small candle Privacy policy

Small Candle Consulting – Privacy Policy

1. About this policy

This privacy policy explains how Small Candle Consulting (ABN 841 628 356 90) manages personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). It describes what personal information we collect, how we use and disclose it, how we keep it secure, and how you can access or correct your personal information or make a privacy complaint.

By using our services or interacting with us (including via our website), you agree to the handling of your personal information as set out in this policy, subject to your rights under the Privacy Act.

2. Who we are and how to contact us

Small Candle Consulting provides governance, leadership, coaching, training and related advisory services to individuals, businesses, community sector-organisations and government agencies.

If you have questions about this policy or how we handle personal information, or if you wish to request access, correction or make a complaint, please contact:

• Managing Director, Small Candle Consulting
• Email: mark@smallcandle.com.au
• Phone: 0418789922
• Postal address: 41 Neil Currie Street Casey ACT 2913

We will take reasonable steps to respond in the manner and timeframe described in this policy.

3. What personal information we collect

The personal information we collect depends on your relationship with us (for example, learner, coaching client, employee, contractor, supplier, or business partner). It can include:

• Identity information: name, title, date of birth, gender, identification documents (such as driver licence, passport, Medicare card, photographic work pass).
• Contact details: address, email address, telephone number and preferred contact method.
• Employment and education information: CV and work history, qualifications, skills, professional memberships, referees, schooling information, employment status.
• Financial and administrative information: bank account details, superannuation details, tax file number (TFN), invoicing details, ABN, details relevant to payments or reimbursements.
• Learner and client information: enrolment details, course participation and completion records, coaching and mentoring engagement details, feedback and evaluations, and information needed to tailor services or meet funding/reporting requirements.
• Online information: log and usage data from our website, information collected through cookies and similar technologies, and subscription preferences for newsletters or other communications.

We may also collect limited sensitive information (such as information about racial or ethnic origin, religious beliefs, professional or trade association membership, trade union membership, sexual orientation or practices, or criminal record) where it is reasonably necessary for our functions or activities and you have consented or where required or authorised by law.

4. How we collect personal information

Where reasonable and practicable, we collect personal information directly from you. This includes when you:

• enrol in a course or program
• engage us for coaching, mentoring, facilitation or consulting services
• apply for a job or contract role with us
• provide goods or services to us, or partner with us on a project
• subscribe to our newsletters, blogs or other updates
• complete a form (online or paper), sign a contract, email or otherwise communicate with us
• provide testimonials or feedback.

We may also collect personal information about you from third parties where it is unreasonable or impracticable to collect it directly from you, or with your consent, for example from:

• referees, previous employers or education providers
• funding bodies, sponsoring or employing organisations
• government agencies where required or authorised by law.

We may collect personal information about employees and contractors as part of our personnel records, in accordance with employment and workplace laws.

5. Anonymity and pseudonymity

Where lawful and practicable, you may deal with us anonymously or by using a pseudonym, for example when making a general enquiry about our services. However, if you do not provide certain personal information, we may not be able to deliver some services (such as enrol you in a program, provide coaching, or enter a contract).

6. Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information where it is reasonably necessary for, or directly related to, our functions and activities, including to:

• provide, administer and improve our training, facilitation, coaching, mentoring and advisory services
• manage enrolments, learning records and completion data
• communicate with learners, clients, participants, suppliers and partners
• plan, coordinate and report on support and training services, including national or jurisdictional reporting as required
• assess job or contractor applications and manage personnel records
• manage our business operations, including billing, financial management, risk management, compliance and quality improvement
• send you information about our services, events or resources that may be of interest, where permitted by law and consistent with your preferences.

We may use or disclose personal information for the primary purpose for which it was collected, for related secondary purposes that you would reasonably expect, where you have consented, or where required or authorised by law.

7. Direct marketing

We may use your contact details to send you newsletters, updates, event invitations or other information about our services that we believe may interest you, in accordance with APP 7 and the Spam Act 2003.

You can opt out of direct marketing communications at any time by using the unsubscribe facility in our emails or by contacting us using the details in section 2.

8. Disclosing personal information

We may disclose personal information to third parties where reasonably necessary for our functions and activities, including to:

• your sponsoring or employing organisation (for example, to confirm enrolment or completion where they have funded your participation)
• government departments or agencies, regulators and statutory bodies where required or authorised by law (for example, national reporting bodies such as the Department of Education, NCVER, or Centrelink, where relevant)
• professional advisers such as accountants, auditors and lawyers
• third‑party service providers who support our operations (for example, IT and cloud hosting providers, learning management systems, communication platforms, survey tools, document storage, and payment processors)
• referees and former employers, when you have consented and where relevant to recruitment or contracting processes.

We take reasonable steps to ensure that any third party to whom we disclose personal information protects it in a manner consistent with this policy and the APPs, including through confidentiality obligations and appropriate contractual terms.

9. Overseas disclosure

Some of our third‑party service providers may store or process personal information on servers located outside Australia (for example, cloud‑based email, document storage or learning platforms). Where this occurs, we will take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information, or that another exception under the Privacy Act applies.

We will not otherwise disclose your personal information to overseas recipients without your consent, unless required or authorised by law.

10. Website, cookies and analytics

When you visit our website, we may collect certain information using cookies and similar technologies. This can include your IP address, browser type, pages visited, time and date of visit and referring site, which we use for website administration, security, and to understand how visitors use our site.

You can usually configure your browser to reject cookies or notify you when a cookie is being used, though this may affect how our website functions. If we use online analytics or marketing tools, we will do so in a manner consistent with this policy and applicable laws.

11. Security of personal information

We take reasonable steps to protect personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure, as required by APP 11. These steps include physical security measures (for example, secure filing areas and controlled office access) and technical measures (for example, secure data networks, password protection, access controls and data back‑ups).

Learner information is retained and managed in accordance with relevant records laws, including the Territory Records Management Act and relevant records disposal schedules, where they apply. When personal information is no longer needed for any authorised purpose, and we are not required by law to retain it, we will take reasonable steps to destroy or de‑identify it.

12. Access to personal information

You may request access to the personal information we hold about you by contacting us using the details in section 2. We will respond to your request within a reasonable period and, if we decide to refuse access, we will provide you with written reasons and information about how you can complain.

We may refuse access in limited circumstances permitted by the APPs, for example where giving access would unreasonably impact the privacy of others, where the request is frivolous or vexatious, or where the information relates to existing or anticipated legal proceedings or commercially sensitive decision‑making.

13. Correction of personal information

We take reasonable steps to ensure that personal information we hold is accurate, up‑to‑date, complete and not misleading. If you believe that any personal information we hold about you is incorrect, incomplete or out of date, please contact us so we can update it.

Where we refuse to correct your personal information as requested, we will provide you with written reasons and information on how you can complain.

14. Complaints

If you have a concern about how we have handled your personal information, please contact us using the details in section 2 and provide as much detail as possible about your concern. We will acknowledge your complaint and aim to provide you with a written response within 14 days, or otherwise within a reasonable time.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). Further information is available on the OAIC website at www.oaic.gov.au.

15. Updates to this policy

We may update this Privacy Policy from time to time to reflect changes to our practices, business or legal requirements. The current version will be available on our website and you may request a copy in another form using the contact details in section 2.