Privacy Policy (Full)

MÉDECINS SANS FRONTIÈRES AUSTRALIA PRIVACY POLICY

Médecins Sans Frontières Australia Ltd (MSFA) respects your right to the protection of your personal information. This Privacy Policy details how we manage, collect, use, disclose and hold this information.

In this Privacy Policy, personal information, as defined in the Privacy Act 1988 (Cth) (Privacy Act) means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  1. whether the information or opinion is true or not; and
  2. whether the information or opinion is recorded in a material form or not. 

 

PART 1 – PERSONAL INFORMATION MANAGEMENT

What we collect and how we collect it

We collect information, such as:

  • Name and address;
  • Telephone/e-mail contact details;
  • Bank account/credit card numbers; and
  • Employment/education history;

The personal information we actually collect varies depending on the purposes for which it was collected. For more information, see Part 2 of this Privacy Policy – “Specific Information Collection Details”.

It is our usual practice to collect personal information directly from the individual. From time to time, MSFA may also collect personal information from publicly available sources such as telephone directories or mailing lists, provided that the collection is conducted in a fair and lawful manner, the information is reasonably necessary for our functions or activities and it would be impracticable or unreasonable for us to collect the information from you. We may also collect anonymous traffic data on our website to improve our services.

Why we collect your personal information and what it is used for

We only collect, use and disclose personal information where that information is reasonably necessary for purposes which are directly related to one or more of our functions or activities.  These include:

  • Processing of donations;
  • Recruitment of field staff;
  • Communication with our supporters on our field activities;
  • Provision of our services;
  • MSFA membership management;
  • Marketing activities; and
  • Recruitment of volunteers

For the purposes of the GDPR, we collect, use and disclosure your personal information on the basis that it is necessary for:

  • the performance of a contract or intended contract which you are a party to; and
  • our legitimate interest in processing employee information.

We use your information to process your donations, to advise you on how your support is helping, and to keep you updated on events and our work in the field. We also use information provided to us to process applications for field work.  We may use your personal information to send you direct marketing materials. Where you no longer wish to receive direct marketing materials from us in future, you may contact us at any time using the contact details provided below.  Where we have facilitated direct marketing to you from personal information we have obtained from a third party, you may also request we disclose the original source of the information. 

You may request at any time that you remain anonymous when dealing with us or use a pseudonym, and to the extent that it is lawful and practicable for us to enable you to do so, we will accommodate that request. However, if personal information is not provided in full where we have indicated that it is required or when it is otherwise requested, we may not be able to process your donations, recruit you as field staff, enable you to become a member of MSFA, and our employees, contractors and consultants may not be able to provide services to you, either in an effective manner or at all.

Disclosure

We only disclose  personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities, unless required to disclose it by law, unless we have your consent, or unless one of the following situations apply:

Transfer within MSF for the recruitment of field staff

MSF is an international organisation working in more than 60 countries. MSF is made-up of 5 operational centres (Europe-based), 23 other sections and 1 international office (Geneva). In the course of recruitment for field staff, personal information may be transferred between MSFA and the operational centre/field operations, to facilitate the recruitment process. This personal information may also include your health information, which is sensitive information for the purposes of the Privacy Act. We will not disclose your health information without your consent, unless the disclosure is directly related to the purpose of collection. Furthermore, we will take all reasonable steps to ensure that MSF’s various operational centres, sections and offices will comply with the Privacy Act and this Privacy Policy when they handle your personal information and are only authorised to use your personal information for the purpose for which it was collected.

Outsourcing

We may also use external service providers to provide us with certain outsourced services, such as helping us with our mailings. These service providers are required to sign confidentiality agreements to maintain the privacy of your information and we only disclose your personal information to them to the extent necessary for them to perform the services we have requested. Some of these external service providers may be based overseas, for example, we receive account management services from a third party service provider which requires personal information of donors to be held in the United States of America. 

Where we do provide your personal information to such external service providers, we will take all reasonable steps to ensure that those external service providers comply with the Privacy Act and this Privacy Policy when they handle your personal information and are only authorised to use your personal information for the purpose for which it was collected. 
 
We do not give information about you to government agencies, organisations or anyone else unless one of the following applies:

  • You have consented;
  • You would expect us to or we have told you we will;
  • we are required to by law;
  • we believe on reasonable grounds that disclosure is required to prevent or lessen significant risk to your life or physical, mental or emotional health or that of another person;
  • we take appropriate action in relation to a reasonable suspicion of unlawful activity, or misconduct of a serious nature, that relates to our functions or activities;
  • disclosure is required to assist any entity, body or person to locate a person who has been reported as missing;
  • disclosure is made for the purpose of establishing, exercising or defending a legal or equitable claim; or
  • disclosure is made for the purposes of a confidential alternative dispute resolution process.

