Privacy
The Alcohol and Drug Foundation (ADF) is committed to protecting your privacy. Our Privacy Policy sets out how we collect and manage personal information and the steps we take to protect it. Your use of ADF websites indicates that you accept the Privacy Policy and approve the collection, use and disclosure by ADF of your personal information according to the terms of the Policy.
Purpose
The Privacy Amendment (Enhancing Privacy Protection) Act 2012 has been designed to regulate the way organisations collect, use and keep personal information.
The Alcohol and Drug Foundation (ADF) is committed to protecting the privacy of any personal information it holds about individuals in accordance with Australian Privacy Principles (APPs) and ensuring responsible use of artificial intelligence systems.
This Policy outlines the manner in which the (ADF) manages the personal information it holds on its employees, service users, customers, suppliers and other stakeholders and the measures it takes to protect any personal information it holds.
The ADF has a commitment that all its dealings are characterised by openness and transparency. The ADF will only collect personal information by fair and lawful means and not in an unreasonably intrusive manner.
Why the ADF collects personal and sensitive information
The ADF will not collect personal information unless the information is reasonably necessary for, or directly related to, one or more of the organisation’s functions or activities.
The ADF will not collect sensitive information unless the information is reasonably necessary for, or directly related to, one or more of the organisations’ functions or activities and where the individual has consented to the collection.
The ADF collects personal information to enable us to perform our business functions and meet our legal obligations. All information captured from the use of the ADF’s online platforms which is used to conduct research and analysis is de-identified.
You consent to the ADF using your personal information for sending you correspondence, including promotional material, about the ADF’s products and services, as well as the products and services of third parties. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages. You can contact us using the contact details specified below if you do not want to receive marketing or other information from us.
How the ADF collects personal and sensitive information
The ADF takes reasonable steps to comply with all relevant privacy laws concerning the collection of personal information. Wherever possible, the ADF will collect information directly from the person concerned, unless an exception under the relevant privacy law applies.
Examples of circumstances where the ADF collects personal information directly include:
- job applications submitted for employment vacancies
- updates provided by people regarding their name, address, contact details etc
- queries via phone/email with regards to information on alcohol and other drugs
- banking, superannuation and tax details provided to payroll/finance
Examples of when exceptions to the collection of personal information directly from people may apply include (but are not limited to) where the:
- relevant personal information is publicly available information
- collection of personal information is authorised by the person concerned
- collection of personal information from someone else is required or permitted by law
When the ADF collects personal information via the Internet, competitions, surveys, interviews, promotional activities and any other media we use to collect personal information, we will inform how the information will be used and disclosed. In all cases, information will be held in accordance with all applicable privacy laws.
What types of personal and sensitive information does the ADF collect?
The types of personal information collected and held by the ADF generally include names, addresses, and personal contact details. Personal information about people may also be contained in their position description, employment agreements and performance plans.
In some circumstances, the ADF may hold personal information including current or past medical conditions and medication requirements. We will not collect sensitive information (including, for example, racial or ethnic origin, or political views, religious or philosophical beliefs, trade union membership, or details of health, disability of sexual activity or orientation) without consent.
Display advertising for Google Analytics and De-identified Data
The ADF uses Google Analytics Demographics and Interest Reporting on all our websites. Visitors can opt-out of Google Analytics for Display Advertising and customise Display Network ads using the Ad Settings. Additionally, visitors can also download and install the Google Analytics Opt-out Browser Add- on. This add-on instructs the Google Analytics JavaScript running on websites to prohibit sending information to Google Analytics.
The data collected from Google’s Interest-based advertising or third party audience data (such as age, gender and interest) with Google Analytics will help us determine who is visiting our websites and in turn, help us to better serve and understand our customers.
The ADF AI chatbot system collects only:
- De-identified conversation data
- Anonymous usage patterns
- Anonymous user feedback
AI Chatbot Privacy
The ADF employs an AI-powered chatbot to provide information about alcohol and other drugs. All conversations with the chatbot are captured for monitoring and service improvement. The chatbot does not collect or store any personal information and all conversations are completely de-identified. No identifying details are required to use the service and conversation data is used only for service improvement in aggregate, de-identified form. Users will be clearly informed when they are interacting with the AI chatbot and can provide feedback anonymously.
Security of AI Systems
The ADF implements specific security measures for AI systems:
- Regular security audits and testing
- Secure data storage and transmission
- Monitoring for system misuse
- Regular updates and maintenance
- Prevention of re-identification of anonymous data
Users Rights and AI Systems
Users have the right to:
- Know they are interacting with an AI system
- Understand what de-identified data is collected
- Provide anonymous feedback
- Lodge complaints about system concerns
How the ADF uses personal and sensitive information?
In general, the ADF uses personal information for the following purposes:
- To provide products or services that have been requested
- To help us manage and enhance our products and services, including analysing future customer needs
- To communicate
- To provide ongoing information about our services to people that we believe may be interested
- For marketing and promotional purposes
- To enable partners and sponsors of the ADF to market and promote their products and services to you
- To comply with legal obligations
The ADF will only use personal information for purposes directly related to or as is reasonably necessary for us to deliver one or more of the organisation’s functions or activities, to administer an employment function or activity, to fulfil its obligations as an employer, or as otherwise required or permitted by relevant laws.
The ADF may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:
- the organisation collected the information from the individual; and
- the individual would reasonably expect the organisation to use or disclose the information for that purpose; and
- the organisation provides a simple means by which the individual may easily request not to receive direct marketing communications from the organisation; and the individual has not made such a request to the organisation.
Where an individual has provided sensitive information to an organisation, it will be necessary for the organisation to obtain the individual’s consent before using that information for direct marketing purposes.
Identifiers
The ADF will not adopt as its own identifier an identifier that has been assigned by a government agency. Where practicable the ADF will not use or disclose an identifier assigned to an individual by a government agency.
Anonymity
Whenever it is lawful or practicable, people will have the option of not identifying themselves when dealing with the ADF.
Cookies
The ADF’s websites use cookies. Cookies are pieces of information that a website can transfer to an individual's computer for record keeping. Cookies can make using our website easier to navigate by storing individual preferences. This will enable individuals to take full advantage of the services that we offer. The use of cookies is a widely used industry standard and most major websites use them.
Individuals can configure their computer to not accept cookies; however some functionality may be lost.
Provision of personal information to third parties
In limited circumstances, the ADF may be required to disclose people’s personal information to ADF consultants, contractors and service providers performing services including legal and accounting services, credit reporting, training, IT service provision, mail house and printing services.
Other than those third parties referred to above, the ADF will not disclose people’s personal information to any third party unless it has reasonable grounds to believe:
- It is authorised to do so by the relevant person.
- The safety of the person, or others, are at risk.
- The ADF is required to and is permitted by law to do so.
Security
The ADF takes reasonable steps to ensure the personal information it holds about people is protected from risks such as loss, unauthorised access, destruction, modification or disclosure. The ADF only permits its employees or consultants to access people’s personal information for legitimate business purposes.
If the ADF determines it no longer requires an individual’s personal information, the ADF will take reasonable steps to de-identify or securely destroy that information as soon as possible.
Cross border disclosure of personal information
In general, the ADF will not transfer personal information about individuals internationally.
If the ADF discloses personal information about an individual to a person (the overseas recipient) who is not in Australia or an external Territory and who is not the ADF or the individual, the ADF will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles.
Where the ADF uses servers that are hosted overseas, the ADF will take a risk management approach to ensure that personal information routed overseas is not accessed by third parties.
Updating general personal information - right of access, correction and complaints
The accuracy of personal information is important. The ADF takes reasonable steps to ensure personal information it holds about individuals (e.g. name, address, personal contact numbers, bank account details etc.) is accurate, complete, up-to-date and relevant.
An individual has the right to request access to and correction of personal information in the following ways:
Job applicants –through the People & Culture team (please contact peopleandculture@adf.org.au)
Any other individual – by contacting the ADF via email privacy@adf.org.au, or via post at PO Box 818, North Melbourne, VIC 3051
An individual has the general right to access the personal information the ADF holds about them. The ADF can deny a request in some circumstances and if it does so, will provide written reasons for that denial. There is no fee for an individual to request access to their personal information that the ADF holds.
Individuals have the right to request the correction of personal information which the ADF holds. The ADF does however reserve the right to refuse to correct information in some circumstances. If the ADF refuses to correct any personal information, and subsequent agreement cannot be reached between the parties on this issue, a request may be made that a note or statement regarding the correction requested be attached to the personal information.
Advertising
www.adf.org.au does not host any form of advertisement.
Updates to our Privacy Policy
We may vary our Privacy Policy from time to time to take account of new laws and technological changes to our operations and practices and the changing business environment. For an up-to-date copy of the Privacy Policy please, contact the Privacy Officer.
Any questions about this Policy should be directed to the Privacy Officer. Contacting the Alcohol and Drug Foundation’s Privacy Officer:
Via e-mail – privacy@adf.org.au
Via post - The Privacy Officer, The Alcohol and Drug Foundation, PO Box 818, North Melbourne, VIC 3051
For further information on the Privacy Act, please visit the website of the Office of the Privacy Commissioner at http://www.oaic.gov.au
Definitions
AI Chatbot - An artificial intelligence technology used by the ADF to provide information about alcohol and other drugs in a conversational format, operating without collecting personal information.
De-identified Data - Data that has been processed to remove all identifying information, making it impossible to identify any individual from the information.
Privacy Officer - The role of the Privacy Officer is to assist employees to appropriately implement the Australian Privacy Principles (APP’s) and to be a contact point for employees, the public and stakeholders who have queries about the ADF’s Privacy Policy and practices.
Personal Information - Personal information is defined as ‘information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified or reasonably identifiable individual’. Examples of personal information can include a person's name, address and date of birth, but can also include bank account details, photos, videos, and information about what an individual likes, their opinions and where they work.
Sensitive Information - This is information about an individual’s racial or ethnic origin, political opinions, political affiliations, philosophical beliefs, professional or trade association memberships, trade union memberships, sexual preferences or practices, criminal record or health information.
Unsolicited personal information - Unsolicited personal information is personal information we receive that we have taken no active steps to collect.
Australian Privacy Principles (APPs) 1-13 - Refers to the actual principles in the Privacy Amendment (Enhancing Privacy Protection) Act 2012. The Privacy Amendment Act and the Australian Privacy Principles can be found in full on the Office of the Australian Information Commissioner website, which can be found here http://www.oaic.gov.au/