The Digital Compass The Digital Compass

The Digital Compass

Privacy Policy

1

About this policy

How The Digital Compass handles personal information.

The Digital Compass is an Australian management consultancy, operated by The Digital Compass Pty. Ltd. ACN (to be confirmed) ABN (to be confirmed).

This policy explains how we handle personal information: what we collect and why, who we share it with, and how you can see it, correct it or make a complaint. We follow the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

It covers our clients and the people we work with at client organisations, the consultants and partner firms who deliver our work, people who contact us or visit our website, people who come to our events or subscribe to our updates, and our suppliers.

2

What we collect

We only collect what we need for the relationship you have with us.

If you areWe may collect
A client or prospective client contactYour name, role, organisation, work email and phone number, our correspondence with you, and notes of meetings and calls.
A consultant or partner firm working with usYour name and contact details; your business details (ABN, business structure and GST registration); bank account details for payments; your experience, skills, qualifications, certifications and availability; the rates and fees you agree with us; insurance certificates and expiry dates; your signed agreements; timesheets, expense claims and payment records; activity logs for any Microsoft 365 account we give you; and, only where an engagement requires it, your security clearance level, police check or confirmation of your right to work.
Someone who contacts us or visits our websiteYour name, email address and anything you include in your message, plus technical information such as your browser, device and pages visited (see section 4).
An event attendee or subscriberYour name, email address and organisation, and any dietary or accessibility needs you choose to tell us.
A reference contactYour name, role, organisation and work email address, the case study or use case you agreed to, and what you agreed to: being named, having it published, or taking a call from a prospective client.
A supplierContact and payment details for the people we deal with.

Sensitive information

Some information, such as health information or criminal record information, is sensitive under the Privacy Act. We only collect it with your consent and where it is reasonably necessary, for example a police check a client requires for an engagement, or accessibility needs for an event.

Staying anonymous

You can make a general enquiry without giving us your name, or using a pseudonym. We can't deliver work for you or engage you as a consultant without knowing who you are.

3

How we collect it

Mostly from you directly. Where it comes from someone else, we'll take reasonable steps to let you know.

  • From you, when you email or call us, meet with us, fill in a form on our website, sign up to the TDC Platform, sign an agreement with us or register for an event.
  • From meetings. We may record or transcribe meetings held on our Microsoft 365 accounts to capture notes and actions. We always tell participants beforehand and ask for their agreement.
  • From our consultants and partners, when they introduce us to an organisation.
  • From clients, who give us the details of their people we'll work with on an engagement.
  • From public sources, such as company websites and professional networking sites like LinkedIn.
  • From others with your consent, such as referees, insurers or background check providers.
4

Our website and cookies

Our website uses cookies to work properly and to help us understand how it's used.

Cookies are small files your browser stores. We use cookies the site needs to function and, where we use analytics tools, cookies that tell us how visitors use the site in aggregate, such as which pages are popular. We don't use them to identify you personally.

You can block or delete cookies in your browser settings. Some parts of the site may not work as well if you do.

5

Why we use it

To run our business and deliver our services, and for the other purposes you'd reasonably expect.

  • To respond to enquiries and manage our relationships with clients, consultants, partners and suppliers.
  • To scope, propose and deliver consulting engagements.
  • To put together the right team for each engagement.
  • To run our internal systems for contracts, insurance and compliance checks, timesheets, expenses, invoices and payments.
  • To send marketing, newsletters and event invitations (section 6).
  • To show who works with us, by naming the consultants and partner firms who have agreed to it, with their logo, photo or experience summary, on our website and in proposals.
  • To keep our systems and information secure.
  • To meet our legal obligations, including tax, accounting and record keeping.
  • To record the case studies and references that clients and contacts have agreed to, and to use them when we bid for work.
  • To improve our services.

We won't use your information for an unrelated purpose unless you agree or the law allows it.

6

Marketing, newsletters and events

We may send you insights, updates and event invitations. You can opt out at any time.

We send marketing to business contacts, subscribers and the consultants who work with us where the law allows, in line with the Spam Act 2003 (Cth). Every marketing email has an unsubscribe link, or you can email enquiries@thedigitalcompass.com.au and we'll take you off the list.

If you register for an event, we use your details to run it. If we take photos or video at an event, we'll say so at the event.

7

AI and automated decisions

We use AI tools to help us work. People make the decisions.

We use AI tools in our internal systems and our day-to-day work to draft documents, summarise notes, answer questions about our policies and help us identify which consultants suit an engagement. We use these tools under business terms that don't allow our data to be used to train the provider's models. Nobody working on our engagements may put a client's personal information into an AI tool unless the client has agreed.

AI may help us identify consultants who suit an engagement, based on their experience, skills and availability, and our systems check that anyone working on an engagement has a signed agreement and current insurance. People make the decisions. We don't make any decision that significantly affects you by automated means alone.

8

Who we share it with

Only with the people who need it to deliver our services, and never for sale.

  • Clients, when we propose a consultant for an engagement. We share the details of their experience relevant to that work.
  • Consultants and partner firms delivering an engagement, who receive the work contact details of client staff they need to deal with. They are bound by our agreements and policies.
  • Service providers who run technology for us, such as email and document storage, accounting, electronic signing and AI tools.
  • Professional advisers, such as our accountants, lawyers and insurers.
  • Government agencies and regulators, where the law requires it, such as the Australian Taxation Office.

We never sell personal information.

9

Overseas disclosure

Our main database is in Australia, but some of our providers process information overseas, mainly in the United States.

Some of our service providers may store or process personal information outside Australia. The country where this is most likely is the United States. Some providers also use data centres in other countries, which can change over time.

We choose established providers and take reasonable steps, including through our contracts with them, to make sure they handle personal information consistently with the Australian Privacy Principles.

10

Keeping it secure

We take reasonable steps to protect personal information from misuse, loss and unauthorised access.

We limit access to the people who need it, secure the devices and accounts used for our work, and keep client information on client systems or our own wherever we can. Everyone who works on our engagements is bound by our confidentiality, privacy and security requirements.

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How long we keep it

Only as long as we need it, or as long as the law requires.

We keep personal information while we need it for the purposes in section 5, and for as long as we must keep records for tax, accounting and legal reasons. Everyone who works on our engagements must delete engagement information held outside our systems within 10 business days of the engagement ending.

If you ask us to close your TDC Platform account, we'll delete your details and keep only the records we are legally required to keep. When we no longer need information, we destroy it or de-identify it securely.

12

Accessing and correcting your information

You can ask to see the personal information we hold about you and ask us to correct it.

  • Email enquiries@thedigitalcompass.com.au with "Privacy" in the subject line. We'll check your identity before we release anything.
  • We'll respond within 30 days. There's no charge to ask.
  • Consultants can update most of their own details directly in the TDC Platform.
  • If we refuse a request, we'll tell you why in writing and how you can complain.
13

Data breaches

If something goes wrong, we act quickly and tell the people affected where the law requires.

If we suspect a data breach, we contain it and assess it straight away. Where it is likely to cause serious harm, we notify the people affected and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme.

14

Complaints

Tell us first. If you're not happy with our response, you can go to the regulator.

If you think we've mishandled your personal information, email enquiries@thedigitalcompass.com.au with "Privacy complaint" in the subject line. We'll acknowledge it, look into it and respond within 30 days.

If you're not satisfied, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.

15

Changes and contact

We'll update this policy as our business changes, and post the new version here with its date.

The Digital Compass Pty. Ltd. ACN (to be confirmed) ABN (to be confirmed), trading as The Digital Compass

(to be confirmed)

enquiries@thedigitalcompass.com.au