top of page

Privacy Policy

Policy last updated: 16 November 2023

1               Purpose and nature

Community Security Group (VIC) Limited (ACN 113 749 769) (CSG) recognises the importance of your privacy.  This Privacy Policy explains how CSG intends to collect, store, use, disclose, protect and otherwise handle your personal information having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by CSG or any of its respective related entities, subsidiaries, employees or volunteers, to you as to the manner in which CSG will or may collect, store, use, disclose, protect or otherwise handle your personal information.  Some matters are beyond the control of CSG, such as third party malicious or criminal attacks.

CSG may allow its respective related entities, subsidiaries, employees and volunteers to use and process your personal information in the same way and to the same extent that CSG is permitted to under this Privacy Policy.  These related entities, employees and volunteers comply with the same obligations that CSG has to protect your personal information under this Privacy Policy.

2               What is personal information?

Personal information is information or an opinion about you, whether true or not and whether recorded in a material form or not, from which you can be reasonably identified.

3               Why does CSG collect personal information?

CSG collects personal information for the following primary purposes:

(a)            to build critical incident management capability within community organisations to prepare for specific risks they may face;

(b)            to provide expertise to individual community organisations to design critical incident plans;

(c)            to provide crisis training and conduct trial scenarios with organisations to prepare for crisis events;

(d)            to help organisations put into action their critical incident plan in the case of a crisis;

(e)            to assist with wider community communications in the event of a crisis or emergency event;

 (f)            to observe external environments for potential crises and initiate responses as needed;

(g)            to provide training to our volunteers;

(h)            to provide training and support to youth groups, sporting clubs and youth movements;

 (i)            to provide mentoring, learning experiences and inspirational events to develop leadership skills for women in the Jewish community;

 (j)            to otherwise provide support, guidance and direction to organisations and facilities in the Jewish community;

(k)            to process financial donations, including when using third party donation platforms and services that CSG has engaged to provide this service

on its behalf;

 (l)            to provide emergency support and assistance in the event of a security related incident or medical emergency;

(m)           to conduct security assessments in respect of:

I.      private and public functions;

II.     individuals seeking to attend a CSG community installation, which includes synagogues, schools and community functions;

III.    prospective employees and contractors seeking to work at a CSG community installation; and

IV.    prospective volunteers seeking to join CSG;

(n)           to facilitate volunteer opportunities between volunteers and third party community organisations that participate in the Volunteer Surge

Program operated by Jewish Community Crisis Management, a division of CSG (Surge Program).

(o)           as set out in further detail in the Surge Program Volunteer Terms of Use (which is accessible at this link: https://www.jccm.org.au/surge-terms-

volunteers), to determine whether it will permit a person to participate in the Surge Program as a volunteer;

(p)           to communicate with you about CSG; and

(q)           to process general enquiries.

CSG may also use your personal information for secondary purposes closely related to these primary purposes.

If CSG does not collect your personal information, it may not be able to provide its services to you or third parties.

4               What personal information does CSG collect?

The types of personal information collected by CSG may include:

(a)            names;

(b)            dates of birth;

(c)            gender and gender identification;

(d)            contact details (including address, email address, telephone number(s), residential address, emergency contact information, and other

contact details);

(e)            profession or occupation details;

(f)             membership of certain organisations, such as youth groups or other community groups;

(g)            your personal health information, such as pre-existing medical conditions, to the extent this is required;

(h)            credit card details;

(i)             bank account details;

(j)             tax file numbers;

(k)            copies of identification documents issued by governments and other regulatory bodies (including passport, driver’s licence, working with

children check, private security individual licence, and other forms of identification);

(l)            the performance of a Nationally Coordinated Criminal History Check by the Australian Criminal Intelligence Commission, commonly called a

police check, to produce a certificate that shows police information including any disclosable court outcomes and pending charges relating to you in Australia, or such other similar checks; and

(m)           any other personal information you provide to us.

 

4.1    Sensitive Information

The personal information collected by CSG may include sensitive information, which is defined in the Privacy Act as information or an opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.  CSG will only use sensitive information:

(a)            for the primary purpose for which it was obtained;

(b)            for a secondary purpose that is directly related to the primary purpose;

(c)            with your consent; or

(d)            where required or authorised by law.