Profiling

We (or our service providers on our behalf) may collate information about you and your preferences, and evaluate certain things about you, to create a profile to personalise our communication and interaction with you.
 
We (or our service providers on our behalf) may also use personal information to identify market segments and use that information for data analytics and direct marketing.
 
We do not engage in any automated profiling which may result in decisions having a legal or similar material impact on you.
 
Data analytics
 
We (or our service providers on our behalf) may use your name, street address, email address and phone number to conduct data analytics, including the creation of look-alike audiences.
 
We use the results of data analytics for a range of purposes, including marketing, product and service development, and policy development.
 
In conducting such data analytics, we will also collect personal information about others from our third party service providers.
 
We do not use sensitive information for data analytics.
 
Other circumstances
 
In limited circumstances, our employees, consultants and contractors may collect health information from you in relation to specific services that are being or will be provided by us.  We will only collect this information with your consent, and will provide an additional statement to you about our collection, use and disclosure of such information.
 
Information quality, access and correction
 
We take reasonable steps to make sure that the personal information we collect is accurate, complete and up-to-date. These steps include maintaining and updating personal information when we are advised by individuals that their personal information has changed and at other times as necessary. 

You are in control of any personal information you provide to us. If at any time, you would like to correct the personal information we have about you or if you would like to change your preferences for contact from us, you can let us know by contacting us at the email or postal addresses listed below.

You can access the personal information we currently hold about you or request that we change that personal information at any time.  We endeavour to respond to any such request within a reasonable period.  We will allow access or make the changes unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information. If we cannot agree to make requested changes to personal information, we will provide you a written notice which sets out the reasons for our refusal and the mechanisms available to complain about the refusal.

We will attach this statement to our records.  You may also request access to personal information we hold about you in archive for legal and administrative reasons, which are not current records [but if you do, we may charge you a reasonable fee for the cost of providing access].

There is no cost associated with making a request for access to or correction of your personal information [but there may be a cost associated with accessing that personal information]. You can obtain further information about how to request access or changes to the information we hold about you by contacting us (see details below).

If you wish to allow another person to access your details (eg family member) you need to notify us in writing and it will be noted on your record.

You have the right to withdraw your consent to the processing of your personal information. By withdrawing consent, this will not affect the lawfulness of processing based on consent prior to it being withdrawn.  

In some cases, you may have the right to access any data we used as input to create a profile about you, as well as the profile itself.

Information security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification or disclosure.

These steps include a properly configured firewall, encrypted transmission of electronic data where required/appropriate, up-to-date anti-virus software, regular monitoring of all network traffic and strict access control policies on electronic data. There is also securing of paper files in locked cabinets and physical access restriction to these files.

When no longer required, personal information is destroyed in a secure manner or deleted.

 

PART 2 – SPECIFIC INFORMATION COLLECTION DETAILS

This section further details the specific methods of personal information collection we undertake and how that information is used.

Donation Information

We collect personal information from donors in order to process/receipt their donations and to send out periodic mailings relating to our work in the field and how donors can further support this work. 

This personal information may include:

  • Name and address
  • Your date of birth
  • Social Media information you have supplied to us.
  • Telephone/e-mail contact details
  • Credit card and/or bank account details
  • Bequest intentions.

We also engage an external service provider to transmit electronic supporter communications ( e.g. our monthly E-Newsletter, fundraising emails, or invitations to MSFA-related events). The external service provider collects personal information about your use of our supporter communications, for example, whether you click-through or unsubscribe from the service.  The external service provider uses the collected personal information for the sole purpose of preparing reports to help us improve the efficacy of our supporter communications. MSFA takes measures to ensure the privacy of the personal information included in these reports.

Donor questionnaire responses

We also collect personal information from donors through questionnaires posted out to help us better understand their needs.

The information collected will depend on what you choose to provide us with but may include the following:

  • Reason for donating
  • What other charities and causes you may support
  • What publications you read and how frequently
  • What your interests and hobbies are
  • What television stations you watch, which types of programs and how often
  • Your travel destinations
  • Your date of birth
  • The industry you work in

This information is used to more effectively communicate with you personally on specific areas of interest. It is also used as aggregated, de-identified data to assist us in making cost-effective fundraising method choices.

Field staff information

We collect personal information from applicants for field work, field staff, and referees to enable the recruitment/ongoing employment process, to contact relatives/friends in the case of a health/security incident in the field and to send out periodic mailings relating to our work in the field and internal events.  We only collect health information after the applicant consents to the collection as part of the application form for field work.  In circumstances where the applicant refuses to provide such a consent, the applicant will not be considered for field work. 

This information will include:

  • Name, address, date of birth, telephone/e-mail contact details (including relatives/friends)
  • Bank account details
  • Passport details
  • Employment history
  • Police reports
  • Educational history
  • Health information (only that which is relevant to field work)
  • Contact log
  • Information pertaining to your employment references
  • driver's licence or other secondary form of identification
  • medical registration
  • travel history, where relevant to field work (e.g. for visas)

Where necessary, to facilitate the recruitment process, personal information may be sent to Africa, Asia, Caribbean, Central America, Europe, North America, Oceania and South America and including to other MSF offices, but only where the applicant has consented by signing an application form for field work which explains this process. Occasionally social media may be used to assist in assessing an application for field work.

Field staff applications may be retained in the event that they are unsuccessful for the purpose of their consideration in future roles that may become available.

De-identified information is used to monitor recruitment processes, for data presentation in our annual report and for internal MSF international reporting.

MSFA Association members data

We collect personal information on MSFA Association members to maintain the MSF-A Membership Registry (under the Corporations Act 2001), issue receipts for annual fees and to send out periodic mailings relating to internal events and our work in the field.

This information will include:

  • Name and address
  • Telephone/e-mail contact details
  • Credit card and/or bank account details
  • Meeting attendance
  • Contact log

Our website

The only personally-identifying  information collected from visitors to our website www.msf.org.au is that which is provided to us on a voluntary basis.  Where you provide unsolicited personal information to our website, we determine whether or not we should be collecting such personal information and in circumstances where such information is not reasonably necessary for our functions and activities, we destroy or de-identify the information.

Google Analytics is our analytics tool for the website. Each page is tagged using Google Analytic's universal tracking pixel which collects anonymous traffic data. We use Google Adwords to run pay-per-click advertising campaigns, this includes interest and demographic ad targeting using the information made available by Google. 
 
We use Optimizely for A/B testing. We have an Optimizely pixel on each page of the site that collects anonymous traffic data.

Any personal information you provide to us (such as an e-mail address) will only be used for the purpose for which it is collected. We do not trade, sell or rent to any third party information captured or voluntarily submitted on this website.

Any external websites linked to/from MSFA website are not controlled by MSFA and therefore we cannot take responsibility for content, claims or adherence to the privacy laws here or overseas.

Cookies

Cookies are small files that a website transfers to your computer. Most web browsers are automatically set to accept cookies. Your browser controls will allow you to restrict, block or delete cookies.

We use cookies:

  • To collect non-identifying statistical information on how many people visit our website, what country/city/region they are from, which browser/operating system they are using and pages viewed on the website.
  • To allow functionality for the user within our website
  • For use of third party advertising or social media services to enable tracking and retargeting for online marketing material. We have floodlight tags (or Doubleclick tags) that collect cookies for our programmatic advertising activity. We then show remarketing ads to people that have visited our website.

By using this site, you agree that we may place these types of cookies on your device.

What rights do I have?

  • In addition to any other rights identified in this Privacy Policy, you have the right to ask us to delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
  • In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for profiling, data analytics, or direct marketing).
  • These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. 
  • To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to the Office of the Australian Information Commissioner.

To the extent that there is no conflict and that the level of protection of the individual is higher under European law, MSF Australia will look to apply the higher standard not only because it is part of a Movement that has a significant presence in Europe, but also because of the importance the organisation places on protecting individuals’ right to privacy, regardless of nationality or location. 

Contact Us

Questions/complaints about privacy:

  • Call 1300 136 061 (cost of a local call) or (02) 8570 2600
  • By e-mail to [email protected]
  • Mail us at Privacy Officer, Médecins Sans Frontières Australia Ltd, PO Box 847, Broadway NSW 2007
  • We will endeavour to respond to complaints within 14 days of their receipt. If you are dissatisfied with our response, you may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au).

Updating your information through our Supporter Relations team:

  • Cost of a local call 1300 136 061
  • By e-mail to [email protected]
  • Mail us at Médecins Sans Frontières Australia Ltd, P O Box 847, Broadway NSW 2007

For more information please contact our office in Sydney:

Street address
Médecins Sans Frontières Australia Ltd
Privacy Officer
Level 4, 1-9 Glebe Point Road
Glebe NSW 2037
Ph: 1300 136 061

Postal address
Médecins Sans Frontières Australia Ltd
Privacy Officer
PO Box 847
Broadway NSW 2007

This Privacy Policy may change from time to time. This policy was last updated on 12/02/2020.