Donation, Site User and Privacy Policy

Global Development Group – Donations and Refund Policy (Updated 04 September 2026)

(NB in accordance with GDG’s full “Privacy, Donation & Site User Policy)

Applies to: All donations are received subject to this policy and/or our site user policy (including privacy policy). This applies to all donations made via GDG’s website, fundraising platforms, bank transfer, cheques, cash or other approved channels.

Summary Statements (in compliance with ATO specific audit directives):

In principle, all AUD donations to GDG with a preference for GDG approved aid and development projects &/or benevolent activities are tax deductible in Australia.

All donations are received as voluntary, unconditional gifts (‘free and clear – with no strings’) to GDG as a charity – irrespective of any contrary statements made by GDG &/or project personnel.

GDG will take all reasonable steps to record and consider donor project preferences and will endeavour to follow them, however…

GDG must exercise charity discretion and cannot legally guarantee a preference will be met.

Additionally, if funds raised exceed the requirement for any project – for any reason, including non-compliance or closure of a project – funds may be directed to another approved project/activity without notice.

Note:

Donations are not purchases of goods or services and therefore do not create a legal entitlement for a refund. Refunds will only be considered in exceptional circumstances (see below).

GDG may impose a minimum donation threshold of $2 or more as a fraud prevention measure.

No non-development activities (evangelism, welfare or political activities) are funded by, or are a part of Global Development Group aid and development projects.

If, in their own time, board members, staff, volunteers and contractors of GDG or partner organisations undertake or participate in evangelism, proselytism and/or missionary work, partisan political activities or welfare, they must ensure that their activities are not perceived or viewed as being on behalf of or representative of Global Development Group.

1. Purpose

Purpose: This policy explains how Global Development Group (ABN 57 102 400 993) (“GDG”, “we”, “us”, “our”) manages donations, issues receipts, and considers refund requests. It aligns with:

Australian charity law

ATO deductible gift recipient (DGR) requirements

ACNC Governance Standards

ACNC External Conduct Standards

ACFID Code of Conduct

Fundraising Institute Australia (FIA) Code of Conduct

AML/CTF and sanctions obligations

2. Nature of donations

Voluntary gifts: Donations are voluntary, irrevocable gifts (“with no strings attached”) to support GDG’s charitable purposes and may optionally indicate a preference for an approved project – which GDG will note and consider but cannot legally guarantee: the charity must exercise discretion (ATO Audit requirement).

No purchase: Donations are not payments for goods or services and are therefore not subject to Australian Consumer Law (ACL, 2010). Donations do not create a contractual or legal right to a refund.

3. Receipting and tax deductibility

DGR status: GDG is endorsed as a deductible gift recipient (DGR) as an entity and for eligible activities.

We issue Receipts: In Australia, for donations made in AUD, we issue DGR-compliant tax deductible receipts showing our name, ABN, date, amount, a statement that the donation is a gift, and any noted – but not guaranteed – project preference. (ATO Audit & ATO guidance: https://www.ato.gov.au/non-profit/gifts-and-fundraising/deductible-gift-recipients).

Tax advice: circumstances vary so donors should seek tax advice about deductibility.

4. Refunds – general principle

No general legal right to refunds: GDG has no legal obligation or justification to refund donations – which are, by definition, voluntary unconditional gifts, not purchases. However, we may consider refunds in limited circumstances as set out below, on a case-by-case basis.

5. Refunds – limited circumstances and 30-day window

Time limit: Requests must be made within 30 days of the donation date.

Grounds for consideration: We may consider a refund due to…

Error: incorrect amount, duplicate payment, or mistaken frequency;

Unauthorised/fraud: the transaction was not authorised by the account holder;

GDG processing error: we misapplied your instructions;

Misrepresentation: you can demonstrate that you were materially misled about the nature or purpose of the donation;

Vulnerability/hardship: there are exceptional circumstances involving donor vulnerability or serious financial hardship.

Evidence: We may request supporting information (e.g., bank statements, correspondence, supporting medical statements/declarations) to assess the request.

