The Privacy Act 1988 – Australian Privacy Principles
All staff and volunteers are required to sign an agreement that they will comply with all Privacy Principles. The Board of Directors are also aware and informed of all privacy policies and ensure that practices and procedures are in place so policies are followed. Staff and volunteers have access to the PRONIA privacy policies, in the event that they require them.
Personal Information as defined in the Privacy Act
Information or an opinion about an identified individual, or an individual who is reasonably identifiable which, may be true or false. It may also be recorded in a material format.
Examples of personal information may include opinions of others about work performance, work experience and qualifications, aptitude test results and other information obtained by PRONIA in connection with possible work placement. Personal information also includes sensitive information.
Sensitive Information as defined in the Privacy Act
Sensitive information is intrinsic information which may be instrumental in identifying an individual. This includes information or an opinion relating to an individual’s;
- Racial or ethnic origins
- Political opinions or membership of a political association
- Religious or philosophical beliefs and affiliations
- Membership of a professional or trade association or union
- Sexual orientation or practices
- Criminal record
- Health information
- Genetic or biometric information
Health Information as defined in the Health Records Act
Health information includes:
- Personal information or an opinion about:
- Physical, mental or psychological health, at any time of an individual
- An individual’s disability
- Expressed wishes about the future health services an individual wishes to receive
- An existing health service that an individual receives
- Additional personal information that is collected with the aim of providing a health service
- Other information about an individual that is collected in connection with a donation or intended donation of body parts or substances or organs
- Genetic information that could be predictive of an individual’s or their descendants’ health
The Australian Privacy Principles
Australian Privacy Principle 1 – Open and Transparent Management of Personal Information
This document contains information pertaining to the Australian Privacy Principles which relate to the following points regarding:
- The type of information collected and held by the PRONIA
- How information is collected and held
- Purposes for which information is collected, held, used and disclosed
- Access to information to make any changes or corrections
- How to make a complaint regarding any breach of privacy and how PRONIA will deal with such claims
- Likelihood where information is disclosed to individuals overseas and the countries where they are located are to be specified
Australian Privacy Principle 2 – Anonymity and Pseudonymity
Service users of PRONIA are able to remain anonymous if it is practicable to do so. However, in the event where a service is required information must be provided without anonymity or pseudonyms as this hampers PRONIA’ ability to provide appropriate services and function across all our areas of operation, including: issuing invoices or receipts to you, delivering appropriate care and contacting our network of staff, service users and members.
Australian Privacy Principle 3 – Collection of Solicited Personal Information
PRONIA will initially collect information from you upon your completion of our membership, donation or community directory forms or through any other information you provide related to any services you may receive from us.
In collecting information, only authorised PRONIA employees will have authority to obtain personal and sensitive information. All PRONIA employees have been carefully screened and signed confidentiality agreements to not make any unauthorised disclosure of confidential information in which they may become privy in the course of their employment with PRONIA. Collection of information from service users is obtained within private settings to further ensure their privacy.
Other information PRONIA may collect about you is relative to the contact we have with you. For example:
- Any health information which is relative to any service you receive from PRONIA
- Fundraising initiatives
- Information regarding any personal circumstances to provide assistance through our Family and Community Services Unit and Aged and Co-ordinated Care Unit
- Information about a business or service you wish to advertise in our “I Love All Things Greek” Community Directory
- Banking or financial information of your business or service to arrange payment for any services you may have provided PRONIA with.
- Any other additional information you provide us with
PRONIA cannot solicit personal or sensitive information from you without your consent prior to collection unless a health or emergency situation occurs in which case personal and/or sensitive information must be provided.
PRONIA will only collect information in a lawful and fair manner.
Australian Privacy Principle 4 – Dealing with Unsolicited Personal Information
Should PRONIA receive any unsolicited personal information about you or a related business or service that you are engaged with; PRONIA staff will determine if such information could have been solicited from you. For personal information that is not identifiable in any Commonwealth record, PRONIA will de-identify or destroy the information, if it is lawful to do so.
Australian Privacy Principle 5 – Notification of the Collection of Personal Information
At the time of collecting information, PRONIA staff will identify themselves and the organisation, and provide their contact details to you. They will also notify you that they will collect or have collected your personal information.
PRONIA staff will explain the purpose for the collection of your information and of any consequences that occur for not having collected your personal information. In such cases, the lack of information may limit PRONIA’ capacity to provide a quality service to you. Where additional information is required to provide a service to you, your consent will be obtained prior to us contacting any other organisation or individual. Should any of your information be incorrect PRONIA staff will inform you how you can view your collected personal information and how to make any amendments to it.
Australian Privacy Principle 6 – Use or Disclosure of Information
We will not refer your information to another internal unit or program within the organisation without your consent prior to doing so.
Your personal and sensitive information may be utilised in relation to:
- A program or service that you receive or are a part of, including your service needs, assessment results or additional special needs you may have
- Administration, invoicing and payment purposes
- Any community directory advertising or additional fundraising events that you participate in
- Our membership database
- The management of any complaint or inquiry in which you may be involved
- Any insurance claim or proposal that requires disclosure of your personal and sensitive information
Individuals or organisations that your information may be disclosed to include:
- Employees or clients of PRONIA
- Our insurers
- A professional association or registration body that has a proper interest in the disclosure of your information
- Our contractors and suppliers (eg. Our IT contractors and database designers)
- Any individual, organisation or authority with a lawful entitlement to obtain your information
PRONIA will indicate on its own internal system that such a disclosure has been made in the case of the latter.
Australian Privacy Principle 7 – Direct Marketing
The Business Development Unit is responsible for any direct marketing that PRONIA undertakes related to fundraising activities. Events that PRONIA conducts include, the “I Love All Things Greek” Community Directory, dinner dances, its annual Radiothon, raffles and scoping for sponsorship opportunities.
PRONIA utilise various communication channels to market its fundraising initiatives or events. This may occur through email, post, telephone, the internet or other digital formats. In all communications, the relevant PRONIA staff member will provide information, or make the individual/organisation aware of the option not to receive further correspondence
Separate to marketing initiatives, PRONIA facilitates its own radio program every Wednesday on 3XY Radio Hellas, where it promotes a number of its programs and services within the Greek speaking community.
Australian Privacy Principle 8 – Cross-border Disclosure of Personal Information
PRONIA will first ensure that any overseas recipient it discloses information to, will act in accordance with the Australian Privacy Principles defined in the Australian Privacy Act 1988, unless your consent is provided initially for such a disclosure.
Other instances in which PRONIA may disclose information is through request by an Australian court order or where a situation in which suspicious behaviour is observed or criminal investigation pursues.
Australian Privacy Principle 9 – Adoption, Use or Disclosure of Government Related Identifiers
Unless required under Australian law or court order, PRONIA will not utilise government related identifiers to identify you as an individual.
Only if it is necessary to verify your identity will PRONIA utilise a government related identifier. Additional circumstances which permit the disclosure of government related identifiers relate to requests from law enforcement authorities or a court of law and any situation in which there is concern of suspicious or unlawful activity.
Permission for PRONIA to adopt your government related identifier(s), is only allowed if prescribed in any relevant and applicable government regulations.
Australian Privacy Principle 10 – Quality of Personal Information
Through regular and ongoing communication PRONIA takes all steps to ensure that the personal information (or information of your business or service, related to any marketing initiatives) that is collected is complete, up to date and accurate for any purposes of use or disclosure.
Clients are also encouraged to inform PRONIA staff of relevant units of any changes to their information so that information can remain accurate and up to date.
Australian Privacy Principle 11 – Security of Personal Information
Personal, sensitive and health information of all PRONIA service users, sponsors, members, suppliers, volunteers and community contacts are protected and stored securely to avoid misuse, prevent loss and unauthorised access and modification. All information collected from or about you is treated as confidential within PRONIA. No unauthorised individual is permitted to access confidential information. Staff utilise personal, sensitive and health information as it relates to their work and keep this in their possession from period required to complete their work or finalise the matter at hand.
Hard copy documents containing your information are kept on PRONIA premises in a location which negates the possibility of casual access by unauthorised persons. A clear desk clear screen policy is also in practice to avoid access to confidential information by unauthorised persons. PRONIA premises are protected by appropriate security systems after business hours. Similarly, electronically stored data are kept in databases with restricted access and are protected against viruses. These are protected in the same way as hardcopy files.
Should PRONIA no longer require your information for any purposes, PRONIA will abide by appropriate time-lines to destroy your information or have it de-identified. Any information that is required to be archived are transferred to our archiving room which is only accessible by authorised staff members.
Australian Privacy Principle 12 – Access to Personal Information
If at any stage you require access to your information PRONIA will ensure that access is granted. For information about access to your information contact our head office on (03) 9388 9998.
Circumstances which prevent PRONIA from granting access to your information are:
- If provision endangers the life of another individual or public health and safety
- The privacy of other individuals is impacted
- The request for access is one without value or seriousness
- If information relates to legal proceedings
- Revealing negotiations of PRONIA intentions related to you
- Access is unlawful or unauthorised by an Australian court order
- PRONIA has reason to believe your conduct has been unlawful, prejudicing any appropriate action to be taken by PRONIA or a law enforcement body’s activities
- Access would prejudice a commercially sensitive decision making process
However, PRONIA will attempt to provide information to you in a way that satisfies your request for access without jeopardising any circumstances at hand. If necessary, information will be provided to you through a mutually agreed intermediary.
Upon your request for access, PRONIA will ensure that your request is granted within a reasonable amount of time, and in the appropriate format you wish to view this information
PRONIA does not charge individuals for making a request to access their information. However a small, non-excessive charge may be applicable dependent on the time taken to access your information. PRONIA will advise you if such a charge is applicable prior to granting your request.
If PRONIA cannot provide access to your personal, sensitive, personal information, nor provide it in the format requested, PRONIA will provide you with documented reasons for this in addition to any other reasons prescribed by regulations, and details of mechanisms available for you to file a complaint.
Australian Privacy Principle 13 – Correction of Personal Information
Should you believe that information held by PRONIA is incorrect, incomplete, out of date or misleading, you can request to correct the information. PRONIA will allow for correction of your information to ensure its validity. Alternatively, if your request is refused you are able to request that PRONIA attach a statement regarding the refusal of correction to highlight the inaccuracy of information PRONIA possesses. PRONIA will make the associated statement apparent to users of the information.
In the event PRONIA refuses your application to correct information PRONIA will provide you with a written notice that outlines the reasons for the refusal, mechanisms in which you can complain and describe any other matters prescribed by relevant regulations.
Should you be dissatisfied, at any point, with PRONIA’s treatment of you or your request, for information the Office of the Australian Information Commissioner can be contacted on 1300 363 992.