The purpose of this document is to set policy for the use of personal
information by ASBA Limited (‘ASBA’).
ASBA only collect, hold, use and disclose personal information to carry
out our primary goals to promote high quality professional development
opportunities, enable collegial networking, be a leader in governance
championing, and supporting other educational bodies with advocacy and support
for the education sector.
This policy applies to all personal information held and/or collected by
Collection of personal information
We collect personal information for the purposes stated in this Policy
from our members, non-members, participants in our courses, third parties,
service providers, suppliers, contractors, consultants, sponsors and
individuals who interact with ASBA.
We collect and hold information from Members about their members or
prospective members through membership related applications. This information
includes name and contact details, gender and career history. We also collect
date of birth to enable us to uniquely identify members and to assess what
products and services may be most suitable and of interest for members.
We may keep information that prospective members have entered when they
start, but do not complete, an online membership application form to enable us
to contact them about becoming a member.
Education and training
We collect and hold enrolment information from members and non-members
and may keep a record of the courses completed.
We collect and hold information which members and non-members provide
through applications to attend events such as conferences and briefings. This
includes, if applicable:
- Sensitive information
such as dietary or mobility requirements;
- Travel bookings;
- and Image (video or
photographs) or sound recordings (but only if you have not opted-out from
this). We keep a record of the events and workshops a member or non-member has
From time to time, we or our service providers may collect your personal
information via surveys. We will only use the personal information collected
for analytical purposes, updating our records or to assist with improvement or
development of our products and services. By completing these surveys, you
accept that your personal information may be transferred outside Australia.
We collect information indirectly about members, but only in
circumstances where a member would reasonably expect it, or where the member
has consented. Examples include referee comments and criminal history checks
for some membership related applications.
Notice where you give us information about
If you give us personal information about any other individuals (e.g.
guests attending a conference or other event) we ask that you tell the
individual that you have done so and make them aware of this Policy, for
example, by giving them the link to it.
of personal information
We use personal information we collect and hold through membership,
educational and training course and event applications or attendance to:
- Administer and meet
member requirements for the particular service, course event or program;
- Help us improve the
particular service, event or program;
- Identify and analyse
member and non-member activities and interests in order to better meet member
needs and attract new members;
- Enable us to target
marketing communications to members and non-members; and
- Enable ASBA to further
- We will not use your personal information for any purpose which you
would not reasonably expect unless it is consistent with the Privacy Act. If we
think a member may not expect a particular use of information we hold about
them, we ask for consent before we use it for that purpose.
Sound and image recordings of events
We use sound and image recordings of our events to enable us to improve
our events, and for promotional purposes. We will give you a chance at the time
you apply to participate in an event to indicate if you do not want us to use
your voice or image. You can also contact the ASBA if you want to express your
Our advertising and marketing material, content, information and
communications (marketing material) is sent to members and non-members about
whom we hold records to provide information about the AICD’s products and
services which may be of personal and/or professional benefit. These products
or services may extend beyond those provided by the AICD and include offers
from third parties.
We may send any of these marketing materials by mail, telephone, email,
SMS or other electronic methods, such as through social media or targeted
advertising. If you indicate a preference for a method of communication, we
will try to use that method where it is practical for us to do so.
When you access our websites, we may display
customised marketing material to you based on data stored in your cookies – you
accept that your opt-out options may be different for this kind of marketing
our handling of cookie data). Service providers we use, including remarketers,
may also display our marketing material on other parties’ websites that you
visit. The display of that marketing material may be based on your prior visits
to our websites and other internet activity. We may also use data supplied by
service providers to improve our marketing material and advertising campaigns.
Disclosure (sharing) of personal information
We only disclose sensitive information such as health information for
the purposes for which you gave it to us or for directly related purposes you
would reasonably expect.
We disclose the name, title and post nominal of event participants to
speakers, organisers, hosts or facilitators under strict conditions to enable
them to carry out their role in relation to an event, for example, to organise
table lists, or facilitate introductions. We also disclose this information to
sponsors and potential sponsors to enable them to assess whether or not to
sponsor an event and disclose this to providers of special member offers from
time to time under strict conditions.
We disclose information about members to other members via ASBA
publications – for example, about new members or the completion of a course in The
Contractors and partners
We disclose personal information to contracted service providers who
assist us with a number of our functions and services including service
providers of technology, data processing, contact centre, legal, accounting,
business consulting, auditing, archival, delivery, banking, payments, market
research, content production and mailing but only for the purpose of fulfilling
We disclose information to partners in some of our programs, for
example, about applicants for scholarships to assist us with scholarship
Where authorised or required by law
As authorised by the Privacy Act we disclose personal information in
connection with law enforcement activities by enforcement bodies, for example,
Australian Securities and Investments Commission investigations or other
investigations into suspected fraud or unlawful activity.
We are required by the Corporations Act 2001 (Cth) to allow an
individual to inspect ASBA’s member register and view current and past members’
names and addresses. However, the Corporations Act prohibits the individual
from using the information gained to contact or send material to members, and
from using it for other prescribed purposes.
From time to time, we may send your personal information overseas. Where
we use a service provider that hosts personal information in other countries,
we take steps that are reasonable in the circumstances to ensure that the host
does not breach the Australian Privacy Principles. The steps we take include:
- Adding provisions in our
contract with the service provider that require them to protect the personal
information they hold; and
- When choosing a service
provider, including in our considerations the privacy law or scheme (if any)
that applies in the country in which the service provider operates.
- If we have your consent,
or the overseas recipient is located in a country whose privacy laws are the
same or substantially similar to those of Australia, we comply with the
Australian Privacy Principles when disclosing your personal information to that
If a privacy breach occurs that involves a service provider located
outside Australia, we support and work with members or non-members in handling
Our websites, emails, apps and social media
When you visit our websites or download, access or register to use our
websites, (which may also include the use of any of our products, services or
apps) we may collect your personal information such as your name, address,
email address, phone number, date of birth, username, password and other
information. We may also collect information automatically, including technical
information related to your mobile device, your device’s unique identifier,
your mobile network information, the type of mobile browser you use and
information about the way you use our products, services or apps.
Depending on the particular product, service or app you use, and only
after you have agreed to such collection, we may also collect information
stored on your device, including contact information, location information or
other digital content.
Our websites may contain links to other sites. We are not responsible
for the privacy practices or policies of those sites and we suggest that you
review the privacy policies of those other sites.
If you send us an email, that address will be recorded automatically by
our e-mail messaging system for the purpose of replying to your e-mail. However
for normal communication with you we will use the e-mail address you provide in
your membership application/renewal, unless you ask us to use a different
When we send you emails or other electronic messages, we record
information about your interactions with the email including when and where you
open the message and click on particular links.
This helps us to better understand what information is of interest to
you and to improve the content.
We participate in social media such as our LinkedIn group, or Twitter.
If we think it is relevant to the quality of service that ASBA provides or its
objectives, we sometimes record the nature of the topic discussed by a
particular individual and their name and follow up with further conversation
offline about which we take notes.
Social media services also handle your personal information for their
own purposes. These sites have their own privacy policies. We are not
responsible for the privacy practices or policies of those sites and we suggest
that you review their privacy policies.
Security of personal information
We regularly assess the risks of misuse, interference, loss,
unauthorised access, modification or disclosure of personal information and
ensure that we have adequate measures, including policies, procedures and
technology, to address those risks. For example, we limit staff access to
personal information to that which they need to carry out their role. We
conduct regular internal and external audits to assess whether we have
adequately complied with or implemented these measures.
Retention of personal information
We hold most information about members and non-members for 7 years.
to and the accuracy of personal information
You have a right to ask for access to the personal information we hold
about you. Unless there is a lawful reason not to, we will give you access to
it and allow you to correct any incorrect information.
We will ask you to verify your identity to ensure we don’t give
information to the wrong person. If we don’t give you access to your personal
information or refuse to correct it we will tell why. You may ask us to make a
note of your requested correction to be located alongside information we have
not agreed to correct.
Our contact details are at the end of this Policy.
Requests for access and complaint resolution
In the event that you have a question, concern or complaint regarding
the way in which we handle your personal information, you should contact our
Privacy Officer direct at:
We take your privacy concerns seriously. Where you express any concerns
that we have interfered with your privacy, or seek access to information about
you that we hold, we will respond within 48 hours to let you know who will be
handling your matter and when you can expect a further response.
If you are unsatisfied with our response you can complain to the Office
of the Information Commissioner Telephone: 1300 363 992. Email:
Changing this policy
We will amend this Policy from time to time and notify you of any amendments
through our publications and by posting an updated version on our website at
Any amendments to this Policy will be effective immediately upon being
posted to our websites. Your use of our websites, products or services following
such amendments represents your acceptance to be bound by the Policy, as
Suggestions about improving this Policy are
welcomed. Please contact us at xx should you wish to provide