Privacy Policy
Parties
You will be referred to throughout this Privacy Policy as “you” or “your”. LBI Foundation and the IMPACT Program will be referred to throughout as “us”, “we” or “our”.
Overview
We understand the importance people place on their personal information being collected. Personal information collected by us is treated with the appropriate degree of privacy and confidentiality.
This Privacy Policy is intended to provide you with a general explanation of how we may collect, store, use and disclose your personal information. This Privacy Policy should be read in conjunction with any other terms and conditions that appear in or are linked to the Online IMPACT Program website.
Amendments
This Privacy Policy was last amended on 15th September 2024 and will be reviewed and updated from time to time to ensure that it reflects our current information handling practices and any relevant legislative changes. We reserve the right to amend this Privacy Policy at any time, with such amendments to take effect from the date of publication of the amended policy on this website (www.online.impactprogram.net).
Type of Information Collected
We may collect personal information that is reasonably necessary for the provision of our products and services, including the delivery of our suite of accredited IMPACT training and the continuous improvement and evaluation of the IMPACT Program. We collect information from two sources:
IMPACT Trainees
We collect the following information from every person who registers to IMPACT Online and is assigned the descriptor of “IMPACT Trainee”.
- IP address.
- Full name and email.
- Agency and agency location (where provided).
- A list of their registered enrolled and completed courses.
- Data and information generated as part of course completion.
IMPACT Self-Assessment Check-In
As part of their involvement with the IMPACT Program, current IMPACT Trainees are invited to complete a self-assessment process of their progress with the IMPACT Program. This self-assessment requires collects the following information.
- IP address.
- Description of supporting adult role and context (compulsory).
- Their level of accreditation and touch-points with the IMPACT Program (compulsory).
- Age, gender, cultural background (opt out option provided).
- Completion of Likert survey data (non-compulsory).
- Email address (non-compulsory).
You are not obliged to provide us with your personal information if it is against your wishes to do so, however, not all our services or functions on our website will be available to you if you do not allow us to collect this personal information.
Storage of Information
We store your information in an electronic format and keep it in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.
The sources of information from “IMPACT Trainee” and “IMPACT Self-Assessment Check-In” are stored on separate database held on a WordPress account controlled by us. The two databases can be manually integrated through the unique WordPress identifier (or user ID) that is assigned to all registered users.
We will only integrate data-bases for the purpose of program evaluation or research, and when this occurs, your information will be managed and treated in a de-identified manner. In other words, your name and email address is not held on the integrated data-base.
Use of Information
The personal information that we collect and hold about you depends on your interaction with us. Generally, we will only collect and hold your personal information where it is reasonably necessary for us to maintain our training services and evaluate the IMPACT Program. We will use your personal information (including sensitive information) for the primary purpose it was collected, or if your personal information is to be used for a secondary purpose, it will be used:
- To operate, maintain and provide to you the features and functionality of our products and services to you.
- To communicate with you.
- To deal with enquiries and complaints made by you relating to our products and services.
- To address your questions, issues and concerns.
- To facilitate our internal business operations.
- To determine products and services that may be of interest to you and to send you news alerts and communications in accordance with your preferences; to analyse our products and services and customer needs with a view to developing new or improved services; and/or
- Because disclosure or use is required or authorised by law.
We do not sell personal information, and we do not provide your personal information to third parties (exception in University approved research – see below) unless one or more of the following situations apply:
- You would reasonably expect, or have been advised that your personal information may be used or disclosed.
- If the use or disclosure is required by lawful authority.
- If the use of disclosure relates to one or more of the prescribed ‘general permitted situations’ under the Privacy Act 1988 (Cth) (“Privacy Act”), including, but not limited to, a serious and imminent threat to somebody’s life or health, or if it is reasonably necessary for law enforcement.
We may disclose your personal information for the purposes for which it was collected:
- External service providers that may assist us in our business in providing administration, information technology, payment processing, data hosting or other services.
- Anyone else as required by applicable law.
Marketing and Testimonials
The information you provide through this site may be used in an unrestricted manner in the delivery of marketing services by us, including social media and public testimonials. This will only occur in a de-identified and/or group level manner, where your name and identity is not attributed nor linked to any information you provide in the public space.
Third Party Researcher
Information you provide may be released to a third-party researcher from an Australian University when the following conditions are met:
- The research has been approved by us.
- The research has been approved unconditionally by a university recognised ethics committee.
Protection and Retention of Information
We will take reasonable steps to ensure that the information we hold about you is relevant, accurate, up-to-date, and complete. We take reasonable and practicable steps to protect your personal information from loss, misuse, modification, disclosure, interference, or unauthorised access.
When your personal information is no longer required for the purposes for which it was collected, we will take all reasonable and practicable steps to de-identify or destroy the information in a secure manner.
We will only retain your personal information for as long as we maintain a relationship with you and for a reasonable period of time afterwards where we possess a legitimate business need to retain that personal information. Once we no longer possess a need to retain your personal information, we will ensure that it is deleted or anonymised.
Sale of Business
If the IMPACT Program is acquired by another business, sells all or a portion of its assets, or undergoes reorganisation, financing or change of control, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.
Accessing Your Personal Information
You can request that we provide you with access to information we hold about you. You can contact us by submitting a request in writing to the address below. We will consider your request within a reasonable time frame following receipt of your request and action in accordance with the applicable laws.
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act as amended from time to time. If complying with your request for access or amendment requires considerable time and expense on our part, we may charge you a reasonable fee for providing you with information. If we are unable to agree to your request, we will provide you with an appropriate explanation.
Personal Information of Children
Our services are not directed at persons under 16 years old and we do not knowingly collect personal information from children under 16 years old. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information.
Contact Us
If you require further information about this Privacy Policy, our management of your personal information, or if you think we may not have complied with any aspect of this Privacy Policy, please contact us at the address set out below:
226 Melbourne St
North Adelaide, SA, 5000
For information about privacy generally, or if your concerns are not resolved to your satisfaction, you can contact the Office of the Australian Information Commissioner (“OAIC”) by visiting www.oaic.gov.au, sending an email to enquiries@oaic.gov.au, telephoning 1300 363 992 or writing to the OAIC at GPO Box 5218, Sydney NSW 2001.
Jurisdiction
This Privacy Policy is subject to the laws of South Australia, Australia. You submit to the exclusive jurisdiction of the courts of South Australia Australia. This applies regardless of your location when accessing our website or website content.
Agreement
By registering as a user to IMPACT Online you are hereby agreeing to the conditions of this Privacy Policy.