Purpose

Anglicare Southern Queensland is committed to protecting your privacy in an open and transparent way in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, and all applicable Queensland privacy legislation (Privacy Laws). This policy statement sets out how Anglicare Southern Queensland collects, uses, discloses, stores and disposes of personal information in accordance with our legal obligations.

This policy statement does not apply to personal information that is exempt under the Privacy Laws, including the personal information of our employees relating to their former or current employment with us.

What is personal information?

“Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable:

a) whether the information or opinion is true or not
b) whether the information or opinion is recorded in a material form or not.

Personal information also includes sensitive information which is information or an opinion about an individual’s:

• health information
• racial or ethnic origin
• political opinions
• religious beliefs or affiliations
• philosophical beliefs
• membership of a political, professional or trade association or union
• sexual orientation or practices
• criminal record
• genetic or biometric information.

Health information means information or an opinion about the health (including an illness, disability or injury) of an individual, or an individual’s expressed wishes about the future provision of health services to that person, or the health service provided or to be provided to that person. It also includes other personal information collected to provide, or in providing, a health service to that person.

How and why we collect personal information

Personal information is collected in various ways including completed agreements, interviews, appointments, forms, questionnaires, surveys, photographs and recordings (images and voice) including via CCTV (see below). Where possible, we collect personal information from the individual directly (or their legal decision maker or immediate family). In some situations, personal information is obtained from a third party e.g. from a health care professional such as a general practitioner.

We will only collect information that is reasonably necessary to perform one or more of our functions or activities. Functions and activities for which we collect personal information include:

• assessment of clients and potential clients for our services
• accommodating clients in residential aged care facilities and retirement villages
• providing or arranging community care and service programs
• participation in research trials
• assessment of applications from prospective employees and volunteers
• compliance with our legal and contractual obligations with government and their agencies
• assessing suitability and qualifications of contractors/suppliers
• administrative functions including procurement, audit, quality improvement, insurance, accounting and bequests and gifts
• marketing and fundraising.

Without relevant personal information we may not be able to carry out our functions or activities.

Type of information do we collect?

The personal information we collect, and hold will depend on your relationship with Anglicare Southern Queensland, the nature of the service we are providing and our legal obligations.

We collect a range of personal information including names, dates of birth, contact details, next of kin, legal representatives, health information, tax file numbers and other government identifiers (such as Medicare, Centrelink and Department of Veteran’s Affairs numbers), medical practitioner’s contact details, bank account/credit card details, copies of identification documents, employment history, education background, socio-demographic and other information about suitability for duties.

Closed Circuit Television (CCTV) surveillance

CCTV refers to camera surveillance that captures images of people and activity. Any personal information collected through CCTV surveillance must comply with the Privacy Law.

CCTV operates in the common areas of certain Anglicare Southern Queensland premises. The main purpose of this is to maintain a safe and secure environment for our employees, clients, residents and their visitors. We may use personal information gathered from CCTV for security, risk management and incident investigation purposes. Access to CCTV footage will only be granted where access is required or authorised by law.

Use and disclosure

We will use and disclose your personal information for the particular purpose(s) for which it was collected (Primary Purpose). We may also use your personal information for a purpose other than the Primary Purpose (Secondary Purpose) if:

• you have given your consent
• you would reasonably expect us to use or disclose the information for that Secondary Purpose
• the information is not sensitive information, the Secondary Purpose is related to the Primary Purpose.

Depending upon the function or activity for which information has been collected, we may disclose personal information to third party organisations including:

• government departments and agencies that provide funding.
• contractors who provide some of the services we offer. In this instance, we ensure that the contractors are subject to obligations of privacy and confidentiality.
• other service or health providers involved in providing services to you.
• emergency services and statutory bodies such as Queensland Police Service and the Queensland and Commonwealth Government Departments with statutory obligations.

Overseas disclosure

We will not disclose personal information overseas except with your consent or where we reasonably believe that the overseas recipient is subject to arrangements substantially similar to Australian privacy laws.

Anonymity

We will allow you to interact with us anonymously or using a pseudonym where it is practicable to do so.

For most of our functions and activities we will require at least a name and contact information to be able to assist you. If you wish to use a pseudonym that is linked confidentially to your real identity, please let us know and we will consider your request.

Marketing

Any direct marketing using your personal information, e.g. email address, will be limited to circumstances where you have consented to us using your personal information in this way or you would reasonably expect us to use or disclose your personal information for that purpose. You have the right to contact us to opt-out of receiving direct marketing communications from us.

Cookies

We use cookies, pixels and other tracking technologies (“Cookies”) when you visit our websites to gather anonymous data and improve user experience.

If you decide to delete or block certain cookies, your experience on our websites may be limited or some parts of the websites will not work at all.

We may also engage third parties who may use our cookies to improve our advertising relevance to you on their site.

Social networking services

We use social networking services to communicate with the public about our work. We will obtain your consent prior to posting any of your personal information on a social networking service. Each social media service has its own set of terms and conditions including a privacy policy statement.

Storage and security

Personal information may be held electronically or in hard copy either by Anglicare Southern Queensland or by a third-party data storage provider. We will take reasonable steps to ensure that the personal information we hold is protected from misuse, loss, interference, unauthorised access, modification or disclosure.

Our protection of personal information includes:

• limiting physical or electronic access to record storage
• a consent process to limit the disclosure of personal information
• entering into confidentiality agreement with employees, contractors and third-party organisations that may have access to personal information
• having in place business continuity and recovery plans
• maintaining technology security products
• destroying or de-identifying personal information when it is no longer required by law or our record retention policies
• providing staff with information and training about our Policy Statement, Policy Position and practices with respect to the safety of personal information.

We will notify you as soon as reasonably practicable if there has been any unauthorised access, disclosure or loss of your personal information that is likely to result in serious harm to you.

Accessing and correcting your personal Information

We take all reasonable steps to ensure that the personal information we hold about you is accurate, up-to-date and complete.

You can ask for access to personal information that we hold about you or ask that we correct that personal information.

Requests to access or correct personal information must be made in writing, with proof of your identity to:

Privacy Officer
Anglicare Southern Queensland
PO Box 10556
Brisbane Adelaide Street Qld 4000

Email: privacyofficer@anglicaresq.org.au

We may decline an access request where an exception exists under the Privacy Law. Exceptions include where giving access would

• be unlawful
• pose a serious threat to life, health, or safety
• have an unreasonable impact upon the privacy of another person
• be frivolous or vexatious
• relate to existing or anticipated legal proceedings (and the information would not otherwise be discoverable in those proceedings)
• likely prejudice the taking of appropriate action in relation to suspected unlawful activity or serious misconduct
• likely prejudice an enforcement related activity conducted by an enforcement body.

Privacy complaints

If you believe that we have not protected your personal information in accordance with this Policy Statement, you can lodge a complaint with our Privacy Officer at the above address.

We will endeavour to acknowledge your complaint within 14 days of its receipt and make a determination on the complaint within 30 days of its receipt.

If resolution has not been obtained to your satisfaction you may refer the matter to the Australian Information Commissioner as follows:

• Telephoning: 1300 363 992
• Emailing: enquiries@oaic.gov.au
• Writing to: Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001

Changes to this Policy Statement and our Policy Position

We reserve the right to review, amend or update this Policy Statement or our Policy Position at any time.

Privacy Policy Position

For a copy of the Privacy Policy Position, please contact policy@anglicaresq.org.au or contact us on 1300 610 610.