Evidence for Learning: Privacy

Privacy

Privacy information for website users

Privacy Policy, current as at July 2022.

Evidence for Learning (E4L/ Evidence for Learning) is an initiative of Social Ventures Australia Limited (SVA) (ABN 94 100 487 572). E4L is committed to protecting your privacy. Data protection laws require us to provide you with information about how we collect, use and handle your personal information. This notice also contains information on what to do if you have questions, concerns or complaints.

We take reasonable steps to ensure your personal information is protected from misuse, interference, loss and unauthorised access, modification or disclosure.

We review our Privacy Policy periodically to ensure it is up-to-date so we encourage you to revisit it from time to time. This policy was last updated in July 2022.

Scope

This Policy applies to all our staff, volunteers, contractors and suppliers who handle personal information collected by E4L and its related entities and collaborators (we, us, our). It applies to personal information for individuals that are external to us such as donors, clients and suppliers (you, your).

By providing your personal information to us, you consent to the use, storage and disclosure of the personal information you provide to us as described in this Policy.

Information collection

In the course of our activities, E4L collects a range of personal information about our supporters, investors, clients, subscribers, visitors to our website and other people with whom we interact.

We will only collect information about you that is reasonably necessary for our functions or activities. This may include:

  • your name, address and contact details
  • your organisation and position title
  • your payment and financial details and information about any previous interactions you may have had with us
  • information associated with web browsing, email, text messaging, phone calls or other electronic international with you including your phone number and user name
  • for donors, details relating to your donations and information relevant to the purpose of better identifying donor sources
  • for others, other information relevant to the purpose of providing services to you
  • sensitive information about you that may include your gender, age, date of birth, health, disability, mental health, racial or ethnic origin, religious affiliation and other particulars required as part of our funding obligations and/​or that are relevant for the proper provision of services that we provide
  • survey and questionnaire responses.

The main way we collect information is when you give it to us, for example, when you make an inquiry on our website, subscribe to our website, make a donation, invest in a fund that we manage, apply for our services, provide feedback on our website or subscribe to our updates. We may also collect information from other sources, for example, your adviser(s), publicly available records, databases or social media. However, where possible, personal information is collected directly from you with your consent at the time of your interaction with us.

Personal information may be collected in hard copy form or electronic form. Hard copy records are required to be held securely. We hold electronic records in databases with security safeguards.

Where consent to collection is sought, it is sought voluntarily from you and we will inform you of what you are consenting to. Our consent agreements are current and specific to the services to be provided to you.

We will not collect sensitive information about you, unless you have consented, it is required by law, or in other special specified circumstances.

Web Analytics

We use Google Analytics to collect data about your interaction with our website. The sole purpose of collecting your data in this way is to improve your experience when using our site. The types of data we collect with these tools include your device’s IP address, geographic location, referring domain and out link if applicable, search terms and pages visited on our website, data and time when pages were accessed on our website. Further information on Google Analytics tracking is available from the Google website.

Cookies

We use cookies on our website which are small files transferred to and stored on your computer that enable our site to recognise your browser and record information about your use of the site. These help E4L understand what parts of the site users find the most useful and improve the effectiveness of the website. The cookies do not personally identify you, only your browser, and they do not read the information on your hard drive or make your computer perform any actions or send information to any other computer via the internet.

Generally, we do not collect sensitive information – such as information about race, religious beliefs or health – about you unless required by law or where you consent for us to do so. We may collect information about your affiliation with certain organisations, such as professional associations.

As well as the cookies we set, we may use third party cookies and other similar technologies set by other websites when you visit them to help us to understand some simple information about the age, location and interest of the people who visit our sites. Third parties may use these technologies to collect or receive information from our website and elsewhere on the internet and use that information to provide measurement services and to target adverts.

We only ever use this information in aggregate, and never associate it with any personal information that might identify you.

You can opt out of being tracked by cookies set by third parties by using the Google ad preferences page or the opt out tool. You can also get more information from Google.

You can opt out of being tracked and the collection and use of information for Facebook ad targeting in your ad settings page on Facebook. You can also get more information from Facebook on their use of cookies and advertising policies.

