Privacy Policy

The Interplay Project Pty Ltd (Interplay, we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it outlines how we collect and manage your personal information.

We comply with all of our legal obligations relating to your privacy as set out in the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles.

We collect and use your personal information in accordance with the Australian Privacy Principles, our ethical frameworks are formally approved and in line with our Cultural Data Protocols and Values Statement.

If you have comments, questions or concerns about any aspect of this policy, please email our Privacy Policy Officer at [email protected].

1. What is personal and sensitive information?

In general terms, personal information is any information that can be used to personally identify you. This may include your name, address, telephone number, and email address. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

Sensitive information is a subset of personal information, and includes information or an opinion about a person’s:

  • Racial or ethnic origin;

  • Political opinions;

  • Political associations;

  • Culturally sacred knowledge;

  • Religious beliefs or affiliations;

  • Philosophical beliefs;

  • Memberships of professional or trade associations or trade unions;

  • Sexual preferences or practices;

  • Criminal record;

  • Health information;

  • Genetic information that is not otherwise health information;

  • Biometric information.

Sensitive information that we collect about you is subject to extra protection under the Act.

2. Information we collect

We collect personal and sensitive information in order to perform our professional services and functions. At all times we try to only collect the information we need for the particular function or activity we are carrying out.

Usually, we collect your personal information when you consent to giving it to us. This may include:

  • When you contact us. When you contact us, you may supply personal information including, in most cases, your name, a unique email address and phone number.

  • When you participate in our research or evaluation work. If you are a client or a research participant you may provide us with your personal information. We may also ask you to provide sensitive information but will always seek your consent before doing so. 

  • Third parties. We may also collect information from third parties we are working with, such as a government agency or a client. Such a client may ask us to contact you for the purposes of participating in research we are conducting on behalf of that client.

3. Consent & Anonymity

We will always ask for your informed consent to collect and use your personal and sensitive information before you participate in any of our research or evaluation projects. Consent will usually be sought in the form of a participant information notice and informed consent form that you must read and complete prior to your participation in our research. This document will explain the purpose for why we are collecting your personal and sensitive information and how we plan to use it.

When dealing with us, you have the option to use a pseudonym or not identify yourself at all. However, there may be times that we cannot perform our work properly unless you give us your personal information. We will indicate when this is the case and will always give you the ability to opt-out of communications or choose not to participate in our research projects.

4. De-identifying your personal information

Our main use of your personal information is for our research and evaluation work which is always conducted with the aim of empowering all people to experience optimal wellbeing.

When our research work does not require you to be personally identified, we will take reasonable steps to de-identify your personal information as soon as possible after collection.

When we de-identify your personal information, we will separate out your personal details from other non-identifiable information you provide us. We will then keep your personal and sensitive information secure, and  only disclose the de-identified information to our employees, contractors and clients to be analysed as part of our work.

However, for the duration that we hold your personal information, it will be linked via an anonymous database ID code to link to your de-identified information. This allows us to access your personal information and associated de-identified information when needed.

5. Our use and disclosure of your personal information

We may use your personal information to keep track of your interactions with us, including whether or not you have engaged with us before. We may use this information in order to maintain the quality of our research data, such as identifying and preventing duplicate submissions.

We will not disclose your personal information to any employee, contractor or third party unless necessary. Any disclosure will always be in accordance with the Australian Privacy Principles and only where you have provided prior written consent.

Our other uses of personal information may include:

  • If you contact us. If you have contacted us we may collect, hold and use your name, email address or phone number to communicate with you.

  • Web Analytics. We collect non-personally identifiable information of your usage of our website and other digital technology platforms (Analytics). Generally, we use Analytics to ensure our technology is functioning correctly and to generate reports and analysis about the usage and browsing patterns of the users of our website and technology platforms. We will often use the services of third-party providers located in Australia and overseas to collect and hold Analytics on our behalf. These third parties may also access and use the Analytics for their own analytical and optimisation purposes. We do not tie Analytics to personally identifiable information relating to you. 

  • Legal Requirements. In order for us to cooperate with official investigations or legal proceedings, including, for example, in response to subpoenas, search warrants, court orders, or other legal proceedings we may be required to disclose your personal information. 

  • Acquisition or Transfer. As our business changes, we may buy or sell various assets. In the event that all or a portion of the assets owned or controlled by The Interplay Project Pty Ltd, (including any parent or subsidiary company) are sold, assigned, transferred or acquired by a third party, data collected from the users of our websites and technology platforms may be among such assets.

6. Do we disclose your personal information to anyone outside Australia?

We may disclose your personal information to third parties located outside of Australia, including our data hosting and other IT service providers (some cloud service providers may store data in several countries).

We will take reasonable steps to ensure that the overseas recipients of your personal information do not breach this Privacy Policy or the Australian Privacy Principles.

7. Security

We have implemented a variety of commercially standard encryption and security technologies and procedures to protect the information, including your personal information, stored in our computer systems from unauthorised access. Please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure. We strive to use commercially acceptable means to protect your personal information but we cannot guarantee its absolute security under all conditions. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet.

We also maintain standard physical and electronic procedural safeguards that limit access to your personally identifiable information to our employees or contractors who, through the course of standard business activities, need to access your personal information.

8. Access

The Australian Privacy Principles require us to provide you with access to your personal and sensitive information held by us when you request it. Generally, we will provide you access to your personal and sensitive information in the form that you originally supplied it to us (for example, the results of a survey form you completed). However, we generally do not release other de-identified information generated from your personal information until our research findings have been finalised and validated.

To obtain a copy of any of your personal information held by us, please contact our Privacy Policy Officer using the details at the top of this page. We will need to confirm your identity before we release any information to make sure it is not shared with people who have no right to it.

We will deal with your request to provide access to your personal and sensitive information within a reasonable time period – usually within 30 days of your request. We will not charge you for a request for access to your personal and sensitive information.

There may be some instances where we refuse you access to your personal and sensitive information. If this occurs, we will provide you with a notice that will set out the reasons for the refusal of access and the mechanisms available to you to complain about the refusal.

9. Correcting information

We will take reasonable steps to ensure that the personal and sensitive information we hold remains accurate.

If you believe your personal information is inaccurate, incomplete or requires updating, please contact us. We will review your request and if we determine the information we hold about you requires correction, we will correct it as soon as practicable.

10. Updates to this policy

Our services are evolving and developing. From time to time, we will review and make changes to this Privacy Policy. Any updated versions of this privacy policy will be posted on our website. This privacy policy was last updated in June 2020.

11. Deleting your personal information

Where we no longer need to hold your personal information for the purpose we gathered it for, we will take reasonable steps to delete it or ensure that it is de-identified.

In accordance with our ethical obligations, you may withdraw your consent to participate in our research at any time. You can also ask us to delete the personal and sensitive information we hold about you. To make a request to delete, please contact our Privacy Policy Officer using the email address listed at the top of this document.

12. Complaints

If you believe we have breached this Privacy Policy or the Australian Privacy Principles, you can make a complaint to our Privacy Policy Officer using the contact details at the top of this page. You have the option to remain anonymous, although this may inhibit our ability to investigate your concerns in appropriate detail.

We will endeavour to deal with your complaint as quickly as possible – usually within 30 days – and to keep you informed of progress.

If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC).