Vitality Club Privacy Policy

Vitality Club is committed to safeguarding the confidentiality of personal or sensitive information collected regarding our service users and their carers, families, advocates, donors, staff and volunteers. This policy sets out how Vitality Club complies with its obligations under the Commonwealth Privacy Act 1988 including the Australian Privacy Principles (APPs) to ensure we meet our legal and ethical obligations.

This policy regulates how we manage personal information, collect, use, disclose, and secure & store personal information. It also details how individuals may access that information and have it corrected if it is wrong.

Legislative Context Legislation that relates to Privacy is:

● Commonwealth Privacy Act 1988

● National Security Legislation Amendment Act (No. 1) 2014

● Privacy Amendment (Private Sector) Act 2000

● National Privacy Principles (2001)

● Privacy and Personal Information Protection Act, 1988

Other Legislation: There are other laws which impact on particular aspects of privacy, such as:

● Workplace Surveillance Act 2005 (NSW)

● Surveillance Devices Act 2007 (NSW) Internal Document | GE-PO- Privacy Policy Version 1.3 (01/2015) Page 2 of 6 Policy Number Objective Policy Description

Vitality Club will ensure all aspects of our operations comply with the Australian Privacy Principles and the Disability Service Standards (Commonwealth & NSW). The Disability Service Standards and the NSW Standards in Action apply to the people we support and families. The National Privacy Principles apply to all people that the organisation holds VITALITY CLUB ABN 32 167 695 052 C4/57 Rothschild Ave, Rosebery, NSW 2018 personal information about. This includes, people we support, families, advocates, staff, volunteers and donors.

All employees, contractors and volunteers of Vitality Club have a responsibility to ensure that personal information is handled in accordance with this policy and that any personal and/or sensitive information accessed in the course of their duties are bound by their commitment to confidentiality.

Personal and/or sensitive information about Vitality Club service users will only be collected when it is directly relevant and needed to provide support services to that person, or where we are required to collect the information.

Upon request, Vitality Club will enable service users and staff the ability to access information kept about them, or to update or amend their held information. Vitality Club will only use personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or operations.

Vitality Club seeks and values survey information, comments, suggestions and ideas and may seek permission to post a comment or image on our site or other written communications. (for example: for a F.A.Q section or a photo for publicity purposes). We will not identify you personally, though we may use first name or initials, and certainly will not disclose your email address or phone number without your express written permission. The use of any written pieces or image is entirely voluntary and at your own discretion and risk.

You can change your mind about your preferences in respect of direct marketing and make choices at any time by contacting our office on 0433 648 834.

The types of personal and/or sensitive information that we collect may include your name, address, other contact details, information about your racial or ethnic origin, religious beliefs or affiliations, sexual orientation or practices, criminal record, health information and other such information that is relevant for us to provide our products and services to you in the manner that you have requested, or to comply with the Law.

We generally collect personal and/or sensitive information directly from you using our standard forms, over the internet, via email or through a telephone conversation with you. With your consent, we may collect personal and/or sensitive information from third party contractors or agents and government instrumentalities who are involved in the provision of our products and services. We collect your personal and/or sensitive information for any one or more of the following reasons:

● providing our products or services to you, including the direct marketing of those products or services;

● to assist with your queries;

● facilitating our internal business operations, (for example fulfilment of any legal or regulatory obligations)

● analysing our services and client needs with a view to developing new and/or improved services.

Vitality Club will not disclose identifying information without written consent. We do not give identifying information to other agencies, organisations or anyone else unless one of the following applies: - the person has consented; - the person would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies; - it is required by law or is necessary to protect the rights or property of Vitality Club or any other individual - it will prevent or lessen a serious and imminent threat to somebody’s life or health; - it relates to a criminal issue.

Where the person we support is unable to provide consent, we will obtain written consent from the Person Responsible. In some instances, verbal consent from a Person Responsible may be necessary and will be documented.

Vitality Club takes steps to protect the personal information it holds against loss, unauthorised access, use, modification or disclosure and against other misuse. These steps include secure handling procedures, access restrictions, ensuring documents are stored in locked cabinets when not in use, password protection, and restricted access for all electronic files. Each Business Service will ensure their own secure procedures relevant to their service and processes.

When no longer required, personal information is destroyed in a secure manner or deleted. If a service user has a complaint in relation to privacy or to request a copy of their personal information, the request should be made in writing, directed to: Operations Manager, Mail: P.O. Box 325 Rosebery NSW 1445 | Phone: 0433 648 834

You should expect an acknowledgement within 7 days of the complaint or concern being received. You will be advised of how your complaint or concern will be dealt with. Your complaint or concern will be investigated by the Operations Manager in consultation with the Executive Team. You will receive written advice of the response to your concern or complaint, or advice of further processes required, within 28 days. If the response you receive is not acceptable to you, we may suggest conciliation or arbitration on the matter. You may also make a formal complaint to the Privacy Commissioner.

Where an employee has a concern or complaint in relation to privacy it should be dealt with within the Vitality Club feedback and complaints procedures.

Our site may use cookies to enhance your experience while using our site. Cookies are pieces of information that some sites transfer to the computer that is browsing that site and are used for record-keeping purposes at many sites. Use of cookies makes surfing easier by performing certain functions such as saving your passwords, your personal preferences regarding your use of the particular site and to make sure you don’t see the same ad repeatedly. Many consider the use of cookies to be an industry standard.

Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. Vitality Club utilises internet-based third-party data storage, processing and services, or “cloud computing”, which may involve the disclosure of your personal and/or sensitive information to overseas recipients. We acknowledge that we are not required to ensure that overseas recipients handle your personal and/or sensitive information in compliance with Australian Privacy Law. Notwithstanding, we will where practicable in the circumstances take reasonable steps to ensure that overseas recipients use and disclose such personal and/or sensitive information in a manner consistent with this Privacy Policy.

Please remember that no one can guarantee the complete security of information transmitted over the Internet. Therefore, you should be careful about the personal information which you provide. Rest assured that we will do everything we can to safeguard your information.

Our site contains links to other sites. Please note that when you click on one of these links, you are entering another site for which Vitality Club has no responsibility. We encourage you to read the privacy statements on all such sites as their policies may be different than ours. If you have any concerns or questions about this Privacy Policy, please direct them to Operations Manager, Mail: P.O. Box 325 Rosebery NSW 1445 | Phone: 0433 648 834