcock’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to The Woolcock or have committed a breach of the criminal law).
The Woolcock undertakes to use Your information only if it has demonstrable relevance to the particular use to which it is being put.
The Woolcock undertakes to use Your information in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
Information Disclosure
Disclosure refers to making Your information available to any party other than The Woolcock and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
The Woolcock undertakes to disclose Your information only under the following circumstances:
• win the course of business being conducted between You and The Woolcock, where disclosure is necessary to a contractor, such as a transport company. Where Your information is disclosed in this way, The Woolcock undertakes to exercise control over The Woolcock’s contractors to ensure that their actions are compliant with these Terms;
• in other circumstances that are directly implied by the purpose agreed between You and The Woolcock at the time of data collection or subsequently. Where Your information is disclosed in this way, The Woolcock undertakes to exercise control over The Woolcock’s contractors to ensure that their actions are compliant with these Terms;
• with your consent, or at your request;
• where required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena. In these circumstances, The Woolcock will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
• where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where The Woolcock believes on reasonable grounds that the disclosure of Your information will materially assist in the protection of the life of health of some person), provided that The Woolcock will apply due diligence to ensure that the exercise of the permission is justifiable.
In all cases, The Woolcock undertakes to disclose only such of Your information as is necessary in the particular circumstances.
Information Retention and Destruction
Subject to the qualifications immediately below, The Woolcock undertakes:
• to retain Your information only as long as is consistent with its purpose; and
• to destroy Your information when its purpose has expired, and to do so in such a manner that Your information is not subsequently capable of being recovered.
This undertaking is qualified as follows:
Your information may be retained in The Woolcock’s logs, backups and audit trails within short-term retention cycles that are devised to protect the organisation’s operations. In such cases, Your information will be destroyed in accordance with those cycles;
Your information may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, The Woolcock:
will take any reasonable steps available to it to communicate to You that Your information is being retained, unless it is precluded from doing so by law; and
• will only retain Your information while that provision is current, and will then destroy Your information;
Your information may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect The Woolcock’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to The Woolcock or have committed a breach of the criminal law). In these circumstances, The Woolcock will only retain Your information while that situation is current, and will then destroy Your information.
Access by You to Your Personal Information
The Woolcock undertakes to provide you with access to Your information, subject to only such conditions and processes as are reasonable in the circumstances. In particular, The Woolcock undertakes to enable access conveniently, without unreasonable delay, and without cost.
You can request access to your personal information by contacting The Woolcock (02 9114 0000 or admin@woolcock.org.au). Please provide details of exactly what information you require. We may ask you some personal questions to identify you and ensure the confidentiality of Your information.
The Woolcock undertakes to establish and operate identity authentication protections for access to Your information that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with The Woolcock (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your information, The Woolcock undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your information.
You undertake:
• not to seek access for frivolous purposes, or unreasonably frequently;
• to accept that deletion of some data may not be consistent with the provision of particular services by The Woolcock to you.
The personal information we hold should be accurate, complete and up-to-date. If at any time you believe that we hold incorrect personal information about you, please notify us and we will correct your personal information.
Information about Data-Handling Practices
The Woolcock undertakes to make information available to you about the manner in which The Woolcock handles Your information:
• in general terms, in a readily accessible manner; and
• in more specific terms, on request.
Where Your information is disclosed to a contractor, The Woolcock undertakes to make information available to you on request about the manner in which The Woolcock’s contractors handle Your information.
The Woolcock undertakes to ensure that the information provided is meaningful, and addresses your concerns.
You undertake:
• not to seek such information for frivolous purposes, or unreasonably frequently; and
• to accept that the disclosure of excessive detail may harm the security of Your information and The Woolcock’s business processes, and may harm The Woolcock’s commercial interests.
Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about The Woolcock’s behaviour in relation to these Terms, you undertake:
• to communicate them in the first instance:
• to The Woolcock only;
• in sufficient detail;
• through a channel made available by The Woolcock for that purpose;
The Woolcock undertakes:
• to provide one or more channels for communications to The Woolcock, which are convenient to users;
• to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and The Woolcock’s reference-code for the communication;
• to promptly provide a response to the communication, in an appropriate and meaningful manner.
You further undertake to not pursue The Woolcock through any Regulator or the media:
• until and unless The Woolcock has had a reasonable opportunity to respond to the initial communication; and
• while The Woolcock and you remain are conducting a meaningful dialogue about the matter.
Enforcement
The Woolcock declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between You and The Woolcock, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which The Woolcock is domiciled or performed the relevant acts.
If you wish to discover the relevant Australian laws, The Woolcock draws your attention to the http://www.privacy.gov.au/.
Changes to These Privacy Undertakings
The Woolcock undertakes:
• not to materially change these Terms in a manner that reduces the protections for Your information;
• to take all possible steps to prevent any organisation that acquires this organisation or any of its relevant assets from materially changing the Terms applicable to Your information in a manner that reduces the protections for Your information;
• where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organisations;
• where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
• to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.
Definitions
The Woolcock means the Woolcock Institute of Medical Research.
Your information means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that The Woolcock is capable of correlating with you, using such means as server-logs and cookie-contents.
Your information does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.
Consent means your concurrence with an action to be taken by The Woolcock. Consent may be express or implicit, but in either case must be informed and freely-given.
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