Hellenic Australian Lawyers Association and its related entities (referred to as HAL, we, us or our) are committed to the protection of personal information that relates to you in accordance with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth) (Privacy Act).
1. What information is covered by the Privacy Act?
“Personal Information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
“Sensitive Information” is Personal Information about an individual that includes health information, genetic information, biometric information or templates, or personal information that is also information or an opinion about an individual’s race or ethnicity, their religious, political or philosophical beliefs, opinions or affiliations, their sexual orientation or criminal record.
2. What kind of information do we collect and hold?
We may collect and hold Personal Information about you such as your name, gender, date of birth, contact details (including your address, phone numbers and emails, whether personal or for work), financial information, payment details, bank account details, products and services information and preferences. We may also collect Personal Information that you submit to us via the Website, including when you request us to provide services such as information in electronic form to another party.
3. Why do we collect Personal Information?
3.1 Why do we collect your information?
We collect Personal Information from individuals that is reasonably necessary for one or more of our functions or activities, including: in order to allow us to conduct our services and functions, to meet any regulatory requirements which apply to our services, to market and sell our services and to conduct related activities.
3.2 How you may deal with us
If you choose not to provide your Personal Information to us, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.
4. Collecting Personal Information
4.1 When and how do we collect your information?
We collect Personal Information directly from you when you: visit our Website, supply or buy products or services, request information about us or our products or services, provide feedback, respond to a survey, change your content or email preferences, enter into an agreement or contract with us, fill in a form or a request for services (including an application for membership with us or an application to participate in an event), fill in a form on our Website, or contact us by telephone, facsimile, email, post or in person.
4.2 Do we collect information about you in other ways?
We may also collect Personal Information about you via third parties including from our direct mail and email, events or online marketing.
In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.
5. Information collected via our Website
We will not collect any Personal Information about users of our Website except when they knowingly provide it or as otherwise described below. For example, we may collect Personal Information from users of the Website when they:
(a) complete an online form, including registering to receive updates, promotional material or other information; and/or
(b) otherwise correspond with us.
5.2 Click Stream Data
When you visit and browse our Website, our Website host may collect Personal Information for statistical, reporting and maintenance purposes. Subject to clause 7.2, the Personal Information collected by our Website host will not be used to identify you. The information may include:
(a) the number of users visiting our Website and the number of pages viewed;
(b) the date, time and duration of a visit;
(c) the IP address of your computer; or
(d) the path taken through our Website.
Our Website host uses this information to administer and improve the performance of our Website, including to assist with the diagnosis of and to provide support for any issues with our Website or services.
Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns.
5.4 Links to external websites
6. How we use Personal Information?
6.1 How we use the Personal Information we collect about you?
We use the Personal Information we collect about you for HAL’s functions and activities, which may include the following:
(a) to provide you with information, products or services you have requested, including where we engage third parties to provide you with goods or services on our behalf;
(b) to promote and market our products and services to you, including to communicate with you via SMS or email newsletters;
(c) to personalise and customise your experiences on our Website;
(d) to help us research the needs of our members and wider audience;
(e) to conduct research for the purposes of improving existing products or services or creating new products or services;
(f) to provide you with ongoing information about us and our activities;
(g) to allow us to provide third party information and offers in which we believe you may be interested;
(h) to use aggregated or de-identified information for the purposes of data analysis, research and reporting;
(i) to comply with regulatory or other legal requirements;
(j) for any other use required or permitted by law or any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
We may use your Personal Information for a secondary purpose if that secondary purpose is related to the purposes listed in this clause 6.1, if we have your consent or if otherwise provided for under the Privacy Act.
6.2 Direct marketing
We may use your Personal Information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about us or the products or services we offer.
You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 14.
7. When do we disclose Personal Information?
7.1 Who do we disclose your Personal Information to?
Depending on the nature of your relationship with us, we may disclose your Personal Information to our officers and employees, service providers who assist us in our operations (including third party service providers based overseas), government agencies, other third parties, (including parties that we engage to provide you with goods or services on our behalf or who are connected with or involved in our relationship with you), or otherwise as required by law. If we disclose Personal Information overseas we will take steps to ensure that our service providers are obliged to protect the privacy and security of the Personal Information and use it only for the purpose for which it is disclosed.
7.2 Service providers
We may also share non-personal, de-identified and aggregated information for research or promotional purposes in connection with providing requested information or services to you, or for the purpose of improving our services. We will not sell your Personal Information to third parties for marketing purposes.
8. Disclosure of your Personal Information overseas
Your Personal Information may be disclosed outside of Australia to an entity in a foreign country, including third party service providers (Overseas Entities). The countries in which these Overseas Entities are located/likely to be located will depend on any overseas events that HAL may be organising and may include Europe, Canada and the United States of America and Asia. It is possible that the Overseas Entities may be subject to foreign laws that do not provide the same level of protection of information as in Australia. We take reasonable steps to ensure that these overseas entities do not breach the APPs and that they are obliged to protect the privacy and security of your Personal Information and use it only for the purpose for which it is disclosed.
9. Storage and security of Personal Information held by us
We will take reasonable steps to protect your Personal Information from misuse, interference and loss and from unauthorised access, modification or disclosure.
We aim to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on our computer systems.
10. Updating and correcting your Personal Information
We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You can update your Personal Information at any time by contacting us in any of the ways specified in clause 14. We welcome any changes to your Personal Information so as to keep our records up to date.
11. How long will we keep your Personal Information?
We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law.
Where we no longer need to keep your Personal Information in accordance with this clause 12, we will take reasonable steps to destroy or de-identify your Personal Information.
If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons, or as otherwise required by law).
12. Finding out what Personal Information we hold about you
You are entitled to access Personal Information that we hold about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Australian Privacy Principles or at law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
A request for access can be made by contacting us in any of the ways specified in clause 14.
13. How to contact us and more information?
Att: Privacy Officer
Hellenic Australian Lawyers Association Inc.
599 Canterbury Road, Surrey Hills Victoria 3127.
You can find out more information about the Privacy Act and the Australian Privacy Principles from the Office of the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au or by email at firstname.lastname@example.org.
Last updated: March 2019