Ethical Clothing Australia's Privacy Policy

1     Introduction

1.1 Ethical Clothing Australia is committed to protecting the privacy of personal information that the organisation collects, holds and administers.

1.2 We must ensure that personal information is collected and managed sensitively and in accordance with the relevant Privacy Laws.

1.3 We must implement and maintain steps to ensure that personal information is protected from misuse and loss, unauthorised access, interference, unauthorised modification or disclosure.

1.4 This Policy is complementary to Ethical Clothing Australia’s Privacy Collection Statement published on its website, and the Code of Practice.

1.5 This Policy sets out specific obligations regarding the collection of personal and sensitive information. It is separate to the Confidentiality Policy which outlines obligations regarding the protection of any confidential information that is gathered or collated as part of Ethical Clothing Australia’s operations. It is also in addition to obligations that employees have in relation to confidential information, as outlined in their employment contracts.

2. Purpose

2.1 This Policy outlines the types of information we collect, how we manage your information from initial collection to use and storage, who we may disclose it to and how you can find out more about the information we hold about you. It includes:

1. The types of Personal and Sensitive information (together your Information) we collect about you.
2. Protections that are in place regarding the collection and safeguarding of your Information.
3. The correct use and disclosure of any Information.
4. The storage, management and destruction of your Information.
5. Procedures that must be followed including for marketing activities, and
6. Mandatory reporting of any suspected breaches of law or breaches of this Policy.

2.2 This document also outlines our Privacy Collection Statement, governance structures, responsibilities and processes that have been established to give effect to this Policy.

3       Application

This Policy applies to all employees, student placements, consultants, subcontractors/agents, suppliers and their staff. This Policy also applies to Members of the Homeworker Code Committee and the Textile Clothing and Footwear Union officers employed as part of the Service Level Agreement.

4       Information We Collect

4.1 We collect and administer a range of Personal and Sensitive information for the purposes of our operations.

4.2 Personal information in general is information which directly or indirectly identifies you and is divided into the following categories:

1. ‘Personal Information’ which is information or an opinion about you such as your name, contact details, age, photographs, qualifications, employment and training records, business details, ABN, payroll details, bank and superannuation details, driver’s licence and tax file number.
2. ‘Sensitive Information’ which is information or an opinion about you such as your racial or ethnic origin, religious beliefs, trade union membership or criminal record, sexual orientation and health information and records.

4.3 The kinds of Personal Information we collect from you will depend on your dealings with us and may include: your name, address, email address, phone number, emergency contacts, employment history, qualification and training records, CV, director ID, date of birth, ABN/ACN, tax file number, superannuation information and bank details.

4.4 We will only collect your Sensitive Information with your express consent.  Sensitive information we may collect includes union membership information.

5       Our Commitments

5.1 To protect and safeguard your Information we will:

1. Only collect personal or sensitive information which is necessary to support and    administer our operations and business functions or to comply with applicable laws.
2. Collect personal and sensitive information directly from you wherever possible.
3. Only collect sensitive information with your consent.
4. Only collect personal and sensitive information by lawful and fair means and not in an unreasonably intrusive way.
5. Consider requests for anonymity or pseudonymity, if practical, when collecting your information.
6. Tell you how your information has been collected and why we have collected it.
7. Only use and disclose your Information if it is required for our operational and business functions or a directly related secondary purpose, and if for another purpose with your consent.
8. Store your personal and sensitive information securely, protecting it from misuse, interference, loss, unauthorised access, modification or disclosure.
9. Provide you with access to your Information upon request, and the right to update and correct your Information.
10. Destroy or de-identify your information when it is no longer required.

6       How Your Information Is Collected

6.1 We may collect your Information at the following times as part of our operations and business functions:

1. During our recruitment, employment and onboarding process.
2. When you apply for or renew your accreditation with Ethical Clothing Australia.
3. When you complete our accreditation application or renewal forms.
4. When you review and agree to the Code of Practice.
5. When you take our online eligibility quiz.
6. When you provide information as part of our compliance audit.
7. As part of our marketing activities and events.
8. When undertaking a contract with us.
9. When you use our website, via ‘cookies’ which collect information about server address, browser used and date, time and our web pages visited.
10. From publicly available information, including social media platforms.

7       Why We Collect Your Information

7.1 We collect your information which is necessary to achieve our operational and business functions and activities including for:

1. Considering and managing employment, consultant, contractor/sub-contractor and supplier applications/engagements and records.
2. Following up on information provided via the eligibility quiz.
3. Assessing applications for accreditations and renewals.
4. Ensuring compliance with our Code of Practice.
5. Managing data breach incidents and reporting.
6. Managing concerns, grievances and/or complaints in accordance with our policies.
7. Marketing and communication purposes.
8. Complying with applicable laws and regulations.

8       Use and Disclosure of Your Information

8.1 We may disclose your Information to the following parties:

1. Our employees, contractors or agents who assist with administration and management of your Information.
2. Related entities of Ethical Clothing Australia such as the Homeworker Code Committee.
3. Third party providers of Ethical Clothing Australia engaged to conduct its primary purpose.
4. Textile, Clothing and Footwear Union officers employed as part of the Service Level Agreement.
5. To verify your accreditation status with Government agencies for procurement purposes.
6. Organisations that assist us with marketing, communication and advertising activities.
7. To refer requests for contact details from retailers, designers and others looking for accredited manufacturers.
8. Professional advisors and consultants.
9. Our IT and Website systems and service providers and Finance service providers.
10. Third parties in accordance with your direction if appropriate to do so and agreed by the National Manager.
11. Authorised representatives.
12. Referees, other employers seeking a reference, or employee union representatives.

8.2 We will not disclose any Information to an overseas recipient, including a provider of IT services such as servers or cloud services, without establishing that they are privacy compliant.

9       Storage and Management of Your Information

9.1 We store your information in electronic and hard copy form and protect your information from misuse, interference, loss, unauthorised access, modification or disclosure in the following ways:

1. Limit access to your information to those who need to know.
2. Confirm with you that your Information is up to date, accurate and complete.
3. Destroy/de-identify records in accordance with our Records Management Policy, once no longer required.
4. Use technology to prevent unauthorised access to our electronic databases
5. Provide staff training and implement policies and procedures relating to the use of computers and management of personal information.
6. Report any instances of breach or suspected breach of this Policy in accordance with the Privacy Act and our Data Breach Response Plan Policy.
7. Conduct audits of information management procedures.

10  Complaints or Questions

Any questions or complaints you may have in relation to this Policy or the management of your Information can be directed to:

The National Manager

By Telephone: (03) 7068 6366

By Email: Rachel@ethicalclothingaustralia.org.au

In writing: Attention the National Manager, PO Box 2087, Fitzroy, VICTORIA, 3065