1. Privacy Policy Statement

1. Authentic Leaders Group (ALG) takes privacy seriously.  We are committed to providing quality services to all Authentic Leaders clients and stakeholders, whilst maintaining our obligations in respect of the responsible handling, use and storage of all Personal Information collected.

2. In this Privacy Policy references to ‘ALG’, ‘we’, ‘us’ and ‘our’ refers to Authentic Leaders Group and includes any entity carrying on business in Australia on behalf of or under the ALG group of entities. 

3. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. 

4. A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au. 

5. The purpose of this Privacy Policy is to describe how ALG processes and uses the different types of Personal Information collected about, including but not limited to, existing customers, former customers, prospective customers, suppliers, vendors, consultants, business partners, visitors and any other applicable third party (hereafter referred to as “you”). You can also find out here how to change inaccurate personal information and how to opt out of receiving communications from us.

6. The primary purpose for collecting Personal Information from you is in order for us to provide a complete service and/or product experience and to ensure that we are able to maintain a productive relationship with you.  

7. This Privacy Policy also provides information regarding how employees’ personal information and employee records are collected, used and accessed at ALG.  Please note that employee records held by ALG are exempt from the APPs.

8. To the extent that the contents of the Policy refers to obligations on ALG, they are guidelines for management or summaries of applicable legislative requirements only and are not contractual terms, conditions or representations on which a staff member may rely.
   
   
   
   

2. What is Personal Information and why do we collect it?

1. Personal information is information or an opinion that identifies an individual.  Examples of Personal information include names, addresses, email addresses, phone and facsimile numbers.

2. This information is obtained in many ways including a) If you access or register with our website or engage with us via social networking services, including by the use of cookies, which may track what you view on our website and also other websites that you visit. b) If you subscribe to any of our mailing lists. c) In connection with the supply of Services. d) If you request us to provide you with information regarding Authentic Leaders Group Services. This may include online, email, SMS, and telephone inquiries. e) Third parties we may engage to assist us in the provision of services, marketing, and advertising. f) We may also supplement the information that we collect from you (such as your email address) with additional information about you and your company obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information). This helps us update, expand and analyse our records, identify new customers, and provide products and services that may be of interest to you.. 

3. We collect your Personal Information for the primary purposes of:

   1. To perform and manage our business relationship with you, including to assist you to use our services;

   2. To inform and conduct marketing activities including to promote any other products or services, unless you tell us not to;

   3. To manage invoicing and payment systems and services;

   4. To facilitate communication between you, us and the other Authentic Leaders Group users; and

   5. For research, product development and data analysis to predict trends and identify products and services of value to participants;.  

4. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. 

5. ALG collects different types of Personal Information including, but not limited to:

   1. Your solicited and unsolicited personal contact information;

   2. Your business contact information;

   3. The types of services sought from and provided by us to you;

   4. Searches made on our websites;

   5. Enquiries made of our services;

   6. Payment information;

   7. Username and passwords for your account/s on one of our business platforms;

   8. Any form of communication made with us, whether it be via phone, online or through participation in online forums.

6. The type of Personal Information collected will depend on the nature of our engagement with you and may be collected from various sources including:

   1. from you directly;

   2. from your use of our products, including online site and computer systems; and

   3. from outside sources or third parties. 

7. When we collect Personal Information, we will, where appropriate and where possible, inform you of how and why we are collecting the information and the intended purposes for which it has been collected. 
   
   
   
   
   

3. Sensitive Information

3. Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

4. Sensitive information will be used by us only:

   1. For the primary purpose for which it was obtained;

   2. For a secondary purpose that is directly related to the primary purpose; or

   3. With your consent, or where required or authorised by law. 
      
      
      
      

4. Anonymity

1. Wherever it is lawful and practicable, persons have the option of not identifying themselves or using a pseudonym when entering into transactions with us.
   
   
   
   

5. Third Parties

1. Where reasonable and practicable to do so, we will collect your Personal Information only from you.  However, in some circumstances we may be provided with information by third parties.  In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. 
   
   
   
   

6. Disclosure of Personal Information

1. We will only use and disclose your Personal Information for the purposes which you provide it.

2. Your Personal Information may be disclosed in a number of circumstances including, but not limited to, the following:

   1. To our staff or staff of our associated entities, so that your enquiry, project, or account can be properly and adequately established, processed and handled;

   2. To Third Parties, local and international, where you consent to the use or disclosure; and

   3. Where required or authorised by law. 

3. Should your Personal Information be disclosed by us, it will be done so only in accordance with and to the extent required by the law.  When your Personal Information is disclosed by us we will, where appropriate and reasonable, inform you of how and why the Personal Information has been disclosed, to whom it has been disclosed and the type of Personal Information disclosed. 

4. By providing us with your Personal Information you are consenting to the disclosure of this Personal Information by us, for the primary purposes for which it was provided and obtained. 
   
