Homestead For Youth is committed to protecting the privacy of an individual’s personal information. The following sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us, and the way we collect, use and disclose your personal information.
In handling your personal information, we will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the thirteen Australian Privacy Principles in the Privacy Act.
We have policies and procedures in place to ensure that:
- personal information is managed in an open and transparent way
- the privacy of personal information of participants and staff are protected
- we collect and handle personal information fairly
- personal information we collect is used and disclosed for legally permitted purposes only
- we regulate access to and correction of personal information
- we maintain the confidentiality of personal information through appropriate storage and security.
The kinds of information we collect
Consumer personal information is collected to provide care and services. Personal information we collect could include your:
- name, address, telephone number and email address
- date of birth
- advocate or emergency contact’s telephone number and email
- health information
- diversity status (ethnicity, lifestyle preferences).
How we collect personal information
Participant personal information may be collected from:
- you, the participant
- your family members or significant others
- your advocate
- your doctor or other service providers or facilities.
We will collect personal information directly from you unless:
- we have your consent to collect the information from someone else
- we are required or authorised by law to collect the information from someone else
- it is unreasonable or impractical to do so.
You can withdraw your consent at any time by contacting us; although you should be advised that this may impact on our capacity to provide services.
Purpose of collecting personal information
Personal information is collected for the purposes of providing care and services. The information may be used to:
- provide support services
- enable service providers and medical practitioners to provide care and services
Disclosure of personal information
We may disclose your personal and health information, for the purpose of your care and services, to:
- service providers who assist us in providing care and services, medical practitioners, external health agencies such as the ambulance service, hospitals, the National Disability Insurance Scheme, and other relevant government organisations
- a person you have nominated as being your advocate, e.g. parent, child or sibling, spouse, a relative, a member of your household, a guardian, an enduring power of attorney, or a person you have nominated to be contacted in case of emergency, provided they are at least 18 years of age.
We may not use or disclose personal information for a purpose other than providing care and services, unless:
- you have consented
- the purpose is related to providing care and services, and you would reasonably expect disclosure of the information for that purpose
- we believe on reasonable grounds that the disclosure is necessary to prevent or lessen a serious and imminent threat to your life, health or safety or a serious threat to public health or public safety
- we have reason to suspect unlawful activity and disclosure is required or authorised by law.
We will not disclose your personal information to an overseas recipient.
Security of personal information
We take all reasonable steps to ensure that the personal information we hold is protected against misuse, loss, unauthorised access, modification or disclosure. We hold personal information in both hard copy and electronic forms in secure databases on secure premises and on secure, cloud-based technology, accessible only by our authorised staff.
Accessing the personal information that we hold about you
Under the Privacy Act, you have a right to access your personal information that is collected and held by us. If at any time you would like to access or change the personal information that we hold about you, or you would like more information on our approach to privacy, please contact us.
To obtain access to your personal information, you will have to provide us with proof of identity. We will take all reasonable steps to provide access to your personal information within seven (7) days from your request.
Records of current and past employees which are related to the employment relationship are managed in accordance with workplace laws. Privacy laws may apply to employee personal information if the information is used for something that is not related to the employment relationship between our organisation and the employee.
Personal information collected and held by us in relation to our volunteers will be managed in accordance with the Privacy Act.
Privacy data breaches
In the event that your personal information is lost, stolen or subject to unauthorised access or disclosure, we will implement our Management of Data Breach Policy and Procedure.
All complaints regarding privacy can be lodged via our complaint handling process.
At all times, privacy complaints will:
- be treated seriously
- be dealt with as promptly as possible
- be dealt with in a confidential manner
- not affect your existing obligations or affect the commercial arrangements between you and us.
You will be informed of the outcome of your complaint following completion of the investigation.
Homestead for Youth’s Board is responsible for developing, adopting and reviewing this policy.
Homestead for Youth’s CEO is responsible for the implementation of this policy, for monitoring changes in Privacy legislation, and for advising on the need to review or revise this policy as and when the need arises.
Homestead for Youth will:
- Only collect information that is necessary for the performance and primary function of Homestead for Youth.
- Notify stakeholders about why we collect the information and how it is administered.
- Notify stakeholders that this information is accessible to them.
- Collect personal information from the person themselves wherever possible.
- If collecting personal information from a third party, be able to advise the person whom the information concerns, from whom their personal information has been collected.
- Collect Sensitive information only with the person’s consent. (Sensitive information includes health information and information about religious beliefs, race, gender and others).
- Determine, where unsolicited information is received, whether the personal information could have collected it in the usual way, and then if it could have, it will be treated normally. (If it could not have been, it must be destroyed, and the person whose personal information has been destroyed will be notified about the receipt and destruction of their personal information).
Use and Disclosure
Homestead for Youth will:
- Only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose.
- For other uses, Homestead for Youth will obtain consent from the affected person.
- In relation to a secondary purpose, use or disclose the personal information only where:
- a secondary purpose is related to the primary purpose and the individual would reasonably have expected us to use it for purposes; or
- the person has consented; or
- certain other legal reasons exist, or disclosure is required to prevent serious and imminent threat to life, health or safety.
- In relation to personal information which has been collected from a person, use the personal information for direct marketing, where that person would reasonably expect it to be used for this purpose, and Homestead for Youth has provided an opt out and the opt out has not been taken up.
- In relation to personal information which has been collected other than from the person themselves, only use the personal information for direct marketing if the person whose personal information has been collected has consented (and they have not taken up the opt-out).
- Provide all individuals access to personal information except where it is a threat to life or health or it is authorized by law to refuse and, if a person is able to establish that the personal information is not accurate, then Homestead for Youth must take steps to correct it. Homestead for Youth may allow a person to attach a statement to their information if Homestead for Youth disagrees it is inaccurate.
- Where for a legal or other reason we are not required to provide a person with access to the information, consider whether a mutually agreed intermediary would allow sufficient access to meet the needs of both parties.
- Make no charge for making a request for personal information, correcting the information or associating a statement regarding accuracy with the personal information.
Storage Homestead for Youth
- Implement and maintain steps to ensure that personal information is protected from misuse and loss, unauthorized access, interference, unauthorized modification or disclosure.
- Before Homestead for Youth discloses any personal information to an overseas recipient including a provider of IT services such as servers or cloud services, establish that they are privacy compliant. Homestead for Youth will have systems which provide sufficient security.
- Ensure that Homestead for Youth data is up to date, accurate and complete.
Destruction and de-identification Homestead for Youth
- Destroy personal information once is not required to be kept for the purpose for which it was collected, including from decommissioned laptops and mobile phones.
- Change information to a pseudonym or treat it anonymously if required by the person whose information Homestead for Youth holds and will not use any government related identifiers unless they are reasonably necessary for our functions.
Homestead for Youth will:
- Take reasonable steps to ensure the information Homestead For Youth collects is accurate, complete, up to date, and relevant to the functions we perform.
Data Security and Retention
Homestead for Youth will:
- Only destroy records in accordance with the organisation’s Records Management Policy.
Homestead for Youth will:
- Make this information freely available in relevant publications and on the organisation’s website.
Access and Correction
Homestead for Youth will:
- Ensure individuals have a right to seek access to information held about them and to correct it if it is inaccurate, incomplete, misleading or not up to date.
- Allow people from whom the personal information is being collected to not identify themselves or use a pseudonym unless it is impracticable to deal with them on this basis.
Making information available to other organisations
Homestead for Youth can:
- Release information to third parties where it is requested by the person concerned.
Your privacy is important
This statement outlines the Homestead for Youth's policy on how the Homestead for Youth uses and manages personal information provided to or collected by it.
The Homestead for Youth is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act and is compliant with the Privacy Amendment (Enhancing Privacy Protection) Act 2012. [OPTION: In relation to health records, the Homestead for Youth is also bound by the Victorian Health Privacy Principles which are contained in the Health Records Act 2001].
What kind of personal information does the Homestead for Youth collect and how does the Homestead for Youth collect it?
The type of information the Homestead for Youth collects and holds includes (but is not limited to) personal information, including sensitive information, about:
- .Family history and case notes
- .Mental Health history and self reports
Personal Information you provide:
The Homestead for Youth will generally collect personal information held about an individual by way of [OPTIONS: phone calls, forms, face to face sessions, meetings etc]. You do have the right to seek to deal with us anonymously or using a pseudonym, but in almost every circumstance it will not be practicable for us to deal with you or provide any services to you except for the most general responses to general enquiries, unless you identify yourself.
Personal Information provided by other people:
In some circumstances the Homestead for Youth may be provided with personal information about an individual from a third party, for example a General Practitioner, School or counsellor.
In relation to employee records:
How will the Homestead for Youth use the personal information you provide?
The Homestead for Youth will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which you have consented.
In relation to direct marketing, the Homestead for Youth will use your personal information for direct marketing where you have provided that information, and you are likely to expect direct marketing: only then you will be sent direct marketing containing an opt out. If we use your personal information obtained from elsewhere we will still send you direct marketing information where you have consented and which will also contain an opt out. We will always obtain your consent to use sensitive information as the basis for any of our direct marketing.
We may use video surveillance for security purposes and the footage will be used only by the Homestead for Youth and by the providers of our security services for security purposes. Surveillance videos are not used by the Homestead for Youth for other purposes and the footage is not publicly available. Surveillance cameras are not located in any bathrooms or change room facilities.
Job applicants, staff members and contractors:
In relation to personal information of job applicants, staff members and contractors, the Homestead for Youth’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be.
The purposes for which the Homestead for Youth uses personal information of job applicants, staff members and contractors include:
- for insurance purposes;
- to satisfy the Homestead for Youth’s legal obligations,
Where the Homestead for Youth receives unsolicited job applications these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.
The Homestead for Youth also obtains personal information about volunteers who assist the Homestead for Youth in its functions or conduct associated activities, such as to enable the Homestead for Youth and the volunteers to work together. [#]
Marketing and fundraising:
[OPTION: The Homestead for Youth treats marketing and seeking donations for the future growth and development of the Homestead for Youth as important]. Personal information held by the Homestead for Youth may be disclosed to an organisation that assists in the Homestead for Youth’s fundraising, for example, the Homestead for Youth’s ### organisation.
Who might the Homestead for Youth disclose personal information to?
The Homestead for Youth may disclose personal information, including sensitive information, held about an individual to:
- government departments;
- people providing services to the Homestead for Youth,
- ..; and
- anyone you authorise the Homestead for Youth to disclose information to.
Sending information overseas:
The Homestead for Youth will not send personal information about an individual outside Australia without:
- obtaining the consent of the individual (in some cases this consent will be implied); or
- otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.
[We do/do not use overseas providers of IT services including servers and cloud services.]
How does the Homestead for Youth treat sensitive information?
In referring to ‘sensitive information’, the Homestead for Youth means:
“information relating to a person’s racial ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record, that is also personal information; and health information about an individual”.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.
Management and security of personal information
The Homestead for Youth’s staff are required to respect the confidentiality of personal information and the privacy of individuals.
The Homestead for Youth has in place steps to protect the personal information the Homestead for Youth holds from misuse, loss, unauthorised access, modification, interference or disclosure by use of various methods including locked storage of paper records and passworded access rights to computerised records.
Updating personal information
The Homestead for Youth endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. A person may seek to update their personal information held by the Homestead for Youth by contacting the Privacy Officer of the Homestead for Youth at any time.
The Australian Privacy Principles and the Health Privacy Principles require the Homestead for Youth not to store personal information longer than necessary. In particular, the Health Privacy Principles impose certain obligations about the length of time health records must be stored.
You have the right to check what personal information the Homestead for Youth holds about you.
Under the Commonwealth Privacy Act and the Health Records Act, an individual has the right to obtain access to any personal information which the Homestead for Youth holds about them and to advise the Homestead for Youth of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation. To make a request to access any information the Homestead for Youth holds about you, please contact the Privacy Officer in writing.
The Homestead for Youth may require you to verify your identity and specify what information you require. Although no fee will be charged for accessing your personal information or making a correction, the Homestead for Youth may charge a fee to retrieve and copy any material. Homestead for Youth If the information sought is extensive, the Homestead for Youth will advise the likely cost in advance.
How long will the Homestead for Youth keep my information?
Under our destruction and de-identification policies, your personal information that is no longer required will be de-identified or destroyed. In many circumstances, however it will be kept for marketing purposes, as you will have consented to that in writing with us.
Homestead For Youth Privacy Statement- accessible via our website
This Privacy Statement provides information on how Homestead For Youth Ltd manages personal information collected; including personal information collected through their website at http://www.homesteadforyouth.org
Homestead For Youth Ltd realises the importance of ensuring that personal information held by the company is treated confidentially and is committed to ensuring that all personal information is only collected, disclosed, used and stored in accordance with the National Privacy Principles set out under the federal Privacy Act 1988.
What is Personal Information?
‘Personal Information’ is information or an opinion (including information or an opinion forming part of a database) 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.
Collecting personal information:
Homestead For Youth Ltd will not collect or monitor any personal information about an individual without their consent. The only personal information collected is what has been provided voluntarily.
Use and disclosure of personal information
Any personal information that we collect will only be used and disclosed for the purpose for which it has been provided to us.
Personal information may need to be disclosed to external service providers engaged by Homestead For Youth Ltd in order for those service providers to fulfill their service obligations to the firm. For example: IT service providers who assist in managing Homestead For Youth Ltd’s servers and networks may need to access client data in order to maintain the servers and networks;
Where personal information is disclosed to an external party, Homestead For Youth Ltd will take steps to ensure that the external party treats such information confidentially and in accordance with the federal Privacy Act 1988.
If you have registered through our website to receive email communications from us, we may use your contact details to send you newsletters, marketing emails or invitations to Homestead For Youth Ltd updates, seminars or events, which may be of interest to you. However, you may at any time opt out of receiving such materials by emailing us at info@H4Y.com.au or simply ‘unsubscribing’ from our email list via the link at the bottom of the email we have sent. If you do send us a request to have your details removed, we will remove your contact details from our distribution lists.
Accessing and Correcting Personal Information
You may request us to provide you with access to personal information we hold about you. We will process all requests for access to personal information in accordance with the National Privacy Principles. In most cases, we will provide you with access to your personal information. However, we may refuse access in certain situations as listed in the National Privacy Principles. If we refuse to give you access, we will provide you with reasons for our refusal.
If any personal information we hold about you is not accurate, complete or up to date, please let us know and in most cases, we will use all reasonable efforts to update the information.
Personal information security
Homestead For Youth Ltd is committed to keeping secure the data you provide to us and we will take all reasonable precautions to protect your personally identifiable information from loss, misuse or alteration.