Privacy Policy

The Keeping Place is committed to respecting the privacy and confidentiality of its users. This Policy sets out how The Keeping Place collects, uses, stores and protects the personal information and confidentiality of members and users of The Keeping Place software application.

Contents

Purpose and scope

The Keeping Place is committed to protecting and upholding the rights of customers, clients, staff and members to privacy and confidentiality in the way The Keeping Place collects, stores and uses information about them, their needs and the services The Keeping Place provides.

This Privacy Policy applies to all Personal Information collected by The Keeping Place via The Keeping Place software application and website (www.thekeepingplace.com).

This Policy sets out how The Keeping Place manages your Personal Information and Confidential Information. It also details the responsibilities of The Keeping Place staff, contractors, volunteers and third-party providers who come into contact with Personal Information and Confidential Information.

By providing Personal Information or Confidential Information to The Keeping Place and using The Keeping Place software application, you are agreeing to be bound by this Policy and agree that you have had sufficient opportunity to read and understand them.

The Keeping Place may update this Policy from time-to-time. Any changes will take effect upon first publication.

Definitions

‘Administrator’ means the person(s) designation by the KP Partner to administer the the Keeping Place Site to End Users on the KP Partners behalf. Administrators may be able to access, disclose, restrict or remove Customer Data in or from End User accounts. Administrators may also have the ability to monitor, restrict or terminate access to End User accounts.

‘Confidential Information’ is information about individuals or organisations that must be kept secret. The most important factor to consider when determining whether information is confidential is whether the information can be accessed by the public. Confidential Information includes but is not limited to Personal Information, the data of KP Stakeholders or information about The Keeping Place, the KP Members, End Users or other stakeholders, including business, organisational and operational information.

‘Customer Data’ means stored data, account data, documents, multi-media, spatial file and other data submitted to The Keeping Place software application by a KP Partner or its End Users.

‘End User’ means users of a KP Partners’ Keeping Place Site and may include members, employees and consultants affiliated with a KP Partner.

‘Keeping Place Site’ means the domain established and configured for a KP Partner on The Keeping Place software application by The Keeping Place.

‘KP Members’ means all KP Partners, individuals and organisations named on The Keeping Place register of owner-members, who are entitled to attend meetings, speak and vote.

‘KP Partners’ means those Aboriginal and Torres Strait Islander organisations and groups, including Prescribed Bodies Corporate, Aboriginal Land Corporations, Traditional Owner Groups and other stakeholders who are owner-members of The Keeping Place and who control and manage a Keeping Place Site on The Keeping Place software application.

‘KP Stakeholders or You’ means The Keeping Place personnel, the KP Partners and third-party service providers (including employees, members and affiliates of these organisations), End Users, customers, clients and the wider community with an interest in The Keeping Place.

‘Personal Information’ is information or an opinion about an identified individual, or an individual who is reasonably identifiable. For example, this may include your name, age, date of birth, gender, contact details and postcode. It may also include financial information, including your credit card information, or a photograph of you. Personal Information does not include anonymous, aggregated or de-identified information or information about companies which does not identify individuals.

‘Sensitive Information’ is a category of Personal Information and may include information about racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal record, membership of a professional, trade association or trade union or sexual preferences.

‘The Keeping Place or We or Us’ means The Place of Keeping Ltd (ABN 12 633 397 172), established to manage all business, technology, financial and strategic matters and activities associated with The Keeping Place software application, website, mobile applications, social media sites and associated products and services.

‘The Keeping Place personnel’ means collectively, directors, officers, employees, contractors, agents and third-party suppliers, including IT service providers and their personnel and subcontractors, of The Keeping Place.

The Keeping Place software application’ means the cloud-based software application procured, developed, supported and operated by The Keeping Place for the purpose of assisting with the management of cultural heritage, land management and native title related information.

Personal Information we collect

Personal Information

The Keeping Place will only collect and use Personal Information where it is reasonably necessary to deliver the services of The Keeping Place software application and to otherwise conduct the functions and activities of The Keeping Place, or as required by law.

We may collect the following types of Personal Information from KP Stakeholders including:

  • your name;
  • your address, email, telephone and emergency contact details;
  • your gender, age and date of birth;
  • information relating to services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your inquiries;
  • information relating to you that you provide to us directly or indirectly through your contact with us or your use of our website, social media sites, mobile applications, electronic media or other related resources or sites;
  • information to enhance your experience of The Keeping Place application, our products and services, activities, events, website, social media sites, mobile applications or other related resources or sites;
  • your IP address, web log and related domain, browser, computer and connection information, statistics on page views, traffic to and from sites, ad data, device ID, device type, geo-location information;
  • your employment and governance history; and
  • any other Personal Information relevant to your relationship with us.

Sensitive Information

We may also collect Sensitive Information where it is reasonably necessary to fulfil one or more of our functions and activities, for instance ensuring The Keeping Place software application is managed in accordance with The Keeping Place Cultural Protocols.

Sensitive Information is a type of Personal Information which relates to, for example, a person’s race or ethnicity, political opinions or religious beliefs. We may collect the following types of Sensitive Information including:

  • your language group, apical group, ceremonial status; or
  • your membership of a trade union.

The Keeping Place will only collect Sensitive Information with your consent or as required by law.

