Effective as of June 18, 2018
Blue Dragon Children’s Foundation takes privacy seriously.
We are committed to protecting the privacy of our program beneficiaries, our donors and supporters, and anyone else who interacts with us.
Blue Dragon collects, uses, and stores personal information to assist us with our work of helping those in need.
Disclosure of this information is only done under very strict limitations, and we will never sell or ‘rent out’ your information to any third party; nor do we purchase mailing lists.
This policy has been developed for our operations in Vietnam, and takes into account our interactions with other Blue Dragon Children’s Foundation charities around the world.
This policy has been developed to clarify how and why we collect and use personal information and what to do if you have any questions or complaints.
Blue Dragon collects some personal information from people who interact with us.
According to the Australian Privacy Act 1988, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.
The kind of personal information Blue Dragon collects will depend on the type of initiatives you support or enquire about. Personal information collected may include (but is not limited to):
- Your contact information – name, address, email address and telephone number;
- Your date of birth, gender, and occupation;
- Your bank account or credit card details for donations (if given and agreed to by you);
- A history of your donations or interactions with Blue Dragon;
- Certain details about your personal interests.
You may choose to remain anonymous, use a pseudonym or to not provide certain personal information.
Choosing to not share certain information with us may mean we are not able to process a receipt for your donation or provide information or other services you request, or keep you updated with Blue Dragon news.
Information collected by licenced Blue Dragon groups, such as Blue Dragon International, Blue Dragon USA, and Blue Dragon UK, may be shared with Blue Dragon Vietnam for the purpose of communicating with donors and supporters.
1) How we collect information
There are a number of ways we collect information from you, including:
- Directly from you when you provide information by telephone, in person, via our website, or on forms;
- From fundraising events you attend;
- From your online interactions with Blue Dragon’s social media;
- From a third party known to you who makes a donation or nominates you as the recipient of communication regarding that donation;
- From a third party donation platform which processes your donation on our behalf.
2) Use and disclosure of information
To carry out our work of providing assistance to children in Vietnam, your personal information may be used to:
- Process your donation and provide receipts;
- Provide you with information about how your donation is used;
- Confirm your identity when you make enquiries about your donation;
- Communicate with you about the work that Blue Dragon is undertaking;
- Address feedback or complaints you may have;
- Assist us with carrying out any other work related to the above purposes.
Sometimes we may need to share some of your personal information with external service providers whose functions may include:
- Mailing operations (see below);
- Information technology services or consultants;
- Website usage analysis;
- Payment of donations.
Third Party Donation Platforms
If you choose to use PayPal, GiveNow, GiveALittle or BT MyDonate or other third parties as a way to donate to Blue Dragon, you will provide your personal data including a credit card number, directly to them.
We obtain and store your details, excluding credit card details.
The third party’s privacy policies will apply to the information you provide. Please read their respective policies found on the their websites.
External mailing operations
If you wish to receive newsletters and other electronic updates, you can give your consent to opt-in via our website, email or other written request and you can unsubscribe from our newsletters and emails at any time (via unsubscribe links in the newsletter).
We use the services of MailChimp, an email automation platform to process our bulk electronic communications.
We take reasonable steps to ensure any external organisations we engage are contractually bound to privacy and confidentiality obligations in relation to your personal information and that personal information is only used for the specific purpose for which we provide it.
Information shared with Mailchimp only includes directly relevant personal information, and not all information we may hold in our database.
In very specific instances, we may have to disclose your personal information for a specific purpose to third parties such as:
- Relevant taxation agencies;
- Credit providers;
- Credit reporting and fraud checking organisations;
- Authorised legal representatives nominated by you;
- Our accountants, auditors and lawyers;
- Law enforcement, government or other organisations, as required by law, particularly in relation to protecting the privacy and protection of children.
For further information see Section 9. Opting out, access and correction of your personal information.
3) Job and volunteer applications
Blue Dragon keeps records of all applicants for employment and volunteer positions.
We store these files electronically and may use the information provided to contact applicants about similar positions in future.
4) Surveillance and security cameras
Some Blue Dragon buildings are equipped with surveillance and security cameras for the purpose of ensuring the safety of residents and staff, and our property.
Cameras are never used in private areas such as bedrooms or bathrooms.
Surveillance footage may only ever be reviewed with the permission of the CEO or, in their absence, the Operations Manager.
Footage is stored for a maximum of two weeks unless an incident has occurred and needs to be kept for legal reasons.
Footage from cameras is used only to review incidents such as theft or violence, and will not be shared with anybody external to the organisation other than police.
5) Beneficiary information
All of Blue Dragon’s beneficiaries, regardless of their age, have a right to privacy.
We only share information with the public when it is non-sensitive and we have the informed consent of the person, as defined by Blue Dragon’s Child Protection Policy; or we have the informed consent of their parent/guardian if they are under 18; or if the information is completely non-identifying.
Blue Dragon keeps case notes and records on paper and in electronic files.
Written notes are stored in locked rooms; electronically stored information is password protected.
We do not share beneficiary information with external agencies without the informed consent of the person, unless required to by law.
6) Storage and security of information
We hold personal information in a number of different formats including (but not limited to) software programs (located both onsite and offsite, including in the cloud), databases, filing systems and in offsite backup storage.
The following are third parties we use to store personal data:
Save and Continue Link Recovery
We sometimes use forms that are quite lengthy and therefore offer a way of saving the information you have partially input.
Save and Continue links are stored in a database. You are able to obtain a URL to view the partially completed form via a link sent to your email address you provide us. There are no cookies used for this functionality.
Links created will last 30 days. After that period, the link will no longer be accessible. The link is shareable only by you, so be wary about who you share the link with.
Protection of personal information
Blue Dragon takes all reasonable steps to protect your personal information from loss, unauthorised access, modification, disclosure or other misuse.
All information is held securely and password protected.
How long we hold and use the information after you have ceased donating or interacting with us will depend on the type of interaction you had with Blue Dragon and any requirements under law.
We will de-identify or destroy your information when we no longer need to keep it or when you instruct us to do so, in accordance with relevant government regulations.
7) Sensitive personal information
We normally do not collect any sensitive information.
However, there may be some situations where we may need to do so, for example we may require you to provide information about your criminal record if you were planning to visit, volunteer or work with the children we assist.
We could only do this with your express consent.
8) Tracking and cookies
We collect statistics on visitor traffic to our website such as length of visit and pages viewed. The information is anonymous and does not identify specific visitors.
We may track your visit to our website by using ‘cookies’.
A cookie is a text-only string of information that a website transfers to the browser’s cookie file on the hard disk of your computer or device to enhance your experience when visiting our website.
If you prefer not to allow the use of ‘cookies’, you may be able to adjust your browser to turn them off or notify you when ‘cookies’ are being used.
However, if you disable cookies, you may not be able to access certain areas or take advantage of certain features or services on our website.
9) Opting out, access and correction of your personal information
If you want to opt out of future communications, access the personal information that Blue Dragon holds about you or update or correct your personal information please contact us via email.
We will process your request within a reasonable time frame.
In some circumstances we may deny access to or refuse to change your personal information to the extent this is permitted under the Australian Privacy Principles and the rules of GDPR.
In such circumstances, we will let you know the reasons for doing so; for example, we may need to verify that any requests to delete, change or view your personal information have been made by you.
10) Requests and complaints about privacy
Please notify us at the details shown below if you have any queries, requests or complaints relating to Blue Dragon’s handling of your personal information.
11) Breaches of this policy
Any actual or potential breach of this policy will be reported by the CEO of Blue Dragon Vietnam to the Chair of Blue Dragon Children’s Foundation International (firstname.lastname@example.org).
The Chair is responsible to report this to the Office of the Australian Information Commissioner if required under Australian law at www.oaic.gov.au.
Regarding a breach of privacy relating to an EU individual, the CEO of Blue Dragon Vietnam will report the breach to the relevant GDPR Member State’s Data Protection Authority.
We may make changes to this policy from time to time without notice. Any major changes will be announced to you, the user, via our website or newsletter.
13) Further information