Privacy Policy: Online Hate Prevention Institute (including Fight Against Hate & CSI CHAT)
Your privacy is important to us. This document explains our approach to privacy in relation to the services we provide, including through our Fight Against Hate and CSI CHAT software tools. In this document we explain what personal information we collect , how and why we use this personal information, and when we share it with others. If you choose to use our Services, you agree to the collection and use of information in relation to this policy.
We also collect, use and share personal information related to both people who do and people who do not use our services and we do so on the legal bases explained in this policy and in compliancy with both the GDPR and the Australian Privacy Principles. The Personal Information that we collect is used for providing and improving the service, protecting public safety and preventing harm. We will not use or share personal information with anyone except as described in this Privacy Policy.
Who we are
The Online Hate Prevention Institute (ABN: 65 155 287 657) (“OHPI”) is an Australian charity and the owner and operator of the Fight Against Hate and CSI CHAT software systems. We operate in the public interest to prevent harm to human beings as a result of online content.
One way we prevent harm from online content is through our online tools which empower the public to report harmful online content outside the mechanisms provided by the platforms hosting this content. We use the reported data to reduce the risk of harm, and through our analysis tools we enable others (our partner organisations) to work with data that is relevant to them so they too can help to reduce the risk of harm.
You can contact us as noted at the end of this policy.
Our tools
The Fight Against Hate system allows the public to report online content. Fight Against Hate’s reporting interface can be accessed directly, or can be accessed through “gateways” embedded in partner organisations’ websites. Fight Against Hate also provides partner organisations with basic analysis functionality so they can see details and summaries of content reported though their gateway. Regardless of whether the system is accessed directly or through a gateway, the software, data and control of access to that data remains with OHPI and is subject to this privacy policy.
The CSI CHAT system has been created for experts, including those in partner organisations, and allows them to conduct more advanced analysis, processing and reporting on the data that was originally reported to Fight Against Hate through one or more gateways.
We operate a mailing list, donation system, surveys, and run petitions which members of the public can use to engage with us and support our work.
Personal Information We Collect About Our Users and How We Use It
Personal information of users, as described below, is needed as long as the user wishes to maintain an account in the system. User information will therefore be retained until a user contacts us to close their account.
Basic personal information we collect about users
We collect personal information about you as a user in order to enable us to provide you with the service and to improve the service. We collect this data directly from you, from external systems you authorize to share this information with us, or from technical information your device provides as part of your connection to our service. This information is collected on the basis of consent, that is, that you give us permission to collect this data as a condition of using the service.
The specific personal information we collect:
| What we collect | Why we collect it | How we collect it |
| Your name | To personalize your experience | This data is collected from Facebook when you register with Fight Against Hate using the Facebook login option. |
| Your e-mail address | 1) To communicate with you
2) For account security purposes |
This data is collected from Facebook when you register with Fight Against Hate using the Facebook login option. |
| IDs for linked accounts | To enable you to register / login using a linked account | This data is collected from Facebook when you register with Fight Against Hate using the Facebook login option. |
| Your IP Address | For security purposes | This is collected automatically when you visit a page hosting a Fight Against Hate gateway |
Sensitive personal information we collect about users
We may also give you with the opportunity to optionally provide sensitive personal information as described in the table below.
| What we collect | Why we collect it | How we collect it |
| Location, year of birth, gender, sexual preference, religion, nationality and ethnicity. | This information, when provided, will enable those using our systems for analysis to select reports that have come from certain segments of the community based on these attributes. When reports are presented for such analysis, the specific details of who reported the content (i.e. the details in the table above) will not be shared. | We will only collect sensitive information directly from you. It will only be collected by you entering it into our system, for example, by editing your profile page. |
We also collect financial information in relation to donations and the campaigns / areas of work the donor wishes to support. This is collected to meet our legal obligations and to allow us to make resource allocation decisions in a manner that takes account of the wishes of donors. This data is only collected directly from you, when you provide it to us, while making a donation.
Personal information we create about users
Based on your interactions with Fight Against Hate, the system will generate data which may be considered an opinion about you. These opinions relate to the types of things you report and how accurate the system considers you to be.
