INCLUSIVE HOUSING AUSTRALIA’S PRIVACY POLICY

 

Policy Statement

Inclusive Housing Australia (IHA) is committed to safeguarding the confidentiality of personal or sensitive information collected with regard to the people we support. IHA is also committed to protecting the privacy of participants, its stakeholders and employees. This document is our privacy policy and it tells you how we collect and manage your personal information.

 

Purpose of Policy

This policy sets out how IHA complies with its obligations under the Privacy Act 1988 (C’th)(the Act), including the Australian Privacy Principles (APPs) to ensure we meet our legal and ethical obligations to respect the rights and privacy of people we support, and its employees.

 

This policy regulates how we manage personal information, collect, use, disclose, and secure and store personal information.   It also details how individuals may access that information and have it corrected if it is wrong.

Personal Information

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to identify you personally. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

Policy Number Objective Policy Description
     
1.1 Ensure all employees and adhere to the Australian Privacy Principles & privacy provisions within the Disability Service Standards (C’th & NSW) IHA will ensure all aspects of our operations comply with the Australian Privacy Principles and the Disability Service Standards (C’th & NSW).
 
The Disability Service Standards (C’th) and the NSW Standards in Action apply to the people we support and families. The National Privacy Principles apply to all people that the organisation holds personal information about. This will include all stakeholders such as investors, funding agencies, educational institutions, NGO’s, advocacy and community organisations, and other service providers.
 
     
1.2        Responsibilities of employees, contractors, and Privacy Officer All employees and contractors of IHA have a responsibility to ensure that personal information is handled in accordance with this policy and that any personal and/or sensitive information accessed in the course of their duties are bound by their commitment to confidentiality.
 
IHA has appointed a Privacy Officer to respond to any concerns, complaints or alleged breaches in relation to privacy. The Privacy Officer’s responsibilities are limited to:
·         receive and respond to any requests for access to personal information; and
·         report any requests or complaints to the Chief Operating Officer.
 
1.3 How IHA will ensure compliance To ensure compliance IHA will develop specific procedures to effectively manage personal information, including sensitive information, in the context of the broad range of services we provide.
 
     
1.4
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.5
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.6
 
 
 
 
 
 
 
 
 
 
 
 
 















1.7
 
 
 
 
 
 
 
 
 
 





1.8
 
 
 		 Ensure the quality of the data and relevance
 
 
 
 
 
 
 
 
 
 
 
 
Use of personal information
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Kinds of personal and/or sensitive information that we collect and hold
 
 
 
 
 
 
 
 
 
 
 
 















How we collect and hold personal information
 
 
 
 
 
 
 
 
 





The purposes for which we collect, hold, use and disclose personal information
 		  IHA will take all reasonable steps to make sure that the personal and/or sensitive information it collects, uses or discloses is accurate, complete and up to date. Personal and/or sensitive information about IHA partnership organisations, stakeholders, investors and employees will only be collected when it is directly relevant and needed to provide support services to that person, or where IHA is required to collect the information.
 
IHA will put in place procedures to allow service users and employees the ability to access information kept about them, update and or amend their personal information.
 
IHA will only use personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or operations.
 
When you provide IHA with personal and/or sensitive information you will be given the option to tell us that you do not want that information to be used for direct marketing purposes. You can change your mind about your preferences in respect of direct marketing and make choices at any time by following any instructions in relevant communications or by contacting:
 
Privacy Officer
Inclusive Housing Australia
Suite 8.02 333 George Street
Sydney NSW 2000
(1800 442 732)
[email protected]
 
The types of personal and/or sensitive information that we collect may include:
·         name,
·         address,
·         telephone number,
·         email address and other account names for other electronic communication channels,
·         age or birth date,
·         employer, profession, occupation or job title,
·         any donations you have made to IHA (in cash or in kind),
·         financial information,
·         photographic images,
·         attendance records,
·         contact details for guardian, financial manager, NDIS plan nominee, next of kin.
·         details of the products and services you have purchased from us or which you have enquired about together with any additional information necessary to deliver those products and services and to respond to your enquiries,
·         any enquiries or feedback you have made about a donation, product or service,
·         any additional information necessary to receive a donation, deliver any products or services and respond to your enquiries or feedback,
·         any additional information relating to you that you provide to us directly through our website or indirectly through use of our website or online presence, through our representatives or otherwise; and
·         information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.
 
We may also collect information that is not personal information because it does not identify you or anyone else.
 
We collect personal and/or sensitive information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect information through lawful and fair means including using our standard forms, over the internet, via email or through a telephone conversation with you. With your consent we may collect personal and/or sensitive information from third party contractors or agents and government instrumentalities who are involved in the provision of our products and services.
 
 
 
 
We collect your personal and/or sensitive information for any one or more of the following reasons:
providing our products or services to you, including the direct marketing of those products or services;
·         to assist with your queries;
·         to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
·         for the administrative, marketing, planning, product or service development, quality control and research purposes of IHA, its related bodies corporate, contractors or service providers;
·         to provide updated personal information to our related bodies corporate, contractors or service providers;
·         to update our records and keep your contact details up to date;
·         to process and respond to any complaints made by you;
·         analysing our services and client needs with a view to developing new and/or improved services; and
·         to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of Australia.
 
1.9
 
 
 
 
 
 
 
 
 
 
 
 



1.10
 
 
 
 
 
 
 
 
 
 
 
 
1.11
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 		 Disclosure of Information
 
 
 
 
 
 
 
 
 
 
 
 



Direct Marketing Materials
 
 
 
 
 
 
 
 
 
 
 
IHA will not disclose identifying information without written consent
 		 IHA may disclose your personal information to:
·         our employees, related bodies corporate, contractors or service providers for the purposes of operation of our business or website, fulfilling requests by you, and to otherwise provide products and services to you;
·         suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes; and
·         any organisation for any authorised purposes with your express consent.
 
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate within Australia.
 
 
We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS and email in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
 
We do not provide your personal information to other organisations for the purposes of direct marketing.
 
IHA does not give identifying information to other agencies, organisations or anyone else unless one of the following applies:
·         the person has consented;
·         the person would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies;
·         it is required by law or is necessary to protect the rights or property of IHA or any other individual
·         it will prevent or lessen a serious and imminent threat to somebody’s life or health;
·         it relates to a criminal issue
 
Where the person we support is unable to provide consent, we will obtain written consent from the Person Responsible or Guardian. In some instances, verbal consent from the Person Responsible or Guardian may be necessary and will be documented.
 
Where there is uncertainty as to the direct benefit of the release of information which does not remove the names of individuals and or other identifying characteristics such as home address, or there is doubt that individuals would not consent to the release of this information IHA will seek approval from the concerned people or the designated Person Responsible or Guardian prior to the release of the information.
1.12 Security of Information IHA takes steps to protect the personal information it holds against loss, unauthorised access, use, modification or disclosure and against other misuse. These steps include secure handling procedures, access restrictions, ensuring documents are stored in locked cabinets when not in use, password protection, and restricted access for all electronic files.
 
Each Business Service will ensure their own secure procedures relevant to their service and processes.
 
When no longer required, personal information is destroyed in a secure manner or deleted.
 
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
 
     
1.13 Complaints or Concerns in Relation to Privacy If a service user has a complaint in relation to privacy, it should be made in writing, directed to:
 
Privacy Officer
Inclusive Housing Australia
Suite 8.02 333 George Street
Sydney NSW 2000
 
You should expect an acknowledgement within 7 days of the complaint or concern being received. You will be advised of how your complaint or concern will be dealt with.
 
Your complaint or concern will be investigated by the Privacy Officer in consultation with the IHA Executive Office. You will receive written advice of the response to your concern or complaint, or advice of further processes required, within 28 days.
 
If IHA’s response is not acceptable to you, we may suggest conciliation or arbitration on the matter. You may also make a formal complaint to the Privacy Commissioner.
 
The provisions of this subclause do not apply to Employees of IHA. Where an employee has a concern or complaint in relation to privacy it should be dealt with under IHA Complaint Procedures, or where access to the individual’s Personnel File is required, requests should be made directly to Human Resources.
     
1.14
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.15
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

1.16

 
 
 
 
 
 
 
 














1.17
 
 
 




1.18           




                                      		 Requesting Access or Change to Information
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

Disclosure of personal information to overseas recipients
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 


Contacting Us
 
 
 
 
 
 
 
 















Changes to our Privacy Policy






Approvals		 Policy Users may request a copy of their personal information. The request should be made in writing, be specific in detailing what information you are requesting and directed to:
 
Privacy Officer
Inclusive Housing Australia
Suite 8.02 333 George Street
Sydney NSW 2000
(1800 442 732)
[email protected]
 

You should expect an acknowledgement within 7 days of the complaint or concern being received. You will be advised of how your complaint or concern will be dealt with.

 
 

IHA utilises internet-based third-party data storage, processing and services, or “cloud computing”, which may involve the disclosure of your personal and/or sensitive information to overseas recipients. If you consent to this disclosure of your personal and/or sensitive information subclause 8.1 of Australian Privacy Principle 8 will not apply and by engaging us to provide products or services to you and/or providing us with such personal and/or sensitive information you do consent to the disclosure of your personal and/or sensitive information outside Australia, and acknowledge that we are not required to ensure that overseas recipients handle your personal and/or sensitive information in compliance with Australian Privacy Law.
 
Notwithstanding, we will where practicable in the circumstances take reasonable steps to ensure that overseas recipients use and disclose such personal and/or sensitive information in a manner consistent with this Privacy Policy. The third parties referred to above, to whom we may provide your personal and/or sensitive information, may be located in countries including the United States and Singapore. 
 

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.
 
We will treat your request or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
 
Please contact our privacy officer at:
 

Privacy Officer

Inclusive Housing Australia
Suite 8.02 333 George Street
Sydney NSW 2000
(1800 442 732)
[email protected]

 

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website.

 

 

 

Date of Approval:
Date of review:
Signature of Chief Operating Officer:
Signature of Board Chair: