Privacy Policy
Introduction
The purpose of this policy is for Pioneers of Australia (PoA) to communicate to the general public how PoA handles personal information including the collection, use, disclosure and protection of such information in compliance with the Australian Privacy Principles. This policy will be included in all documents where PoA requests personal information and will be available on the PoA website. Therefore, this policy is written in a manner to address those reading this policy.
Purpose
Pioneers of Australia (PoA) and its related entities are committed to protecting individuals’ personal information in accordance with the Privacy Act 1988 (Commonwealth) and other applicable data protection laws as described in this Policy.
Scope
This Privacy Policy applies to all personal information collected and maintained by PoA and describes how your privacy is respected and protected.
The nature of personal information we collect and retain
PoA collects personal information which enables us to provide a variety of services to you.
Generally, information PoA collects relates to:
- Those interested in joining our organisation including cross-cultural service, employment and voluntary roles
- Financial and prayer partners including representatives of Australian and overseas churches
- Others including organisations in Australia and overseas with whom we partner with or have secondment arrangements
The type of information includes (but is not limited to) name and contact details: communication preferences; personal connections to other organisations; professions or occupations; banking details; tax file number; superannuation details and related information.
Some of the personal information we collect may be sensitive information and may include information about your health and wellbeing, ethnic origins, Christian faith, involvement in Christian service, criminal history, genetic or biometric information and financial details. This information is collected to assist in the application process to serve with PoA, to provide member care, training and administration services.
Collection of personal information
We collect personal information directly from you unless it is unreasonable or impracticable to do so. In those instances, we will endeavour to ensure you are aware of this.
By submitting information to PoA you are consenting to the retention and use of that information by PoA for the purposes for which it is submitted.
We collect this information in a variety of ways:
- Through access and use of our website (with the use of cookies)
- During conversations between you and our team
- When application papers to serve with PoA are completed
- Through response forms by which you become prayer or financial partners or attend events
- Requests for organisational information
- When joining our mailing list
Such purposes include (but are not limited to):
- Assessing suitability for service or employment with PoA
- Keeping you informed about matters you have expressed an interest in, including the work of PoA and the ongoing support of this work
- Processing authorised payments as directed by you
- Complying with any legislation, law and regulatory requirements
Disclosure of personal information
An individual’s personal information may be disclosed to others where required for PoA to undertake its work and/or to comply with Australian law. Such disclosure will either be in accordance with the consent given by the individual when the information was collected as in this policy or as might be reasonably anticipated in the circumstances in which the personal information is provided to us. If PoA is unsure, it will seek consent before disclosing the information.
PoA from time to time needs to share information with other Pioneers entities, as part of working within the Pioneers International organisation. PoA may disclose personal information to third party service providers, agents, contractors or those organisations with whom we have agreements or memorandum of understandings. Such parties may be overseas. Where information is so provided, PoA will take reasonable steps to ensure those parties provide suitable protection of the personal information provided to them.
We will provide this information only with your consent, unless one of the other purposes of disclosure listed above applies.
We will not disclose personal information to another entity for the purposes of that entity soliciting charitable donations or for the purposes of that entity selling any goods or services to you.
Protection of personal information
We take reasonable steps to protect the personal information we collect and retain from misuse, interference, loss, unauthorised access, alteration and/or disclosure.
Steps include physical measures, computer security measures, training of personnel, confidentiality agreements and access restrictions.
Our donor database is protected by secure user IDs and passwords, to help protect it from misuse, unauthorised access, modification or disclosure.
The PoA website is enabled for online transactions using a secure payment gateway. Donations are processed in Australia, including donations from all other countries, in Australian Dollars. Secure pages on our website are protected by a 128-bit encryption, using SSL technology.
However, despite the security on the site, you should be aware that there are inherent risks in transferring information across the Internet and we cannot accept liability for any breaches.
PoA takes reasonable steps to ensure that personal information sent to an overseas recipient is handled in a manner which does not breach Australian Privacy Principles.
Access to and update of personal information
PoA takes reasonable steps to ensure the personal information it retains is accurate, complete and up to date. We rely on individuals to advise of any changes to their personal information in a timely manner.
You may request to access and to correct your personal information held by PoA at any time by contacting us. All reasonable requests will be responded to as quickly as possible.
There may be instances where we cannot grant access to the personal information if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. In addition, disclosure of sensitive information may inhibit the decision-making processes or operational activities of PoA. If that happens, we will advise you as soon as practicable.
Under certain circumstances, you can ask for your personal information to be deleted (the ‘Right to be Forgotten’). This would apply if your personal information is no longer required by PoA for the purposes it was collected for, or your consent for the processing of that data has been withdrawn from PoA.
PoA will take reasonable steps in a reasonable time, to comply with such a request, subject to suitable exceptions.
PoA will ensure that appropriate processes are in place for personal information that is no longer required to fulfil the identified purposes will be destroyed, erased, or made anonymous.
Privacy complaints
Complaints or feedback to PoA in relation to its compliance with the Australian Privacy Principles and/or this policy should be directed to the PoA Privacy Officer using the contact details below.
PoA will investigate and seek to resolve your concern or complaint in a timely manner.
If you are not satisfied with the outcome, you may contact the Chair of the PoA Board for the matter to be reviewed.
All requests will be treated confidentially.
Contact Details
Please use the contact link on our website or contact our Privacy Officer using the details set out below.
Privacy Officer
Post: PO Box 151 Forest Hill VIC 3131 Australia.
Email: privacy@pioneers.org.au
Whistleblower Policy
Introduction
This Whistleblower Policy has been developed because whistleblowing can protect Pioneers of Australia (PoA) and its related entities from significant legal, financial, cultural and reputational risks. It provides a process for individuals to raise matters that may otherwise go undiscovered. Undetected misconduct within an organisation can impact trust of our members, financial and prayer supporters, employees, volunteers and all PoA related parties.
This policy ensures compliance with ACNC governance standards and whistleblower protection regime of the Corporations Act 2001 (Corporations Act).
Pioneers Ministries Foundation is a company limited by guarantee and a related entity to Pioneers of Australia (PoA).
This policy will be made available to officers and employees at the time of their induction with PoA.
A copy of this policy will be included with all PoA policies and procedures.
Policy Statement
Pioneers of Australia (PoA) and its related entities are committed to the highest ethical standards in the conduct of all its operations and relationships. PoA is focused on detecting and eliminating misconduct and promoting and supporting a culture of honesty, integrity, compliance and sound corporate governance.
As followers of Christ, we are to speak truthfully and lovingly without intimidation or manipulation even when confrontation or correction is required (Eph 4:15). God is for those who speak truth even when it is difficult to do so.
The objective of this policy is to encourage reporting of wrongdoing that is of legitimate concern by providing a convenient and safe reporting mechanism, and protection for people who make disclosures of serious wrongdoing.
Scope
This Policy applies to the PoA Board, personnel including staff and field members, volunteers and interns. It extends to suppliers. contractors, consultants, service providers (their employees and subcontractors) and to all those who have a business relationship with PoA.
This policy is to be followed in reporting any instances of suspected behaviour which is unethical, illegal, fraudulent or undesirable conduct involving PoA.
Definitions
Terms used in this Policy are:
- Whistleblowing – The act of disclosing actual or suspected wrongdoing or misconduct within an organisation. Whistleblowing does not include matters of personal grievances or workplace complaints and concerns which would usually be resolved through staff grievance and dispute resolution policy
- Whistleblower – A person who reports known or reasonably suspected wrongdoing or misconduct within the organisation
- Wrongdoing/Misconduct – An act or omission that involves a breach of law, organisational policy, or generally recognised principles of ethics
Roles and Responsibilities
Every person associated with PoA has a role and responsibility in ensuring PoA is run ethically and in accordance with its rules and policies. Where matters related to breaches or wrongdoing are identified they should be raised as soon as possible.
In instances where a person has concerns about making a report, reports can be made anonymously.
- Whistleblower
Protection is available to Whistleblowers who disclose wrongdoing that is serious in nature; made in good faith; and made with reasonable grounds to believe it is true.
Protection is not available where the disclosure is vexatious in nature with no substance. This will be treated in the same manner as a false report and may itself constitute wrongdoing.
A Whistleblower must provide information to assist any inquiry or investigation of the wrongdoing disclosed. If the whistleblower does not share their identity, PoA or the authority to whom the misconduct was reported will assess the concern in the same way as if they had revealed their identity. However, there may be some practical limitations in conducting the investigation.
- Whistleblower Protection Officer (WPO)
PoA board will appoint a Whistleblower Protection Officer (WPO) who is authorised to receive whistleblower disclosures, to support and to provide protection to the Whistleblower according to this policy.
In cases where the Whistleblower does not feel safe to speak to the WPO they may seek to discuss the matter with the PoA Board Chair.
If the misconduct cannot be raised with anyone associated with PoA, the Whistleblower may approach Australian Securities and Investments Commission (ASIC) or the Australian Prudential Regulation Authority (APRA) or their lawyer.
The WPO will provide mentoring and other support deemed necessary. The WPO is responsible for keeping the Whistleblower informed of the progress and outcomes of the investigation subject to considerations of privacy of those against whom a disclosure has been made.
- Whistleblower Investigation Officer (WIO)
The Whistleblower Investigation Officer (WIO) will be appointed jointly by the PoA Board Chair and the WPO. This Officer may be internal or external to PoA. The WIO will have internal independence of line management in the area affected by the wrongdoing disclosure.
The WIO is responsible for receiving whistleblower disclosures of wrongdoing and overseeing its investigation and resolution.
The WIO may consult with other officers in PoA to assist in the investigation and may seek the advice of internal or external experts as required.
The WIO must, after reasonable assessment, be satisfied that action taken in response to the investigation is appropriate to the circumstances and ensure that all investigations are carried out in line with the principle of procedural fairness.
Reporting and Investigation
Any information provided to PoA or an external body as referred to in this policy may be used in the assessment of an investigation or in ascertaining appropriate action.
When a matter of misconduct is reported, the Whistleblower should provide as much information as possible. Information such as dates, times, location, individuals involved, other witnesses, physical evidence (e.g. documents, images) and any other general information that may be helpful to assist the organisation to determine how to take appropriate action.
If PoA or the external authority to which the matter was reported determines that it should be investigated, the investigation may be conducted in line with this policy and may involve WPO, WIO and the PoA Board Chair. All investigations will be conducted in a manner that is procedurally fair, confidential, conducted without bias and in a timely manner.
At the end of an investigation, the Whisleblower will be informed of the outcome of the investigation. PoA may in certain circumstances, whether required by law or in its discretion, inform other external regulatory bodies or the relevant authorities of any contents of the investigation.
The investigation will conclude with a report from the WIO or another investigator involved in relation to matters reported externally. The report will include findings on the allegations and a summary of the evidence on which the findings were based. To the extent permitted under applicable laws, the WIO may inform the Whistleblower and/or a person against whom allegations were made, of the findings.
Whistleblower Protection
PoA is committed to protecting and respecting the rights of Whistleblowers who report wrongdoing in good faith.
PoA will take reasonable precautions to store any records relating to a report of wrongdoing securely and to restrict access to authorised persons only. Unauthorised disclosure of information that could prejudice confidentiality and identify a Whistleblower will be regarded seriously and may result in disciplinary action.
PoA strictly prohibits all forms of detrimental conduct against people who are involved in an investigation of a whistleblower disclosure in response to their involvement in that investigation.
The Whistleblower will have access to the assistance of the WPO as provided in this policy. Any concerns may be escalated by the Whistleblower directly to the PoA Board Chair if the WPO has not adequately resolved a complaint regarding detrimental conduct or this policy has not been followed in the investigation process.
PoA may not be able to provide the same practical support to non-employees or other associated parties that it provides to current employees or relationships present at the time of reporting. Therefore, the processes in this policy will be adapted and applied to the extent reasonably possible.
It is important to understand that if a person reports a matter of wrongdoing, they are not exempt from the consequences of their own misconduct.
Contact Details
PoA Board Chair: boardchair@pioneers.org.au
Whistleblower Protection Officer (WPO): wpo@pioneers.org.au