Privacy Policy

Think Human (we/us) is committed to protecting your personal information and complying with the Privacy Act 1988 (Cth) (“Privacy Act”) and Australian Privacy Principles (APPs). 

This document describes the policies and procedures that we have in place for the management and protection of personal and sensitive information that Think Human collects and holds.

The Privacy Act regulates the collection, use, disclosure, storage and security of personal information of government agencies and private organisations. The Privacy Act includes 13 binding Australian Privacy Principles (“APPs”) with which Think Human must comply in relation to its management of personal and sensitive information.

Think Human is a private limited liability company and is bound by the Privacy Act 1988 (Cth) , as a private organisation.

The Privacy Act 1988 (Cth) (“Privacy Act”) regulates the collection, use, disclosure, storage and security of personal information of government agencies and private organisations. 

What sorts of personal information does Think Human collect and hold?

Personal information is:

information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

We collect personal information from staff, contractors, partners and from the public from a wide range of areas in our own work and in work we complete for other organisations. For example, we may hold personal information in the following types of records:

  • Research data for projects involving human participants
  • Client records
  • Project files with research partners
  • Personnel records
  • Recruitment records
  • Contractor information
  • Statutory appointment information (e.g. Board members)
  • Occupational Health and Safety records
  • Rehabilitation case management files
  • Security Files
  • Subscription details (e.g. for Think Human publications)
  • Legal files

These types of files held by us from time to time may include personal information such as:

  • name, residential address, occupation and residential email and telephone contact details;
  • opinions and reactions to testing and research;
  • health information; and
  • credit card or other personal financial details (where someone has purchased a service).

The personal information on some of these files may also include sensitive information, including information about a person’s cultural background or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information or genetic information.

How does Think Human collect and hold personal information?

Where it is reasonably practicable to do so, we collect personal information directly from the person. However, on occasions, we may need to collect personal information from other sources such as public records, parents or guardians of children under the age of 18 years and third parties. When dealing with children, we seek parental consent prior to the collection of personal information, including photographs.

We may collect personal information in various ways, including via:

  • Online forms (such as subscription forms or registration forms for an event);
  • Surveys (hard copy or online);
  • Information associated with accessing and using Think Human websites;
  • Over the telephone ;
  • In person in a meeting or interview scenario;
  • Via emails or other correspondence sent to Think Human;
  • By taking photographs or videos at Think Human events;
  • Third parties, for example reports from referees of prospective employees; or
  • From publicly available information, such as interactions with Think Human via social media sites.

For what purposes does Think Human collect, hold and use personal information?

With Think Human’s extensive and diverse activities, we collect, hold and use personal information throughout Think Human for many different purposes and via different methods. We only collect personal information for purposes directly related to our functions or activities directly in engagement with Think Human or on behalf of a client we are partnering with, and only where it is necessary for or directly related to such purposes.

When we collect personal information from you for certain specific activities, where required, we will use a collection notice that deals specifically with that collection, including a description of the purposes for which we will use the personal information collected in that instance. Where relevant, our internal procedures and systems embed privacy protections to ensure we comply with our obligations under the Privacy Act.

We may use or hold personal information for the following general purposes:

  • to provide consulting, coaching and mentoring services to both public and private sector clients;
  • to manage our employees and contractors, including to consider prospective employees;
  • to undertake research and testing as part of our functions as a consultancy (such as information about individuals participating in research sessions, including health information only when relevant to the area of focus);
  • to maintain subscriber records for our publications; and
  • to promote and market our activities.

From time to time, we may need to disclose personal information to our clients or our joint venture partners or share information with contractors or agents who provide services to us, such as off-site file storage facilities and financial institutions which transmit payments on our behalf.

We will collect personal information from you for the purposes described in a collection notice and will only use or disclose your personal information for other purposes if:

  • you have consented to the other use;
  • you would reasonably expect, or have been told, that your personal information is usually passed on to other entities;
  • it is required or authorised by law;
  • it will prevent or lessen a serious threat to someone’s life, health or safety (including public health and safety);
  • required to take appropriate action in relation to suspected unlawful activity or serious misconduct;
  • required to locate a missing person; or
  • required to assert a legal or equitable claim or to conduct an alternative dispute resolution process.

Set out below is some further detail of how we may use personal information collected for certain of our main activities.

Visiting the Think Human website

When visiting www.thinkhuman.com.au a record of your visit is logged. The following information, supplied by your browser, is recorded for statistical purposes to help improve the Think Human website:

  • user’s server address (IP address)
  • user’s internet service provider (ISP)
  • user’s operating system (for example Windows, Mac etc)
  • user’s top level domain name (for example .com, .gov, .au, .uk etc)
  • date and time of the visit to the site
  • pages accessed and the documents downloaded
  • previous site visited if you visited from a hyperlink to our website via another web page
  • exit link
  • screen resolution
  • type of browser used.

No attempt will be made to identify users or their browsing activities except in the unlikely event of an investigation required by law where a law enforcement agency may exercise a warrant to inspect the Internet Service Provider’s logs.

