Privacy Policy

1. Policy Statement

Uniting AgeWell respects the right of individuals to privacy and is committed to:

• protecting the privacy of personal information it collects, holds and administers in the process of providing services and conducting its business;
• managing the privacy of personal information in accordance with the Australian Privacy Principles as prescribed in The Privacy Amendment(Enhancing Privacy Protection) Act 2012.

2. Purpose

The purpose of this policy is to provide information on Uniting AgeWell processes:

• to manage the collection, storage, use, and disclosure of personal information;
• for individuals to access and amend their personal information;
• to provide feedback or make complaints to Uniting AgeWell about management of personal information.

3. Practice Standard

3.1. Collection

Uniting AgeWell will only collect personal information, subject to the consent of each individual, that is necessary for the provision of high quality services and care or to meet other business needs. Such personal information may include health or sensitive information. When collecting personal information Uniting AgeWell will inform individuals of the purpose for collecting the information, how it will be used, and that it may be accessible to them on written request.

3.2. Security and Storage

Uniting AgeWell will:

• take all reasonable steps to ensure that personal information is stored safely and securely. This includes storage of hard copy documents as well as electronic / technological and communication systems;
• ensure security, integrity, and privacy of personal information and periodically review and update security protocols of relevant processes and technologies;
• ensure that access to personal information is only provided to authorised personnel.

3.3. Access and Correction

If requested in writing, Uniting AgeWell will provide individuals with access to their personal information unless such action:

• is unlawful; · threatens or may threaten the health or safety of any individual;
• has an unreasonable impact upon the privacy of other individuals; or
• the request is frivolous or vexatious; or
• access is otherwise exempt under the Australian Privacy Principles.

Requests for access to personal information should be made through the Uniting AgeWell Privacy Officer. Contact details are provided in 3.12.

3.4. Retention

Personal information will be retained for as long as necessary to provide required services and to comply with legal requirements.

If personal information is no longer required for any purpose, including legal purposes, Uniting AgeWell will take reasonable steps to securely destroy or deidentify that personal information.

3.5 Use and Disclosure

Uniting AgeWell will only use personal information for the purpose for which is collected unless:

• the individual provides consent;
• the purpose directly relates to the purpose indicated at the time of collection; · there is a threat to health or safety;
• unlawful activity is suspected;
• disclosure is required by law, including compulsory notices from courts of law, tribunals or government agencies;
• an individual is incapable of giving or communicating consent and personal information is required to be given to a ‘responsible person’ for the necessary provision of appropriate care or treatment or for compassionate reasons;
• a person is acting on behalf of the individual, including persons nominated by the individual such as, executors, trustees and legal representatives.

3.6 Direct mailing

From time to time Uniting AgeWell may use personal information for direct mailing purposes. An opportunity will be provided for individuals to opt out of having their information used for this purpose.

3.7 Data Quality

Uniting AgeWell will endeavor to ensure that personal information collected is relevant, accurate, complete, and up-to-date for the purpose for which it is to be used. Personal information will be updated promptly when individuals advise any change.

3.8 Identifiers

Uniting AgeWell will identify individuals (including clients and staff) by a unique identifier assigned internally by Uniting AgeWell. Uniting AgeWell may, however, retain a record of other external personal identifiers that are required to provide services, coordinate with other care agencies, or otherwise fulfil service, operational, or reporting obligations.

3.9 Anonymity

Where lawful and practicable, Uniting AgeWell allows people to participate in activities anonymously. Such activities may include participating in surveys, completing evaluation forms, or making a donation.

3.10 Overseas Data Flows

Uniting AgeWell will not transfer personal information to third parties outside Australia unless the individual’s consent has been obtained and similar privacy laws apply in the relevant overseas country.

3.11 Internet and email

When you visit Uniting AgeWell websites, our server or our Internet Service Provider makes a record of your visit and may log the following information:

• your server address (which includes your top level domain name - e.g. com, .gov, org);
• your IP address;
• location data (where available);
• the date and time of your visit to the site;
• the pages you accessed and documents downloaded;
• the previous site(s) you have visited;
• the type of browser you are using; and
• various types of metadata.

We use this information for marketing purposes, as well as to optimise and personalise your use of the Uniting AgeWell website.

3.11.1 Access to information collected

Uniting AgeWell will not make an attempt to identify individual users. However, in the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect our Internet Service Provider's logs.

3.11.2 Use of information collected

Uniting AgeWell will only record the details which you proffer if you send us a message. Your e-mail address will only be used for the purpose for which you have provided it and it will not be added to a mailing list or used for any other purpose without your consent. Users should be aware that there are inherent risks transmitting information across the Internet.

3.11.3 Cookies

Cookies are small files stored on your computer or mobile device which collect information about your browsing behaviour. Cookies do not access information which is stored on your computer.

This web site will use persistent cookies for statistical purposes, and session cookies to enable users to remain signed in to the website. Cookies can be either "persistent" or "session" based. Persistent cookies are stored on your computer, contain an expiration date, and may be used to track your browsing behaviour upon return to the issuing website. Session cookies are short-lived, are used only during a browsing session, and expire when you quit your browser. Upon closing your browser the session cookie set by this website is destroyed and no personal information is maintained which might identify you should you visit our website at a later date. When signing in, you may opt for a persistent cookie to enable you to remain signed in to the website after you have closed your browser.

Uniting AgeWell may also use products offered by third parties such as Google and social media platforms like Facebook to undertake activities including:

• website analysis;
• ongoing monitoring of the success of marketing campaigns; and
• online behavioural advertising designed to supply you with advertising that is more relevant to your needs when you visit our website or other websites that promote our services.

You can choose if and how to accept cookies by configuring the preferences and options in your web browser. For example, you can set your browser to notify you when you receive a cookie or to reject cookies. If you decide not to accept cookies, however, you may not be able to gain access to all the content and functions of our websites.

3.12 Feedback and complaints

If you would like to provide feedback to Uniting AgeWell, or to lodge a complaint regarding the way that the organisation manages your personal information then please contact the Uniting AgeWell Privacy Officer.

The Privacy Officer 130 Lonsdale Street Melbourne 3000 Phone 03 9133 5021 Email: [email protected]

Complaints may also be lodged with Commonwealth Government’s Information Commissioner. Where any such complaints are lodged Uniting AgeWell will work the Commissioner and the individual to resolve the issue.

4. Monitoring and Improvement

This policy will be reviewed every 3 years or as required.

5. Related Documentation

UA Recruitment Policy

6. References

The Privacy Amendment (Enhancing Privacy Protection) Act 2012

The Privacy Act 1988

Health Records Act 2001 (Vic)