This Privacy Policy applies to the collection, use, disclosure and handling of personal information by White Cloud Foundation (ABN 99 150 511 569) (“WCF”, “we” or “us”), including personal information collected via our website at www.whitecloudfoundation.org (“Website”) and through our Meals for Mums and Tele-Mental Health services.
WCF is committed to protecting the privacy of individuals and is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (the “Act”). We collect, use or disclose personal information in accordance with the Act and this Privacy Policy.
Personal information
This Privacy Policy concerns any personal information or sensitive information of yours which is provided to us.
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 is any personal information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics, biometrics or biometric templates.
We may collect sensitive information from you, such as your health information, where it is reasonably necessary for us to provide our services to you. Unless otherwise permitted by the APPs, we will only collect your sensitive information with your consent. If you do not consent to us collecting that information, you can choose not to give us that information about you, however we may not be able to provide some or all of our services to you without collecting some sensitive information about you.
What personal information do we collect and why?
The types of personal information that we collect and hold about you will depend on the nature of your engagement with us. The types of personal information that we collect about you may include:
- your name and date of birth;
- your contact details, such as your telephone number, address and email address;
- information about you that you provide in the course of our communications with you;
- (if you consent to your healthcare provider referring you to our Meals for Mums service) your health information, including your medical history, if you identify as a First Nations person, if you are currently pregnant, and if you have any dietary requirements;
- (if you self-refer or consent to your healthcare provider referring you to our Tele-Mental Health service) your health information, including your medical history;
- (if you are a healthcare provider referring a patient to the Meals for Mums or Tele-Mental Health services) the organisation that you work for;
- (if you are a WCF volunteer) the organisation that you work for, and any registration details or qualifications relevant to your area of practice;
- (if you are making a donation to WCF, purchasing merchandise on our Website, or purchasing a ticket/s or registering for one of our events) your payment information, which may include your credit card details;
- (if you attend any of our events or fundraisers) photos of you taken during that event or fundraiser;
- (if you volunteer to fundraise for WCF) details of the fundraising you intend to undertake and details about your insurance (if relevant);
- your preferences for receiving further information from us about our future events and fundraisers; and
- (if you are a job or volunteer applicant or a prospective employee or volunteer) information about your qualifications, work experience and any other information you include in your application or we collect from your referee.
In principle, you are under no obligation to provide us with your personal information. You could choose to remain anonymous or use a pseudonym when dealing with us if it makes you feel more comfortable. However, if you choose not to identify yourself, we may not be able to provide our services to you or respond to your requests.
For example, we cannot provide our Meals for Mums service to you without your address and phone number because we need to deliver the meals to your home address and may need to contact you about meal options. However, you can still use a pseudonym if you would prefer, and you can ask your referring healthcare provider to advise us if your particular circumstances mean that your personal information is sensitive (and should be kept confidential).
You can also access our Tele-Mental Health service anonymously or under a pseudonym, however, due to the nature of the Tele-Mental Health service, we may not be able to provide some or all of our services to you without collecting some personal information about you.
If there is ever any personal information that you must provide in order for us to interact with you, we will ensure that:
- in our written interactions with you (e.g. donations, buying tickets or merchandise, Meals for Mums and Tele-Mental Health service referrals), that information will be indicated with an asterisk (*) or clearly identified to you through other similar means; or
- in our verbal interactions with you (e.g. as part of the Tele-Mental Health service), we will only ask you for the personal information that we require to provide our services or perform our functions.
If you choose to provide us with any other personal information in those circumstances, (in addition to the mandatory information that we specifically require), you will be doing so on a voluntary basis, and you understand that we may collect such information.
The personal information you provide us may be used for a number of purposes connected with our operations and mission, including to provide you with our services (including health services), enter into contractual arrangements with you, promote services, events, activities, or programs that we consider you may be interested in, or otherwise to manage our business or carry on our functions and activities, as more specifically described below.
Accessing our services (Meals for Mums, White Cloud Tele-Mental Health)
If you are accessing our services, your personal information and sensitive information (including your health information) may be used to:
- address or respond to any of your requests or enquiries;
- facilitate provision of our Meals for Mums and Tele-Mental Health services to you;
- develop and improve the quality and scope of the services, content and resources offered to you, and seek your feedback;
- contact you to invite you to be interviewed or photographed for a media story.
We may use your information for other purposes where we have your consent, to prevent injury or death, or as permitted by law (including for law enforcement or public health and safety reasons).
From time to time, we may also de-identify and aggregate information about the use of our services to undertake research, or to report to our partners and sponsors about our services and programs. You will not be able to be identified from this information.
Volunteering, donating or attending events
If you are volunteering with us, making a donation to us, attending our events or otherwise engaging with us on another basis, we may use your personal information to:
- register you to assist us as a volunteer, donor, supporter or fundraiser;
- receive and process your donation;
- if you have made a significant donation, show your name on our Website or social media (unless you choose to make a private or anonymous donation);
- if you are fundraising for WCF, show your name and the amount of money you have raised on our Website or social media;
- receive your ticket purchase and register your attendance at our events;
- use photos of you taken at our events on our Website or in marketing communications;
- inform you of our existing and proposed services, events and fundraisers (if you have agreed to receive these communications);
- invite you to participate in surveys and provide feedback to us; and
- where you are a job or volunteer applicant or prospective employee or volunteer, to consider your job application, and to give you an offer of employment. We may use your information for other purposes where we have your consent, to prevent injury or death, or as permitted by law (including for law enforcement or public health and safety reasons).
How we collect your personal information
We collect personal information that is necessary for our business activities and in order to provide and develop our services. We may do this in a number of ways.