We will not release your personal information collected via the Think Human website to any person unless the law requires or permits it or your permission is given. We provide a secure environment and a reliable system but you should be aware that there are inherent risks associated with the transmission of information via the Internet. For those who do not wish to use the Internet, we provide alternative ways of obtaining and providing information; e.g. by contacting Think Human by phone or e-mail.

Emailing Think Human

When you send an e-mail to a Think Human address ([email protected]), the content and your details, including your e-mail address, become part of our records. Your e-mail address, acquired in this way, will not be added to any mailing list unless specified in a collection statement or unless we obtain your consent.

Completing an online form

Should you decide to complete and submit an online form on any part of the Think Human website, we:

  • may record personal details provided by you such as; e-mail address, street address, telephone number, occupation, company, areas of interest etc to the extent they are relevant to the purpose for which we are collecting them.
  • will only used this information for the purpose for which it was collected.
  • will not disclose this information without your consent except where Think Human may be required by law to disclose the information.

Research activities

We may conduct research involving human participants and this research may involve the collection of personal information, including health information, genetic information, or information about a person as part of social research. The collection of such information may also have ethical approval requirements.

When dealing with personal information in a research context, we will usually de-identify that information. If personal information is not de-identified, we will deal with personal information collected in the course of research in accordance with the Privacy Act.

We may also deal with personal information of research partners or clients when providing co-design research services and service prototyping services to both public and private sector clients. This may include the following sorts of personal information:

  • Name, address, occupation and residential email and telephone contact details;
  • Opinions and reactions to testing and research; or
  • Health information.
  • Client information;
  • Credit card or other personal financial details;
  • Photographs, video and/or audio files.

If we collect your personal information as part of our research activities, we will use that information for the purposes of the specific research activity and we may also add it to a database for the purpose of contacting you about future Think Human activities, but only where you would reasonably expect this or have consented.

Think Human Enquiries service

When you contact us for general information about our activities or about our work generally, we may:

  • Log the contact (online or otherwise) in a secure database;
  • Record your name and other contact details, and information about the nature of the enquiry and response provided;
  • Seek consent to contact you to provide feedback on the service provided.
  • Not disclose the information collected without your consent except where Think Human may be required by law to disclose the information.

Direct communication from Think Human

We store the contact details of a wide range of clients and stakeholders, ranging from direct subscribers to newsletters, to business, research and community contacts. This information may be used to disseminate information and to facilitate participation in events and Think Human activities. In managing this information, we will:

  • hold all personal information in secure databases, both at onsite and offsite locations.
  • ensure that at any time, a recipient of e-mailed mass communication may ask to “unsubscribe” from our central marketing/communication database.
  • ensure that a direct link to “unsubscribe” is generally made available in mass communications from us. Alternatively, unsubscribe requests can be made directly to [email protected].

Managing our personnel and other support services functions

Think Human will collect personal information from prospective employees for the purposes of administering a recruitment process. Think Human’s employee records are subject to the Privacy Act and we use the personal information of Think Human staff for the purposes of administering their employment with us. This may include using and disclosing personal information for:

  • general management of employment;
  • performance management (misconduct, grievance, probation);
  • financial, legal, security, information technology and communications matters related to a staff member’s employment.

Engaging with the public about our services

We collect personal information in the course of promoting and marketing our activities to the public, including via the following:

  • Promotions / competitions;
  • Photographs of individuals taken at Think Human events;
  • Collecting data about the public’s opinions on design (e.g. feedback via social media);
  • Sending marketing material to clients;
  • maintaining membership or subscriber records for our publications
  • Think Human coaching and mentoring services.

Think Human contracting other service providers 

We may, from time to time, engage service providers to provide services to us. Where those services involve a service provider dealing with personal information on our behalf, we will ensure that our contract with the service provider obliges the service provider to comply with the same level privacy obligations as Think Human.

How does Think Human store personal information?

Each area of Think Human that collects personal information stores that information securely on Think Human’s IT systems. These systems are password protected and where required, only certain people are authorised to access the information. We are also required to comply with other government policies in relation to storage and security of information, including the Australian Government Policy and Risk Management Guidelines for the storage and processing of Australian Government information in outsourced or offshore ICT arrangements and the Protective Security Policy Framework, complemented by the Australian Government Information Security Manual.

We may use third parties to store some personal information on servers in Australia or overseas, but only where steps have been taken to ensure that the third parties comply with our privacy obligations.

Access to and amendment of personal information held by Think Human

We will provide you with access to your personal information that we hold, subject to any applicable exceptions under the Privacy Act, on request. We will require you to verify your identity and specify, as clearly as possible, the information that you wish to access. We will not charge you for lodging a request for access to your own personal information but may charge for reasonable administrative costs. The fee will be determined on a case-by-case basis and you will be informed beforehand of the likely cost.

Think Human employees seeking their employment details should initially do so in accordance with Think Human’s human resources processes.

If you can establish that information held by us about you is inaccurate, irrelevant, out of date, incomplete or misleading, we will take reasonable steps to amend it. If we disagree with your view about the status of this information, we will provide reasons for the refusal and record a statement in our records of your view.

Complaints

If you have a privacy related complaint about us, please contact Think Human’s Privacy Officer on 0466 544098 or [email protected].