Safe Futures Foundation
Disclosure generally means the release of information to an outside body.
Employee records mean a record of personal information relating to the employment of the employee. This may include health information, the engagement, training, disciplining or regisnation of the employee, the termination of employment of the employee, the terms and conditions of employment of the employee, the employee's personal emergency contact details, leave records, taxation, superannuation or banking details and the employee's salary or wages.
Primary purpose means the dominant reason for information being collected.
Personal information means information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not, about an individual (not corporate body) whose identity is apparent, or can reasonably be ascertained, from the information or opinion. It includes all personal information regadless of its source.
Sensitive information is a subset of personal information. It means information or opinion about an individual's racial or ethnic origin, political opinions, membership of a political association, relivious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information about an individual.
Supporter records mean a record of personal information relating to the supporter's relationship with Safe Futures Foundation. This includes address, phone number, email/social media profiles, DOB, financial information and other personal details.
Volunteer records mean a record of personal information regarding to the engagement of the volunteer. This includes address, phone number, email/social media profiles, DOB and other personal details.
Safe Futures Foundation abides by the Federal Privacy Act 1998 (the Act) which applies to the private sector and not-for-profit organisations. Safe Futures Foundation also abides by the ten National Privacy Principles which were introduced as an amendment to this Act in December 2001.
Further information can be accessed at http://www.privacy.gov.au.
Applying the National Privacy Principles
The National Privacy Principles apply to the collection, use and disclosure of personal or sensitive information. A definition of personal and sensitive information is provided in this document in Section – Definitions.
Safe Futures Foundation may use personal information for the primary purpose for which it was collected or for a reasonably expected related purpose.
Exemptions from the National Privacy Principles
Safe Futures Foundation is exempt from complying with the National Privacy Principles in the following situations:
Employee Records – Safe Futures Foundation may use or disclose information contained in employee records where it is directly related to the employment relationship. This applies to current and former employees. If Safe Futures Foundation discloses personal information regarding employees, the third party to whom the information is disclosed, such as a superannuation fund, will be bounds by the National Privacy Principles.
This exemption does not apply to candidates for potential employment with Safe Futures Foundation, or the agency representing a potential future employee. Candidates need to authorize Safe Futures Foundation to use their personal information to undertake activities relating to the recruitment process, such as checking employment history and contacting referees. Please refer to the section "Candidate Resumes" set out below further information.
- Use in Legal Proceedings – Safe Futures Foundation may use or disclose personal information where it is reasonably believed that use or disclosure is necessary for proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
- Service Providers – The disclosure is needed in order for Safe Futures Foundation's contracted service providers (who are bound by privacy legislation) to assist in tasks such as mailing or donation processing.
Information Collected by Safe Futures Foundation
Safe Futures Foundation may collect different types of information depending on the purpose of collection.
Safe Futures Foundation may collect the following information from supporters:
- Name, address, and contact information;
- Interest in Safe Futures Foundation's programs;
- Credit card or bank account details; and
- Other information relating to personal circumstances.
- Includes personal information disclosed in conversations, meetings with supporters.
Safe Futures Foundation may collect the following information from employees, volunteers, contractors and workers:
- Name, address, occupation, professional memberships and contact information;
- Date of birth;
- Bank account details;
- Tax File Number and taxation information such as HECS information;
- Work permission documentation;
- Work history
- Health history in some circumstances, such as for insurance purposes;
- Emergency contact details;
- References; and
- Superannuation information.
If an employee does not give Safe Futures Foundation the above requested information, it may affect Safe Futures Foundation's ability to meet its obligations as an employer or provider of work.
Collecting Sensitive Information
Generally, Safe Futures Foundation does not collect sensitive information. However, Safe Futures Foundation may collect sensitive information in certain circumstances with consent or where it is required by law.
Collecting Personal Information
Safe Futures Foundation will generally only collect personal information from the person concerned. This may be collected through means such as written correspondence, via telephone or in meetings with employees.
At and before the time (or, if it is not practicable, as soon as practicable after) SFF collects personal information, steps will be taken to ensure the individual is aware of:
- SFF's identity and contact information;
- The fact that the individual concerned is able to gain access to the information;
- The purpose for which the information is collected;
- To whom SFF usually discloses information of the type collected;
- Any law that requires the particular information to be collected; and
- The main consequences ( if any) if all or part of the information is not provided.
If it is reasonable and practicable to do so, SFF will collect personal information about an individual only from that individual.
In some circumstances it may be necessary for one or more functions or activities for SFF to collect personal information about an individual from a third party.
Where SFF has collected personal information about an individual from a third party, all reasonable stpes will be taken to ensure the individual is aware of the matters listed above.
Personal Information Provided to SFF by Another Individual
If an individual provides personal information to SFF about someone else he or she must ensure that he or she is entitled to disclose that information and that SFF is able to legally collect such information.
Use of Personal Information
SFF does not sell collected information.
SFF will disclose the purpose for which personal information will be used.
SFF will use personal information obtained for the primary purpose it was collected or reasonably related purpose.
SFF will only use the information for other purposes if the individual's consent is obtained, or if SFF is otherwise entitled to do so under the Act.
Access to Personal Information
Employees of SFF will only access personal information necessary to perform their functions or activities, such as providing information or for employment related activities such as an application for employment with SFF.
In some circumstances it may be necessary for SFF to disclose personal information about an individual for employment related activities. For example, SFF may need to provide information to the following:
- Government authorities;
- A court, tribunal or regulatory authority; or
- Superannuation funds and insurers.
SFF will request consent to disclose any information to third parties. For example, for an employee, this may include situations such as financial institutions or potential employers contacting SFF to confirm details of employment.
SECURITY OF PERSONAL INFORMATION
SFF makes every effort to ensure that the personal information held is protected from misuse or unauthorized access, modification or disclosure.
Accessing Personal Information
SFF takes reasonable steps to make sure that the information collected and used is accurate, complete and up-to-date. Supporters may contact SFF at any time if they wish to:
- Change their personal information
- Cancel some or all of the communications that SFF provides (opt-out mechanisms are included on the majority of communications)
- Request access to the information that SFF holds about them (minimum administration fee may be charged); or
SFF is entitled to refuse a request to access personal information in particular circumstances (such as where providing access would be unlawful or would have an unreasonable impact on the privacy of other individuals).
If SFF rejects a request for access, reasons for the decision will be given to the individual concerned.
Where the request is accepted, SFF may charge a reasonable fee for providing access to the personal information.
Using Personal Information for Marketing Purposes
SFF may sometimes disclose names and addresses to third parties for the purpose of allowing them to market their products and services. Supporters are given the opportunity to opt out of such communications and can contact SFF's Privacy Officer for further details.
To comply with privacy legislation, all parties involved in the recruitment process of volunteers and employees must ensure the following:
- Details of a candidate must not be discussed with any other person, other than those involved in the selection process. SFF may be liable for a breach of the candidate's privacy if other employees or Managers become aware that the candidate has applied to SFF.
- Managers must not retain a hard or soft copy of any candidate resume whether they are successful or unsuccessful. Successful candidates will have a copy of their resume placed on the personnel file and unsuccessful applications will be held by Human Resources for three months.
- All resumes that are forwarded to Managers from Human Resources must be returned once the position has been filled. Human Resources must be returned once the position has been filled. Human Resources will retain these applications for a period of three months post the successful person starting. The exception to this is if permission is sought from the applicant and he or she agrees to have their resume retained by SFF. If the applicant advises they no longer remain interested, the resume must be destroyed.
- Managers or staff who receive resumes directly should forward the resume to Human Resources.
Maintenance of Employee, Volunteer and Supporter Records
SFF is required to keep employee and volunteer records for seven years from the date on which an entry is made, or from the termination of an employee's employment, depending on which event occurs earlier.
In the case of other records, such as taxation records, SFF must maintain these records for continuous period of seven years from the date the entry is made.
Supporter information is captured on the SFF database indefinitely.
Method of Disposal of personal Information
All information of a private, personal or confidential nature should be disposed of by SFF in a manner that ensures the privacy of the individual to whom it relates.
Destruction of information will usually be means of shredding or secure disposal by registered waste contractors.
COMPLIANCE WITH THIS POLICY
Employees, volunteers and contractors must comply with this Policy. If an employee fails to comply, they may be subject to disciplinary action, up to and including termination of their employment. If a volunteer fails to comply, they may also be subject to disciplinary action and their engagement with SFF terminated. If a contractor fails to comply, their contract may be terminated without notice.
ACCESS TO THIS POLICY
QUESTIONS OR COMPLAINTS
If an individual has further queries, problems, complaints, or would like to give Safe Future Foundation feedback, they should contact Safe Futures Foundation at firstname.lastname@example.org or call 03 98770311.
REVIEWING AND MONITORING THIS POLICY
This policy will be monitored and reviewed in line with the process in the Policy Framework. The Head of Human Resources, supported by the Supporter Relations Coordinator is accountable to the Chief Executive Officer and Board for managing and maintaining this policy. All members of the Leadership Team are accountable for ensuring that the functional teams understand and adhere to this policy in their day-to-day work. When compliance issues surface, the Leadership Team members will work wit staff members to address these issues promptly.
Any updates/revisions to the policy must be endorsed by the Chief Executive Officer and Leadership Team before being submitted to the Board for their approval.
If the Chief Executive Officer becomes aware of any ongoing concerns or problems with privacy, she will take these issues seriously and work to address these concerns. If a privacy problem is not resolved to an individual's satisfaction, he or she may take a complaint further by contacting the Federal Privacy Commissioner's office or visiting http://www.privacy.gov.au.