Privacy Statement

1. RESPONSIBILITIES 

Travellers Aid Australia acknowledges its responsibilities to respect the importance of privacy and  confidentiality as an individual right. Travellers Aid collects and stores personal information and  or sensitive information from its clients, staff, customers, board, volunteers, students and the  broader community to provide appropriate and responsive service delivery. This Privacy  Statement has been developed to pursue the highest standard in the protection and preservation  of privacy and confidentiality. 

2. DEFINITIONS 

2.1. What is Personal Information? 

2.1.1. Personal information is information or an opinion, whether it is true or not, about an  individual whose identify is apparent, or can be reasonably ascertained, from that  information or opinion. 

2.1.2. For the purposes of this Privacy Statement, a reference to personal information  should be read as including sensitive and health information, unless otherwise  specified. 

2.2. What Is Sensitive Information? 

2.2.1. Sensitive information is a subset of personal information which is afforded a higher  level of protection under the Australian Privacy Principles (APPs). This includes  information which relates to an individual’s race or ethnic origin, political opinions  or memberships of a political association, philosophical beliefs, religious beliefs or  affiliations, membership of a professional or trade association or union, sexual  preferences or practices, criminal record or health information about an individual. 

2.2.2. Our collection, use and disclosure of personal information, including sensitive  information, will comply with the APPs.

2.3. What is Health Information? 

Health information is personal information that is also information or an opinion about the  physical, mental or psychological health of an individual, a disability of an individual, an  individual’s expressed wishes for the future provision of their healthcare, or a health service  provided to an individual. 

2.4. Travellers Aid Privacy Statement 

This Privacy Statement, and Travellers Aid’s internal privacy procedures, have been  prepared on the basis that Travellers Aid is a Health Service Provider as defined in the  Health Records Act 2001. 

3. PROCEDURES 

3.1. Overview 

3.1.1. Travellers Aid complies with the Australian Privacy Principles (APPs), Information  Privacy Principles (IPPs) and Health Privacy Principles (HPPs). 

3.1.2. Travellers Aid is committed to protecting personal information in accordance with  these laws. 

3.1.3. This Privacy Statement sets out how we manage your personal information,  including sensitive and health information. It describes the types of information we  collect and hold and why we do so, how to access and correct information, and  how to make a privacy complaint. 

3.2. What Personal Information Do We Collect and Hold? We may collect the following types of personal information: 

3.2.1. Name, address, age or birth date, gender, race, telephone number, email address,  details of next of kin/responsible person, physical abilities, health information,  details of health care professionals, social circumstances information, details of  your profession, occupation or job title. 

3.2.2. Details of services you have received from us or which you have enquired about,  together with any additional information necessary to deliver those services and to  respond to your enquiries, for example details of your medication and care needs. 

3.2.3. Any additional information relating to you that you provide to us directly or  indirectly through use of our website. 

3.2.4. Information you provide to us through our service centres, customer surveys or  visits by our representatives from time to time. 

3.2.5. We may also collect some information that is not personal information because it  does not identify you or anyone else. For example, we may collect anonymous  answers to surveys. 

3.2.6. For job applicants, employees or volunteers, we may collect details about  employment history, qualifications, resumes, references, banking details, fitness  for work or other such documents. 

3.3. How Do We Collect Your Personal Information? 

We collect your personal information directly from you unless it is unreasonable or  impracticable to do so. When collecting personal information from you, we may collect in  ways including: 

3.3.1. During conversations between you and our representatives. 

3.3.2. When you complete an application. 

3.3.3. We may also collect personal information from third parties who provide services  to you, health care professionals and organisations such as law enforcement  agencies and other government departments and agencies. 

3.3.4. Travellers Aid will only collect sensitive information and health information about  you with your consent.

3.4. Information Given in Confidence to Travellers Aid 

3.4.1. On occasion Travellers Aid may receive personal information about an individual,  from someone other than the individual, with the request that the information be  kept confidential. 

3.4.2. Travellers Aid will only collect health information about an individual with their  consent. Should the individual consent to Travellers Aid receiving confidential  information about the individual from a person other than the individual, in these  circumstances Travellers Aid will: 

3.4.2.1. Confirm that the information is to be kept confidential; 

3.4.2.2. Record the information only if it is relevant to the provision of health  services to, or the care of, the individual; 

3.4.2.3. Take reasonable steps to ensure that the information is accurate and not  misleading; and 

3.4.2.4. Take reasonable steps to record that the information is given in  confidence and is to remain confidential; 

3.4.3. Travellers Aid will take reasonable steps to ensure that the person giving the  information to Travellers Aid in confidence is aware of the Privacy Statement. 3.5. What Happens If We Can’t Collect Your Personal Information? If you do not provide us with the personal information described above, some or all of the  following may happen: 

3.5.1. We may not be able to provide the requested services or functions to you, either to  the same standard or at all. 

3.5.2. We may not be able to provide you with information about functions and services  that you may want, including information about special activities or promotions. 3.6. For What Purposes, Do We Collect, Hold, Use and Disclose Your  Personal Information? 

We collect, hold, use and disclose your personal information for the following purposes: 3.6.1. To provide quality functions and services to you. 

3.6.2. To provide best possible quality of customer service. 

3.6.3. To answer enquiries and provide information or advice about existing and new  functions or services. 

3.6.4. To send communications requested by you. 

3.6.5. To update our records and keep your contact details up to date. 

3.6.6. To comply with relevant laws and legislation. 

3.6.7. To meet government funding requirements. 

3.6.8. Your personal information will not be shared, sold, rented or disclosed other than  as described in our Privacy Policy, Privacy Procedures and Privacy Statement  documents. 

3.7. To Whom May We Disclose Your Information 

For the purposes of providing quality services to you, there will be times when Travellers  Aid will need to disclose your personal information to third parties, this may include: 3.7.1. Contractors or service providers for the purposes of operation of our organisation,  

fulfilling requests by you and to otherwise provide functions and services to you. 3.7.2. Health care providers and your representatives including your guardian and/or  family. 

3.7.3. The use and disclosure of personal information that meets the criteria of “Permitted  General Situation” and/or “Permitted Health Situation” (as a condition of govern ment contractual agreement). A written note of the use/disclosure is to occur.  (Refer to Section 5–References for further detail on relevant legislative measures). 

3.7.4. Suppliers and other third parties with whom we have commercial relationships, for  business, marketing, and related purposes. 

3.7.5. Any organisation for any authorised purpose with your express consent.

3.7.6. The law also allows some uses without consent, such as law enforcement  purposes and to protect safety. 

3.7.7. Travellers Aid is conscious of its obligations regarding use and disclose of  personal information. Travellers Aid will only use and disclose personal  

information in a manner which is consistent with its legislative obligations. 

3.8. Data Retention 

3.8.1. Travellers Aid will take reasonable steps to protect the health information it holds  from misuse and loss and from unauthorised access, modification or disclosure. 3.8.2. Travellers Aid will not delete health information relating to an individual even it if is  later found or claimed to be inaccurate unless: 

3.8.2.1. The deletion is permitted, authorised or required by the regulations or  any other law; or 

3.8.2.2. The deletion is not contrary to the regulations or any law and occurs, on  the later date of: 

3.8.2.2.1. In the case of health information collected while the  

individual was a child, after the individual attains the age of  

25 years; or 

3.8.2.2.2. In any case, more than 7 years after the last occasion on  

which a health service provided to the individual by the  

provider. 

3.9. Direct Marketing Materials 

3.9.1. Travellers Aid may, from time to time, use your personal information to provide you  with current information about our services, offers you may find of interest, 

changes to our organisation, or new services being offered by Travellers Aid, or  any company with whom we are associated. 

3.9.2. These communications may be sent in various forms, generally by mail, in  accordance with applicable marketing laws. You may at any time opt-out of  receiving such information by advising us in writing or telephoning. 

3.9.3. We do not provide your personal information to other organisations for the  purposes of direct marketing. 

3.10. Updating Your Personal Information 

It is important to Travellers Aid that the personal information we hold about you is accurate  and up to date. During the course of our relationship with you we may ask you to inform us  if any of your personal information has changed. While we take care to ensure that your  personal information that we collect, use and disclose is correct and up to date, we may ask  that you: 

3.10.1. Advise Travellers Aid if you know of any errors in your personal information. 3.10.2. Keep Travellers Aid informed of any changes to your personal information. 3.11. How Can You Access and Correct Your Personal Information? 3.11.1. You may request access to any personal information Travellers Aid holds about  you at any time by contacting us. 

3.11.2. Where we hold information that you are entitled to access, we will try to provide  you with suitable means of accessing it (e.g. by mailing or emailing it to you). We  may charge you a fee to cover our administrative and other reasonable costs in  providing the information to you. We will not charge for simply making the request  and will not charge for making any corrections to your personal information. 

3.11.3. There may be instances where we are not required to provide you with access to  your personal information. For example, if it interferes with the privacy of others, if  the information relates to existing or anticipated legal proceedings, if your request  is vexatious, if the information is subject to confidentiality, or another permissible  exception applies. An explanation will be provided to you in writing if we deny you  access to your personal information.

3.11.4. If you believe that personal information Travellers Aid holds about you is incorrect,  incomplete or inaccurate, then you may request us to correct it. 

3.11.5. If appropriate we will correct the personal information at the time of the request  otherwise, we will provide an initial response to you within seven days of receiving  your request. Where reasonable, and after our investigation, we will provide you  with details about whether we have corrected the personal information within 30  days. Travellers Aid may need to consult with other entities as part of our  

investigation. If we refuse to correct personal information we will provide you with  written reasons for not correcting the information. 

3.12. Making Information Available to Another Health Service Provider 3.12.1. You may: 

3.12.1.1. Request that Travellers Aid provide health information relating to you,  which is held by us, to another health service provider; 

3.12.1.2. Authorise another health service provider to request health information  relating to you which is held by us. 

3.12.2. In such circumstances Travellers Aid, upon payment of a prescribed fee (if  applicable) and subject to the terms of this Privacy Statement, will provide a copy  or written summary of that health information to that other health service provider  as soon as practicable. 

3.13. What Is The Process For Complaining About A Breach of Privacy? 3.13.1. If you believe that your privacy has been breached, please contact us and provide  details of the incident so that we can investigate it. Our procedure for investigating  and dealing with privacy breaches will be undertaken by the Chief Executive  Officer of Travellers Aid who will initiate the course of action to examine if a breach  has occurred. 

3.13.2. Where Travellers Aid’s Privacy Policy, Privacy Procedures or Privacy Statement is  inconsistent with Travellers Aid’s legislative obligations, the legislative obligations  will prevail. Where Travellers Aid’s Privacy Policy, Privacy Procedures or Privacy  Statement is silent on a matter, Travellers Aid will look to legislation for guidance  as to its obligations. 

3.14. Do We Disclose Your Personal Information To Anyone Outside  Australia or Victoria? 

3.14.1. Travellers Aid does not itself store or process any of your personal information  outside of Victoria. 

3.14.2. Your health information will only be transferred outside Victoria if: 

3.14.2.1. You consent; 

3.14.2.2. The transfer is for your benefit and it is impracticable to obtain your  consent to the transfer and if it were practicable to obtain your consent,  

you would likely give your consent to the transfer; 

3.14.2.3. The transfer is authorised or required by any other law. 

3.14.3. Our cloud storage providers and IT servers are located within Victoria. 3.14.4. Some of our third-party providers, for example cloud storage providers, may store  data outside of Victoria. However, all of these providers are contractually  required to comply with the HPPs, IPPs and APPs. 

3.14.5. If we transfer health information outside of Victoria, we will take reasonable steps  to ensure that the recipient of the information does not hold, use or disclose the  information inconsistently with the HPPs and APPs. 

3.15. Using Government Related Identifiers 

3.15.1. If Travellers Aid collects government identifiers, such as Medicare, Veterans  Affairs, Centrelink details we do not use or disclose this information other than  authorised by law. 

3.15.2. Travellers Aid will never use a government identifier in order to identify you.

3.16. Support Without Identifying You 

3.16.1. In most circumstances, it will be necessary for TAA to identify you in order to  successfully provide services and functions to benefit you. 

3.16.2. However, where it is lawful and practicable to do so, TAA will offer you the  opportunity of using our services without providing us with personal information, for  example if you make general enquiries about current events, services offered,  promotions etc. 

3.17. Security 

3.17.1. Travellers Aid takes reasonable steps to protect your personal information by  storing it in a secure environment and that it remains private and confidential within  our organisation at all times. 

3.17.2. We may store your information in electronic and paper form and will take  reasonable steps to protect any personal information from misuse, loss and  unauthorised access, modification or disclosure. 

3.18. Further Information 

You may request further information about the way we manage your personal information  by contacting us. 

4. RELATED DOCUMENTS 

⬧ Travellers Aid Privacy Policy 

⬧ Travellers Aid Privacy Procedures 

⬧ Travellers Aid Privacy Work Instructions 

⬧ Travellers Aid Information Technology Policy 

⬧ Travellers Aid Information Technology Procedures. 

5. REFERENCES 

⬧ Privacy Act 1988 (Commonwealth) 

⬧ Privacy and Data Protection Act 2014 (Victoria) 

⬧ Health Records Act 2001 (Victoria) 

⬧ Office of the Australian Information Commissioner APP Guidelines 

⬧ Justice Connect Privacy Compliance Manual 

⬧ Justice Connect Privacy Guide – Not-For-Profit Law Guide 

⬧ Website: www.oiac.gov.au 

⬧ Website: www.legislation.vic.gov.au 

⬧ Website: www.comlaw.gov.au 

⬧ Website: www.nfplaw.org.au 

⬧ Website: www.cpdp.vic.gov.au 

6. AUTHORISATION 

Chief Executive Officer 
Travellers Aid Australia