5               How does CSG collect your personal information?

CSG will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner.

5.1    Collecting information from you

If it is reasonable and practical to do so, CSG will collect personal information directly from you.

CSG may collect your personal information directly from you when you:

(a)            report a security incident or medical emergency;

(b)            submit an enquiry to CSG’s Crisis and Emergency Department;

(c)            make a financial donation, including when using third-party donation platforms and services that CSG has engaged to provide this service on

its behalf;

(d)            create an individual fundraising campaign for the benefit of CSG through the third-party donation platform;

(e)            register a private or public function for the purposes of security assessment;

(f)             attend or propose to attend an event that CSG is involved in or has organised;

(g)            are contracted or employed or propose to be contracted or employed at an event that CSG is involved in or has organised;

(h)            volunteer or propose to volunteer with a third party community organisation by way of the Surge Program, including by registering as a user

on a CSG website that is developed and maintained for the Surge Program;

(i)             are a contact person nominated by a community organisation that participates or proposes to participate in the Surge Program;

(j)             volunteer or propose to volunteer with CSG; or

(k)            submit a general enquiry.

When you provide CSG with personal information, you consent to the use, disclosure and handling of your personal information and sensitive information (to the extent it is collected) in accordance with this Privacy Policy and any subsequent amendments (see clause 15).

 

5.2    Collecting information from third parties

CSG may also collect information about you from other people (e.g. a third party administrator, personal referees or independent sources), including but not limited to when a third party notifies CSG of a security incident or medical emergency that involves you.  However, CSG will only do so where it is not reasonable or practicable to collect the information from you directly.  Where CSG has collected your information from a third party, such personal information will be held, used and disclosed by CSG in accordance with this Privacy Policy and any subsequent amendments (see clause 15).

 

5.3    Collecting information from open-source websites

Where required, CSG may also collect information about you from open-source websites (including social media) as part of its routine background check process to ascertain whether you are eligible to:

(a)            attend a CSG community installation;

(b)            be employed or contracted to work at a CSG community installation; or

(c)            volunteer for CSG.

This process may involve cross-checking and, if necessary, updating the information already provided by you.  Where CSG has collected your information from an open-source website, such personal information will be held, used and disclosed by CSG in accordance with this Privacy Policy and any subsequent amendments (see clause 15).

 

5.4    Collecting information from visits to CSG’s website

CSG may also collect information based on how you use its websites (including the Surge Program website), including through 'cookies', web beacons and other similar technologies.

Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable CSG’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).

We use cookies to provide you with a more consistent experience across our services.  No attempt is made by CSG to use Cookie Information to personally identify you.  However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser.  Please note that some parts of CSG’s website may not function fully for users that disable cookies.

 

5.5    Unsolicited information

If CSG receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, CSG will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.

6               How does CSG hold your personal information?

The security of your personal information is important to CSG.  Accordingly, CSG takes reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure, whether the information is stored in physical or electronic form.  These steps include the implementation of the following safeguards:

(a)            use of encrypted HTTPS for all communications;

(b)            storage of all data on a password-controlled database that has no open connection to the internet and is regularly reviewed for vulnerabilities;

(c)            password protection and two-factor authentication for back-end administrations;

(d)            staff training;

(e)            system firewalls;

(f)             internal information security policies; and

(g)            frequent consultation with cyber security experts.

CSG will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.

 

6.1    Security breach procedures

CSG’s data security practices have been adopted with a view to protecting the data held by CSG.  Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums.  Accordingly, CSG cannot guarantee any transmission will be completely secure.

7               How does CSG use your personal information?

CSG may hold, use or disclose your personal information so that it can provide its services to you, including emergency support in the event of a security related incident or medical emergency, and also provide emergency warnings and alerts to you.

CSG may also hold, use or disclose your personal information to:

(a)            provide training, resources, support and other assistance in line with the purpose for which its collects your personal information;

(b)            if you volunteer or propose to volunteer by way of the Surge Program, for the purposes set out in the Volunteer Terms of Use, which is

accessible at this link: [insert];

(c)            provide other emergency services, including the police, fire or ambulance services, with your personal information in the event of a security

incident or medical emergency;

(d)            contact you about a reported medical event or security incident to request additional information;

(e)            log any reported incidents;

(f)             compile statistics and reports about logged incidents;

(g)            consider any concern or complaint that you raise against CSG or to manage any legal action between you and CSG;

(h)            prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or

(i)             comply with any relevant laws, regulations, codes of practice and court orders.

In addition, where CSG forms a reasonable belief based on the personal information you provide that disclosure of your information to an enforcement body, such as Victoria Police or the Australian Federal Police, is reasonably necessary for any enforcement related activity by that enforcement body, including the conduct of surveillance, intelligence gathering or monitoring activities, then CSG will disclose your information to such enforcement bodies accordingly.

7.1    Direct Marketing

CSG may also use your personal information to identify and promote products or services that may be of interest to you. For example, if you have previously donated to CSG, we may contact you about future donation opportunities.

At any time you may opt out of receiving direct marketing communications from CSG.  To do so, you may contact CSG using the contact details set out in clause 0.  Unless and until you opt out, your consent to receive direct marketing communications from CSG and to the handling of your personal information for this purpose will continue.

8               How is personal information disclosed to others?

CSG does not sell, rent or trade personal information to or with third parties.

CSG may disclose your personal information to third parties in limited circumstances, including:

(a)            to other government authorities or agencies when required or requested to do so;

(b)            to third party service providers (such as data storage providers and service providers engaged to process financial donations);

(c)            to the Council for Jewish Community Security for the purpose of receiving financial donations on behalf of CSG; and

(d)            if you participate or propose to participate in the Surge Program:

I.      as a volunteer, to a:

  1. personal referee for the purpose of your Assessment;

  2. third party community organisation that participates in the Surge Program for the purpose of facilitating a volunteering opportunity;

II.     as a contact person nominated by a third party community organisation that participates or proposes to participate in the Surge

Program, to a volunteer participating in the Surge Program for the purpose of facilitating a volunteering opportunity.

CSG is not responsible for the privacy practices applying in respect of the third parties listed above.

 

7.1    Third party links

CSG’s website may contain certain links to other websites.  CSG does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.

 

9               How you may access or correct your personal information

You may contact CSG to request access to your personal information it holds about you at any time.  You may also ask CSG to correct information about you that you may believe is inaccurate, incomplete or out of date.

Please contact CSG using the contact details set out in clause 14CSG will need to verify your identity before giving you access to, or correcting, your personal information.  CSG will respond to the request within 14 days.  There is no charge to make a request, however, CSG may charge a reasonable fee to cover the administrative costs of retrieving your personal information.

In certain circumstances, CSG may refuse, or be unable, to correct or provide you with access to your personal information.  In these circumstances, CSG will write to you to explain the reasons why this is the case.

10              How you may complain if you have concerns about how CSG has managed your personal information

If you have a complaint related to how CSG has managed your personal information, please contact CSG using the contact details set out in clause 14.  CSG may ask you to place your concerns in writing so that compliance staff from CSG can fully understand and investigate your complaint.  CSG will need to verify your identity before responding to your complaint.

CSG will provide you with an estimated response timeframe in relation to your complaint.  In any event, CSG will endeavour to respond to your complaint within 14 days.

If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au to have your complaint heard and determined.

11              How to contact us

If you have any questions about this Privacy Policy or CSG’s management of your personal information, please contact CSG on:

Attention:          Privacy Officer

Tel:                   03 9519 8600

Email:              admin@csgvic.com.au

Mail:                 306 Hawthorn Rd, Caulfield VIC  3162

12              Changes to CSG’s Privacy Policy and information handling practices

This Privacy Policy is subject to change at any time so we encourage you to review this Privacy Policy at regular intervals.  If CSG changes this Privacy Policy, an updated version will be posted on CSG’s website.  By continuing to use CSG’s services after that time, you will be deemed to have accepted any changes to CSG’s Privacy Policy.

bottom of page