You can opt out of tracking from all participating companies through the European Interactive Digital Advertising Alliance​‘Your Online Choices’ site. In the UK, click on the ​‘Your ad choices’ menu option.

By continuing to use our sites and by using video and social media functionality, you consent to the relevant cookies being set on your device.

For general information about cookies, and how to control and disable them, please visit www.allaboutcookies.org.

IP Analytics – Anonymity:

We anonymise your IP address as soon as data is received, before any storage or processing takes place. The last octet of your IP address is set to zero while still in memory. For example; an IP address of 51.48.129.811 would be changed to 51.48.129.0

Only after this anonymity process occurs is the request transmitted to our analytic providers, your full IP address recorded as all anonymity happens in memory processing (nearly) instantaneously after the request has been received.

By continuing to use our site, you agree to the placement of cookies on your device. If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.

Mailing List

We will collect information that you provide to us when signing up to mailing lists to obtain updates regarding the platform or for us to seek feedback from you regarding the platform, registering for our events, or submitting feedback on your experience with our website.

We use a Campaign Monitor to manage our mailing list. You can access Campaign Monitor’s Privacy Policy here. When subscribing to our mailing list, you will be asked to give your express consent that Campaign Monitor may use your data for analytics purposes. Analytics are performed when you click on links in the email, or when you download the images in the email. They include which emails you open, which links you click, your mail client, if your action occurred on mobile or desktop and the country geolocation of your IP address.

Anonymity

Where possible, we will allow you to interact with us anonymously or use a pseudonym. For example, if you contact us with a general question, we will not ask for your name unless we need it to adequately handle your question. However, for most of our functions and activities we usually need your name and contact information and enough information about the particular matter to enable us to fairly and efficiently handle your inquiry, request or complaint.

Use and disclosure of information

SVA only collects personal information that is reasonably necessary for our work and helps us engage with you. We collect, hold and use personal information only for the primary purposes for which it was collected or as set out below including:

  • to provide services which may include managing your support, responding to your requests, comments and questions
  • to process your donation or investment
  • to conduct marketing and social functions including but not limited to keeping you up-to-date with other initiatives or opportunities that we may think may interest you
  • to comply with the requirements of funding bodies as part of a funding agreement with us
  • to operate fundraising and charitable activity in support of our objectives
  • to undertake marketing, fundraising and promotional activities, including activities to better identify donor sources, events and conferences organised and held by us
  • to provide customer service functions, including handling enquiries, complaints and feedback
  • to facilitate proper governance processes such as risk management, incident management, internal audit and external audits
  • to gather feedback from you and other individuals about the quality of the services that we provide so that the services we provide can be continuously improved
  • to understand, through aggregated information, trends and patterns which we use for research and advocacy
  • to satisfy legal obligations, comply with applicable laws and meet the requirements of bodies which regulate the services we provide
  • to fulfil other purposes which you have consented to.

SVA may share personal information within the SVA group, and we may disclose the information to service providers who provide services to us in connection with our activities. We will not sell, loan or provide your information to any third party for the purpose of direct marketing without your consent.

We will not disclose your personal information to other external organisation except:

  • as required by funding agreements
  • as required by law
  • for transfer to another service provider in accordance with funding agreements
  • where we have your consent to do so through your acceptance of this policy and the disclosure relates to the goods or services we provide to you
  • for a purpose permitted by this policy
  • if you request us to do so.

Examples of organisations and/​or third parties that your personal information may be provided to include:

  • secure payment gateways, secure data storage providers, research agencies and mail distribution providers that send our communications
  • a government agency, as required by our funding agreements
  • third party service providers who assist us with the delivery of services or who provide services to or partner with us to enable us to deliver services, or in undertaking quality assurance of our services
  • third party service providers who assist us with fundraising activities or strategy, identifying donor sources or analysis of our fundraising activities, strategy or patterns (including data collectives)
  • third parties who assist us with co-ordination of advocacy, volunteers or community activities
  • government or non-government agencies where we have a reasonable concern regarding your safety or wellbeing
  • third parties who collate and/​or analyse information for the purposes of research and advocacy
  • third parties for the electronic storage of information, some of which may be overseas.

