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Privacy Policy

Purpose

This Privacy Notice is intended to comply with the Privacy Act 1988 (Cth), and, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR or other applicable European data protection laws.

Privacy Notice

This Privacy Notice is designed to tell you what will happen to the information you provide through this website or through any other form of communication with Cerebral Palsy Alliance (CPA) (ABN 45 000 062 288), who manages and handles CPAdvance training. It also sets out how we use your personal data and sets out your privacy rights.

Data Controller

For the purposes of GPDR and UK GDPR, Cerebral Palsy Alliance ABN 45 000 062 288 is the data controller in respect of personal data collected and processed through CPAdvance training, except where otherwise specified.

Privacy Officer

CPA has an internal privacy officer for you to contact if you have any questions or concerns about CPA’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to the CPA Privacy Officer at privacy@cerebralpalsy.org.au or +61 02 9975 8000 or PO Box 171, Forestville NSW 2087.

How we collect and use (process) your Personal information

This Privacy Notice applies to any personal information of yours which is provided to us. This information is generally limited to first name, last name, job title, employer name, work address, work email, and work phone number. We use this information to provide customers with goods and services purchased from us. Most CPAdvance training customers will provide their personal information directly to CPA. However. we may receive this from third parties, for example, if your employer signs you up for CPAdvance training or certification. Where we collect personal data indirectly, we may obtain it from employers, professional accreditation bodies, training coordinators, health professionals, government agencies, referral organisations or publicly available sources. The categories of personal data obtained may include identity, contact, employment, professional qualification, training and accreditation information. Where required by applicable law, we will provide further information regarding the source of the data and our use of it.

You may always access and update your data with CPA if you have a CPAdvance training account and contact us at privacy@cerebralpalsy.org.au

Personal information is any information about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.

Sensitive information (also referred to as Special Category Data under GDPR) is any personal information about an individual’s racial or ethnic origin, political opinions or memberships, religious or philosophical beliefs, membership of a professional or trade association or union, sexual orientation or practices, criminal record, or information about health, genetics, biometrics or biometric templates.

We will only collect, use or disclose sensitive information about you (Special Category Data) as permitted or required by law, including under Article 9 GDPR.

Lawful bases for processing

Where GDPR applies, we process personal data under one or more of the following legal bases:

  • Article 6(1)(a): consent;
  • Article 6(1)(b): performance of a contract;
  • Article 6(1)(c): compliance with legal obligations; and
  • Article 6(1)(f): legitimate interests.

Where we rely on consent, you may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the consent was withdrawn.

Where processing is based on our legitimate interests, those interests include administering and improving our services, maintaining relationships with customers and stakeholders, protecting the security of our systems and supporting our charitable objectives. Where we rely on legitimate interests as our lawful basis, you have the right to object to such processing. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms or the processing is required for the establishment, exercise or defence of legal claims.

Anonymity and pseudonymity

Where lawful and practicable, you may choose not to identify yourself, or to use a pseudonym when dealing with us in relation to a particular matter. However, we may require you to identify yourself where required or authorised by law, or where it is impracticable for us to deal with you anonymously or under a pseudonym.

How we collect your personal information

We collect personal information that is reasonably necessary for our business activities and to provide, develop and improve our services. We may collect personal information:

  • directly from you when you provide it to us or our agents or contractors;
  • from publicly available sources;
  • from our own records of your use of our services and website;
  • from third parties where you are referred to us; and
  • where collection is required or authorised by law.

What personal information do we collect and why?

We collect personal information that is reasonably necessary for our functions and activities, including to provide and administer our services, programs and training activities, such as the CPAdvance training program.

The types of personal information we collect may include:

  • identity and contact information, such as your name, address, telephone number and email address;
  • demographic information including place of work and occupation;
  • information about your use of our services and programs; and
  • financial information, including payment details.

If you do not provide the personal information we request, we may be unable to provide you with our services or programs, respond to your enquiries, or otherwise meet your requests.

We may collect, hold, use and disclose your personal information to:

  • verify your identity and communicate with you;
  • manage our relationship with you;
  • provide, administer and improve our services and programs;
  • respond to any enquiries, feedback and complaints;
  • comply with funding, reporting, legal and regulatory obligations;
  • provide updates about our services, programs and training activities.

We may use your personal information to send you information about our services, programs, events and training activities by mail, telephone, email, SMS or other electronic means where permitted by law. You may opt out of receiving these communications at any time by contacting us as set out below or using the unsubscribe facility included in the communication.

We may also use your personal information for other purposes that are related to the purposes described above and that you would reasonably expect. We will not otherwise use or disclose your personal information without your consent, unless required or authorised by law.

Sharing your personal information

We may disclose your personal information where you have consented, where required or authorised by law, or where reasonably necessary for the purposes described in this Privacy Notice.

We may disclose your personal information to:

  • our related companies and business partners;
  • service providers and contractors who assist us in delivering our services, including providers of information technology, data analytics, data storage, banking, payment processing, auditing, accounting, legal, consulting, marketing, communications, event management, printing and mailing services.

When making such a disclosure, we take reasonable steps to ensure they handle personal information in accordance with applicable privacy laws and appropriate confidentiality obligations.

Does your personal information leave Australia?

We may disclose or transfer personal information outside Australia where:

  • you have consented;
  • the disclosure is required or authorised by law; or
  • the disclosure is reasonably necessary for any of the purposes set out in this Privacy Notice, including where we engage service providers that store or process personal information on our behalf.

Where personal data is transferred outside the EEA, UK or Switzerland, we will ensure appropriate safeguards are implemented, including:

  • transfers to jurisdictions recognised as providing an adequate level of protection;
  • execution of Standard Contractual Clauses (SCC), (where applicable); or
  • other lawful transfer mechanisms permitted under applicable data protection laws.

A current list of countries in which our service providers process personal data is available upon request.

In the course of our operations, personal information may be stored or processed using cloud infrastructure or service providers located in Australia and overseas, including in jurisdictions such as the United States, Ireland and the United Kingdom.

We take reasonable steps to ensure the overseas recipients handle personal information in a manner consistent with the Privacy Act 1988 (Cth), GDPR and other applicable data protection laws.

Your privacy rights

Subject to applicable law, you may have the right to:

  • access your personal data;
  • rectify inaccurate personal data;
  • request erasure of your personal data;
  • restrict processing of your personal data;
  • object to certain processing activities;
  • receive your personal data in a portable format;
  • withdraw consent at any time where processing is based on consent; and
  • lodge a complaint with a competent supervisory authority.

We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.

Where GDPR applies, we will generally provide information and respond to requests free of charge. However, where a request is manifestly unfounded or excessive, particularly because of its repetitive nature, we may charge a reasonable administrative fee or refuse to act on the request as permitted by applicable law.

We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information and we will take appropriate steps to update or correct such information in our possession.

Where GDPR applies, we will generally respond to requests relating to your GDPR rights within one month of receipt. This period may be extended by up to two additional months where permitted by law, taking into account the complexity and number of requests.

In certain circumstances permitted by applicable law, including where a request is manifestly unfounded or excessive, we may refuse to act on the request or charge a reasonable administrative fee. If we refuse a request, we will provide reasons and information about available rights of complaint, unless we are legally prohibited from doing so.

Storage and security

We take all reasonable precautions to safeguard the personal information we hold from loss, misuse, unauthorised access, modification, disclosure or destruction. We may store personal information in digital or hard copy form. We maintain a range of physical, administrative and technical safeguards designed to protect the personal information including, depending on the circumstances, access controls, password protection, premises security and network firewalls.

While we take reasonable steps to protect personal information, no method of transmission over the internet is completely secure or error-free. In particular, communications sent to or from this website, including emails, may not be secure.

Data retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal, regulatory, accounting and reporting obligations, resolve disputes and enforce agreements. When personal information is no longer required, we take reasonable steps to securely destroy or de-identify it.

Links to other websites

Website analytics and cookies

As you navigate through this website, certain information may be collected automatically without you actively providing it. This may occur through the use of technologies such as cookies, internet tags (including web beacons), analytical tools, and the collection of navigational data.

Cookies are small text files stored on your device when you visit a website. We use cookies to:

  • remember your preferences and improve your browsing experience;
  • analyse website traffic, usage patterns and trends; and
  • support our marketing and communication activities.

Some cookies are essential for the operation of the website, while others are optional and used for analytics or to tailor the website to your preferences. Except where strictly necessary for operation of the website, cookies and similar technologies will only be deployed following your consent where required by applicable law. You may manage your cookie preferences through our cookie consent banner or your browser settings. However, if you choose to disable cookies, some features or functionality of the website may not operate as intended. We may also use third-party service providers that use cookies and similar technologies to collect and process information about your use of the website. This information is generally aggregated and does not identify you personally.

Individual Rights and Consequences of Not Providing Data

Where personal information is required to provide services, accreditation, certification, training or other programs, failure to provide the requested information may prevent us from delivering those services or meeting legal or regulatory requirements.

Notifiable Data Breaches scheme

In the event of any loss or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will:

  • investigate, and
  • notify you and the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act 1988 (Cth).

Automated Decision-Making

We do not currently make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. If this changes, we will update this Privacy Notice and provide any additional information required by applicable law.

Complaints

If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Notice or the Privacy Act 1988 (Cth), please contact us as set out below. Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.

We will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can make a formal complaint with the Office of the Australian Information Commissioner (OAIC), which is the regulator responsible for privacy in Australia.

Complaints must be made in writing to:

Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

www.oaic.gov.au

Phone: 1300 363 992

Individuals located in the EEA, UK or Switzerland may lodge a complaint with the data protection authority in their country of habitual residence, place of work or place of the alleged infringement.

How to contact us

If you believe we have not complied with this Privacy Notice, the Privacy Act 1988 (Cth) and, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR or other applicable European data protection laws and would like to make a complaint, please go to our Feedback page.

If you wish to exercise your right to opt out of receiving our marketing materials, or you have any questions or concerns about this Privacy Notice or our information practices, please contact us at:

The Privacy Officer
Cerebral Palsy Alliance
PO Box 171, Forestville NSW 2087 
Email: privacy@cerebralpalsy.org.au
Phone: 1300 888 378 (+61 2 9975 8000)

Changes to this Privacy Notice

This Privacy Notice may change from time to time as updated on this website. Before providing us with personal information, please check this Notice on our website for any changes.