Policy last updated: [4 August 2021]
This Privacy Policy is maintained by the Zionist Federation of Australia and its related entities (together, the ZFA). This Privacy Policy explains how the ZFA intends to collect, store, use, disclose, protect and otherwise handle your personal information having regard to the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act).
Personal information is information or an opinion about you from which you can be reasonably identified whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
The primary purpose for which the ZFA collects and uses your personal information is to provide you with information and material about the ZFA and its campaigns and projects, and to enable you and/or your children to participate in the programs, initiatives and services that the ZFA may offer from time to time including Israel GO.
The ZFA may also collect and use personal information for a secondary purpose closely related to the primary purpose above.
If the ZFA does not collect your personal information, it may not be able to provide services to you and your children.
4.1 Personal information
The types of personal information collected by the ZFA include:
(a) names;
(b) contact details (including address, email address, telephone number(s) and other contact details);
(c) dates of birth;
(d) gender;
(e) schools attended;
(f) bank details; and
(g) any other information you provide to us
4.2 Sensitive information
The personal information collected by the ZFA may include sensitive information, which is defined in the Privacy Act to include information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
The types of sensitive information that the ZFA may collect and hold may include, but is not limited to, you and your child’s Jewish community organisation affiliation, and medical information.
The ZFA will only use sensitive information:
(a) for the primary purpose for which it was obtained;
(b) for a secondary purpose that is directly related to the primary purpose;
(c) with your consent; or
(d) where required or authorised by law.
The ZFA will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide the ZFA with personal information, you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy (and any subsequent amendments to this Privacy Policy).
5.1 Collecting information from you
If it is reasonable and practical to do so, the ZFA will collect personal information directly from you.
Depending on how you choose to interact with the ZFA, the ZFA may collect your personal information when you contact, or are contacted by, the ZFA or its service providers by telephone, by email, through the websites operated by the ZFA, via social media and other via digital services, or when you complete a form or document on your own or your child’s behalf and provide it to the ZFA.
5.2 Collecting information from third parties
The ZFA may also collect information about you from other people or from independent sources. For example, the ZFA may collect personal information about you from character referees if you apply for a program offered by the ZFA. However, the ZFA will only do so where it is not reasonable and practicable to collect the information from you directly.
Where the ZFA has collected your information from a third party, such personal information will be held, used and disclosed by the ZFA in accordance with this Privacy Policy.
5.3 Collecting information from visits to the ZFA’s websites
The ZFA may also collect information based on how you use the the ZFA’s websites including through ‘cookies’, web beacons and other similar technologies.
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable the ZFA’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).
No attempt is made by the ZFA to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of the ZFA’s websites may not function fully for users that disable cookies.
5.4 Unsolicited information
If the ZFA receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, the ZFA will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
The security of your personal information is important to the ZFA. Accordingly, the ZFA takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure if stored electronically, in hard copy or both. However, the ZFA does not guarantee that unauthorised access to your personal information will not occur, either during transmission of that information to the ZFA or after the ZFA receives that information. These steps include the implementation of the following safeguards:
(a) periodically updating our security measures in light of current technologies;
(b) password protected databases;
(c) staff training;
(d) system firewalls; and
(e) internal information security policies.
The ZFA will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.
6.1 Security breach procedures
The ZFA’s data security practices have been adopted to protecting the data held by the ZFA. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, the ZFA cannot guarantee any transmission will be completely secure.
The ZFA may hold, use or disclose your personal information so that it can contact you with information and material about its organisation and provide you with the services that you request.
The ZFA may also hold, use or disclose your personal information to:
(a) send you regular updates, newsletters or other information as requested by you;
(b) request your participation in surveys run by the ZFA;
(c) enable you or your child to participate in programs or initiatives run by the ZFA;
(d) fulfil administrative functions associated with the ZFA’s initiatives and services, such as payment processing and entering into contracts with you;
(e) consider any concern or complaint that you raise against the ZFA or to manage any legal action between you and the ZFA;
(f) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or
(g) comply with any relevant laws, regulations, codes of practice and court orders.
The ZFA may share your personal information with third parties where necessary, including with:
(a) financial institutions for payment processing;
(b) its contracted service providers or partners, including:
(i) accommodation and travel providers;
(ii) data storage and archive service providers;
(iii) function and event organisers;
(iv) marketing and communications agencies;
(v) research and statistical analysis providers;
(vi) delivery and shipping providers; and/or
(vii) business advisers (such as accountants, auditors and lawyers).
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant services to you.
The ZFA’s websites may contain links to other websites. The ZFA does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.
8.2 Cross-border disclosure
The ZFA may transfer your personal information to entities in foreign countries to assist the ZFA in providing its services, programs or projects to you, such as to entities located in Israel and the United States.
Where your personal information is transferred to an entity in a foreign country, the ZFA will take such steps as are reasonable in the circumstances to ensure that the information will not be held, used or disclosed by the recipient of the information in a manner that is inconsistent with Australian privacy laws.
8.3 Website users
Where you make public comments or posts on the ZFA’s websites or social medial platforms, you understand that your comments and posts will be publicly available. You may use a pseudonym when posting content on the ZFA’s websites or social media platform if you do not wish to publish your personal information.
You acknowledge that third parties may be able to view and use any personal information you make available in public comments and posts. The ZFA does not take any responsibility for the personal information you make publicly available on the ZFA’s websites or social media platforms.
You may contact the ZFA to request access to the personal information it holds about you and your child at any time. You may also ask the ZFA to correct information about you that you may believe is inaccurate, incomplete or out of date.
Please contact the ZFA using the contact details set out in section 11 below. The ZFA will need to verify your identity before giving you access to, or correcting, your personal information. The ZFA will respond any such request within a reasonable period after the request is made. There is no charge to make a request, however the ZFA may charge a reasonable fee to cover the administrative costs of retrieving your personal information.
In certain circumstances, the ZFA may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, the ZFA will write to you to explain the reasons why this is the case.
If you have a complaint related to how the ZFA has managed your personal information, please contact the ZFA using the contact details set out in section 11 below. The ZFA may ask you to put your concerns in writing so that its compliance staff can fully understand and investigate your complaint.
The ZFA will provide you with an estimated response timeframe in relation to your complaint. In any event, the ZFA will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.
If you have any questions about this Privacy Policy or the ZFA’s management of your personal information, please contact the ZFA on:
Attention: Marlene Kotkin
Tel: 03 9272 5564
Email: zfa@zfa.com.au
This Privacy Policy is subject to change at any time so we encourage you to review this policy at regular intervals.
If the ZFA changes this Privacy Policy, an updated version will be posted on its website at [www.zfa.com.au/privacypolicy].
By continuing to use the ZFA’s services or otherwise interacting with the ZFA after that time, you will be deemed to have accepted any changes to its Privacy Policy.