Indigital Pty Ltd has obligations concerning the collection, use, disclosure and storage of personal information. These obligations are set out in the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act), and other applicable State and Territory privacy laws.
You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
What is personal information?
“Personal information” is information or an opinion about an identified individual or reasonably identifiable individual, whether true or not or whether recorded in material form or not.
What personal information do we collect and hold?
The personal information we collect and hold includes information about customers (including students, teachers, and elders), employees, prospective employees and contractors.
The personal information that we collect and hold may include an individual’s:
- date of birth;
- email address;
- the location from which you have come to the site and the pages you have visited;
- technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system; telephone number and other contact details;
- credit card information;
- workplace; and
- information provided to us via customer surveys.
What Sensitive information do we collect and hold?
“Sensitive information” is a sub-category of personal information which includes information about an individual’s racial or ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health information, genetic or certain biometric information.
Sensitive information that we may collect includes:
- racial or ethnic origin (Aboriginal or Torres Strait); and
- health information.
How do we collect and hold personal information?
We may collect personal information from the individual concerned or from a third party.
We may collect this information when you communicate with us through our website, by telephone, by e-mail or through a written application or via a survey.
We have processes in place to ensure that our records remain accurate, complete and up to date, including by verifying the information with you each time you use our services or from other sources.
If the information is no longer required by us for any purpose for which it was collected and is no longer required by law to be retained by us, we will destroy or de-identify the information.
These records may be retained for up to 7 years.
Can I remain anonymous?
You can always choose to deal with us anonymously or by using a pseudonym.
However, please note that if you choose to remain anonymous, this may affect your ability to access or use certain functions of our website or services.
If you wish to remain anonymous when dealing with us via a telephone call, please advise the team member assisting you. Providing your personal details enables us to retrieve information about that call at a later date.
Why do we collect, hold, use and disclose personal information?
We collect, hold, use and disclose personal information for the following purposes:
- to enable you to access and use our website and Indigital services;
- to operate, improve and optimise our website and services and yours and other users’ experience;
- to design and customise our Indigital programs to meet your needs;
- to send marketing and promotional messages to you and other information that has been requested or which may be of interest; and
- to comply with our legal obligations.
To whom do we disclose personal information?
We may disclose personal information to external service providers so that they may perform services for us or on our behalf.
When we disclose personal information to third parties, we make all reasonable efforts to ensure that we disclose only relevant information and that it is accurate, complete and up to date and that the third party will comply with the Privacy Act in relation to that information.
We may disclose personal information in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by the Privacy Act.
These other disclosures may include where:
You would reasonably expect the disclosure to occur (for example, quality assurance purposes or training);
We are authorised or compelled by law to disclose;
it will prevent or lessen a serious threat to someone’s life, health or safety or a threat to public health or safety;
it is necessary as part of the establishment or defence of a legal claim;
it is requested by an enforcement agency such as the police; or
it is a necessary part of an investigation following a complaint or incident.
Disclosure of personal information outside Australia
Where we disclose information outside of Australia, we will take reasonable steps to ensure that any such person to whom personal information is disclosed will deal with that information in a way that is consistent with the APPs.
Do we use your personal information for marketing?
We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
A “cookie” is a small file stored by the web browser software on a computer when you access our website (an explanation of cookies can be found at the website of the Australian Information Commissioner at www.oaic.gov.au.)
Our website uses Google Analytics, a web analytics service provided by Google Inc. (Google).
The information generated by the cookie about your use of the website (including their IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of compiling reports on the website activity and providing other services relating to the website and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate a person’s IP address with any other data held by Google.
You can opt out of the collection of information via Google Analytics by downloading the Google Analytics Opt-out browser add here.
Microsoft Forms (schools and organisations only)
We use Microsoft Forms to capture information when we run our Indigital Programs with schools and organisations.
Information captured through Microsoft Forms includes:
- name of main contact at school;
- email of main contact at school; and
- role of main contact at school.
- Student information is de-identified. We may also ask whether there are any students with special needs at a school and will record gender and cultural background numbers of participants.
Security of your personal information
To protect personal information from misuse and loss, and from unauthorised access, modification or disclosure:
- our staff are trained in how to keep your information safe and secure;
- we store your hard copy and electronic records in secure systems; and
- we use trusted contracted service providers (including cloud storage providers).
The personal information of our employees, systems and most of the third parties we share information with are located in Australia, with some of this personal information stored in secure cloud systems.
Our sites may have links to other websites not controlled or owned by us. We are not responsible for these sites or any consequence of a person’s use of those sites. In particular, we are not responsible for the privacy policies or practices of the operators of other websites. We recommend that you review the privacy policies of those external websites before using them.
Third party sites and platforms
We note that where you use third party sites or platforms (such as app stores) to access our services, we are not responsible for such sites or platforms or any consequence of a person’s use of those sites or platforms. We are not responsible for the privacy policies or practices of the operators of those sites or platforms and we recommend that you review the privacy policies of those sites or platforms before using them.
How can I access or correct my personal information?
We have measures in place to ensure that the information we hold about individuals is accurate, complete and up to date. If you learn that personal information we hold about you is inaccurate, incomplete or not up to date you should contact us so that the information can be updated.
If you wish to see what information we hold about you, you can ask us for a copy.
Sometimes it may not be possible to give you a copy of the information if it was provided anonymously, if it contains details about other people, or if it would be unsafe to provide the information (for instance, if it may lead to harm being done to another person).
If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons.
If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
You will be notified of any likely costs before your request is processed.
How can I make a complaint?
If you have a complaint or concern regarding our handling of your personal information or think that your privacy has been affected you should contact us as detailed below for an examination of your complaint or concern. If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC). See www.oaic.gov.au for how to make a complaint.
Chief Operating Officer: Joanna Baker
Phone: 0413 960 313
Postal address: Building 3.3, 1 Dairy Road Fyshwick, ACT 2609
|Revision||Date||Owner||Description of changes|
|1.025||July 2022||Chief Operating Officer||Refresh of existing policy|