How we collect Personal Information

We collect Personal Information from you in a variety of ways including:

  • from KP Partners;
  • when you apply to become a KP Member;
  • when you register as a User of The Keeping Place software application, website, mobile applications or social media sites;
  • in face to face meetings;
  • in telephone conversations;
  • in postal, phone, facsimile, email, electronic, mobile application or social media correspondence;
  • in forms, surveys, feedback or questionnaires filled out by you;
  • in Customer Data, data, materials and information contributed by a KP Partner or End User to The Keeping Place software application;
  • when you request information from us;
  • when you use or interact with The Keeping Place software application, our website, social media sites, mobile applications or other related resources or sites, including by way of a log of your interactions including your search questions, any third-party website links and system site activity through the use of cookies;
  • when we engage with you in the course of our functions and activities.

We may also collect Personal Information from recruitment consultants, your previous employers and other third parties when you apply for a position with The Keeping Place (including your name, contact details, work history and relevant records checks).

How we disclose Personal Information

The Keeping Place does not routinely disclose Personal Information to third parties unless:

  • you give your consent;
  • the disclosure is directly related to the primary purpose of collection, for example, it is necessary to provide you with access to The Keeping Place application or is for a function or activity of The Keeping Place for which you are involved;
  • it is necessary for maintenance of or is related to a person’s membership, employment or other position within The Keeping Place;
  • it is a requirement of our funders, grant or service providers, in which case only basic Personal Information will be shared to the extent necessary;
  • it is necessary to prevent or respond to technical or service issues with The Keeping Place software application;
  • to protect the rights, property or personal safety of a person or any member of the public or the interests of The Keeping Place;
  • the use or disclosure is or otherwise required or permitted by laws, regulations or professional standards.

We may also share non-personal, de-identified and aggregated information for research, funding, sponsorship, tender or promotional purposes.

We may disclose Personal Information, including to third party suppliers, cloud-based and other service providers and website hosts located outside of Australia, for example, in the United States. We will take all reasonable steps to ensure that any overseas recipient deals with such Personal Information in a way that is consistent with the Privacy Act 1988 (Cth).

KP Partner responsibilities

KP Partners may specify End Users as Administrators of their Keeping Place Site. KP Partners are responsible for maintaining the confidentiality of passwords and access to their Administrator accounts. The Keeping Place’s responsibilities do not extend to the internal management or administration of a Keeping Place Site.

KP Partners are required to prevent unauthorised use of their Keeping Place Site by its End Users and may terminate any unauthorised use or access to their Keeping Place Site. End User accounts may only be provisioned, registered and used by a single End User.

The Keeping Place software application is not intended for End Users under the age of 18 years of age. KP Partners are required to ensure that it does not allow any person under the age of 18 years of age to be registered as an End User and will notify The Keeping Place promptly of any unauthorised access to The Keeping Place software application.

Security

We will take all reasonable steps to protect your Personal Information from misuse, interference and loss, unauthorised access, modification or disclosure to at least the same level we protect the information of The Keeping Place, whether held electronically or otherwise.

Links

The Keeping Place software application, website, mobile applications and social media sites may contain links to sites and embedded content owned and operated by third parties. We do not endorse those linked sites and are not responsible for the privacy practices or policies of those sites, or any content on those sites. We encourage you to review each site’s privacy policy, especially if you intend to disclose any Personal Information via that site.

Access and correction

We will endeavour to keep your Personal Information accurate and up-to-date. You may request access to the Personal Information we hold about you. We will provide access to this information where reasonable and practical to do so, and in accordance with the Privacy Act 1988 (Cth).

Anonymity

Your provision of Personal Information to use is optional, however, because of the nature of the activities of The Keeping Place, it is generally impractical for us to deal with you on an anonymous basis or through the use of a pseudonym, although sometimes this may be possible (e.g. when we receive User feedback).

Confidentiality

Duties of The Keeping Place personnel

The Keeping Place uses best endeavours to keep Confidential Information in confidence.

The Keeping Place personnel will protect and uphold the confidentiality of information disclosed to them in the course of their work.

The Keeping Place personnel will:

  • protect the Confidential Information of the KP Stakeholders;
  • only access and use information obtained through their involvement, employment, placement or service provision to The Keeping Place for the purposes of carrying out their duties and obligations;
  • not disclose, copy, release, sell, alter or destroy an any Confidential Information of the KP Stakeholders without the written consent of the relevant KP Stakeholder unless it is part of their duties or an authorised work practice, and if so, follow the correct procedures;
  • never disclose End User or KP Partner passwords to The Keeping Place software application unless authorised to do so by the particular End User or representative of the KP Partner;
  • within 72 hours, report any activities that they suspect may compromise the confidentiality and integrity of Confidential Information.

These obligations will continue until the Confidential Information is in the public domain.

Permitted disclosure

The Keeping Place may disclose Confidential Information to The Keeping Place personnel or KP Partners, as required:

  • on a need-to-know basis for the purposes of carrying out the functions and activities of The Keeping Place; and
  • once the personnel or KP Partner have been directed to keep confidential all Confidential Information to be disclosed.

The Keeping Place may be required by law to disclose Confidential Information and will:

  • notify the discloser of the Confidential Information of the requirement of disclosure;
  • endeavour to disclose no more than the minimum amount of Confidential Information required to satisfy such law; and
  • exhaust all reasonable steps to maintain such Confidential Information in confidence.

Feedback

The Keeping Place welcomes feedback in relation to the operation of the principles in this Privacy Policy. The Keeping Place will respond to any inquiries, feedback, complaints or disputes in a timely, transparent and respectful way in accordance with The Keeping Place Feedback, Complaints and Dispute Resolution Guidelines.

If you have any inquiries, feedback or complaints concerning your privacy or Customer Data, please contact The Keeping Place:

The Keeping Place

Level 1, 191 St Georges Terrace, Perth

Email: info@thekeepingplace.com