Outside the Locker Room Charity Ltd (ACN 635 277 762) trading as Outside the Locker Room (OTLR, us, we, our) maintain a policy of strict confidence concerning your (you, your) personal information (Privacy Policy).
This Privacy Policy details how we deal with your personal information and has been developed in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). Under the Act, personal information means any information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether recorded in a material form or not. Sensitive information is a subset of personal information and includes health information, racial origin and criminal record information.
In relation to health information, we are also bound by the Victorian Health Privacy Principles which are contained in the Health Records Act 2001 (Vic).
By providing your personal information to us directly or indirectly you accept the terms of this Privacy Policy.
1. What kinds of information do we collect?
The type of information that we collect from you will depend on how you engage with us. We will collect the following: name, contact information including phone number and email address, address, preferences and interests, and any other personal information that you submit to us, via our websites, including https://otlr.org.au/ (Site) and the OTLR - Outside the Locker Room mobile application (App).
Additionally:
● If you represent a community group, sporting club, school or workplace, we will collect information about that group, club, school or workplace, and your job title.
● If you participate in a program run by us, including through your community group, sporting club, school or workplace, we may ask to collect your name, contact information and any personal information you shared if we determine you require further assistance. If you share any sensitive information we will also collect this.
● If you apply for a position with us, for instance as an employed program facilitator, or as a Welfare Champion (a registered mental health professional), we will also collect information about your work experience, gender, and payment details. We will also collect information, such as information required for working with children checks and police checks. If you are contracted as a Welfare Champion, we will collect your tax file number and superannuation details.
● If you are involved in our fundraising efforts, we will also collect your address, contact name, email, and telephone number and that of your organisation.
● If you engage with us via our welfare support, including our App, we may also collect sensitive information. We may collect your date of birth, gender, community information, location, emergency contact, mental health and medical history, welfare information (such as drug and alcohol use), risk assessment, information on your current mental health, and other necessary consultation notes (including any socio-economic status, advice, plans or follow up requirements, in the case of counselling sessions).
● If you engage with us as a supplier, we will also collect your bank details, ABN, business address, name and contact details, and your role. We will only collect sensitive information if you consent and it is relevant to providing our services.
2. How do we collect your personal information?
We collect your personal information directly from you or where our suppliers or your community group, sporting club, school or workplace provide us with your information. The main ways we collect personal information about you are when you:
● request to receive the services offered and provided by us, including the services listed above;
● register to be on our mailing list;
● submit an expression of interest via Google Forms;
● participate on our social media platforms such as Facebook, Instagram, Youtube and LinkedIn;
● participate in a program run by us, including through your community group, sporting club, school or workplace, and provide sensitive information to us or information that we determine indicates you require further assistance;
● engage with us via our welfare support, including our App;
● apply for a position with us, including as a contractor;
● provide your information at, or in relation to, an event; and
● otherwise submit personal information about yourself, or someone else, to us, our suppliers or our Site or App.
We will only collect your personal information from third parties if you give the third party your consent to provide the information to us or it would be reasonably expected. We will only collect sensitive information with your consent.
If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information. This includes where an organisation, such as your community group, sporting club, school or workplace, provides your personal information to us.
3. If you are under 18 years of age
If you are under 18 years of age you must ask your parent or legal guardian to approve your provision of personal information before you submit your personal details to us.
4. Use of personal information
This Privacy Policy deals with personal information of registered users, customers, service providers and other third parties.
We will only use your personal information for the purposes for which it was given to us, or for purposes which are directly related to the provision of our services.
Your personal information may be used by us in a number of ways, including:
● to assist you conveniently and easily accessing the services that we offer and provide, including the services listed above;
● to contact you for research purposes and to organise events or services;
● to conduct research, where we obtain your consent to do so;
● to contact you about forming and maintaining research partnerships and community and fundraising relationships with you;
● for internal record keeping;
● to periodically send communications about information which we consider that you may find interesting;
● if you apply for a position with us, to determine your suitability for the role;
● to allocate resources; and
● develop and roll out programs; and with your consent, we may also use sensitive information collected to:
● assist you conveniently and easily accessing the services that we offer and provide, including to provide appropriate facilitators, recommendations and referrals;
● conduct research, where we obtain your consent;
● provide advice and guidance;
● inform training resources;
● if you are engaged as a Welfare Champion or apply for a position with us, to assess your suitability for a particular OTLR program or in order to provide support to a particular individual;
● if you submit an application on behalf of your organisation, including a community group, sporting club, school or workplace, to determine if it is eligible for a sponsored program run by us;
● if you participate in a program we run through an organisation, including your community group, sporting club, school or workplace, and we determine you require further assistance or you reveal sensitive information, for our welfare team to contact you and provide our services; and
● if you engage with our welfare support, including via our App, to provide counselling support and our health services.
