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DNA Family History Research Office (“we”, “us” or “our”) respects your privacy and recognises that family history and DNA research can involve highly personal and sensitive information.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information. Our privacy practices are designed to align with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) and, where applicable, other Australian and New South Wales privacy legislation.

1. Information we may collect

Depending on the services you use, we may collect information including:

• your name, address, telephone number and email address;

• billing, booking and correspondence information;

• dates and places of birth, marriage and death;

• family trees, genealogical records, photographs and historical documents;

• information about family relationships and biological relationships;

• DNA testing information, including ethnicity estimates, DNA matches, shared DNA measurements and chromosome data;

• raw DNA data where this is required for an agreed service;

• GEDmatch kit numbers and information from other genealogy or DNA platforms;

• information about relatives and other individuals appearing in genealogical records; and

• information you voluntarily provide during consultations, research or correspondence.

Genetic information is considered sensitive information under Australian privacy law and is handled with particular care.

2. How we collect information

We generally collect personal information directly from you when you:

• contact us;

• book a consultation, workshop or service;

• provide documents, family trees or DNA information;

• participate in a consultation;

• communicate with us by telephone, email, online forms or other means; or

• authorise us to undertake genealogical or DNA research on your behalf.

Information may also be obtained from publicly available genealogical and historical sources, archives, family-history databases, DNA platforms or other sources where this is reasonably necessary for the research you have commissioned.

3. Why we collect and use information

We use personal information primarily to provide the services you have requested. This may include:

• genealogical research;

• family-tree construction and analysis;

• DNA and genetic-genealogy analysis;

• identifying or investigating family relationships;

• tutoring and consultation;

• GEDmatch and DNA-match analysis;

• digitisation and organisation of family records;

• communicating with you about your research;

• administration, invoicing and appointment management; and

• improving the services we provide.

We will not use sensitive or genetic information for unrelated purposes without your consent unless permitted or required by law.

4. DNA and genetic information

We recognise that DNA information can reveal information not only about you but also about biological relatives.

DNA information supplied to us is used only for the purpose of providing the service you have requested or for another purpose to which you have expressly agreed.

We do not sell, trade or commercially distribute client DNA information.

We will not make your raw DNA data, DNA matches or biological relationship information publicly available without your permission.

Where analysis requires the use of a third-party service such as GEDmatch, a DNA testing company or another specialist analytical platform, this will only be done where it is reasonably necessary for the agreed service and, where appropriate, with your knowledge or consent.

5. Information about other family members

Genealogical research inevitably involves information about relatives and other individuals.

Australian privacy legislation generally protects information relating to living identifiable individuals. Information relating solely to deceased persons is generally not personal information for the purposes of the Commonwealth Privacy Act.

Where you provide sensitive information about another living person, we ask that you only provide information that is reasonably necessary for the research and that you have an appropriate basis for providing it.

We will treat information about living relatives with the same care and discretion that we apply to information about our clients.

6. Disclosure of information

We do not disclose personal information to third parties except where:

• it is necessary to provide a service you have requested;

• you have consented to the disclosure;

• a professional or technology service provider requires limited access in order to provide services to us;

• disclosure is required or authorised by Australian law; or

• another lawful exception applies.

Service providers may include website and booking providers, secure cloud-storage providers, email providers, payment processors, genealogy databases and DNA-analysis platforms.

We do not sell client lists, genealogical information or DNA information to third parties.

7. Overseas services and data storage

Some genealogy, DNA, website, email, cloud-storage and technology providers operate outside Australia or store information on servers located overseas.

Where an overseas service is used, we take reasonable steps appropriate to the circumstances to protect personal information and to use reputable service providers.

Because the location of cloud infrastructure and genealogy databases may change from time to time, information may be processed or stored in countries in which our service providers operate, including the United States and other jurisdictions.

Where particularly sensitive information is to be transferred to a third-party DNA or genealogy service, we will where appropriate discuss this with you as part of the service being provided.

8. Security

We take reasonable steps to protect personal and sensitive information from misuse, interference, loss, unauthorised access, modification or disclosure.

Depending on the information involved, these measures may include password protection, access controls, secure devices, secure cloud services and limiting access to information to what is reasonably necessary.

No method of electronic transmission or storage can be guaranteed to be completely secure. We therefore also minimise the amount of sensitive information retained wherever reasonably practicable.

9. Retention and deletion

Personal information is retained only for as long as it is reasonably required to provide our services, maintain appropriate business and research records, meet legal or accounting requirements, or deal with subsequent questions relating to completed research.

Sensitive DNA files and other information that is no longer reasonably required will be securely deleted, destroyed or de-identified where practicable, subject to any legal requirement to retain it.

You may also ask us to delete information that you have supplied. We will comply where reasonably practicable and where we are not legally required to retain the information.

10. Accessing or correcting your information

You may request access to personal information that we hold about you or ask us to correct information that is inaccurate, incomplete or out of date.

We will respond to reasonable requests within an appropriate period and in accordance with applicable privacy law.

There may be limited circumstances in which access cannot legally be provided, including where providing access would unreasonably affect the privacy of another person.

11. Anonymity and pseudonyms

Where practicable, you may make a general enquiry without identifying yourself.

However, most genealogical and DNA services require sufficient identifying and family information to enable the requested research to be carried out.

12. Website information, cookies and analytics

When you visit our website, certain technical information may be collected automatically by our website platform or analytics services. This may include:

• IP address;

• browser and device type;

• pages visited;

• referring website;

• approximate location; and

• information collected through cookies or similar technologies.

This information may be used to operate the website, understand how visitors use it, improve its performance and measure the effectiveness of our communications.

You may be able to restrict or disable cookies through your browser settings, although doing so may affect some website functions.

13. Marketing communications

We may contact existing or prospective clients about our services where permitted by law.

You may opt out of marketing communications at any time by using an unsubscribe facility where provided or by contacting us.

We will not use DNA information or sensitive family information for marketing purposes.

14. Data breaches

If a data breach involving personal information occurs, we will take reasonable steps to contain and assess the breach.

Where required by the Notifiable Data Breaches scheme under the Privacy Act, we will notify affected individuals and the Office of the Australian Information Commissioner.

15. Privacy complaints

If you have a concern about how we have handled your personal information, please contact us first so that we can investigate and respond.

We will take privacy complaints seriously and endeavour to resolve them within a reasonable period.

If you are not satisfied with our response and the Privacy Act applies to the matter, you may be able to make a complaint to the Office of the Australian Information Commissioner (OAIC).

Where New South Wales health-information legislation applies, you may also have rights through the Information and Privacy Commission NSW.

16. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our services, technology or legal obligations.

The current version will always be published on our website together with its effective date.

17. Contact

For questions about this Privacy Policy, requests to access or correct information, requests for deletion, or privacy complaints, please contact:

DNA Family History Research Office
Sydney, New South Wales, Australia
Email: dan [at] dnarnold.com
Website: www.dnarnold.com