Process: In the limited circumstances where a refund request is approved by GDG, we will only ever process a refund for the same (or less) amount, in the same currency and to the same bank account or credit/debit card as originally used for the donation. All reasonable steps will be taken to minimise the incidence of fraudulent refunds made to incorrect accounts.

6. When refunds will not be made

Outside 30 days: We will not refund donations made more than 30 days ago.

Funds already committed: We will not refund donations already disbursed or committed to projects.

Change of mind: We will not refund donations where the donor has simply changed their mind &/or no longer wishes to support the project.

7. Process for requesting a refund

How to request: Contact:
Admin at Global Development Group: [email protected]
Phone: (+61) (0)7 3341 6475

Information required: name, contact details, date and amount of donation, payment method, and the reason or justification for the refund request, and provision of sufficient supporting evidence.

Assessment: We will assess requests case-by-case and respond within a reasonable time. We may request additional information or evidence to verify your request.

8. Tax implications of refunds

Tax deductions: If a donation is refunded you may need to amend any tax return where a deduction was claimed. This may result in potential fees and interest charges levied by the ATO.

ATO reporting: GDG may adjust its reporting &/or report to the ATO as required.

9. AML/CTF, Sanctions and suspicious activity

Compliance: We may delay, refuse or return donations where required by AML/CTF or sanctions laws, and report suspicious matters to the ACNC, DFAT, the AG’s Department, AUSTRAC or other authorities.

10. Relationship with Privacy Policy

Privacy: Refund requests will be handled in accordance with GDG’s Privacy Policy, including how we collect, use and store personal information and how we use information to verify the circumstances relating to refund requests.

(Updated September 2026)

Introduction and scope

In general: This Privacy Policy explains how we collect, use, disclose, store and protect personal information, including in connection with donations, sharing personal information with our approved project partners, our commitment not to give or sell your information to unauthorised third parties and our anti-terrorism and compliance obligations.

We value your privacy and are committed to the highest levels of professional service, including protecting the privacy of those who support us and those with whom we support and work with – in Australia and in developing countries overseas.

You have a right to choose whether or not, or how, you share your information with us on the basis of our Privacy Policy – including the option to utilise a pseudonym, alias or give anonymously – but some choices may impact on our ability to provide certain responses to you – such as your ability to donate and then receive a receipt for a donation; or to receive newsletters, updates or communications from us or our Project Partners about project activities, fundraising, reports or events.

We will only use your personal information for the purpose of our projects and activities when we have your consent to do so (express or implied), or such use is permitted or otherwise required by law.

By providing your personal information you agree to it being collected, held, utilised, disclosed/shared and managed as explained by this Privacy Policy.

Our Website will always have the most current version of this Privacy Policy.

Applies to: All users of GDG’s website, donors, fundraisers, supporters, Project Partners, beneficiaries, staff – employees, reps & volunteers, directors, and other individuals whose information we handle.

Global Development Group (ABN 57 102 400 993) (“GDG”, “we”, “us”, “our”) is an Australian ACNC-registered charity working with Project Partners to implement humanitarian aid and development projects overseas. GDG is approved by the ATO as an Item 1 DGR PBI and with a 9.1.1 Developing Country Relief Fund.

We are committed to managing personal information in accordance with:

Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)

OAIC APP Guidelines and the Notifiable Data Breaches (NDB) scheme

ACNC Governance Standards and External Conduct Standards

ACFID Code of Conduct (voluntarily; not a member)

Fundraising Institute Australia (FIA) Code of Conduct (voluntarily; not a member)

ATO requirements for disclosure & deductible gift recipient (DGR) receipting

Attorney-General’s Department, DFAT and AUSTRAC expectations on anti-money-laundering and counter-terrorism financing (AML/CTF)

