Privacy Policy

Your privacy is important

This statement outlines LCP Global’s policy on how we use and manage personal information provided to or collected by it.

LCP Global is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act and is compliant with the Privacy Amendment (Enhancing Privacy Protection) Act 2012. In relation to health records, LCP Global is also bound by the Victorian Health Privacy Principles which are contained in the Health Records Act 2001 (and other state legislation).

LCP Global may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to LCP Global operations and practices and to make sure it remains appropriate to the changing LCP Global environment.

What kind of personal information does LCP Global collect and how is it collected?

The type of information LCP Global collects and holds includes (but is not limited to) personal information, including sensitive information, about:

  • you before, during and after your use of the Leadership Capacity Program;
  • your employer;
  • job applicants, staff members, volunteers and contractors; and
  • other people who come into contact with LCP Global.

Personal Information you provide:

LCP Global will generally collect personal information held about an individual via use of the Leadership Capacity Program. On occasions, people other than you may provide personal information – for instance, your employer. You do have the right to seek to deal with us anonymously or using a pseudonym, but in almost every circumstance it will not be practicable for us to deal with you or provide any services (including the leadership journal) to you except for the most general responses to general enquiries, unless you identify yourself.

Personal Information provided by other people:

In some circumstances LCP Global may be provided with personal information about an individual from a third party, for example, a report provided by a medical professional or a reference from another organization.

In relation to employee records:

Under the Privacy Act, the Australian Privacy Principles do not apply to an employee record. As a result, this Privacy Policy does not apply to LCP Global’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between LCP Global and employee. However, LCP Global must provide access and ensure compliance with the Health Privacy Principles under the Victorian Health Records Act 2001 and other state legislation.

How will LCP Global use the personal information you provide?

LCP Global will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which you have consented.

Before any of your personal information is used for reporting to your corporate employer or for leadership research, it will be de-identified and edited to ensure your identity cannot be directly or indirectly established at any time.

Personal information you provide to us during the completion of the Leadership Capacity Program, will be shared with your nominated coach for the purposes of leadership coaching. Coaches are subject to the same privacy policy as well as strict confidentiality requirements.

Job applicants, staff members and contractors:

In relation to personal information of job applicants, staff members and contractors, LCP Global’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be.

The purposes for which LCP Global uses personal information of job applicants, staff members and contractors include:

  • in administering the individual’s employment or contract, as the case may be;
  • for insurance purposes;
  • engaging in marketing forLCP Global;
  • to satisfy LCP Global’s legal obligations.

Where LCP Global receives unsolicited job applications these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.

Marketing

In relation to direct marketing, LCP Global will use your personal information for direct marketing where you have provided that information, and you are likely to expect direct marketing, then you will be sent direct marketing containing an opt out. If we use your personal information obtained from elsewhere, we will still send you direct marketing information where you have consented and which will also contain an opt out. We will always obtain your consent to use sensitive information as the basis for any of our direct marketing. We never sell or distribute your personal information to direct marketing companies.

Who might LCP Global disclose personal information to?

LCP Global may disclose personal information, including sensitive information, held about an individual to:

  • government departments;
  • people providing services to LCP Global, including coaches;
  • recipients of LCP Global publications, like newsletters and magazines; and
  • anyone you authorize LCP Global to disclose information to.

Sending information overseas:

LCP Global will not send personal information about an individual outside Australia without:

  • obtaining the consent of the individual (in some cases this consent will be implied); or
  • otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.

We do use overseas providers of IT services including servers and cloud services.

How does LCP Global treat sensitive information?

In referring to ‘sensitive information’, LCP Global means:

“information relating to a person’s racial ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record, that is also personal information; and health information about an individual”.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.

Management and security of personal information

LCP Global has in place steps to protect the personal information LCP Global holds from misuse, loss, unauthorized access, modification, interference or disclosure by use of various methods including locked storage of paper records and passworded access rights to computerized records.

When you use our website, having your cookies enabled will allow us to maintain the continuity of your browsing session and remember your details when you return.

Updating personal information

LCP Global endeavors to ensure that the personal information, it holds, is accurate, complete and up-to-date. A person may seek to update their personal information held by LCP Global by contacting the Privacy Officer of LCP Global at any time (admin@lcp-global.com).

The Australian Privacy Principles and the Health Privacy Principles require LCP Global not to store personal information longer than necessary. In particular, the Health Privacy Principles impose certain obligations about the length of time health records must be stored.

Under the Commonwealth Privacy Act and the Health Records Act, an individual has the right to obtain access to any personal information which LCP Global holds about them and to advise LCP Global of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation.

To make a request to access any information LCP Global holds about you, please contact the Privacy Officer in writing.

LCP Global may require you to verify your identity and specify what information you require. Although no fee will be charged for accessing your personal information or making a correction, LCP Global may charge a fee to retrieve and copy any material. If the information sought is extensive, LCP Global will advise the likely cost in advance.

How long will LCP Global keep my information?

Under our destruction and de-identification policies, your personal information, that is no longer required, will be de-identified or destroyed. In many circumstances, however it will be kept for statistical, research and marketing purposes as you will have consented to that in writing with us.

Enquiries and privacy complaints

If you would like further information about the way LCP Global manages the personal information it holds, please contact the Privacy Officer. If you have any concerns, complaints or you think there has been a breach of privacy, then also please contact the Privacy Officer, who will first deal with you usually over the phone. If we then have not dealt satisfactorily with your concerns we will meet with you to discuss further. If you are not satisfied with our response to your complaint within 30 days from this meeting then you can refer your complaint to the Office of the Australian Information Commissioner via:

email: enquiries@oaic.gov.au
tel: 1300 363 992
fax: +61 2 9284 9666
website: https://forms.business.gov.au/aba/oaic/privacy-complaint-/

—October 2014