Policies

Principals

The Audit and Risk Committee has agreed on the fundamental principles of this policy, and has delegated responsibility for the implementation and monitoring and minor updating of this policy to the CEO.

Terminology

In this Privacy Policy, the terms “OCT”, “we”, “us”, and “our” refer to Otago Community Trust and the terms “you” and “your” refer to you as a website user, or applicant.

“Personal information” includes but is not limited to: your name, email address, mailing address, phone number, user name, date of birth, contact preferences, online activity logs related to our website, IP addresses, cookie, device, browser and operating system identifiers, internet tags, location and navigational data provided by your connection, server addresses, top-level domain names, dates and times of visits to the website, pages accessed and documents downloaded, interactions with tools and advertising, previous websites visited, and the type of browser used.

Collection and Storage of Personal Information

We may collect your personal information – including your email address, name, phone number and mailing address – in the following circumstances:

1. When you voluntarily provide information to us, for example:

•        when you complete forms on our website or elsewhere (including registration forms, application forms and other forms);
•        when you create, modify, or use any accounts or registered user facilities available through our website;
•        in the course of receiving questions, comments or other communications from you; or

   2. As you navigate through the website, certain information may be passively collected (that is, gathered without your active      participation) using various technologies and means, including technical information and usage information individual to you.

Use of Personal Information

The personal information we collect will be used to provide services you have authorised or requested.  We may also use the personal information we collect to:

• assess, fulfil and monitor applications for funding;
• carry out internal research and development, including planning for future funding;
• prepare communications in respect of funding outcomes and case studies (where possible, we will anonymise personal information for this purpose);
•  verify your identity and assist you in case you forget your password or login details;
•  respond to any questions or correspondence from you;
•  manage and improve our website and any related services;
•  provide you with information about a service that you are using (including critical updates and announcements);
•  reduce the need for you to repeatedly enter the same information;
•  analyse website usage, trends and statistics;
•  with your permission, supply you with further information which may be of interest to you; or
• carry out any other use that is authorised by you or is notified to you at the time of collection.

Disclosure of Personal Information

We may need to disclose your personal information in order to meet the purposes set out above. We will not disclose your personal information except in accordance with this Privacy Policy and the Privacy Act 1993. 

We may disclose your personal information to:

• any third party you have authorised us to share your personal information with, or we have notified you that we may share your personal information with and you have not objected;
• government or law enforcement agencies, where we believe that it is reasonably necessary to assist with the maintenance of the law;
• appropriate third parties where necessary to protect your safety or the safety of others;
• suppliers of outsourced functions such as our auditors, lawyers or data storage providers;
• our stakeholders, such as community groups, charitable trusts or our trustees, for the purpose of assessing, fulfilling or monitoring funding applications or otherwise managing our business; or
• any other agency where required or permitted by law.

Please also note that we may share the information we collect in an anonymous form, for example from surveying or tracking information, with other third party partners.  However, we will not sell or disclose personal information about you as an individual to any third party or entity outside of Otago Community Trust or its related entities for marketing purposes. 

Third Party Websites

Our website may contain hyperlinks to third party websites. We are not responsible for the content of such websites, or the manner in which those websites collect, store, use, and disclose any personal information you provide. 

When visiting a third party website from hyperlinks displayed on our website, we encourage you to review the privacy statements of those websites so that you can understand how the personal information you provide will be will collected, stored, used and disclosed.

Storage of Personal Information 

Your personal information is collected by Otago Community Trust and may be held by Otago Community Trust (Level 2, Community Trust House, Cnr Moray Place & Filleul St, Dunedin) or any other associated entities or service providers to OCT on secure servers.

The information collected on, or through, our website is stored on secure servers. 

In accordance with the Privacy Act 1993, OCT may store your personal information for as long as it may lawfully be used by us.

Security

No data transmissions over the internet are completely secure. Accordingly, we cannot ensure the security of information transmitted from or to you. However, once we have received your personal information, we will use reasonable efforts to protect the information against loss or misuse, and against unauthorised access, use, modification, or disclosure. 

Right to Access and Correct Your Personal Information

You have the right to access, request or correct the personal information that we hold about you at any time by contacting our staff at info@oct.org.nz, writing to us, Otago Community Trust, PO Box 5751, Dunedin 9058 or ringing 0800 10 12 40.

Whichever way you make your request, we must take steps to ensure that you’re authorised to do so. Please understand that we must do this in order to protect your privacy. 

The Privacy Act permits us to withhold personal information from you in certain circumstances, such as where the information is commercially sensitive or legally privileged. We might also refuse to provide you with information that is also about other people if we think this would be unwarranted. If we withhold information from you, we’ll tell you why. 

We’re required by the Privacy Act to make a decision on your request – and convey this to you – within 20 working days. Where we cannot make a decision within 20 working days, we’ll let you know and explain why.

We reserve the right, at our discretion, to update, change or revise this Privacy Policy at any time.

Changes to this Privacy Policy will take effect immediately once they are published on this website.

Please check the Privacy Policy periodically for changes. Your continued use of this website or our services following the posting of any changes to the Privacy Policy indicates your acceptance of those changes.

If you have a concern about the way we’ve handled your personal information, let us know. You can speak with our CE using the contact details set out above and we’ll try to resolve your concerns. 

If we can’t resolve your complaint for you, then you have the right to make a complaint to the Office of the Privacy Commissioner by:

•        completing an online complaint form at www.privacy.org.nz; or
•        writing to the Office of the Privacy Commissioner, PO Box 10-094, The Terrace, Wellington 6143.

Appendix 1

UN Global Compact

The UN Global Compact asks companies to embrace, support and enact, within their sphere of influence, a set of core values in the areas of human rights, labour standards, the environment and anti-corruption.

The 10 Principles of the UN Global Compact

Human Rights

Principle 1         Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2         Make sure they are not complicit in human rights abuses

Labour

Principle 3         Businesses should uphold the freedom of association and the effective recognitions of the right to collective bargaining

Principle 4         The elimination of all forms of forced and compulsory labour

Principle 5         The effective abolition of child labour; and

Principle 6         The elimination of discrimination in respect of employment and occupation.

Environment

Principle 7         Business should support a precautionary approach to environmental challenges;

Principle 8         Undertake to promote greater environmental responsibility;

Principle 9         Encourage development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principal 10       Businesses should work against all forms of corruption, including extortion and bribery.

Appendix 2

UN Principles for Responsible Investment

As institutional investors, we have a duty to act in the best long-term interests of our beneficiaries.  In this fiduciary role, we believe that environmental, social and corporate governance (ESG) issues can affect the performance of investment portfolios (to varying degrees across companies, sectors, regions and asset classes and through time).  We also recognise that applying these Principles may better align investors with broader objectives of society.  Therefore, where consistent with our fiduciary responsibilities, we commit to the following six principles of the UN PRI:

1.        We will incorporate ESG issues into investment analysis and decision-making processes.
2.        We will be active owners and incorporate ESG issues into our ownership policies and practices.
3.        We will seek appropriate disclosure on ESG issues by the entities in which we invest.
4.        We will promote acceptance and implementation of the Principles within the investment industry.
5.        We will work together to enhance our effectiveness in implementing the Principles.
6.        We will each report on our activities and progress towards implementing the Principles.