These generated opinions may be used to:
- Vary the system’s confidence about the accuracy of items you reported or reviewed
- Select content for you to review
- Control access to features for more experienced users
- Customize communications with you e.g. by including news related to the sort of content you usually report, and potentially excluding content you don’t usually report
- Select your account for investigation if abuse is suspected
By using the system you give your consent for this processing. The system for calculating the accuracy of a user in making reports, and the opinion on the specific accuracy of individual users, are part of the Online Hate Prevention Institute’s intellectual property. As such these details are not available for inspection. A user may have this information removed by requesting deletion of their account.
Cookies
Fight Against Hate does not directly use cookies. We do allow users to login with Facebook and some features are only available to logged in users. Please see Facebook’s privacy policy in relation to their use of cookies.
CSI CHAT uses session cookies for the purpose of managing user logins. These cookies are used solely to provide the CSI-CHAT service to you.
Collection of User Personal Information Related to Abuse of the System
In the event that a person uses the Fight Against Hate software in an effort to undermine the Fight Against Hate system or OHPI’s work more generally, that user’s data (including all user data described above) will be collected on the basis that OHPI is engaged in a public task, that is, a task in the public interest and protecting system form abuse is part of this task. When data is collected on this basis, the right of a user to have their data erased no longer applies.
Viewing, correcting and deleting users personal information
You can see both the basic and sensitive information we have on you as a user at any time by viewing your profile. From your profile you can add, update or remove any of the sensitive information you have previously provided. Your basic information can only be removed by deleting your account, in which case you will no longer be able to use the system. To delete your account please contact us.
Personal Information We Collect About Reported Content
We collect reports about online content from the public. These reports consist of links to the content, screen captures of this content and text from and relating to the content. This data may contain personal information, for example, where the reported content is an online profile the data captured may include the name associated with that profile which may be a person’s real name. The content captured in a screen capture, or the text extracted from the content may include other personal information such as gender, age, location, or any other personal information the initial poster chose to share via the content they posted online.
Our basis for collecting personal information related to reported content is that our collection and use of this data is a public task, that is, a task carried out in the public interest (GDPR Art 6). This collection is necessary for OHPI to carry out its functions and activities (APP 3.2).
The right to be forgotten (the right to erasure of personal information) does not apply to personal information collected for a public task.
Personal information in reported content is of on-going use to our public purpose, including as part of an archive of reported content. We will retain it as long as it is of value for our public purpose, unless we believe there are overriding grounds to remove specific content sooner.
How We Use Personal Information from Reported Content
Content that is report to Fight Against Hate may be used by the Online Hate Prevention Institute to:
- Request the removal of the content by platform providers
- Notify relevant government agencies of threats to life, health, public safety or property
- Publish material discussing the content
- Run campaigns to encourage reporting of the content
- Analyse the content together with other content on an empirical basis
- Prepare confidential advice based on the content
Personal information such as names and photographs will generally be redacted from content we include in material made available to the public. This personal information may, however, be included when the person is a public figure, a regular promotor of online hate, or where we believe there is a public interest reason in favour of including the information in our public materials. In deciding whether to include personal information in public documents we recognise that such information is already in the public domain, but that our inclusion of this information will create a public record that may persist beyond the original online content.
Personal information such as names and photographs will generally be included in confidential reports. This enables the recipient of such reports such as law enforcement, other government agencies, the company hosting the content, the impacted individual or a representative group of such individuals, to take appropriate action to reduce the risk of harm.
Reported content may also include online account information such as a Facebook user ID. Twitter handle, or YouTube username. We may public this information as it is necessary to carry out our public task, that is, to accurately engage with this form of online content. This includes publishing links to such content when encouraging people to report it.
How we keep your personal information safe
Access to Fight Against Hate and CSI CHAT systems are permitted via an SSL connection. This protects data while it is in transit. User accounts are protected using the Facebook login system. To increase security, users can enable 2 factor authentication via Facebook.
Fight Against Hate has been designed to only give users the information they need. The only person who can see a user’s complete profile, that is both their basic and sensitive personal information, is that user.
When partners see content reported through Fight Against Hate, whether in Fight Against Hate or CSI-CHAT, that content is not associated with any identified or identifiable users.
Neither basic nor sensitive user information about identifiable Fight Against Hate users is accessible through CSI-CHAT. Collections of reported content, or summary data giving the number of such reports, may be generated based on sensitive personal information but this data is an aggregate of data from multiple users and no user is identified or identifiable from this information.
How we share personal information
The Online Hate Prevention Institute also shares personal information with our network of partners around the world. Each partner is a civil society organisation, government agency, academic institution, company or person that has been approved by the Online Hate Prevention Institute.
We may share personal information we have collected on reported content with our partners. When we do so it is on the basis that they have agreed to use the provided data only for work carried out in the public interest. Active partners who can see reported content through CSI-CHAT or Fight Against Hate will vary from time to time.
We may share the name and e-mail address of a Fight Against Hate user with a partner where that user has explicitly given their content to this personal information being shared. Our policy is that users must actively choose to enable such sharing.
When we share information about reported content with partners we may include demographic information about the user(s) who reported that content. The data about reported content will, however, be anonymous as personally identifying information (such as a name or e-mail address) will not be linked to data about reported content. An exception to this policy is when a user gives their content to being associated with a particular report.
Personal Information Rights of Fight Against Hate Users
Access – Fight Against Hate users have a right to access their personal information for free. This can be done as described in the section “Viewing, correcting and deleting users personal information”.
Rectification – Fight Against Hate users have right to have errors in their personal information corrected. This can be done as described in the section “Viewing, correcting and deleting users personal information”.
Erasure – Fight Against Hate users have right to be forgotten, that is, to request their personal information is deleted. This can be done as described in the section “Viewing, correcting and deleting users personal information”.
Restrict processing – You may in some circumstances have a right to restrict the processing of your personal information. Please contact us to make such a request.
Portability – You may copy your personal information from your profile page. If you require it in another format, please contact us.
Withdrawal of consent – You have the right to withdraw your consent to our use of your user information. To do so, please contact us with a request to close your account.
We will respond within 30 days to requests from users to exercise their rights. Where requests are made electronically, we will reply electronically.
Personal Information Rights of a Person Identified in Reported Content
In order to protect the privacy of individuals whose may have been identified in reported content, we cannot give effect to any rights related to personal information (as listed below) until we are satisfied that the request comes from the identified person. We may therefore request additional information to establish both your identity and that the content you are querying relates to you (e.g. that it is your social media account).
Any content provided to us to establish a person’s identity or their ownership of an online account may be collected by us on the basis that we may need it for compliance with our legal obligations and that keeping such a record is in keeping with our public task. Any content you share with us may be added to our system if it was not previously reported to us, but it could have been.
Where we are satisfied beyond a reasonable doubt that the person making a request is the person whose personal information in present in reported content, the following rights apply:
Access – You can ask us to confirm if we are processing your personal information. If we are, you can ask us for a copy of the personal information.
Rectification – You can ask us to correct inaccurate or incomplete personal information.
Restrict processing – You have a right to request restricted processing of your information in some circumstances, for example if a verification of overriding grounds is pending.
Right to object to processing – You have the right to object to the processing of your information. We have the right to argue that there are a compelling legitimate grounds for the processing of your information and that these grounds override your interests, rights and freedoms which form the basis of your objection. Generally we believe that where information is, or was, publically available and attacked the rights of others, there is a compelling legitimate ground to both keep and process such information.
Please note that the rights to erasure and portability do not apply when content is collected on public interest grounds (as is the case here).
Updates to this policy
Please note this policy may change from time to time. This page will be updated if changes are made to the policy. If major changes occur, we will notify registered users by e-mail.
How to contact us
Data Controller: Online Hate Prevention Institute
The Online Hate Prevention Institute’s primary contact person is our CEO, Dr Andre Oboler. You can us through the contact form on our website: https://ohpi.org.au/contact-us/ or by post to our registered office at Level 6, 151 Macquarie St, Sydney NSW 2000.
GDPR Representative: Stefano Gatti can be contacted via: https://www.osservatorioantisemitismo.it/contattaci/