Earthwatch: Complaints Handling Policy

Complaints Handling Policy

Complaints Handling Policy

    Earthwatch is committed to handling complaints.

    Earthwatch Institute (Earthwatch) – ABN 25 875 253 851


    This Privacy Complaints Handling Policy ("Policy") defines a process for the notification, response and resolution of complaints regarding Earthwatch's information handling practices, including the collection, use and disclosure of personal information about any person by any Earthwatch employee or contractor (collectively "Earthwatch personnel"). This Policy applies to any complaint relating to Earthwatch's information handling practices.

    Earthwatch typically collects and uses personal information from donors, expedition participants and volunteers such as identifying information, contact information and financial information (such as credit card details). From time to time, Earthwatch may also collect sensitive information, for example when medical details are required in order to participate in some expeditions.

    When dealing with personal information Earthwatch is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"). This Policy addresses APP 1.2 which requires Earthwatch to take all reasonable steps to implement practices, procedures and systems to enable Earthwatch to deal with inquiries or complaints about Earthwatch's compliance with the APPs. In this Policy, unless otherwise stated, all references to personal information include sensitive information.


    It is the responsibility of the Director of Business Operations to ensure that the procedures in this Policy are followed and that the Policy is maintained and provided to all relevant Earthwatch personnel. It is the responsibility of all Earthwatch personnel to read and comply with this Policy.

    Definitions and Concepts

    Personal and sensitive information – Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is:

    • true or not; and
    • recorded in a material form or not.

    Sensitive information means information or an opinion about an individual’s:

    • racial or ethnic origin; or
    • political opinions; or
    • membership of a political association; or
    • religious beliefs or affiliations; or
    • philosophical beliefs; or
    • membership of a professional or trade association; or
    • membership of a trade union; or
    • sexual preferences or practices; or
    • criminal record,

    that is also personal information; or

    • health information about an individual; or
    • genetic information about an individual that is not otherwise health information; or
    • biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
    • biometric templates.

    When does Earthwatch collect, use and disclose personal information?

    Collection – Earthwatch collects personal information if it or any Earthwatch personnel gather, acquire or obtain personal information from any source and by any means for inclusion in a record or generally available publication. Collection includes whenever Earthwatch keeps personal information it has not asked for or it has come across by accident.

    Disclosure – In general terms, Earthwatch discloses personal information when it releases information to others outside Earthwatch. Disclosure does not include giving an individual information about themselves (this is "access").

    Use – In general terms, use of personal information refers to the handling or management of personal information within Earthwatch, including accessing the information or including the information in an internal publication.

    Referral to the Director of Business Operations

    Any Earthwatch personnel who receive a complaint or query relating to Earthwatch's information handling practices (including the collection, use or disclosure of personal information) ("Complaint") should refer the Complaint to the Director of Business Operations.

    Record of Complaints

    Any Earthwatch personnel who receive a Complaint must ensure a written record of the Complaint is documented which records:

    • the name and contact details of the individual making the Complaint ("Complainant");
    • the details of the Complaint; and
    • the date the Complaint is received.

    The record of the Complaint must be provided to the Director of Business Operations.


    The Director of Business Operations will take all reasonable steps to investigate and resolve the Complaint, which may include:

    • delegating the Complaint to be investigated by appropriate Earthwatch personnel;
    • verification of any alleged data breach;
    • review of collection statements and consents relating to the Complainant;
    • review of Earthwatch's security and management procedures;
    • referral for internal or external legal review and advice and subsequent liaison with legal personnel; and
    • interviewing such persons as the Director of Business Operations deems appropriate.

    Within 14 days of receipt of the Complaint, the Director of Business Operations must provide a written response to the Complainant detailing:

    • if Earthwatch reasonably believes that the subject matter of the Complaint is substantiated, the steps Earthwatch has, or will, take to address or resolve the Complaint;
    • if Earthwatch denies the subject matter of the Complaint and does not reasonably believe that a privacy breach has occurred, the reasons for the denial; and
    • the Complainant's further options in relation to the resolution of the Complaint, including referral to the Office of the Australian Information Commissioner.

    Notification of Complaints to Affected Third Parties

    If a Complaint relates to Earthwatch's collection, use or disclosure of personal information which was:

    • received from a third party;
    • disclosed to a third party; or
    • used by a third party,

    the Director of Business Operations must consider whether to:

    • inform that third party of the Complaint and its outcome; and/or
    • request that third party to amend its information handling practices with respect to such personal information.

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