Data Privacy & Storage Policy
This policy describes how this personal information must be collected, handled and stored.
1. Key details
Policy prepared by: Anders Hofstee
Approved by management on: 1 July 2019
Policy became operational on: 1 July 2019
Next review date: 1 July 2024
2. Introduction
The purpose of this document is to articulate Catalpa's policy for data collection and retention, and to ensure that any collected information that is done so lawfully and inline with our organisation's purpose. This policy describes how this personal information must be collected, handled and stored.
Catalpa will always take into account local contexts and regulations with regards to data privacy, security, storage and retention. Where these regulations are less developed, Catalpa will maintain compliance Australian standards and best practice.
Catalpa also needs to take into account other government regulations with regards to data privacy, security, storage and retention. Where these regulations are weaker we always maintain compliance to the Data Protection Act 1998, and this policy.
Catalpa often needs to gather and use certain information about individuals as required by its projects. Personal or Sensitive Information will only be collected and stored if absolutely necessary and directly related to program outcomes. These may include project data on beneficiaries, partners, program contacts, employees and other people that we have a relationship with or we may need to contact.
Catalpa is committed to keeping information collected through its services and applications safe and secure. Catalpa will never rent or sell data or permit advertising.
3. Why this policy exists
This data protection policy ensures Catalpa:
Complies with data protection law and follows best practice
Protects the rights of staff, customers, beneficiaries, and partners
Is open about how it stores, processes, and retains individuals’ data
Protects itself from the risks of a data breach and articulates the response if one should occur.
4. Data protection law
Australia’s Privacy Act 1998 describes how organisations — including Catalpa — must collect, handle and store personal information. Personal information being information about an identified individual, or an individual who is reasonably identifiable.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Privacy Act is underpinned by thirteen important principles:
Open and transparent management of personal information
Anonymity and pseudonymity
Collection of solicited personal information
Dealing with unsolicited personal information
Notification of the collection of personal information
Use or disclosure of personal information
Direct marketing
Cross-border disclosure of personal information
Adoption, use or disclosure of government related identifiers
Quality of personal information
Security of personal information
Access to personal information
Correction of personal information
5. People, risks and responsibilities
5.1 Policy scope
This policy applies to:
The head office of Catalpa
All branches of Catalpa
All staff and volunteers of Catalpa
All contractors, suppliers and other people working on behalf of Catalpa
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Privacy Act 1988.
5.2 Data protection risks
This policy helps to protect Catalpa from some very real data security risks, including:
Breaches of confidentiality. For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
5.3 Responsibilities
The Data Security Team is ultimately responsible for ensuring that Catalpa meets its legal obligations.
The Director & Co-Founder, Anders Hofstee, is responsible for:
Keeping the board updated about data protection responsibilities, risks and issues.
Reviewing all data protection procedures and related policies, in line with an agreed schedule.
Arranging data protection training and advice for the people covered by this policy.
Handling data protection questions from staff and anyone else covered by this policy.
Dealing with requests from individuals to see the data Catalpa holds about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The Senior Technical Engineer, Peter Coward, is responsible for:
Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The Communications & Storytelling Lead is responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
6. General staff guidelines
The only people able to access data covered by this policy should be those who need it for their work.
Data should not be shared informally. When access to confidential information is required, employees can request it from their managers.
Catalpa will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorised people, either within the organisation or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
Employees should request help from their manager or Catalpa’s Data Security Team, if they are unsure about any aspect of data protection.
7. Data Security
Catalpa’s security protocols are used across data collection, transmission, and storage to protect against unauthorised access and accidental destruction and modification of programme data.
Data is protected through strong encryption whenever possible.
Public key encryption is favored over passwords, both should be updated regularly and never shared between employees.
If data is stored on removable media, these should be kept locked away securely when not being used.
Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
All data transmissions should be conducted through means of end-to-end encryption.
Servers containing personal data should be sited in a secure location with restricted physical access.
8. Data storage and retention
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Senior Technical Engineer.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When not required, the paper or files should be kept in a locked drawer or filing cabinet.
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
Catalpa ensures that data will be backed up frequently.
Personal information will only be kept as long as absolutely necessary, after which it shall be deleted from all means of storage.
9. Data use
Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
The use of encryption and/or pseudonymisation of personal information should be used whenever feasible.
Personal data will not be shared informally. In particular, it should never be sent by email or any other means that does not use strong end-to-end encryption.
Data must be encrypted before being transferred. The Senior Technical Engineer can explain how to send data to authorised external contacts.
Personal data should never be transferred outside of the European Economic Area.
Employees should not save copies of personal data to their own computers unless specifically authorised do so by the Director or Senior Technical Engineer.
9.1 Prohibited usage
Catalpa data will only be used at a population level in any and all analysis that will be carried out. Diagnosis or identification of individual children is not allowed.
Catalpa will never rent or sell data or permit advertising.
9.2 Cultural reporting
Reporting of Catalpa programs and results should take proper account of specific cultural and communication requirements, especially when reporting findings on communities with a high proportion of Indigenous people and people with language backgrounds other than English.
9.3 Understanding and responding local context
Catalpa also needs to take into account other government regulations with regards to data privacy, security, storage and retention. Where these regulations are weaker we will maintain compliance to the Data Protection Act 1998, and this policy.
10. Data accuracy
The law requires Catalpa to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Catalpa should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
Catalpa will make it easy for data subjects to update the information we hold about them. For instance, via the company website.
Data should be updated as inaccuracies are discovered. For instance, if a partner can no longer be reached on their stored telephone number, it should be removed from the database.
11. Data breach & response
In the event that there is unauthorised access or unauthorised disclosure of personal information, the Data Security Team should be immediately notified. Catalpa will disclose any breach to its relevant partners.
In the case where a breach meets the following criteria, Catalpa will also report the breach to the Office of the Australian Information Commissioner (OAIC):
There is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that an organisation or agency holds
This is likely to result in serious harm to one or more individuals, and
The organisation or agency hasn’t been able to prevent the likely risk of serious harm with remedial action
If Catalpa suspects an eligible data breach may have occurred we will quickly assess the incident to determine if it is likely to result in serious harm to any individual and affected individuals will be promptly informed of the nature and extent of the breach.
12. Subject access requests
All individuals who are the subject of personal data held by Catalpa are entitled to:
Ask what information the company holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the Data Security Team at operations@catalpa.io.
The Data Security Team will always verify the identity of anyone making a subject access request before handing over any information.
13. Disclosing data for other reasons
In certain circumstances, governing law may allow personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Catalpa will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
14. Providing information
Catalpa aims to ensure that individuals are aware that their data is being processed, and that they understand:
How the data is being used
How to exercise their rights
That they have the option of dealing anonymously or by pseudonym.
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