Table of Contents
Contact us – We are here to help
You can get in touch with us at any time about the way we handle and safeguard your data.
Email [email protected]
Privacy Officer
Life for a Child C/O Diabetes NSW & ACT
26 Arundel St, Glebe
Sydney NSW 2037, Australia
About us and this Policy
Life for a Child is a trading name of Diabetes NSW (ACN 001 363 766) acting as trustee for the Diabetes Overseas Aid Fund.
Life for a Child’s registered address is GPO Box 9824, Sydney, NSW 2001, Australia.
Life for a Child is also registered in the USA as Life for a Child USA Inc. at PO Box 12903, Tallahassee, Florida 32317, USA.
Life for a Child’s representative under the UK GDPR (defined below) is Emma Klatman, whose registered address is PO Box 3558, Bristol, BS8 9LF and who can otherwise be contacted by email at [email protected].
This Privacy Policy relates to personal data which is obtained by Life for of a Child as a data controller (being an organisation that determines the ways in which your personal data is processed and why). Please note that Life for a Child does not provide any personal data to Life for a Child USA Inc.
The Diabetes Overseas Aid Fund is a public ancillary fund registered as a charity with the Australian Charities and Not-for-profits Commission and has Deductible Gift Recipient status with the Australian Tax Office. Donations to Life for a Child in Australia are received by the Diabetes Overseas Aid Fund and disbursed overseas via Clan Health & Development Relief Fund (CLAN) ABN 30 897 322 928.
What we mean when we say…
In this Privacy Policy, when we say:
- Life of a Child, we, our or us – we mean Diabetes NSW (ACN 001 363 766) acting as trustee for the Diabetes Overseas Aid Fund, with the trading name Life for a Child.
- your data – we mean your personal data, which we describe in detail in section 4.
- our supporters – we mean individuals and organisations who contribute to fundraising, donating money and volunteering in order to support our programme of work.
- our beneficiaries – we mean children and young people living with diabetes in less-resourced countries to whom Life for a Child provides supplies, support, education and assistance.
- our partners – we mean local healthcare providers or healthcare centres which we support who assist us to support our beneficiaries.
- privacy laws – we mean the United Kingdom General Data Protection Regulation (the UK GDPR); the UK Data Protection Act, the Privacy and Electronic Communications Regulations (PECR); the Australian Privacy Act 1998 (Cth) and the Australian Privacy Principles contained therein; the Spam Act 2003 (Cth); and applicable health information laws such as the Health Records and Information Privacy Act 2002 (NSW).
- data controller – we mean an organisation (in this case, Life for a Child) that determines the ways in which your personal data is processed and why.
Life for a Child’s purpose and outreach
We provide supplies, support, education and assistance to young people living with diabetes in under-resourced communities. Our supporters help us to achieve this in a variety of ways, including through fundraising, donating money and volunteering in order to support our programme of work. Our supporters are based all over the world, including in the EU, UK, Canada and the United States, as well as in Australia.
We take active steps to make sure that our supporters are aware of the ways in which they can help us achieve our overall purpose.
What data does Life for a Child collect?
We collect and hold various categories of your data, including personal data about our supporters, personal data about our beneficiaries (including health data), other sensitive data, and data collected by cookies.
Set out below are the main categories of personal data we collect and hold when you provide support to us, are beneficiaries of our services or otherwise engage with us. If you choose not to provide the information we request from you, we may not be able to accept your support, provide the services you require or otherwise engage with you (e.g. as our contractor).
Data about our supporters
• We only collect personal data relevant to the type of transactions or interactions you have with Life for a Child. Whatever your interaction with us, we will only collect the minimal amount of information that is reasonable and relevant to the purpose for which we need it.
• For example, when you contact Life for a Child to make a donation, take a campaign action, or sign up to our online content (such as newsletters) or you telephone, email, write to or text Life for a Child, or engage with Life for a Child via social media channels, we may collect details such as your name, email address, postal address, telephone or mobile number, and bank account details to process donations or otherwise comply with your request.
• If you participate in an event, we may (with your consent) take your photograph or video, or interview you.
• If you participate in market research, we may ask you questions regarding your experience with us, or other survey questions relating to your experience.
• If you are an advocate or fundraiser we may collect information such as your correspondence with us, details of your background and activities with us or relating to the issue/s you are advocating or fundraising for, the events you attend, and/or details about how we would like to work with you.
• Where we gather information about you which is publicly available – for instance as a major donor – this may include your name, contact details, views and positions you have expressed publicly, and details regarding your circumstances (for instance, which political roles you hold or what your background is).
Data about our beneficiaries (including health data)
- We only collect personal data about our beneficiaries as necessary to provide and facilitate our support, education and assistance services. As with supporter data, we only collect the minimum amount of data that is reasonable and relevant to the purpose for which we need it.
- We may also collect health data (which is a type of sensitive personal data) about our beneficiaries, such as your date of birth, gender, weight and height, and core information about your diabetes care. This information will have been shared by the beneficiary’s health provider, which will be Life for a Child’s respective in-country partner. The health provider will have collected this information as a routine part of the beneficiary’s medical care, in accordance with the relevant privacy laws within the beneficiary’s country.
Other sensitive data
• We only collect sensitive personal data – for example, health data or status, and criminal record checks – about our supporters and beneficiaries where there is a clear and specific reason for doing so and where we are permitted to do so under applicable privacy laws. For our beneficiaries, this can include evaluating the effectiveness of our support programs. For our supporters and third parties (including visitors to our premises), this may include collecting information about criminal history only where is required, such as before volunteering at a partner centre or an event.
• For our supporters, we collect this data where we need it to ensure that we provide appropriate facilities or support to enable you to participate in the event or carry out your role and to check that it is appropriate for you to undertake the role. We also collect such data if you volunteer such information to us (for example, if you choose to tell us that you or a family member lives with diabetes). If you apply for a role with us, we may collect this data for equality monitoring but it is unlikely to be identifiable to you.
• Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this we will do it carefully and in accordance with applicable privacy laws.
• Should you support Life for a Child in a substantial way, it may be appropriate for us to tailor our communications to suit your interests. Only if this is the case we may collect sensitive personal data where relevant to our relationship, such as your political or religious views, and where you have provided your consent to such collection. Should you disclose information to us about your health or your family, this may also be recorded (with your consent), so that we can communicate with you in a considerate and appropriate manner.
Data collected by cookies
We may collect de-identified information via cookies on our website, such as your browser type, operating systems and other websites visited. We may also collect some personal information when using cookies, such as where a cookie is linked to your account. There are more details about cookies in section 16.
Data collected for recruitment, employment or contracting purposes
• When you apply for a job or position with us, we may collect certain personal information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us, in order to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.
• When you are employed or contract with us, we may collect personal data from you as part of our employment or contractual relationship (including your general personal details, financial information, education and social information, (in certain circumstances and where permitted by privacy laws) sensitive data about your health and medical conditions and certain criminal convictions or offences, and other work related information).
Data about our partners
We collect details such as the name, postal address, email address and telephone or mobile number about individual doctors and staff working at local clinics in order for us to effective provide our support, education and assistance services to our beneficiaries.
Children and young people’s privacy
We are committed to protecting the privacy of children and young people. For our beneficiaries under 13, we will ensure that appropriate consent has been provided from the beneficiary’s parent or guardian in any circumstance in which we rely upon consent for our collection and processing of personal data (and that it was open for the parent or guardian to withhold or withdraw consent at any time).
Parents and guardians can also exercise privacy rights on their children’s behalf; however, we may need to verify that you are authorised to act on their behalf and collect additional information from you to do so.
When and how do we collect your data?
Here are the most common ways we do this:
When you give it to us directly
We may collect your personal data directly from you when you make a donation, sign up for our newsletter, volunteer, or when you communicate with us or in person at an event or conference. We may also collect personal data directly from you where you (or your parent or guardian, if you are under 13) expressly consent to give it to us. For our partners (including healthcare providers or healthcare centres which we support), we will collect personal data about you as part of our interactions and the information that you provide to us about beneficiaries.
When you give it to us indirectly
• You may give us your information indirectly when you contribute to Life for a Child via fundraising or crowdfunding sites like JustGiving or workplace giving platforms such as Benivity. These independent third parties will pass your data to Life for a Child where you have indicated that you wish to support Life for a Child and have given your consent or if it is a necessary part of completing a contract with you.
• Sometimes your personal data is collected by an organisation working on our behalf. For example, for beneficiaries, this may include a healthcare provider or healthcare centre which we support that provides us with your relevant health data.
When you access our social media platforms
We might also obtain your personal data through your use of social media platforms such as Facebook, Instagram, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their respective privacy notices, which will tell you how to do this.
When the data is publicly available
We may also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like Life for a Child. In this scenario, Life for a Child may seek to find out more about these individuals, their interests and motivations for giving through publicly available information.
How do we use your data?
We use your personal data to accept, process and facilitate your support and fundraising activities, to service our beneficiaries and to engage with our employees and contractors.
We collect, hold, use, disclose and process personal data of our supporters to:
- keep a record of donations made and actions taken by these individuals and our communications with them;
- send thank you notes, program updates, marketing information, fundraising activities and appeals where we have their consent or are otherwise legally permitted to;
- support volunteers, advocates and supporters participating in fundraising events;
- support community based fundraising and campaigning;
- claim matched donations by a third party;
- fulfil contractual obligations entered into with supporters e.g. online purchases;
- conduct market research, invite you to participate in surveys or research about Life for a Child or our work, and analyse and improve our activities and content (see further information about the legal bases for our marketing activities in section 8 below);
- comply with our legal obligations; and
- manage our organisation.
