Privacy

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1. Introduction

This Privacy Policy outlines how Sport Integrity Australia (SIA) manages personal information, in line with our obligations under the:

Privacy Act 1988 (Cth) (Privacy Act),
Australian Privacy Principles (APPs), the Privacy (Australian Government Agencies — Governance) Privacy Code (Privacy Code),
the World Anti-Doping Code (Code), and the:
International Standard for the Protection of Privacy and Personal Information (ISPPPI).

We must also comply with secrecy provisions in the Sport Integrity Australia Act 2020 (Cth) (SIA Act).

1.1 Protection of personal information

Much of the information we collect, and handle is highly sensitive and personal in nature. All individuals who have dealings with us, including our staff, are entitled to the protection of their privacy. We place great emphasis on maintaining and enhancing the privacy and security of the personal information we hold.

Personal information is defined under section 6 of the Privacy Act as information or opinion about an individual, or an individual who is reasonably identifiable whether or not the opinion is true and is recorded in a material form.

1.2 Overview

We collect, hold, use and disclose personal information to carry out our functions or activities under the SIA Act and other legislation that confer powers or functions on SIA, including the Sport Integrity Australia Regulations 2020 (Cth) (SIA Regulations).

Under sections 21(1) and 21(2) of the SIA Act, our main functions and activities are to:

prevent, monitor, detect, investigate and take enforcement action in relation to threats to sports integrity to counter:
- manipulation of sporting competitions
- use of prohibited substances and methods in sport
- abuse of children and other persons in a sporting environment
- failure to protect members of sporting organisations and other persons in a sporting environment from bullying, intimidation, discrimination, or harassment provide
policy advice, and coordinate a national response to such matters, and engage in education, outreach, and capability building.

More information about our functions is available on our website.

1.3 Athlete Privacy

If you are an athlete, additional information about how we handle your personal information is detailed in our Athlete Privacy Statement.

2. Collection of personal information

We only collect the personal information we need to perform our functions and activities.

2.1 Purposes of collection

We collect personal information for a variety of purposes, including:

performing our legislative and administrative functions
policy development, research, education and evaluation
data sharing or data integration with other Australian Government agencies, or other Anti-Doping Organisations (ADOs)
performing our management, employment and personnel functions in relation to staff and contractors
administering requests received by us under the Privacy Act, the Freedom of Information Act 1982 (Cth) (FOI Act) or the ISPPPI, and
complaints handling.

2.2 Means of collection

We may collect personal information when you:

communicate with us by telephone, mail, email, or SMS,
participate in our anti-doping testing or other programs,
attend a face-to-face meeting or event conducted by us or by people or organisations acting on our behalf (e.g. contracted service providers),
use our website(s) or the Sport Integrity App,
participate in a survey administered by us, or
interact with us on our social media platforms.

We may also collect your personal information from other people and organisations, including other government agencies and sporting bodies, where:

you expressly or impliedly consent (e.g. as part of an anti-doping testing program),
this is required or authorised by or under the SIA Act and SIA Regulations or another Australian law (e.g. to confirm your registration with a sport), or
it is impractical or unreasonable to collect it from you (e.g. as part of performing our investigative functions).

We also monitor news and media, including social media, in the public domain.

2.3 Types of personal information we collect

We collect a broad range of personal information, including:

identity data (name, nationality, date of birth, gender),
contact details (address, phone number, email),
information about your personal circumstances,
participation information (e.g. sport and discipline you compete in, organisations and/or sports federations to which you belong, current level of competition, events, and relationships with coaches and medical professionals),
athlete whereabouts data (training, competitions, travel, time at home, vacation, any other regular or exceptional activities),
data relating to test distribution planning (for the testing pools in which you participate),
medical or biological information including:
- medical conditions and medications or supplements used e.g. for a therapeutic use exemption (TUE)
- information derived from laboratory analysis of samples and specimens
- information collected as part of results management (e.g. drug test history),
information related to sport integrity issues (e.g. complaints and reports),
information collected during hearings and appeals, and
photographs, video recordings, and audio recordings.

We also collect personal information relating to contract management and for providing secretariat services to the Australian Sports Drug Medical Advisory Committee (ASDMAC).

Additionally, we collect and hold personal information in relation to job applicants, employees, contractors and others in relation to employment at the agency. The personal and sensitive information may include records relating to:

personnel (including correspondence, travel records, and applications for employment)
payroll matters
disciplinary and counselling matters
identity documents
security clearances and police record checks
work health and safety matters including accident and injury records, and compensation and rehabilitation files.

2.4 Collection of sensitive information

Sensitive information is a kind of personal information that is afforded higher protection under the Privacy Act and, if compromised, may heighten the ‘risk’ that may flow from a data breach.

Sensitive information includes information about racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union memberships or associations, sexual orientation or practices, criminal record, health or genetic information or some biometric information.

The sensitive information we collect and hold in carrying out our functions and activities includes (but is not limited to):

health, medical and biological information, including medical conditions, medications or supplement use,
health and medical information obtained as part of integrity investigations,
details of blood and urine samples of athletes and laboratory derived information, and
health information of staff.

We may only collect sensitive information where:¹

we have consent,
the collection is required or authorised by or under the SIA Act, SIA Regulations, or another Australian law (e.g. information relating to a TUE), or
the collection is otherwise permitted under the Privacy Act, for example, where a ‘permitted general situation’ exists, such as to lessen or prevent a serious threat to safety.

2.5 Collection of personal information from children and young people

In carrying out our functions and activities, we may collect personal information about children and young people, either directly from them, through their parents or guardians, or from their sporting team or coach and others. We protect personal information regardless of a person’s age.

2.6 Collection of unsolicited information

Sometimes personal information is delivered or sent to us by individuals or third parties without us having requested it.

If you provide unsolicited personal information, we will determine if we are able to collect the information. If we can collect the information, we will provide you with notice of collection in accordance with the requirements of the APPs.

If we are unable to collect the information, we will destroy or de-identify the information unless we are required to retain the information in accordance with the Archives Act 1983 (Cth) (Archives Act).

2.7 Collection via our website and App

We collect your personal information when you use the Sport Integrity App or our website. This includes when you supply information (e.g. through completing a form) or through the operation of Google Analytics.

Further information about Google Analytics, including how to opt-out, is set out in the privacy notice on the Google website.

2.8 Remaining anonymous or using a pseudonym

You may wish to remain anonymous or use a different name (pseudonym) when interacting with us.

However, in some circumstances, it may be impractical for you to remain anonymous or use a pseudonym, or we may be legally required to deal with you as an identified individual.

For example, it is necessary to collect some personal information about you to investigate and resolve an integrity complaint.

3. Use and disclosure of personal information

We may use and disclose your personal information for the primary purpose for which it was collected.

For example, if you correspond with us, we may use or disclose your personal information in order to respond to your correspondence, or address matters raised within your correspondence.

We may use or disclose personal information for a secondary purpose if:

you expressly or impliedly consent (e.g. for research as part of a testing program),
you reasonably expect us to use or disclose the information for the other purpose and it is either related, or directly related (in the case of sensitive information), to the purpose for which the information was collected (e.g. to conduct user satisfaction surveys),
we are required or authorised by or under the SIA Act and Regulations or another Australian law (e.g. to anti-doping organisations and sporting bodies),
we reasonably believe that the use or disclosure is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (e.g. to refer suspected match-fixing or child abuse to relevant authorities),
a ‘permitted general situation’ exists as defined in the Privacy Act (e.g. to take appropriate action in relation to suspected unlawful activity or misconduct of a serious nature), or
where your sport has adopted the National Integrity Framework (NIF), information relating to complaints submitted to SIA may be used and disclosed in accordance with your sport’s Complaints, Disputes and Discipline Policy.

3.1 Disclosure of protected information

Because of the potentially severe consequences to an individual, the SIA Act and SIA Regulations impose strict legal obligations on entrusted persons in relation to the disclosure of ‘protected information’.

Protected information is defined under section 4 of the SIA Act as information that:

was obtained under or for the purposes of the SIA Act or a legislative instrument made under the Act; and
relates to the affairs of a person (other than an entrusted person); and
identifies, or is reasonably capable of being used to identify, the person.

It is an offence for the CEO, a staff member, an ASDMAC member, or certain other persons to disclose protected information to a person other than the person to whom the information relates (section 67 of the SIA Act).

However, it is not an offence if the disclosure is authorised by the SIA Act or is required by certain other laws.

The SIA Act authorises the disclosure of protected information in certain circumstances, including:

if the disclosure is authorised by the SIA Act or is required by certain other laws (section 67(2)),
if the disclosure is for the purposes of the SIA Act (section 68),
if the person to whom the protected information relates consents to the disclosure of their information (section 68A),
if the disclosure will enable or assist another body or person to perform or exercise any of the functions, duties, or powers of the body or person, e.g. a sporting administration body or law enforcement agency (section 68B),
if the disclosure is for the purpose of preventing or lessening a serious threat to the life or health of an individual (section 68C),
the protected information has already been lawfully made available to the public (section 68D), or
if the disclosure is by the CEO for the purposes of SIA responding to certain public comments (section 68E).

3.2 Disclosure of personal information overseas

We may be required to disclose your personal information to parties or persons who are located overseas. For example, it may be necessary for us to disclose personal information to ADOs, sporting bodies, government agencies, or enforcement bodies located overseas in the exercise of our functions under the SIA Act.

International organisations which are likely to receive this type of information include:

WADA (located in Canada)
International Sporting Federations (IFs)
bodies established by IFs to investigate integrity breaches in the sport
major games organisers
foreign national anti-doping organisations
any other organisation that is a signatory to the Code and is responsible for undertaking any part of the doping control processes.

Where information is disclosed to WADA, for example by including information in the Anti-Doping Administration and Management System (ADAMS), this information is subject to protections under Canadian law, specifically the Personal Information Protection and Electronic Documents Act (PIPEDA).

If we store your personal information in databases such as the Athlete Whereabouts Online System (AWOS) and ADAMS, ADOs, national anti-doping agencies, international or national sporting federations, sports bodies and major games organisers may be able to access your data in countries where you compete, train, or travel.

For more information, see our Athlete Privacy Statement.

It is not practicable to list every country to which we may provide personal information as this will vary depending on the circumstances.

Otherwise, we will only send your personal information overseas:

with your consent, or
where the disclosure is made to an overseas enforcement body that performs similar functions or exercises similar powers to SIA.

3.3 Disclosure to service providers

We use a number of service providers to whom we disclose personal information. These include providers that host our website servers and manage our information technology and human resources information.

To protect the personal information we disclose, we:

enter into a contract or MOU that requires the service provider to only use or disclose the information for the purposes of the contract or MOU, and
include special privacy requirements in the contract or MOU to ensure your personal information is handled securely and in accordance with the APPs.

4. Storage and security of personal information

Personal information we hold is stored on secure media including an electronic document and records management system, databases, and paper files. We store and dispose of personal information (when no longer required) in accordance with the Archives Act.

Electronic and paper records containing personal information are protected in accordance with Australian Government security policies.

We take all reasonable steps to protect the personal information we hold against loss, unauthorised access, use, modification, disclosure, or misuse.

If we become aware of a data breach or possible data breach, we will take action in accordance with our Data Breach Response Plan Policy.

5. Access to, and correction of, personal information

Under the Privacy Act, the FOI Act and the ISPPPI, you have the right to ask:

for access to personal information that we hold about you, and/or
that we correct that personal information.

You can request access to, or correction of, your personal information by contacting us (see section 8 of this Privacy Policy).

6. Meta Quest Applications Privacy Policy

Sport Integrity Australia built the following applications (apps) which are available for free download from the Apple App Store and Google Play:

‘Sport Integrity App’ – provides information and tools to help maintain the integrity of Australian sport.
‘Health Effects of Doping’ app – offers an immersive exploration of the health effects of performance enhancing drugs, using Augmented Reality.

Sport Integrity Australia also provides two virtual reality (VR) experience online learning tools, which are available on the Sport Integrity Australia website and via the Sport Integrity App:

‘Doping Control VR’ – allows users to experience the process of sample collection including what to do during a test and educates athletes on their rights and responsibilities.
‘Decision Making in Sport VR’ – puts users in challenging scenarios in sport and empowers them to make decisions and visualise possible outcomes to understand the repercussions of their choices.

In this Meta Quest Applications Privacy Policy (Privacy Policy), ‘the Services’ collectively refers to these apps and resources.

The Services, provided by Sport Integrity Australia at no cost, are intended for use as is. This page is used to inform visitors regarding our policies on the collection, use, and disclosure of Personal Information if anyone decides to use the Services.

Definition of terms

In this Privacy Policy, ‘Personal Information’ has the meaning given in the Privacy Act 1988 (Cth), i.e. information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; or whether the information or opinion is recorded in a material form or not.

Sport Integrity Australia may also hold ‘Protected Information’ which is information that was obtained under or for the purposes of the Sport Integrity Australia Act 2020 (Cth) (the Act) or a legislative instrument made under the Act; and relates to the affairs of an individual; and identifies, or is reasonably capable of being used to identify, the individual.

Disclosure of Protected Information is an offence with a penalty of up to two years imprisonment unless an exception under the Act applies. Further information on this is available in this Sport Integrity Australia Privacy Policy.

Other terms used in this Privacy Policy have the same meaning as in the Sport Integrity Australia Privacy Policy unless otherwise defined in this Privacy Policy.

Information collection and use

If you choose to use our Services, you agree to the collection and use of information in relation to this Privacy Policy. The Personal Information we collect is used for providing and improving the Services. We will not use or share your information with anyone except as described in this Privacy Policy.

For a better experience, to enhance education programs, and inform Sport Integrity Australia’s work to protect the integrity of sport, while using the Sport Integrity App we may require you to provide us with certain personally identifiable information, including but not limited to:

age,
sex,
location,
sports preference,
participation level,
association with sport (Athlete, Coach etc.),
searches conducted in the supplement tool, and;
other information accessed in the App.

To protect anonymity, Sport Integrity Australia does not collect any information on submission of the ‘Give Feedback’ forms within the App

The information we request will be retained by us and used as described in this Privacy Policy
The Sport Integrity App also uses third party services that may collect information used to identify you.

Through your use of the Health Effects of Doping app, we may collect data on:

New installs
Daily active users
Monthly active users
Total sessions
Sessions per user
Time spent on the app
User segments for Country and Platforms
Device OS version (e.g. iOS 13.4.1)
Device model (e.g. Samsung S8)
Build Version (e.g. Android 1(5))
Which parts of the app have been used (e.g. Effects and Substances viewed)
Quiz scores.

We do not collect any personally identifiable data through the Health Effects of Doping app, or the Doping Control VR and Decision Making in Sport VR online resources.

Log data

In case of an error in the apps, we collect data and information (through third-party products) on your phone called ‘Log Data’ which may include information such as your device name, Internet Protocol (IP) address, operating system versions, the configuration of the apps when utilising our Services, the time and date of your use of the Services, and other statistics.

Cookies

‘Cookies’ are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites you visit and are stored on your device's internal memory.

The Services do not use these cookies explicitly. However, the apps may use third-party code and libraries that use cookies to collect information and improve their services.

You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of the Services.

Service providers

We may employ third-party companies and individuals due to the following reasons:

to facilitate our Services
to provide the Services on our behalf
to perform Services-related services; or
to assist us in analysing how our Services are used.

We want to inform users of the Services that these third parties have access to their Personal Information.

The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Security

We value your trust in providing us with your Personal Information and therefore strive to use commercially acceptable means of protecting it.

But remember that no method of transmission over the internet, or method of electronic storage, is 100% secure and reliable, and we cannot guarantee absolute security.

Information deletion

If you wish to delete your information collected through the Sport Integrity App and the Health Effects of Doping app, please follow the steps provided within the apps.

If you require assistance deleting your information, or encounter any issues with deleting your information, please contact us at: education@sportintegrity.gov.au

Please note that deleting your information may result in the loss of certain app functionalities or personalised experiences. By choosing to delete your information from the apps, you understand and agree to the potential impact on your app usage.

Links to other sites

The Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us.

Therefore, we strongly advise you to review the privacy policies of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s privacy

The Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age.

In the case we discover a child under 13 has provided us with personal information, we immediately delete this from our servers.

If you are a parent or guardian and are aware your child has provided us with personal information, please contact us so that we may take the necessary actions.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time and will notify you of any changes by posting an updated version on this page. We advise you to review this page periodically for any changes, which are effective immediately after they are posted.

Contact us

If you have any questions or suggestions about the Meta Quest Applications Privacy Policy, please email: privacy@sportintegrity.gov.au

Further Information

Information on Sport Integrity Australia’s Privacy Policy, which explains how we deal with Personal Information generally (including its collection, storage, security, access, use and disclosure), can be found on this page.

7. Your obligations during an investigation

If you are involved in a SIA investigation into a complaint under your sport’s NIF (for example, as a respondent, complainant, witness, parent/guardian, or support person), you will be required to keep information about the investigation confidential for the duration of the complaints process.

This requirement of confidentiality is in place to make sure that the complaints process is not compromised. This means that you must not discuss information about the investigation process with, or provide information to, anyone who is not directly involved (for example, media).

However, you are able to speak on a confidential basis to:

a Member Protection Information Officer in your sport
a legal or other professional adviser
if you are a complainant or a respondent, a person who may be able to give evidence as a witness to the investigation to confirm if they consent to you providing their details to SIA.

You may be required to continue to keep certain information confidential after the investigation has been finalised where you have been given access to personal information or sensitive information of another person as part of the complaints process.

8. Complaints

If you think we may have breached your privacy, or you are not satisfied with our response to your request, you may contact us to make a complaint (see section 8 of this policy).

If you are unsatisfied with our response, you may contact:

the OAIC at enquiries@oaic.gov.au or telephone 1300 363 992
the Commonwealth Ombudsman by online complaint form or telephone 1300 362 072
WADA at compliance@wada-ama.org or privacy@wada-ama.org

9. Contact us

To find out more about how we manage personal information, to make a privacy-related complaint, or to request access to, or correction of, your personal information, please contact our Privacy team via:

Email: privacy@sportintegrity.gov.au
Post: PO Box 1744, Fyshwick, ACT, 2609
Phone: 1300 027 232

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