In limited circumstances, we may use service providers based overseas to process the data that we collect, but will only do so if we reasonably believe that the overseas entity is subject to the same or similar privacy laws to those in Australia, or if you have consented to us disclosing your personal information to the overseas entity.

We may disclose information to third parties but we will only do so with your prior consent or to comply with our legal obligations if required by a Court/​Tribunal, or for co-operating with a regulator, authority or a government department.

You have a right to ask us to restrict the processing of your information in certain circumstances. You also have a right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.

Storage and security of information

We keep personal information in physical and/​or electronic records, at our premises and the premises of our service providers, which may include cloud-based data hosting facilities which may result in your personal information provided to us being transferred to, and stored at, a destination outside Australia including but not limited to the United Kingdom.

You are taken to expressly agree and consent to the transfer, storing or processing of your personal information outside of Australia in submitting it to us. In providing consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection requirements as Australia in relation to personal information. Whilst we seek to ensure through our contracts with external parties that they comply with the Privacy Act regarding the use of your personal information, we have limited control around how some external parties use your personal information.

This website, https://evidenceforlearning.or…, is hosted in Australia.

The security of your personal information is important to us and we actively seek to ensure that all personal information we collect is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. This is done by using SSL encryption, firewalls, password access and secure servers, and all donations and/​or communications made online via our website are secure.

When we no longer need your personal information and we are not required to keep it to comply with any laws, we will take reasonable steps to ensure the information is destroyed or de-identified. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You have the right to ask that we transfer the information you gave us from one organisation to the other, or give it to you. This right only applied if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

This website, including all data provided by users through it, is managed by a third party, Percipio. Please refer to its privacy notice, available here, for further details.

We use third parties for the purposes of customer relationship management. These include Salesforce (our CRM system) and Campaign Monitor.

Other data processors specific to how you have engaged with E4L are detailed in the relevant privacy notices linked above.

Third Party Websites and Platforms

This website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

We use social media platforms such as Facebook, Twitter and LinkedIn to facilitate our business activities and functions and post about our services and other information about our events and activities. If you choose to interact with us through these services, it is your responsibility to review and accept the privacy policy of that service prior to interacting with us.

Accessing, erasing or correcting your information

We strive to make sure your personal information that we hold is accurate, up-to-date, complete and relevant. You can request access to your personal information, and update or correct the information we hold about you, by clicking Preferences’ on the email subscription you receive from us.

You also have the right to ask us to erase your personal information in certain circumstances.

Opt-out

If you do not wish to receive marketing or promotion communications from us, you should unsubscribe’ online where a link is provided. In other circumstances, you should contact us on the email addresses below and we will cease the relevant marketing or promotional communication: info@​evidenceforlearning.​org.​au

Where we are providing services to you, we need to be able to communicate with you in relation to those services.

Mandatory Notifiable Data Breaches

We will comply with the notification and other requirements of the Privacy Act where your personal information held by us has been inadvertently lost or disclosed or improperly accessed and that loss, disclosure or access may result in serious harm to you.

Enquiries and complaints and Your rights

If you have any questions, concerns or complaints about how we handle or manage your personal information, please email us at legal@​socialventures.​com.​au or call us on +61 2 8004 6700. If you have made a complaint, SVA will acknowledge that your enquiry or complaint has been received, let you know who will be handling your matter and give you an estimate of when we can provide a response.

We will treat your enquiry or complaint confidentially. You may contact the Australian Information Commissioner or the Information Commissioner’s Office, the UK supervisory authority for data protection issues wherever you believe that your rights to privacy have been breached by us. However, we would appreciate the chance to deal with your concerns before you approach any of these third parties so please contact us in the first instance.

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. You are not normally required to pay any charge for exercising your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access to your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

For more information about your data rights, you can access:
https://www.oaic.gov.au/
https://ico.org.uk/your-data-matters/