5. Disclosure of personal information
In certain circumstances, it may be necessary for us to disclose your personal information to third parties in order to assist us in providing our services, or where disclosure is required by us to meet our legal and regulatory obligations. Third parties may include:
● digital marketing and other service providers such as Salesforce, Google Forms and Mailchimp;
● social media platforms such as Facebook, Instagram, LinkedIn and Youtube;
● merchandise providers, such as Tribal Sport so that they can process any merchandise orders you place with us;
● technology support service providers, such as Vladica Pty Ltd trading as Digital Innovations IT Solutions, Google Forms and Wordpress, where applicable to the service provided to you; payment processors such as Payments2Us and PayPal Giving Fund, and contracted book keepers;
● data storage providers such as Google and Salesforce (servers located in the United States);
● government and law enforcement agencies and regulators;
● entities established to help identify illegal activities and prevent fraud where authorised by law;
● our contractors like Welfare Champions, funding consultants and volunteers; and
● community groups, sporting clubs, schools or workplaces that request your working with children check number, where you are a Welfare Champion.
In the case of information obtained through our welfare support, subject to law, consultation notes may be provided to other Australian health service providers if they are required to review an individual for the purpose of efficiency and individualised care. To the extent required by law, where we provide a health service under the Privacy Act, we will obtain your consent before disclosing sensitive information to third parties, including other Australian health service providers contracted by the Commonwealth or other government agencies.
We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies (as defined in Section 16A of the Privacy Act).
If we go through a business transition, such as a merger, acquisition by another company, or a sale of all or a part of our business assets, your personal information may be among the assets transferred.
We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy.
6. Disclosure to overseas recipients
To assist in offering our services we use Mailchimp, Facebook, Instagram, Youtube, Linkedin, Salesforce and Google Forms. These services are provided, supported and hosted overseas, including in the United States.
To the extent that the laws and rights of these countries are not equivalent to the laws of Australia and we disclose your personal information to these organisations, you agree to be bound by the laws and rights of the relevant extraterritorial jurisdiction. This country has data protection laws that are not equivalent to the laws of Australia and you may not have equivalent rights of enforcement.
7. Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We may use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve the Site in order to tailor it to users’ needs. We only use this information for statistical analysis purposes, after which the data is removed from the system. Overall, cookies help us provide you with a better website experience 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. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Site.
8. Direct marketing
We use personal information about you for the primary purpose of providing you with our services. We may also use personal information (other than sensitive information, which requires your consent) for other purposes for which you might reasonably expect us to use that information. You authorise us to use any email address or other contact information you provide to use at any time for such above purposes.
You can opt out of receiving electronic communication at any time. You agree and acknowledge that even if you opt out of receiving information about future events or marketing material, we will still send you essential information that we are required to send you relating to the services we provide.
9. Storage and security
The security of your personal information is paramount to us and we use all reasonable endeavours to keep your information in a secure environment and to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us using the details below. We keep records of the personal information we gather from you and we store these on an encrypted or secure server. You warrant that you will not act in a manner that results in us collecting, using or storing information that is in breach of our obligations at law. If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy, securely delete, or de-identify your personal information as appropriate. In the case of information obtained through our welfare team, personal information is stored on a password protected Google drive. If you use the App, we will also collect your personal information. The data information collected from the App is password protected and only accessible by the welfare team, National Welfare Manager and CEO. Any hard copy consultation notes will be the responsibility of the relevant welfare team member to store in a secure and locked cabinet, or be destroyed, subject to law.
10. Notifiable Data Breaches
In the event of a data breach, where your personal information is involved in the breach, we will notify you and the Office of the Australian Information Commissioner if the breach is likely to result in serious harm to you.
11. Accuracy of your information
We take reasonable steps to ensure that the personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us using the below details and we will take reasonable steps to correct it.
12. Variation and consent to variation
We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy.
13. Access to your information and making a complaint
You may request access to the personal information we hold about you. If you do so we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions provided under the Privacy Act. You may request this information by writing to our Privacy Officer.
Where it is practical to do so, when contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.
If you wish to make a complaint about a breach of the Privacy Act by us, you may do so by providing your complaint in writing to the contact details listed below. You may also make a complaint verbally. We will seek to respond to any complaint within a reasonable period of time. We may seek further information from you in order to provide a comprehensive and complete response.
You may also make a complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the Australian Information Commissioner via telephone on 1300 363 992, by submitting a complaint or inquiry online at www.oaic.gov.au or by writing to the OAIC at GPO Box 5218 Sydney NSW 2001.
14. Contact us
If you have any questions, or if you wish to contact us for any of the reasons described above, including to correct or access the information we hold about you or to make a complaint, please contact our Privacy Officer: