⚠ LEGAL DRAFT · HA1 · NOT FOR PUBLICATION

This document is a working draft authored under Standing Order #1 (del.auth) and Standing Order #3 (truthful non-compliance). It is not legal advice. It will be held at HA4 maximum until an external qualified Australian legal practitioner has performed sight-check review. HA5 (board-ratified · publication-ready) is gated on that external legal review per user directive 2026-08-06.

SO #3 · Placeholder registrations. Life Without Debt Ltd is in pre-registration phase. ACNC charity registration, ASIC company registration, and ATO DGR/tax endorsement are not yet finalised. Any registration numbers, ABN references, or DGR statements shown are placeholders under Standing Order #3 (truthful non-compliance) and will be replaced with real values on registration.

Privacy Policy

Life Without Debt Ltd ("LWD", "we", "us", "our") is committed to protecting the privacy of every person who interacts with us — beneficiaries, carers, donors, supporters, referrers, staff, volunteers, and members of the public. This Privacy Policy explains how we collect, use, disclose, hold, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1 · Who we are

Life Without Debt Ltd (ACN: pending · ABN: pending · ACNC registration: pending) is an Australian public benevolent institution. Our paramount beneficiary class is persons in Australia living with terminal, life-limiting, chronic or serious illness, together with their immediate families and primary carers, as defined in clause 4(a) of our constitution.

2 · What personal information we collect

We collect the information reasonably necessary to deliver our services and to meet our legal obligations. Typical categories:

Beneficiary intake data — name, contact details, illness context, carer relationship, consent status, financial hardship indicators, and consumer-debt details relevant to eligibility assessment.
Sensitive information (APP 3.3) — health information is collected only with express consent and only for the purpose of assessing eligibility under clause 4(a).
Donor data — name, contact details, gift amount, payment method reference (tokenised · we do not store full card numbers), gift-aid / DGR receipting information.
Referrer data — name, professional role, organisation, contact details.
Website analytics — device, browser, IP, referrer, and interaction telemetry, collected with consent per our Cookies & Tracking policy.
Communications — records of email, phone, and written correspondence.

3 · How we collect it (APP 3, APP 5)

We collect personal information directly from the individual wherever practical, through our intake forms, donation flows, phone calls, meetings, or correspondence. When a person is referred to us, we collect information from the referrer only with the beneficiary's consent (or the consent of a person with lawful authority to act for them) and we notify the beneficiary of the collection at the earliest reasonable opportunity, in line with APP 5.

4 · Why we collect it (APP 3, APP 6)

We use personal information to: assess eligibility for our services; provide debt-resolution assistance; communicate with beneficiaries, carers, donors, and referrers; issue DGR-compliant receipts; comply with ACNC, ASIC, ATO, state fundraising, and other applicable laws; report anonymised outcomes to donors and grantors; and to safeguard the integrity of our services.

5 · Disclosure (APP 6, APP 8)

We disclose personal information only:

with the individual's consent;
to service providers (secure hosting, CRM, payment providers, professional advisors) bound by confidentiality obligations and, where cross-border, by contractual APP-equivalent protections;
where required or authorised by Australian law;
where necessary to prevent serious threats to life or health.

We do not sell personal information, and we do not disclose personal information to overseas recipients except to the extent our secure hosting and analytics providers process data outside Australia under APP-equivalent contractual safeguards.

6 · Security (APP 11)

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, and disclosure. Measures include role-based access, encryption in transit, encryption at rest for sensitive fields, audit logging (see our AI-governance audit trail at /api/compliance-audit), and secure destruction of records when no longer required.

7 · Access and correction (APP 12, APP 13)

You may request access to the personal information we hold about you and request correction if it is inaccurate, out of date, incomplete, irrelevant, or misleading. Contact us at privacy@cosailifewithoutdebt.org.

8 · Complaints

If you believe we have breached the APPs or this policy, please raise your complaint via our Complaints & Feedback page. If we cannot resolve your complaint to your satisfaction, you may complain to the Office of the Australian Information Commissioner (oaic.gov.au).

9 · AI-assisted operations disclosure

LWD uses AI agents to draft, review, and audit content and to support back-office operations. AI agents do not make service-eligibility decisions and do not decide on debt-resolution outcomes; those decisions rest with authorised humans. Our AI governance is public — see Blended Workforce Design.

10 · Changes to this policy

We review this policy periodically. Material changes will be posted on this page with a revised effective date. This is version 0.1 · HA1 draft · Sprint 34 pending external legal review.

Contact

Life Without Debt Ltd · Australia
Privacy officer: privacy@cosailifewithoutdebt.org

Related: Terms · Cookies · Complaints · Board & Governance