Accessing our services
If you are accessing our services, we may collect your personal information:
- directly from you, when you provide it to us, including if you contact us by phone, videoconference, email or in person, or register for our services;
- in relation to our Meals for Mums services, by way of referral from your medical professional, allied health professional, social worker or counsellor;
- in relation to our Tele-Mental Health services, by way of referral from your General Practitioner, employer, or other referring organisation; or
- by analysing our own records of your use of our services.
Wherever possible, we will try to collect personal information from you directly. In some circumstances, it may be impracticable to collect personal information from you directly, and we may collect your personal information through a third party, for example, through referrals from our partners or affiliated organisations. Where we collect your personal information through a third party, we will take such steps as are reasonable in the circumstances to, among other things, notify you of the collection, the purposes of the collection, our privacy policy and how you may complain about a breach of the APPs.
Volunteering, donating or attending events
If you are volunteering with us, making a donation to us, attending our events or engaging with us on another basis, we may collect your personal information:
- directly from you, when you provide it to us, including if you register for our events or as a volunteer, or make a donation;
- from another person who has registered you to attend one of our events;
- from your participation in public or closed surveys or questionnaires;
- from publicly available resources (for example, if you are a volunteer, to verify your accreditation and Blue Card details using public registration records maintained by the Queensland Government);
- where you are a job or volunteer applicant or prospective employee or volunteer, from your referees; or
- from our fundraising platforms, who provide it to us in accordance with their privacy policies.
While we may use “cookies” and other web technologies to collect information about how website visitors use the Website and to support certain features of the Website, the information collected via these technologies does not identify you personally. Accordingly, such analytical information is not typically considered personal information. However, where your identity is reasonably ascertainable from such information, we will treat this as personal information in accordance with this Privacy Policy.
Sharing your personal information
There are certain circumstances in which we may disclose your personal information.
Accessing our services
If you are accessing our services, we may disclose your personal information or sensitive information (including your health information) to:
- others in accordance with a request made by you;
- in relation to our Meals for Mums services, our third party meal providers;
- in relation to our Tele-Mental Health services, our volunteer clinicians and specialists in areas including psychology, social work, counselling, dietetics and exercise physiology;
- your healthcare provider, emergency services, crisis lines or government health departments if it is necessary to prevent a serious and imminent risk to you or another person’s life, health or safety; and
- our contracted service providers (including in respect of our IT systems), where those service providers are bound by obligations of confidentiality and are only permitted to use the information to provide services to us or on our behalf.
We may also disclose your personal information or sensitive information (including your health information) if:
- it is necessary to prevent injury to life or health;
- we are required or authorised to do so by or under Australian law or a court/tribunal order, which may include any disclosure we are required to make under mandatory reporting laws; or
- otherwise, where permitted by law or the APPs.
We otherwise will not disclose your personal information or sensitive information without your consent.
Volunteering, donating or attending events
If you are volunteering with us, making a donation to us, attending our events or engaging with us on another basis, we may disclose your personal information to:
- our business partners and sponsors that assist with our fundraising and events;
- our professional advisers, including those that provide legal, taxation and audit services, where those advisers are bound by obligations of confidentiality;
- where you are a job or volunteer applicant, to your nominated referees for the purpose of receiving a reference;
- our contracted service providers, where those service providers are bound by obligations of confidentiality and are only permitted to use the information to provide services to us or on our behalf; and
- for our fundraising events, to the venue and catering team.
Does my personal information leave Australia?
Some of the third parties to whom we disclose your personal information may be located outside Australia.
The countries in which these third parties are located will depend on the circumstances. However, in the course of our ordinary business operations we commonly disclose personal information to our IT service providers which are based (and which host our data) in countries including the United States, Canada, and the UK. Where personal information is disclosed to an overseas recipient, we are required to comply with the APP requirements in relation to the disclosure of personal information to overseas recipients.
Access and correction
You may request access to any of the personal information we hold about you by contacting us as specified below. We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.
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.
Direct marketing communications
If you register your email with us, from time to time, we may send you emails about our services, events and fundraisers.
You may opt-out of receiving these communications from us at any time by using any of the opt-out facilities provided in the communications or by contacting us using the details provided below.
Storage and security
We will take all reasonable precautions to safeguard your personal information from loss, misuse, unauthorised access, modification, disclosure or destruction. We may store your information as follows:
- for the Tele-Mental Health service, electronically on Tacklit (our cloud based practice management system for health clinics);
- for the Meals for Mums service, electronically on Sharepoint;
- for information received from your healthcare provider referring you to the Meals for Mums and Tele-Mental Health services, electronically on our email system; and
- for donations, ticket purchases or subscriptions to marketing communications, electronically.
We implement a range of physical and electronic security measures to protect the personal information that we hold, including:
- for Tacklit – access to personal information is controlled by a user profile and requires a password. All data is end-to-end encrypted;
- for Sharepoint – access is restricted to certain employees only as necessary; and
- for all other relevant electronic storage, including our Website and local storage, access is password protected.
Links to other websites
This Website may contain links or references to other websites to which this Privacy Policy may not apply. You should check their own privacy policies before providing your personal information through those websites.
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 Office of the Australian Information Commissioner as soon as practicable in accordance with the Act.
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 Policy or the Act, 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.
WCF 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.
WCF expects our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Office of the Australian Information Commissioner (OAIC):
Phone: 1300 363 992
Mail: Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5288
Sydney NSW 2001
Email: www.oaic.gov.au
How to contact us
If you have any questions or concerns about this Privacy Policy or our information practices, please contact us at: info@whitecloudfoundation.org
Changes to this Privacy Policy
Our Privacy Policy may change from time to time as updated on this Website.
This Privacy Policy was last updated in February 2024.