Key references:
Privacy Act & APPs: https://www.oaic.gov.au/privacy/the-privacy-act
APP Guidelines: https://www.oaic.gov.au/privacy/guidance-and-advice/app-guidelines
ACNC Governance Standards: https://www.acnc.gov.au/for-charities/manage-your-charity/governance-standards
ACNC External Conduct Standards: https://www.acnc.gov.au/for-charities/manage-your-charity/external-conduct-standards
ACFID Code: https://acfid.asn.au/code-of-conduct
FIA Code: https://fia.org.au/pages/ethics-and-standards/code-of-conduct.html
ATO DGR: https://www.ato.gov.au/non-profit/gifts-and-fundraising/deductible-gift-recipients
AUSTRAC charities guidance: https://www.austrac.gov.au/business/how-comply-guidance-and-resources/industry-specific-guidance/charities-and-not-profit-organisations

1. Open and transparent management of personal information (APP 1)

Policy availability: We publish this Privacy Policy on our website and provide it on request in other formats where reasonable.

Governance: We maintain internal privacy procedures, staff training, and a data breach response plan consistent with OAIC guidance and ACNC expectations.

Automated decisions: We do not currently use automated decision-making that significantly affects individuals’ rights. If this changes, we will update this policy in line with future APP 1 requirements.

2. What personal information we collect (APP 3)

Supporters and donors: We may collect name, contact details (email, address, phone), communication preferences, donation history, payment details (via secure gateways), dietary preferences/restrictions (e.g. for event planning/catering) and tax deductible receipt information and AML/CTF screening information.

Project Partners and their personnel: We may collect name, contact details (email, address, phone), role information, due-diligence and compliance records, bank details for project disbursements, dietary preferences/restrictions and AML/CTF screening information.

Beneficiaries and community members: We may collect limited personal information such as name, contact details, images, stories and feedback, safeguarding-related information, in line with ACFID’s dignity and safeguarding principles and AML/CTF screening information.

Website and digital users: We may collect IP address, device and browser details, cookies and analytics data (consent by clicking ‘Accept’ on cookies pop-up window).

Sensitive information: We may collect sensitive information about vulnerability, safeguarding concerns or health only where necessary, lawful and with consent (or under an APP exception – such as safeguarding, serious threat or legal requirement).

3. How we collect personal information (APP 3 & 5)

We take reasonable steps to ensure you are aware of our identity, the purpose of collection, and how to contact us (APP 5).

Directly from you: Examples: donations, forms, questionnaires, emails, phone calls, events, applications, complaints.

From third parties: Examples: Project Partners, fundraising platforms or events, payment processors, referees, regulators; such collection is routine if authorised by us.

From public sources: Examples: public registers, sanctions lists, media reports, where relevant to AML/CTF and risk management.

4. Why we collect, use and disclose personal information (APP 6)

Core purposes:

We use information to:

process donations and issue DGR-compliant tax deductible receipts;

manage and monitor GDG-approved projects;

conduct due diligence on Project Partners;

comply with ACNC, ATO, AUSTRAC, DFAT, AG and other legal obligations;

communicate with supporters – including Project Partner communication direct with supporters;

manage enquiries, complaints and safeguarding;

improve our programs and website.

AML/CTF and anti-terrorism:

We may use information to:

screen against sanctions and watchlists;

investigate suspicious activity;

coordinate with Project Partners;

report to AUSTRAC, DFAT, AG, ACNC, ATO or other authorities where required by law.

Direct marketing:

We or our Project Partners may send updates and fundraising communications in line with APP 7 and the FIA Code. You can opt out at any time.

No sale of data:

We do not sell, rent or trade personal information.

5. Unique aspects of GDG’s Project Partner structure

GDG as accountable entity:

We remain legally responsible in Australia for all GDG-approved projects and for compliance with ACNC External Conduct Standards.

Information sharing with Project Partners:

We may share limited donor or beneficiary information with Project Partners where necessary for:

project administration and reporting – including donor acknowledgment and newsletters, project updates, fundraising activities or events;

enquiries, complaints and safeguarding;

AML/CTF and sanctions compliance.

Project Partners must handle personal information in accordance with this policy, the APPs (where applicable), ACNC External Conduct Standards and GDG’s Partner Agreements.

6. Cross-border disclosure (APP 8)

Overseas recipients:

We may disclose personal and donation information to our approved Project Partners and service providers outside Australia.

Reasonable steps:

We take reasonable steps to ensure overseas recipients protect personal information in a manner consistent with the APPs, or may rely on another APP 8 exception where applicable.

External Conduct Standards:

We take reasonable steps to ensure that overseas activities and partners meet ACNC External Conduct Standards, including in relation to record-keeping, risk management and anti-fraud/anti-terrorism controls. This may include monitoring policies, briefings, training.

7. Donations, tax deductible receipts and refund policy

All donations are received subject to this policy (including privacy policy) and our Donations and Refund Policy. This applies to all donations made via GDG’s website, fundraising platforms, bank transfer, cheques, cash or other approved channels.

Summary: in principle, all donations in AUD to GDG with a preference for GDG approved aid and development projects &/or benevolent activities are tax deductible in Australia, and are not generally refundable. Additionally the ATO requires; 1. Donations are received as unconditional gifts to the DGR charity itself, 2. If funds raised exceed the requirement for any project, the funds may be directed to another project, 3. Tax deductible donations are required to be unconditional gifts and accordingly GDG will note and consider a donor’s preference but cannot always guarantee that it will be granted.

7.1 Nature of donations and DGR receipting

Voluntary gifts: Donations are treated as voluntary, irrevocable gifts (“free and clear – with no strings attached”) to support GDG’s charitable purposes – and may optionally indicate a preference for an approved project – which GDG will note and consider, but cannot legally guarantee. (ATO requirement) This is irrespective of any contrary statements which may have been made by GDG &/or project personnel.

Anti-Fraud: GDG may impose a minimum donation threshold of $2 or more as a fraud prevention measure.

No purchase: Donations are not payments for goods or services are not subject to Australian Consumer Law (ACL) as part of the Competition and Consumer Act 2010 (CCA). Donations do not create a contractual or legal right to a refund.

We issue Receipts: In Australia, for donations made in AUD, we issue DGR-compliant tax deductible receipts showing our name, ABN, date, amount, a statement that the donation is a gift, and any noted – but not guaranteed – project preference (ATO guidance: https://www.ato.gov.au/non-profit/gifts-and-fundraising/deductible-gift-recipients).

Tax advice: circumstances vary so donors should seek tax advice about deductibility.

7.2 Use of Tax Deductible Funds

General rule: Tax Deductible funds are only expected on GDG approved aid and development &/or benevolent activities.

GDG is the charitable recipient of donations to expend on GDG’s charitable activities at its sole discretion. This may include sending funds to support GDG’s approved overseas projects and participating Project Partners overseas and/or in Australia. GDG will take all reasonable steps to record and consider donor project preferences.

GDG is not permitted to guarantee that a donor’s project preference will be met, nor required to provide or offer a refund if a donor’s preference is no longer able to be met – which may happen for many and varied reasons – including non-compliance or closure of a project – in which case funds may be directed to another approved project/activity.

If a project is over funded or if funds exceed the requirement of any project – for any reason, including non-compliance or closure of a project – funds may be directed to another approved project/activity without notice.

Non-Development Activities: no non-development activities (evangelism, welfare or political activities) are funded by, or are a part of GDG aid and development projects.

Personal Activities exception: if, in their own time, board members, staff, volunteers of GDG or partner organisations undertake or participate in evangelism, proselytism and/or missionary work, partisan political activities or welfare, they must ensure that their activities are not perceived or viewed as being on behalf of or representative of Global Development Group.

7.3 No Refunds:

Charitable donations to GDG do not give rise to a legal right for refunds under the Australian Consumer Law (ACL) as part of the Competition and Consumer Act 2010 (CCA). Donations are by nature voluntary gifts to the charity and GDG has no legal obligation or justification to refund donations as there has been no consumer purchase of goods or services.

However, in limited circumstances, GDG may consider a refund within 30 days of the donation where there is substantiated evidence provided of:

Error (incorrect amount, duplicate payment, or mistaken frequency), Fraud (transaction unauthorised), GDG processing error (instructions followed incorrectly), Misrepresentation (materially mislead about nature or purpose of donation), or the donation was made during a period of exceptional Vulnerability or serious financial hardship.

Same account: to reduce risk of fraud, in the limited case of an approved refund we will only ever process it to the same account or card used to process the original donation.

Under no circumstances, we will not refund when donations were made more than 30 days ago, &/or have been disbursed or committed to projects, &/or where the donor has simply changed their mind.

Tax impact: If a donation is refunded, tax returns may need to be amended which may result in potential ATO fees and interest charges. GDG may need to report to the ATO.

7.4 AML/CTF and suspicious activity

Screening and reporting: We may delay or refuse a donation, or return funds, where required by AML/CTF or sanctions laws, and may report suspicious matters to the ACNC, DFAT, the AG’s Department, AUSTRAC or other authorities.

8. Direct marketing and fundraising (APP 7, FIA & ACFID Code)

Use of information: We or our approved Project Partner may use your contact details to send project updates, appeals and event invitations.

Opt-out: You can opt out at any time using unsubscribe links or by contacting us.

Ethical standards: We follow the FIA Code of Conduct and ACFID Code of Conduct in ensuring respectful, non-exploitative communications.

9. Data security, retention and destruction (APP 11)

Security measures: We use secure servers, access controls, encryption for payment data, staff training, and contractual protections with service providers; these may be located in Australia or overseas.

Retention: We retain records for a maximum seven years where required by law (e.g., ACNC, ATO, AML/CTF); only longer if required for safeguarding and risk management.

Destruction/de-identification: When no longer needed we take reasonable steps to destroy or de-identify personal information, consistent with OAIC guidance.

10. Cookies and website analytics

Cookies: We may use cookies and similar technologies to improve site functionality, enhance your browsing experience, serve personalised content, analyse our traffic and understand usage. Accessing our website, you’ll be prompted to ‘Accept’ our use of cookies.

Control: You can adjust your browser settings to refuse cookies, though some features may not work properly and may limit your ability to engage with our website.

11. Access and correction (APP 12 & 13)

Access: You may request access to personal information we hold about you. We will respond within a reasonable time and may charge a reasonable cost-recovery fee.

Correction: You may request correction of inaccurate, out-of-date or incomplete information. If we refuse, we will tell you why and how to complain.

12. Notifiable Data Breaches (NDB) scheme

GDG regards such a breach as being the release of personal information outside the scope authorised by this policy, in which case we will follow the statutory requirements of the Privacy Amendment (Notifiable Data Breaches) Act 2017, informed by guidance of the OAIC Notifiable Data Breaches Scheme.

Assessment: If we suspect an eligible data breach, we will promptly assess the situation within 30 days.

Notification: If required (in the case of a serious breach that cannot be remediated) we will notify affected individuals and the OAIC in accordance with the NDB scheme.

13. Enquiries, complaints and contact details

Contact GDG: Global Development Group Email: [email protected] Postal address and phone: PO Box 651, Rochedale South QLD 4123, +61 (0)7 3341 6475

If unresolved: You may contact:

OAIC: https://www.oaic.gov.au/privacy/privacy-complaints

ACNC (for governance concerns): https://www.acnc.gov.au/raise-concern

14. Legal Message

If you access our website, you agree to be bound by the conditions contained in this legal message and further agree that the Courts of Australia shall have exclusive jurisdiction with respect to any dispute arising from this legal message.

We are not responsible for the contents of, including any product or service advertised in or on any third party website that contain links to this site or to which this site contains links.

We have made every effort to supply accurate, reliable and up-to-date information about our projects and activities. However, to the extent permitted by law, Global Development Group, nor any of its associates, shall not be liable to any person for any loss or damage which may arise from the use of the information contained in this website whether or not its use or dissemination has been approved by ourselves.

15. Changes to this policy

Please note that use of our website and providing personal details in any format conveys acceptance of this Policy. We may update it at any time, so please check back regularly for the latest version/date on our website.