Privacy Policy

Purpose:

The purpose of the privacy policy is to protect information. The things to remember when practicing privacy are:

  • Collect only the information you need
  • Inform the person why you need the information and how you will use it
  • Disclose only as necessary for the service provision
  • Secure information against unauthorized use/disclosure
  • Right for individuals to access information about them which is held by Endeavour Hills Neighbourhood Centre and to correct any errors in that information; and
  • Offer a complaints procedure for investigation and rectification of breaches of this policy.

 

Endeavour Hills Neighbourhood Centre Inc. also known as ehillsnc is committed to upholding the principles of privacy as contained in The Privacy and Data Protection Act 2014, the Health Records Act 2001 and any other relevant legislation. Ehillsnc receives funding from the Department of Education and Training, Department of Health and Human Services, Adult Community & Further Education and the City of Casey, and as recipients of funding the Centre is required to comply with government law, legislation, regulations and policies.

All restricted license or occasional care children’s services will need to comply with the Victorian Health Records Act 2001 because a large percentage of the information they collect on children could be considered as ‘health information’.

To comply with the Australian Privacy Principles 2014 (APP) Endeavour Hills Neighbourhood Centre (ehillsnc) will:

  • make this policy freely available and set in place a procedure for enquiries or complaints of breaches of the APP (APP 1)
  • allow an individual to have the option to not identify themselves or use a pseudonym unless it is impracticable for ehillsnc to do so (APP 2)
  • only collect personal information which is specifically required by funding bodies or by ehillsncto assist with participant needs that relate to ehillsncactivities (APP 3)
  • only collect personal information about an individual from the individual unless it is unreasonable or impracticable to do so (APP3)
  • collect personal information by lawful and fair means e.g. on a formal enrolment form (APP3)
  • upon receiving unsolicited personal information notify the individual concerned or as soon as practicable destroy the information (but only if it is lawful and reasonable to do so) (APP 4 &5)
  • not disclose information about students/participants, employees or volunteers without written consent or as required by funding bodies and statutory bodies unless required by law to do so (APP 6)
  • not use the personal information for any other purpose including direct marketing without the individual’s consent or unless the information has been de-identified (APP 6 & 7)
  • not use or disclose a government related identifier of an individual unless to verify the identity of the individual for the purposes of ehillsnc activities or fulfil funding body obligations or required by law (APP 9)
  • ensure that personal information collected is, where reasonably possible, accurate, up to date, complete and relevant (APP 10)
  • protect against improper access to personal information as it collects reviews, transmits or stores that information and take reasonable steps to destroy the information if no longer needed unless required by law (APP 11)
  • allow free access to an individual’s own personal information within a reasonable time frame and is reasonable and practicable to do so (APP 12) except
  • allow an individual to make corrections or to update their personal information (APP 13).

Breaches to this policy

All breaches to this policy will be treated seriously and may be subject to disciplinary action.

PROCEDURES

  1. Implementation and Enforcement
    Implementation and enforcement of the Endeavour Hills Neighbourhood Centre Privacy Policy rests with the Manager.
  2. Collecting and Handling Personal Information
    Any staff member collecting personal statistical data must have the
    authorization of the Manager.
    No person, other than an authorized staff member, shall have access to documents containing personal information.
    In collecting, handling and using personal information ehillsnc will:
    − only collect personal information directly related to its service delivery and will treat it as confidential
    − at the time of collection, inform people how the information will be used
    − allow people to view any of their personal information held by the organization
    − treat any breaches of privacy seriously
    − support students, staff and volunteers to access grievance/complaint mechanisms if they believe their privacy has been breached.
  3. Requirements of staff and volunteers
    In handling and using personal information, staff and volunteers must ensure they:
    – do not release any personal information without written consent
    – are sensitive in discussing personal information with others
    – keep all personal information confidential, for example by ensuring such information is in locked filing cabinets, returned to its proper location, well protected computer systems, and not on view to others
    – do not use students/participants’ photos or work without consent (Refer to Photo/Work Consent Form)
    – abide by the information storage/record keeping procedures
    – provide written information to students on privacy arrangements at ehillsnc, or, if appropriate, read through the privacy notice for them.
  4. Releasing information in cases of emergency
    In accordance with Endeavour Hills Neighbourhood Centre’s duty of care to its staff, students/participants and volunteers, there may be rare emergencies when the organization needs to disclose personal information.
    In the case of an emergency, personal information can be released but this must be on a need-to-know basis, relative to the scope of the emergency.
    Privacy Policy P3 of 4
  5. Concerns
    Any student/participant, volunteer or staff member who has any issue with these privacy requirements or procedures should raise their concerns with the these privacy requirements or procedures should raise their concerns with the Manager.Manager.
    If a student/participant is concerned that their privacy may have been breached in any way, they should speak to the Manager, in line with the Grievance /Appeals process.
  6. Information collected
    Types of personal information collected by ehillsnc include:
    – contact details of staff students and volunteers, such as name, address and telephone number, emergency contact person
    – any medical information essential to the well-being of staff, students and volunteers
    – students’ Health Care Card or pension numbers, Centrelink numbers and other identifiers when required for a particular stated purpose, for example to determine hardship and inability to pay fees or as a requirement to access government funded classes
    – students’ enrolment details, examples of coursework, assessment details, outcomes of training, and course attendance
    – information on skills, knowledge and experience of volunteers and members of the Committee of Management will be asked for when it is related to their work at ehillsnc and records will be kept of their involvement
    – Children and parents/guardians before and during the child’s attendance at our child care service contact details and emergency contacts and the child’s enrolment details (this information is collected to provide and/or administer our services to children and parents/guardians).
    – details about staff work history, proof of identity, qualifications, professional development activities, hours of work, remuneration, performance appraisal, accumulated leave, superannuation details
    – grievances and appeals outcomes
    – incident reports