   
   
   

7. Security of Personal Information

1. The security of your Personal Information is very important to us. 

2. Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

3. Your Personal Information may be disclosed by us to an associated international entity or international Third Party for the primary purposes for which it was collected or a secondary purpose closely connected to the primary purpose.  It is not practicable to list all the locations where the Third Party recipients of your Personal Information, may be located. If your Personal Information is disclosed to an international entity or Third Party, we will, as required by law, ensure your privacy rights are adequately protected by organisational, technical, contractual and/or other lawful means. 

4. We will take all reasonable steps necessary to protect your personally identifiable information as it is transmitted from your computer to our website and then once it is being used on one of our electronic platforms.  However, you should keep in mind that the transmission of information over the Internet is not completely secure or error-free, so please carefully consider the information you send online.

5. When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to safely destroy or permanently de-identify your Personal Information.

6. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of seven (7) years, during which time the Personal Information will continue to be protected by the principles outlined in this Privacy Policy. 
   
   
   
   

8. Marketing

1. Where we have obtained your consent to do so, or in circumstances where you would reasonably expect that your personal information would be used or disclosed for this purpose, we may contact you from time to time with marketing material about our other products or services. At any time, you may opt out of receiving this material by by email to info@authenticleaders.group. Your consent to receiving this information will remain current until you advise us otherwise.
   
   
   
   

9. ALG’s website 

1. When visiting ALG’s website, the site server makes a record of the visit and logs the following information for statistical and administrative purposes:

   1. the user’s server address – to consider the users who use the site regularly and tailor the site to their interests and requirements;

   2. the date and time of the visit to the site – this is important for identifying the website’s busy times and ensuring maintenance on the site is conducted outside these periods;

   3. pages accessed and documents downloaded – this indicates to us which pages or documents are most important to users and also helps identify important information that may be difficult to find;

   4. duration of the visit – this indicates to us how interesting and informative our site is to candidates; the type of browser used – this is important for browser specific coding;

   5. in order to optimise ALG’s web site and better understand it’s usage, we collect the visiting domain name or IP address, Computer Operating System, Browser Type and Screen Resolution.

2. A cookie is a piece of information that an Internet web site sends to your browser when you access information at that site. Cookies are either stored in memory (session cookies) or placed on your hard disk (persistent cookies). The ALG website does not use persistent cookies. Upon closing your browser the session cookie set by this website is destroyed and no Personal Information is maintained which might identify you should you visit our web site at a later date.
   
   
   
   

10. Access to your Personal Information

1. You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions.  If you wish to access your Personal Information, please contact us in writing. 

2. ALG will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information.

3. In order to protect your Personal Information, we may require identification from you before releasing the requested information.
   
   
   
   

11. Maintaining the Quality of your Personal Information

1. It is important to us that your Personal Information is up to date.  We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date.  If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you. 
   
   
   
   

12. Policy Updates

1. This Policy may change from time to time and is available on our website. 
   
   
   
   

13. Privacy Policy Complaints and Enquiries

1. If you have any queries or complaints about our Privacy Policy please contact us in your local region. 

2. If you are not satisfied after having contacted us and given us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner.
   
   
   
   

14. Employees’ personal information 

1. Importantly, the handling of employees’ personal information by ALG is exempt from the Privacy Act if it is directly related to:

   1. an employee’s current or former employment relationship;

   2. an employee record relating to the employee.

2. This is known as the “employee records exemption”.

3. The section outlines the guidelines that ALG will aim to follow when collecting, using and providing access to employees’ personal information. 

4. Definition of employee record

An employee record is a record of personal information either conventional or in electronic format relating to the employment of an employee. The record comprises information about employment and may include:

1. employee, referee and emergency contact details;

2. applications for employment and supporting documents including resumes;

3. selection committee reports;

4. employment contracts, and other records relating to terms and conditions of employment;

5. details of financial and other personal interests supplied by employees and their immediate family members for the purpose of managing perceived or potential conflicts of interest;

6. proof of Australian citizenship;

7. certified copies of any academic qualifications and/or certifications including but not limited to academic transcripts, working with children checks and police record checks;

8. records relating to salary, employment benefits and leave;

9. medical certificates or health related information supplied by an employee or their medical practitioner;

10. taxation details;

11. banking information necessary to pay salary and wages;

12. superannuation contributions;

13. details of an employee’s membership of a professional or trade association or trade union membership; 

14. information relating to employees’ training and development;

15. information about an employee’s performance and disciplinary action; 

16. leave records.

5. As outlined above, an employee record relating to an employee is, at times, exempt from the Privacy Act.

6. Collection of information

Employees’ personal information will typically only be collected for purposes necessary to the functions and activities of ALG. These include selection, employment, appraisal, discipline, remuneration of staff, and ALG administrative activities.

Employees’ personal information will only be collected by means that are permissible by law.

When ALG collects personal information from an employee, ALG will take such steps as are reasonable in the circumstances (having regard to the purposes for which the information is collected) to ensure that:

1. the information collected is directly relevant to the employment relationship, is not excessive, and is accurate, up to date and complete; and

2. the collection of the information does not intrude to an unreasonable extent on the personal affairs of the employee to whom the information relates.

Where reasonably possible, ALG will only collect personal information directly from the employee to whom the information relates. Frequently this will be collected from official ALG forms but it may also be collected from email, letters or other forms of communication. However, the collection of information may be from a third party or, in the case of a person under the age of 16, authorisation may be given by a parent or guardian of that person.

Employees’ personal information will be shared only as reasonably required and with those who need to access such information. All hard copy records will be maintained in secure areas with access limited to only those who require access.

7. Use of information 

ALG aims to only use the information for the purpose that it was collected unless:

1. the employee to whom the information relates has consented to the use of the information for another purpose;

2. the other purpose for which the information is used is directly related to the purpose for which the information was collected;

3. the use of the information for that other purpose is necessary to prevent or lessen a serious and imminent threat to the life or health of the individual to whom the information relates or of another person; or 

4. if so directed by a court of law.

In particular, ALG will use the personal information it collects about its employee to meet its obligations under the employment contract it has entered with the employee, including administering the payment of wages and to provide employee benefits.

8. Overseas disclosure

Where employees’ personal information is transferred, processed or used overseas, ALG will make every reasonable effort to ensure that information is kept secure and will take reasonable steps to protect it from misuse, loss, interference, unauthorised access, modification or disclosure. 

While reasonable steps are taken to ensure overseas recipients of employees’ personal information are subject to and comply with Australian Privacy Laws, employees acknowledge that these recipients may not be accountable under the Privacy Act and by receiving and acknowledging this policy employees consent to their payroll information being used overseas on this basis.

9. Storage of information 

ALG will typically only store employees’ personal and sensitive data as required for their employment in line with record keeping minimum requirements as set out by government standards. To ensure the security of data, ALG has implemented high quality security standards across its business, including but not limited to:

1. High level security protection software;

2. A mail filtering software which blocks potential threats;

3. Anti-ransomware, anti-virus, anti-spyware measures;

4. Limitations to levels of access of information by our internal employees who manage or use employee’s data.

10. Access to information 

Current and previous employees may request to access their employee records held by ALG.

Access to employee personal information includes an opportunity for the employee to inspect records, take notes or obtain a photocopy or computer printout however, this must be in the presence of a representative from Human Resources.

ALG will respond to an employee’s written and signed request for their employee records as soon as practicable.

The time taken to respond to an employee’s request for access may be influenced by various factors. These may include the method of communication, the type or amount of personal information requested, how the personal information is held, if a third party needs to be consulted and how it is to be provided to the individual making the request.

11. Access for the individual 

ALG may provide an employee access to their personal employee record upon written request by the employee if it is appropriate to do so, however will not be obliged to do so in circumstances, including (but not limited to) where:

1. in the case of employees’ personal information, other than health information, providing access would pose a serious and imminent threat to the life or health of any staff member;

2. providing access would have an unreasonable impact upon the privacy of other staff members;

3. the request for access is frivolous;

4. providing access would be likely to prejudice the outcome of an internal investigation;

5. providing access would be likely to prejudice the outcome of a matter before the Fair Work Commission or Court or incite the employee to commence proceedings;

6. providing access would reveal the intentions of the organisation in relation to negotiations with the employee in such a way as to prejudice those negotiations;

7. providing access would be likely to prejudice an investigation of possible unlawful activity; 

8. denying access is required or authorised by or under law.

12. Access for others 

ALG will not disclose employees’ personal information to anyone or any organisation, unless:

1. the disclosure is related to the purpose for which the information was collected;

2. the employee concerned was reasonably likely to have been aware, or had been notified, that the employee personal information is usually disclosed to the person or agency;

3. the disclosure is necessary to prevent or lessen a serious and imminent threat to life or health of any person;

4. in relation to some investigations and law enforcement process; and 

5. where legislation recognises lawful access by some government agencies.

15. Breaches

1. This Privacy Policy is designed to promote and enhance the confidentiality in the workplace. A failure to comply with this Privacy Policy will be viewed seriously and may result in disciplinary action for staff of ALG, up to and including dismissal.

2. Staff must report breaches of this Privacy Policy to their manager or another appropriate senior manager.

3. ALG will use its utmost endeavours to protect staff who, in good faith and with good grounds, report breaches of the Privacy Policy.

4. The consequences of a breach of this Privacy Policy will vary depending on the type and seriousness of the breach and will be at the discretion of ALG. Depending on the circumstances, the following may take place, including but not limited to: disciplinary action including counselling, a formal written warning or the termination of employment.
   
   
   
   

16. Miscellaneous

1. In this policy “personal information” has the same meaning as under the Privacy Act. Further, “employees’ personal information” has the same meaning as “employee record” under the Privacy Act.

2. This policy is effective from 8/07/2024. We may change this policy from time to time. Although we intend to observe this Privacy Policy at all times, it is not legally binding on ALG in any way. From time to time we may regard it as necessary or desirable to act outside the policy. ALG may do so, subject only to any other applicable contractual rights you have and any statutory rights you have under the Privacy Act or other applicable legislation.