We collect, hold, use, disclose and process personal data of our beneficiaries to:
- keep a record of activities Life for a Child supports;
- support healthcare providers assisting beneficiaries;
- evaluate the effectiveness of our programs;
- comply with legal obligations; and
- manage our organisation.
We collect, hold, use, disclose and process personal data of our employees and contractors to:
- engage and compensate them; and
- otherwise manage our relationship with them.
We collect, hold, use, disclose and process personal data of our partners (including healthcare providers or healthcare centres which we support) to:
- provide services to our beneficiaries; and
- support our partners when they assist beneficiaries;
We may also use and disclose our supporters’, beneficiaries’, contractors’ and partners’ data in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
How do we use your data for marketing?
We may use your information for marketing purposes, but only with your consent and you can opt-out at any time.
Life for a Child will only contact you for marketing purposes – for example, to keep you up to date on our work or let you know of ways in which you can support that work – where we have your consent.
We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work.
We will not send you any marketing material if you tell us that you do not wish to receive it. You can tell us this either by using the unsubscribe facility in the relevant message or by contacting us using the details set out in section 1.
Where you do give us your consent to send you marketing communications, we will continue to do so until you withdraw your consent. You can do this at any time, either for individual channels of communication lines, or for all channels.
How do we use your data for profiling?
We want to improve how we talk to you and the information that we provide you. In some cases, we do so by processing your data automatically to decide (in respect of our supporters) whether particular marketing activities are likely to be of interest, or to suggest an appropriate donation level based on your previous donation history. This is known as profiling and helps us to ensure that our marketing is relevant and appropriate or to better target our fundraising endeavours. Profiling can take place either directly through us or by third parties acting on our behalf. If you wish to opt out of such profiling, you can do so at any time.
What are our legal bases for processing your data?
Life for a Child relies on the following legal bases for our data processing (including our marketing) activities.
Consent
• We may ask for your consent for data collection and processing – for instance where you volunteer with us or engage with a program and can give you a clear choice about what information you need to provide.
• As outlined in section 8 above, we will ask for your consent before we send you marketing communications unless we are otherwise permitted to do so by law.
Legal compliance
If any law requires us to, we may need to collect, process and hold your data. For example, under certain tax laws we are required to retain financial data for seven years.
Public interest or vital interests
In limited situations we may use your personal data where it is necessary for the performance of a task carried out in the public interest or to protect the vital interests of either you or another person. It is likely to be in the public interest or required to protect someone’s vital interests to collect data to prevent crime or dishonesty or safeguard the wellbeing of people with whom we work.
Contract or Memorandum of Understanding (MOU) compliance
• We may collect and process your personal data where a contract (including a binding MOU) requires us to do so.
• For example, where you make a donation to a fundraising campaign which will be matched by a third party, we will process your data for the purposes of submitting a matched claim.
Legitimate interests
• In specific situations, we process your data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests.
• Life for a Child’s legitimate interests include carrying out tasks such as processing donations, running events, servicing our beneficiaries and administering our organisation; and sending updates and marketing information to you or keeping you updated on Life for a Child’s projects, fundraising activities and appeals (in accordance with the principles and requirements outlined in section 8).
• If you have made a donation or have opted in to receive marketing communications, we may use your details to link to your account on Facebook or other social media platform in order to serve you Life for a Child content. This is a form of profiling.
• We may also process your personal data to serve our legitimate interests of analysing your previous support of LFAC in order to offer relevant ways of supporting LFAC in the future.
Who do we share your personal data with?
We may share your personal data with our partners and for other reasons we tell you about in this Policy (including in sections 7 and 8). We will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
We may share your personal data with:
• our employees, contractors and related companies – who help us run our business, receive support and provide services to beneficiaries;
• our third party suppliers and service providers – who help us and deliver our projects, fundraising activities and appeals (eg, through handling responses to our fundraising appeals). In many cases, these suppliers are ‘data processors’ who will only act under our instructions and are subject to equivalent contractual data protection obligations as we describe in this Policy. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure. In other cases, these suppliers are ‘data controllers’ and are required to comply with privacy laws in their own capacity.
• social media platform providers – where you have opted in to marketing communications, we may also use your email address and phone number to match to your account on Facebook or other social media sites in order to show you Life for a Child content while using these services. We may also use those details to identify you if you are a user of these sites whom we believe would be interested in Life for a Child. This is a form of profiling. As outlined in sections 8 and 9 above, you can opt out of receiving marketing communications or profiling activities via the relevant platform or channel at any time;
• regulatory authorities – in order to comply with legal requests where disclosure is required or permitted by law (for example to government bodies, statutory bodies, or law enforcement agencies for tax purposes, where it is in the public interest or for the prevention and detection of crime);
• payment systems operators (eg, merchants receiving card payments); and
• anyone to whom our assets or businesses (or any part of them) are transferred.
Do we store or share your data overseas?
We may store and disclose your personal data overseas. Life for a Child may disclose or transfer your personal data to third party suppliers outside of the country where you are based (including countries which may not have been determined by the UK ICO or equivalent authorities to have a similar data protection regime as your home country). Jurisdictions other than Australia or the UK where we process your personal data include Singapore, Canada, the United States, Germany and Ireland.
When we disclose personal data to third parties in overseas locations, we do so by taking reasonable steps to ensure adequate safeguards are put in place to protect your personal data. This may include (where applicable) entering into the UK ICO’s International Data Transfer Agreement with overseas third party recipients or anything else which is required or permitted by applicable privacy laws.
How do we protect your data?
We ensure that there are appropriate technical controls in place to protect your personal details.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.
Where we use third party providers to collect or process personal data on our behalf, we implement comprehensive checks before working with those parties.
We will also only hold your personal data on our systems for as long as is necessary for the relevant processing activity – for example, we will keep a record of donations for at least seven years to comply with relevant tax and audit rules.
If you request that we stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
How long do we keep your data?
We only keep your data for as long as is reasonable and necessary for the relevant activity, which may in certain circumstances be to fulfil statutory obligations.
Legacy income is vital to the running of the charity. We may keep data you provide to us for as long as is necessary to carry out legacy administration and communicate effectively with the families of people leaving us legacies.
What are your rights in relation to your data?
You have various rights in relation to your personal data, including rights to access, update, delete, restrict processing, or object to or withdraw the use of, your data. You can contact us to exercise any of your rights in relation to your data at any time.
In particular, here are the things you can ask us to do in relation to data we hold about you at any time. Please note that not all of these rights will necessarily be available in your home country – please contact us if you would like to find out more.
Access
You can request a copy of your data, including how we first obtained your details. We will provide this as soon as possible, and within 30 days unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.
Correct
You can ask us to correct or update your data when it is incorrect, out of date or incomplete.
Delete
You can ask us to delete or permanently de-identify your data from our systems. We will do so upon your request, to the extent that we are permitted to do so at law.
Withdraw consent for marketing
You can withdraw your consent for us to use your personal data for direct marketing (either through specific channels or all channels).
Restrict processing
You can request that we no longer engage in profiling about you. Such requests may lead to you not hearing from us in future.
Complain
You can express your concerns or complaints to us about your privacy or the way we are handling your information. We take your concerns seriously and will seek to resolve any issue or concern as soon as possible.
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy.
If you have authorised a third party to submit a request or complaint on your behalf, we will ask them to prove they have your permission to act.
If you’re not happy with the way we handle your query or handle your data (including our response to your request to access your rights outlined above), you have a right to lodge a complaint with the relevant privacy or information commissioner in your jurisdiction (the details are set out at section 16 below).
Using our website and cookies
We use cookies on our website to track your website usage and remember your preferences.
Cookies are small files that store information on your computer, mobile phone or other device. We use them to enable us to improve services for you through, for example:
• measuring how many people are using each page of the website and for how long so that we can try to improve the quality of our website;
• enabling you to view content shared on other sites e.g. YouTube or Twitter.
You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. If you refuse the use of cookies in this way, then you may not be able to access the full functionality of our website. Please refer to your internet browser’s instructions or help screens to learn more about these functions.
Our website may contain links to websites operated by third parties. Those links are provided for your convenience and may not remain current or be maintained. We have no control over and are not responsible for any content or privacy practices of those linked websites. As the privacy policies that apply to those other websites may differ substantially from ours, we encourage you to read them before using those websites.
We may also use third party analytics tools to help us gather and analyse device information. For example, our website uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics also uses cookies. Although these cookies do not identify you personally, they allow information about your use of our website (including your IP address) to be transmitted to Google. For more information, please see Google’s site “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Changes to Life for a Child’s Privacy Policy
This Privacy Policy may be updated from time to time so you may wish to check it each time you provide personal data to Life for a Child. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to submit personal data to Life for a Child, and contact us to tell us to destroy any copies we hold of your personal data.
Find out more
You can find out more about the various privacy laws and other rules, regulations and standards we’ve mentioned in this policy, or lodge a complaint where you are not happy with the way we’ve handled your query or your information (as explained in section 13), by visiting the website of the relevant privacy or information commissioner in your jurisdiction. These details are set out below.
UK | Information Commissioner’s Office (ICO)
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Australia | Office of the Australian Information Commissioner (OAIC) |
Canada | Office of the Privacy Commissioner of Canada https://www.priv.gc.ca/en |
USA | Office of Privacy and Civil Liberties https://www.justice.gov/opcl |
European Union | European Data Protection Board
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