Purpose & Scope
- We are required by the Privacy Act 1988 (Commonwealth) (Privacy Act) to comply with the Australian Privacy Principles (APPs). The APP’s regulate the manner in which personal information is handled throughout its life cycle, from collection to use, disclosure and disposal.
- personal information means information or an opinion (including written and verbal information or an opinion forming part of a data base), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion; and
- sensitive information means personal information which includes details of an individual’s racial or ethnic origin, religious or philosophical beliefs, employment record, criminal record or health/mental health information and/or other personal information that is ‘sensitive information’ as defined in the Privacy Act.
- KINDS OF PERSONAL INFORMATION WE COLLECT
- We collect and hold personal information about customers, relatives of customers, job applicants, employees, prospective contractors, contractors, students on work placement with us, volunteers and other individuals who come in contact with us (you).
- The kinds of personal information we collect may include your name, address and other contact details, bank account details, credit and debit card details and information obtained when you use our website, including which of our pages you have accessed.
- We may also collect sensitive information about you, including without limitation details of your health/mental health and medical history, race or ethnic origin, religion, nationality and in some cases, details of any criminal record you may have.
- The Privacy Act classifies certain information relating to services supplied on terms which allow payment to be deferred for a period of more than 7 days after the services are supplied as ‘credit information’. We may collect and hold credit information about you if we supply services to you and allow payment to be deferred for more than 7 days after supply.
- MANNER AND PURPOSE FOR COLLECTING PERSONAL INFORMATION
- We will generally collect personal information about you directly by way of forms and other documents submitted to us by you, correspondence you provide to us and telephone calls/meetings with you.
- Occasionally, we may collect personal information about you from third parties. For example, we may collect personal information about customers* from their relatives (and vice versa) and we may collect details of your criminal record (if any) from police agencies or agencies who complete police checks on our behalf.
*Note: The term customer is interchangeable with program specific terms that may be used, including consumer, client, resident or patient.
- We will only use personal information for the following purposes unless otherwise required or permitted by law:
- to provide housing and related services to our customers;
- to fulfil our duty of care and legal obligations;
- to ensure that customers receive appropriate healthcare, social support and spiritual support as and when required;
- for our promotion and marketing activities from time to time;
- if you are a job-applicant or a potential contractor, to assess your suitability and (if successful) engage you and to assist with administering your employment or contract;
- for our internal management purposes;
- to manage our relationship with you and where applicable, to manage the payment and recovery of amounts payable to us by you;
- to enable volunteers to work together and to keep such groups informed about matters concerning them; and
- for other purposes which are reasonably necessary in connection with our normal functions and activities.
- If we are unable to collect personal information relating to you, we may be unable to provide you with the services you require or continue our relationship with you.
- We will only use sensitive information for the following purposes unless otherwise permitted or required by law or unless we obtain your consent:
- to provide appropriate housing services to customers, to look after customers’ medical, social and spiritual well-being, to satisfy our legal obligations and to satisfy our duty of care; and
- to assess whether it is appropriate for certain volunteers, students, job applicants and potential contractors to be on or about our premises or interact with customers from time to time.
- DISCLOSURE OF PERSONAL INFORMATION
- We may disclose personal information about you to the following types of entities if required in connection with the purposes listed above:
- medical/healthcare professionals and people providing services to us or you;
- our contractors, consultants, advisers, associates and related entities;
- any industry body, tribunal, court or otherwise in connection with any complaint made by you about us;
- your referees (if you have provided us with referees to assist with a job application, the assessment of a potential contract between you and us or for any other purpose);
- government departments, police agencies and agencies who complete police checks such as CrimTrac; and
- other entities with your consent or as permitted or required by law.
- We will not disclose your credit-related information to entities such as other credit providers or credit reporting bodies without your consent.
- We will not disclose your personal information to recipients located overseas.
- HOLDING INFORMATION
We hold personal information in paper form and electronic form. We have in place steps to protect the information we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
- HOW TO OBTAIN ACCESS TO YOUR PERSONAL INFORMATION
- You may obtain access to personal information which we hold about you by completing a Request for Information form. If you request that we provide you with copies of your personal information, we may require you to verify your identity and specify what information you require.
- If you make a request for copies of your personal information held by us we will endeavour to provide you with such personal information as soon as reasonably practicable. There may be occasions when access to personal information we hold about you is denied including where the release of the requested information would have an unreasonable impact on the privacy of others.
- ACCURACY OF PERSONAL INFORMATION
While we will endeavour to ensure that the personal information collected from you is up to date, accurate and complete, we will assume that any personal information provided by you is free from errors and omissions. You may request that we update or vary personal information that we hold about you by discussion with your key ACH Group contact such as a nurse, advisor or manager. Where correction to information is disputed the matter will be managed by the Privacy Officer – see Section 14.
- DIRECT MARKETING COMMUNICATIONS
From time to time we may use your personal information to provide you with marketing materials in relation to offers and services that we have available. If you would not like to receive direct marketing materials from us you may notify us using the contact details set out below.
- HANDLING COMPLAINTS
- If you are of the view that we have breached the APPs, the Privacy Act or any related privacy code in dealing with your personal information, you may make a complaint verbally, using one of the feedback forms provided by ACH Group or in writing to the manager of the service or to the Privacy Officer – see Section 14.
- When we receive a complaint, we will endeavour to provide you with confirmation as to how we propose to deal with the complaint as soon as reasonably practicable.
- If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner by visiting the following website and following the steps: http://www.oaic.gov.au/privacy/privacy-complaints.
- ANONYMITY AND PSEUDONYMS
You have the option of not identifying yourself or using a pseudonym when dealing with us unless we are required by law or a court/tribunal to deal with individuals who have identified themselves or it is impractical for us to deal with you if you have not identified yourself.
- VARIATION OF POLICY
- CONTACT US
Please direct all enquiries or complaints regarding your personal information or privacy to your key ACH Group contact or to the Privacy Officer, General Manager Corporate Services, PO Box 646, Torrensville Plaza, SA 5031,