The E-Government Act of 2002 issued by the US Department of State’s Privacy Office contain requirements that apply to US based organizations (including Commonwealth) in relation to handling personal information.
THE PURPOSES FOR WHICH THE SPORTS FOUNDATION COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION
Our activities and services, and the purposes for which we collect personal information, include:
- Enabling and managing philanthropic support for JNF through the receipt and processing of tax deductible donations from individuals and distributions from ancillary funds. We collect personal information from individuals and ancillary funds to
- enable donations from individuals and distributions from ancillary funds to be processed, receipted and acknowledged; and
- facilitating ongoing communication with donors and ancillary funds on service level matters or provide them with information on new sporting projects they may wish to support, including via mailing lists.
- Delivering grant programs to enable the achievement of defined JNF objectives. We collect personal information from project partners and potential project partners in order to:
- maintain effective communication during the life of each of the projects; and
- provide us with information regarding the beneficiaries of its grants; and
- enable the correct acquittal of grant funds.
- General business purposes. We collect personal information in order to:
- operate and administer our business
- communicate with individuals, project partners, ancillary funds, service providers and others
- assist with individuals’ queries and queries from financial institutions relating to individual transactions.
- determine whether to engage potential employees and contractors
- complete audit processes and comply with taxation law and other laws and regulations.
HOW WE USE PERSONAL INFORMATION
We use personal information to provide our services and operate our business as described above, and otherwise as required or authorised by law.
THE KINDS OF PERSONAL INFORMATION THAT WE COLLECT AND HOLDS
We may collect personal information in hard copy form or electronically, as well as verbally or over the phone. The personal information that we hold about you will depend on the nature of the activity or service we are providing to you. It may include (but is not limited to) your name, contact details, date of birth, occupation, , financial records and details, employment and travel information.
We only collect personal information to the extent that it is relevant for the relationship we have with you.
We also collect and holds sensitive information, for example information about health, disability and racial or ethnic origin. We will only collect this information where it is reasonably necessary for our functions and activities, and will only do so with your prior consent, in the following situations:
- where we provide services relating to specific groups or demographics (for example, people with a disability, or from a particular cultural background etc ) such as:
HOW WE COLLECT AND HOLD PERSONAL INFORMATION
We will collect personal information directly from you. This may be through application forms, donation forms, athlete acquittal forms, legal agreements, over the telephone, the internet, or in person.
We may also need to collect personal information from other people or organisations. Some examples of the people or organisations from whom we may collect personal information about individuals are:
- ancillary funds;
- project partners and potential project partners: sporting, community and educational organisations including trusts and foundations;
- publicly available sources of information (such as telephone directories and the internet);
- an individual’s representative (such as a parent, coach, project contact, legal adviser, financial advisor, business manager);
- an individual’s employer;
- other government bodies and agencies; and
- financial institutions.
We will hold the information we collect on systems managed and maintained by us and/or our third-party cloud storage service provider (the Cloud Service Provider). We have an electronic documents and records management system that is fully compliant with government and archival standards and legislation.
WHEN WE WILL NOT NEED TO COLLECT PERSONAL INFORMATION
Depending on the nature of your relationship with us, you may not need to identify yourself personally.
You generally have a right to pseudonymity or anonymity when dealing with us, unless:
- we are required or authorised by or under an american law, or a court/tribunal order to deal with individuals who have identified themselves;
- it is impracticable to deal with you if you do not identify yourself;
- you are receiving a service or financial benefit from us, and we require assurance that the service or benefit is being directed to you for a defined purpose.
HOW WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE
We seek to maintain the quality of our information by taking reasonable administrative and technical steps to make sure that the information collected, used and disclosed is accurate, complete and up-to-date. If you wish to correct the personal information that we hold about you, please contact us using the details set out below.
We are committed to protecting online privacy in accordance with Guidelines for the E-Government Act of 2002 issued by the US Department of State’s Privacy Office.
We record visits to this website and log the following information for statistical purposes:
- your server or proxy address;
- date/time/length of the visit;
- files requested;
- your cookies; and
- your searches.
The information is used to analyse our server traffic. No attempt will be made to identify users or their browsing activities except where authorised by law.
WHEN WILL WE PROVIDE PERSONAL INFORMATION TO OTHERS?
Sometimes we may provide personal information to external organisations. Generally, these are organisations that help us conduct our programs and activities.
We strive to limit the personal information we provides to outside organisations to what they need to provide their services to us, and aim to disclose only the personal information necessary to provide services to donors, project partners and the relevant regulatory authorities. We ensure that any organisation that we contracts with:
- meets the privacy standards required by us in protecting personal information and complies with the Privacy Act;
- uses the personal information provided only for the purposes of the specific service being provided to us, and for no other purpose.
We may also need to provide personal information to others outside the JNF where:
- we are required to by law or have a public duty to do so; or
- you have expressly consented to your personal information being supplied to others for particular purposes.
DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS
We seek to limit the disclosure of personal information to overseas recipients.
We provide our services to benefit JNF and this may include JNF project partners throughout the world. At times this may require personal information, including sensitive information, to be disclosed overseas.
We may also disclose personal information to overseas recipients where an individual has expressly consented to their personal information being supplied to overseas recipients (for example, to a parent company that matches gifts made by its JNF-based employees).
We may contract overseas commercial organisations to provide products or services to the JNF or its donors or project partners.
ACCESS AND CORRECTION OF PERSONAL INFORMATION
Any person who believes that the JNF holds personal information about them may contact us to seek access to that information.
If, after accessing information held by the JNF about you, you consider that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading for the purposes for which it is held, you may request that we amend your personal information on our records.
In the first instance a person can request access to their personal information by contacting us as follows:
Jordan Nwora Foundation
Phone: +1 (716) 390-1368
We will respond within a reasonable time. However, we may not always be able to provide access to all the personal information we hold about you or correct your personal information in the manner you have requested. For example, we may not be able to provide access to information that would reveal personal information about another person. Where we are unable to provide you with access to your personal information or correct your personal information as requested, we will notify you and give you the reasons why (except to the extent it would be unreasonable for us to do so).
If you wish to make a complaint about the way we have handled your personal information (including if you think we have breached the Privacy Act), you may do so by contacting us using the details set out above. If you make a complaint, please include contact details such as your name, address, telephone number and email address and clearly describe your complaint.
Any privacy complaints must be made to the JNF in writing. We will endeavour to be as efficient as possible when investigating and responding to any privacy complaints. We will respond to all complaints within a reasonable time period appropriate to the specific complaint.
We will handle all complaints received in accordance with the Guidelines published by the Office of the US Department of State’s Privacy Office in relation to complaints management.
If you are unsatisfied with our response, you may contact the US Department of State’s Privacy Office who may investigate our actions. The Commonwealth Ombudsman may also investigate complaints relating to the JNF. However, the Commonwealth Ombudsman and the Privacy Commissioner will consult to avoid the same matter being investigated twice.