Privacy policy
CEOs for Gender Equity ("CGE") is an Australian not-for-profit organisation that advocates for and assists organisations to implement gender equity initiatives, including through the CGE Job-sharing Toolkit. We handle personal information in line with the Privacy Act 1988 (Cth) ("Privacy Act") and the 13 Australian Privacy Principles ("APPs"). We have chosen to commit to those standards as a matter of good practice, whether or not the Act technically requires us to do so.
1. About this policy
This policy explains:
- what personal information we collect and hold;
- how we collect it;
- why we collect, hold, use and disclose it;
- how we keep it safe;
- how you can access and correct your information; and
- how you can make a complaint regarding how your personal information is handled.
In this Privacy Policy:
- "Organisation" means the business or entity that purchases a seat package relating to the CGE Job-Sharing Toolkit ("Toolkit").
- "Super User" means the person who purchases on behalf of an Organisation and manages that Organisation’s seats.
- "Seat User" means a person invited by a Super User to use a seat.
- "User" means any Super User or Seat User accessing the Toolkit.
- "Subscription" means the annual, seat-based licence to the Toolkit purchased by an Organisation.
2. What we mean by personal information
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form.
Sensitive information is a subset of personal information that has higher protections. It includes information about health, political opinions, religious or philosophical beliefs, racial or ethnic origin, and membership of a trade union, among other things.
CGE does not intentionally request sensitive information through the Toolkit. We will only collect sensitive information from you with your consent and where it is reasonably necessary for our activities, including where collection is required by law or when such information is necessary for the establishment, exercise or defence of a legal claim.
3. What we collect
We may collect the following kinds of personal information:
- your name;
- your work email address and other contact details (such as postal address and phone number);
- the name of your organisation and your role;
- your subscription status and your role in the Toolkit (Super User or Seat User);
- billing and payment-related information;
- records of your enquiries, feedback and complaints; and
- limited technical and usage information when you use our website and the Toolkit (such as browser type, pages visited and session duration).
We only collect personal information that is reasonably necessary for our functions and activities. We practise data minimisation — we do not collect information just because it might be useful later.
4. Your Toolkit data stays private to you
The Toolkit applies a strict individual privacy model.
- The data you create as an individual User, including your diagnostic results and saved budgeting scenarios, is private to you.
- Your individual results and saved data are not visible to your organisation’s Super User, to other Seat Users, or to CGE. They are not shared through the platform.
- You can download your own completed diagnostic results as a self-contained HTML file. Once downloaded, that file is yours to manage, and you are responsible for how you store or share it.
- CGE and its service providers may process limited account, subscription, billing, technical and usage information needed to operate, secure and support the Toolkit. Individual diagnostic results and saved budgeting scenarios are not accessible to CGE or the Organisation’s Super User.
- CGE may collect and use aggregated, de-identified usage data and analytics for improving, developing and promoting the Toolkit and CGE’s mission. That aggregated data will not identify any individual User or Organisation.
5. How we collect your information
We usually collect personal information directly from you when you or your organisation:
- subscribes to the Toolkit;
- creates an account;
- uses the Toolkit;
- contacts us with an enquiry, feedback or complaint;
- attends an event; or
- subscribes to our updates.
Sometimes we receive your information from your organisation’s Super User or authorised administrator when they set up seats for staff.
We only collect personal information by lawful and fair means.
You do not have to give us your personal information. However, if you choose not to, we may not be able to provide you with the Toolkit or respond to your enquiry.
6. Unsolicited information
If we receive personal information that we did not ask for and could not have lawfully collected under this policy, we will destroy or de-identify it as soon as practicable, where it is lawful and reasonable to do so.
7. Dealing with us anonymously
You can browse our website and make a general enquiry or complaint without identifying yourself (either anonymously or by pseudonym), where it is practicable to do so.
We cannot provide Toolkit accounts, subscriptions or receipts anonymously as it is impracticable for us to do so.
8. Why we use your information
We use your personal information for the following purposes:
- to set up and administer accounts, seats and subscriptions;
- to provide, support and maintain the Toolkit;
- to process payments and invoicing;
- to respond to your enquiries, feedback and complaints;
- to send you service and administrative messages about your account or the Toolkit;
- to improve and develop the Toolkit using aggregated, de-identified data;
- to keep our systems secure and prevent fraud or misuse; and
- to meet our legal, governance and reporting obligations.
We generally only use or disclose your information for the primary purpose we collected it for. We will only use or disclose it for another purpose if:
- you consent;
- you would reasonably expect it to be used for a secondary purpose and the secondary purpose is related to the primary purpose; or
- it is required or authorised by law.
If you provide inaccurate or incomplete information, CGE may not be able to provide you with the services requested.
9. Direct marketing and opting out
We do not sell your personal information.
We may disclose personal information to service providers and other third parties where reasonably necessary to operate our organisation, provide our services, administer the Toolkit, process payments, maintain our systems, obtain professional advice or comply with the law.
We do not use sensitive information for direct marketing unless we have received your express consent to do so. You may rescind this consent at any time.
Where you have provided consent for us to use your sensitive information, CGE maintains records of the source of information used and you have the right to request these details.
From time to time, we may use the personal information you have provided us to market our services to you. If we send you marketing communications, you can opt out at any time by using the unsubscribe link in the communication or by contacting our Privacy Officer. We will action your opt-out promptly — within 30 days at the latest, and usually much sooner.
10. Who we share your information with
We may share your personal information with:
- our hosting and IT service providers who run the Toolkit;
- payment and accounting providers;
- email and communications platforms;
- professional advisers such as auditors and lawyers; and
- others where required or authorised by law.
We take reasonable steps to satisfy ourselves that these providers protect personal information appropriately. We review contract terms, conduct periodic reviews, and ask providers to delete information at the end of the arrangement.
We do not sell or trade personal information. We do not share your individual Toolkit results with other individuals or organisations.
11. Overseas disclosure of information
The Toolkit is hosted by third-party infrastructure providers. Some of these providers may store or process information outside Australia and potentially other countries where our hosting, email and communications providers operate.
Before we disclose personal information to any overseas recipient, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles — for example, by entering into contractual arrangements that require the recipient to comply with the Australian Privacy Principles. Where such steps are not practicable, we will only make the disclosure with your consent or where another permitted basis under the Privacy Act applies. You should be aware that, where we rely on your consent to disclose personal information to an overseas recipient, we will not be accountable under the Privacy Act for any subsequent mishandling of that information by the overseas recipient, and you may not be able to seek redress under the Privacy Act.
12. How we keep your information secure
We take reasonable technical, physical and organisational steps to protect your personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These include:
- access controls so staff only see what they need;
- multi-factor authentication on key accounts;
- strong password practices;
- keeping systems patched and up to date;
- staff training and confidentiality obligations;
- secure storage of any hard-copy records;
- supplier due diligence; and
- an incident response process.
CGE takes reasonable steps to ensure its providers maintain appropriate security standards. However, no system can be guaranteed completely secure, and CGE cannot warrant uninterrupted, error-free transmission of data at all times.
13. How long we keep your information
We keep your personal information only as long as we need it for the purposes described in this policy, or as required by law.
We review our holdings regularly and destroy or de-identify information we no longer need. We do not keep information indefinitely just because it might be useful later.
We may keep de-identified and aggregated information for reporting and improvement purposes.
When your Subscription ends, we retain account data for 90 days, after which it is deleted in accordance with our data handling practices. During this 90-day period, your Organisation’s Super User may request export of the Organisation’s account data (excluding individual User diagnostic data) by contacting us. After that period, the data will be deleted.
14. Keeping your information accurate
We take reasonable steps to ensure that the personal information we hold is accurate, up to date, complete and relevant.
You can update your own account details at any time. Please tell us if anything changes or looks wrong.
15. Accessing and correcting your information
You can ask for access to, or correction of, the personal information we hold about you. You may also request deletion of your personal information. We will consider such requests in accordance with the Australian Privacy Principles and respond within a reasonable period, generally within 30 days. We will verify your identity before providing access or making corrections. We do not charge for making a request or for correcting information.
In limited cases we may refuse access — for example:
- where providing access would pose a serious threat to the life and health of a person;
- where providing access would unreasonably affect another person’s privacy;
- where the request is frivolous or vexatious;
- the information is related to existing or anticipated legal proceedings between CGE and a client and would not be discoverable in those proceedings;
- providing access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
- where refusal is required or permitted by law.
If we refuse, we will explain why in writing.
If we refuse to correct information, you can ask us to add a statement noting that you believe it is inaccurate, incomplete, misleading or out of date.
If you ask, we will take reasonable steps to notify others to whom we have previously disclosed the information that we have corrected it.
16. Data breaches
If we become aware of a possible breach, we will act quickly to contain it, investigate and assess whether it is likely to cause serious harm.
If it is an eligible data breach, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as soon as practicable. We will tell you what happened and what you can do to protect yourself and your information.
17. Automated tools
We may use analytics and automated tools to understand how the Toolkit is used and to improve it. These tools process de-identified, aggregated usage data. We do not currently use automated decision-making processes (including by computer program) that use personal information to make decisions that could significantly affect the rights or interests of any individual user.
These tools do not replace appropriate human involvement in decisions that significantly affect an individual.
We will review and update this policy no later than 10 December 2026 to confirm compliance with the new automated decision-making transparency requirements under Australian Privacy Principles 1.7 - 1.9 when they take effect.
18. Complaints
If you believe we have breached your privacy or mishandled your personal information, please contact our Privacy Officer first, in writing where possible.
We will acknowledge your complaint promptly, treat it confidentially and aim to respond within 30 days.
CGE’s Privacy Officer will investigate the issue and determine steps to undertake to resolve your complaint. CGE’s Privacy Officer will contact you if any additional information is required from you and will notify you in writing of the determination.
If you are not satisfied with our response, you can complain to the OAIC. You can contact the OAIC at www.oaic.gov.au or by phone on 1300 363 992.
19. Contact us
If you have any questions about this policy or wish to make a privacy-related request or complaint, please contact us:
Privacy Officer
CEOs for Gender Equity
Level 1 – 926 Hay Street, Perth
Email: ashley@ceosforgenderequity.com.au
Phone: 0427584088
20. Changes to this policy
We may update this policy from time to time.
We will note the date it was last updated at the top of the policy and let subscribers know about significant changes.
Last updated: 24 August 2026.