PRIVACY POLICY

# Privacy Policy

**Trail Rescue Australia**
ABN 23 128 921 979
Effective date: 4 August 2026 ·

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## 1. About this policy

Trail Rescue Australia ("**TRA**", "**we**", "**us**", "**our**") is a specialist trail safety, search and rescue, and remote-area response provider based in Alice Springs (NT) and Mansfield (VIC).

Because of the work we do, we handle personal information in circumstances most businesses never encounter: tracking the location of hikers in remote country, holding next-of-kin details, collecting health information during medical support and evacuations, capturing aerial and thermal imagery during searches, and sharing information rapidly with police and emergency services during a live incident. This policy explains what we collect, why, how we protect it, and the choices and rights you have.

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We are committed to handling personal information in accordance with the **Privacy Act 1988 (Cth)** and the **Australian Privacy Principles (APPs)**. Because we provide a health service and hold health information, we treat all such information to the standard the Privacy Act requires, regardless of our size. Where we operate, state and territory privacy and health-records laws (including in the Northern Territory and Victoria) may also apply.

This policy applies to our website, our services, our training and events, and our field operations.

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## 2. The kinds of information we collect

Depending on how you engage with us, we may collect:

**Identity and contact information** — name, postal and email address, phone number, and emergency contact details.

**Next-of-kin and emergency-contact information** — details of the people you nominate to be contacted, or details you provide to us about a hiker you are arranging monitoring for.

**Trip and activity information** — your itinerary, route, trail, dates, group size, experience level, equipment, check-in schedule and expected finish times.

**Location and tracking data** — real-time and historical position data from satellite messengers, personal locator beacons, GPS trackers and similar devices (for example Garmin, ZOLEO, SPOT or comparable systems) used in our monitoring and overwatch services.

**Health information** — information relevant to your safety and care, which may include pre-existing conditions, medications, allergies, injuries, symptoms, treatment provided, and clinical observations recorded during trail medical support, casualty monitoring or evacuation. Health information is "sensitive information" under the Privacy Act and attracts additional protection.

**Imagery and sensor data** — photographs, video, aerial footage, and thermal/infrared imagery captured by our UAV (drone) and field teams during training, searches, rescues and operations. This may include images of identifiable individuals.

**Booking, course and payment information** — the services or courses you book, and payment-related details (note: card payments are generally processed by our third-party payment provider; we do not store full card numbers).

**Website and technical information** — information collected automatically when you use our website, such as IP address, device and browser type, pages visited and interactions, collected through our website platform and analytics tools.

**Correspondence** — the content of enquiries, forms and communications you send us.

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## 3. How we collect personal information

**Directly from you** — through our website enquiry and booking forms, email, phone, course registrations and in-person discussions.

**From a third party who arranges a service** — for example, a family member, next of kin, employer, guiding company or park ranger who books monitoring, welfare checks or support on behalf of a hiker or group. If you provide us with another person's information, you must ensure you are entitled to do so and, where practicable, that they are aware of this policy.

**From tracking and communication devices** — position, movement and status data transmitted by the devices used in our monitoring and overwatch services.

**Through field operations** — including UAV, thermal and photographic capture during training, searches, rescues and support taskings.

**From police, emergency services and partner organisations** — where we are tasked into or support an incident, we may receive information about a person (including a missing person) from the coordinating authority or from clinical partners such as Outback Wilderness Response.

### Collecting information about people who have not engaged us directly

In search and rescue we sometimes hold information about individuals who have not contacted us themselves — for example a missing or injured person who is the subject of a search, or a bystander incidentally captured in aerial or thermal footage. We collect and handle this information only where it is reasonably necessary for the safety and response function we are performing, and consistent with the emergency and law-enforcement provisions described in Section 5.

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## 4. Why we collect, hold, use and disclose information

We use personal information to:

- deliver the service you or a third party have requested, including monitoring, overwatch, welfare checks, medical support, resupply and response;
- plan and conduct search, rescue and support operations safely and effectively;
- contact you, or your nominated emergency contacts and next of kin, including in an emergency;
- provide training, manage course bookings and issue related materials;
- coordinate with police, emergency services, clinical partners and other agencies during an incident;
- maintain records for safety, operational review, insurance, quality and post-incident analysis;
- meet our legal, regulatory and insurance obligations;
- respond to your enquiries and, where you have opted in, send you updates; and
- operate, secure and improve our website and services.

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## 5. Consent, sensitive information, and emergencies

We generally collect **sensitive information** (including health information) with your consent and only where it is reasonably necessary for our functions — for example, when you give us medical details relevant to your safety, or agree to trail medical support.

However, in emergencies the usual expectation of consent may not be practical. Consistent with the Privacy Act, we may collect, use or disclose personal or sensitive information **without consent** where:

- we reasonably believe it is necessary to lessen or prevent a **serious threat to the life, health or safety** of any individual, and it is unreasonable or impracticable to obtain consent (for example, locating and treating a casualty during an active incident); or
- the collection, use or disclosure is **required or authorised by law**, or is reasonably necessary for one or more **enforcement-related activities** conducted by, or on behalf of, an enforcement body such as the police.

In these situations our priority is the safety of the people involved, and we will share the minimum information reasonably necessary with the appropriate authority or clinician.

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## 6. Who we disclose information to

We may disclose personal information to:

- **Police, SES and emergency services** coordinating or supporting an incident, and to the broader Australian search and rescue system;
- **Clinical and medical partners** — including Outback Wilderness Response — for advanced medical care, evacuation and patient handover;
- **Your nominated emergency contacts and next of kin**, where appropriate or in an emergency;
- **Rotary and aviation partners** (for example helicopter operators) supporting an evacuation or extraction;
- **Our vetted contractors and subcontractors** engaged to deliver a service, who are required to handle information consistently with this policy;
- **Service providers** who support our operations (for example website hosting, satellite communications, data storage, payment processing and analytics);
- **Insurers, legal and professional advisers**; and
- **Others where required or authorised by law**, or where you have consented.

We do not sell personal information, and we do not disclose it for the direct marketing purposes of other organisations.

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## 7. Imagery, aerial footage and thermal data

Our work regularly involves capturing photographs, video and thermal/infrared imagery, including from UAVs, during training and operations. We use this material for operational purposes (such as search, navigation, casualty location and post-incident review), and we may use selected imagery to illustrate our work publicly — for example on our website and social channels — under the "From the Field" material.

Where imagery may identify an individual:

- we take reasonable steps to use it appropriately and, where relevant, to de-identify or obtain consent before publication;
- we will not knowingly publish imagery that identifies a casualty or a person who is the subject of a search in a way that would cause harm or distress; and
- if you believe you are identifiable in imagery we hold or have published and you would like it removed or de-identified, contact us using the details in Section 14 and we will assess your request.

Our aerial operations are conducted under CASA authorisation. Imagery capture may also be subject to state and territory surveillance-devices legislation, which we observe.

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## 8. Storage and security

We hold information in a combination of secure electronic systems and, where necessary, physical records. Operational data may be stored on field devices, satellite communications systems (including Starlink), and cloud-based platforms.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure — including access controls, vetting of personnel, and secure transmission and storage. No system is perfectly secure, but we work to reduce risk and to respond quickly if something goes wrong.

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## 9. Overseas disclosure

Some of the service providers we rely on — including our website platform, analytics, communications and cloud storage providers — may store or process data on servers located outside Australia, or may be located overseas. Where we disclose information to an overseas recipient, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles. [If you can identify the countries in which your key providers store data, list them here — e.g. United States, European Union.]

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## 10. Website, cookies and analytics

Our website is built on the Wix platform. Like most websites, it uses cookies and similar technologies to enable functionality, remember preferences and understand how the site is used. You can control cookies through your browser settings, though disabling them may affect how parts of the site work. We may use analytics tools to collect aggregated, non-identifying usage information to improve the site.

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## 11. Direct marketing

We will only send you marketing or promotional communications (such as course announcements or updates) where you have opted in or where it is otherwise permitted. Every such message will include a simple way to opt out, and you can unsubscribe at any time by contacting us. We will not use sensitive information for direct marketing.

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## 12. How long we keep information

We keep personal information only for as long as it is needed for the purposes described in this policy, or as required by law, insurance or our operational and safety obligations — after which we take reasonable steps to destroy or de-identify it. Some records connected to an incident, a medical intervention or a legal or insurance matter may need to be retained for a longer minimum period. [Confirm your retention periods with your legal adviser and, if you wish, state them here — e.g. incident and clinical records retained for [X] years.]

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## 13. Accessing and correcting your information

You have the right to request access to the personal information we hold about you, and to ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact us using the details below. We will respond within a reasonable period. In limited circumstances we may decline access or correction as permitted by law — if we do, we will explain why and how you can respond. We do not charge for making a request, though a reasonable cost may apply for retrieving and supplying information in some cases.

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## 14. Complaints and contact

If you have a question about this policy, wish to make a request, or want to make a complaint about how we have handled your personal information, please contact us:

**Trail Rescue Australia**
Email: info@trailrescue.com.au
Online: www.trailrescue.com.au/contact
 

Please allow 1–2 business days for a reply. We will acknowledge your complaint, investigate it, and respond within a reasonable time.

If you are not satisfied with our response, you may refer your complaint to the **Office of the Australian Information Commissioner (OAIC)**:
Website: www.oaic.gov.au · Phone: 1300 363 992

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## 15. Data breaches

We are committed to protecting the information we hold. If we experience a data breach that is likely to result in serious harm to any individual whose information is involved, we will respond in accordance with the **Notifiable Data Breaches scheme** under the Privacy Act, including notifying affected individuals and the OAIC where required.

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## 16. Changes to this policy

We may update this policy from time to time to reflect changes in our services, technology or legal obligations. The current version is always available on our website, and the effective date at the top indicates when it was last updated. We encourage you to review it periodically.

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*This policy is written in plain English for clarity. It does not limit any rights you have under the Privacy Act 1988 (Cth) or other applicable law.*

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