This policy applies to all board members, paid staff, contactors, and volunteers. You should read this policy before providing us with any personal (including sensitive) information. By providing us with your personal information or by using the website, you are confirming your agreement to the contents of this policy. From time to time, it may be necessary for us to review and revise this policy. We reserve the right to change this policy at any time.
1. MOWTAS will respect each client’s right to privacy, dignity and confidentiality.
2. MOWTAS is committed to managing personal information in an open and transparent way while protecting the privacy of personal information collected, stored, and administered within the organisation.
3. All personal information will be collected, stored and shared only with consent and in accordance with the Privacy Act (Cth) 1988, which includes the 13 Australian Privacy Principles, the Privacy Amendment Act (Notifiable Breaches) (Cth) 2017 and the Personal Information Protection Act (Tas) 2004.
4. A client’s rights to privacy and confidentiality will be communicated in a way which supports their understanding.
Personal information: Personal information includes a broad range of information, or an opinion, that could identify an individual. What is personal information will vary, depending on whether a person can be identified or is reasonably identifiable in the circumstances.
For example, personal information may include:
- an individual’s name, signature, address, phone number or date of birth
- sensitive information
- credit information
- employee record information • photographs
- internet protocol (IP) addresses
- voice print and facial recognition biometrics (because they collect characteristics that make an individual’s voice or face unique)
- location information from a mobile device (because it can reveal user activity patterns and habits).
Sensitive information is personal information that includes information or an opinion about an individual’s:
- racial or ethnic origin
- political opinions or associations
- religious or philosophical beliefs
- trade union membership or associations
- gender and sexual diversity
- criminal record
- health or genetic information
- some aspects of biometric information.
ROLES AND RESPONSIBILITIES
The Board is responsible for adopting this policy. The Board, General Manager and all MOWTAS staff members, contractors and volunteers are responsible for the adhering to this policy. The General Manager is responsible for monitoring changes in privacy legislation and for reviewing this policy as and when the need arises. Staff and volunteers should note that privacy and confidentiality requirements apply in the following settings:
- The work place.
- At home and in the community.
- When talking with other staff and volunteers.
- When dealing with people at other agencies.
- In social environments.
- When dealing with other clients.
THE PERSONAL INFORMATION WE HOLD AND COLLECT
Meals on Wheels Tasmania will collect personal (including sensitive) information that is necessary for us to carry provide our services; we will only collect sensitive information when we have your consent or when we are required or authorised by law to collect such information. Personal information which fits the definition of sensitive information under the Act generally requires a higher level of privacy protection than other personal information. We do however aim to treat all your personal information with the utmost care.
HOW WE COLLECT AND KEEP YOUR PERSONAL INFORMATION
- How we collect and store personal (including sensitive) information varies depending on the purpose for which it is collected.
- We may collect your personal information:
- Directly from you, either in person, over the phone or by email; •
- From third parties where you have specifically authorised us to do so; or
- Through our website including through forms on our website.
- We will always collect your personal information directly from you unless it is impracticable to do so. This would usually be done in person, over the telephone or by email.
Examples may include:
- Copies of your written correspondence with us; Copies of receipts and/or transaction records in relation to your financial support of our fundraising activities;
- Copies of your application form, request for assistance and/or other associated documents and information that you may provide to us
- Copies of your volunteer agreement or employment agreement and any associated documents and information you provide to us in connection with your volunteering or employment with Meals on Wheels.
We may keep copies of the above documents (in physical and/or electronic form, at our election) as is necessary to carry out our functions and provide our services. All personal information is securely stored at all times by us, or an authorised external service provider and only authorised people will have access to the above documents and information.
WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION
We may collect, hold, use and disclose personal (including sensitive) information for purposes necessary to carry out our functions and provide our services. Generally, these purposes include:
To keep in contact with you as a supporter of Meals on Wheels and to inform you about the role and extent of our work:
To manage our fundraising activities and for taxation record-keeping purposes associated with your donation to Meals on Wheels;
To review your needs and to provide you with the services and assistance we offer;
To inform and improve our service design, delivery and resourcing;
- To provide you with the necessary level of service during your time as a or recipient of Meals on Wheels.
- To provide you with the services requested by you from us;
- To comply with necessary business and accounting standards;
- To comply with our reporting obligations to the Australian Taxation Office and other government agencies and public sector bodies; or
- To facilitate and manage your employment relationship or volunteer arrangement with Meals on Wheels.
We are committed to maintaining your privacy and we will only use your personal information for a permitted purpose for which we have collected the information. There is no obligation for you to provide us with any of your personal information however if you choose not to provide us with your personal information, we may not be able to provide you with the service that you require. You have the option of not identifying yourself or using a pseudonym when dealing with us in relation to a particular matter, unless we believe it is impracticable to do so in the circumstances. If you wish to deal with us in this manner, you must tell us in writing so that we can consider if your request is practicable. We may use personal information (including some sensitive) information to generate aggregated statistical data for the purpose of reporting to Government agencies and to plan for improvements to our services. We take reasonable steps to ensure that the information we report to Government agencies is de-identified and aggregated, so that the statistical data and reports cannot be used to identify you.
HOW WE MAY SHARE YOUR PERSONAL INFORMATION
If necessary to carry out our functions and provide our services, we may need to disclose your personal (including sensitive) information to external service providers (such as information technology service providers, legal service providers, other community service providers, etc.) and other organisations. We will only share your personal information in accordance with your express consent and instructions, subject to the exclusions set out in the Australian Privacy Principles, or in accordance with the specific Privacy Notice provided to you by us at or near the time of collection of your personal information. We do not supply our database information to other marketing organisations not acting on our behalf.
HOW YOU CAN ACCESS AND SEEK CORRECTION TO YOUR PERSONAL INFORMATION
You have the right to access your personal (including sensitive) information, subject to some exceptions allowed by law. If you would like to access or seek correction of your personal information, please contact State Office at the contact details below. For security reasons you will be asked to put your request in writing.
To enable us to verify your request we require you to advise the following:
- Your full name
- Contact phone number
- The relevant department or service (if known) that your request relates to
There is no application fee for making a request to access your personal information. While we do not normally charge for providing individuals with access to their personal information, we reserve the right to charge you for our reasonable costs in complying with a request for access. These costs will not be excessive.
HOW YOU CAN COMPLAIN ABOUT A BREACH OF THE AUSTRALIAN PRIVACY PRINCIPLES
We are committed to protecting your privacy and upholding the Australian Privacy Principles. If you believe we have breached the Australian Privacy Principles, please contact our State Office with your concerns at the contact details below. We take all complaints very seriously and we will endeavour to respond to your complaint and address your concerns as soon as reasonably practicable.
HOW WE COMPLY WITH NOTIFIABLE DATA BREACHES SCHEME
We will notify you in the event your personal (including sensitive) information is involved in a data breach that is likely to result in serious harm. This notification will include recommendations about the steps you should take in response to the breach. We will also notify The Australian Information Commissioner of eligible data breaches. Each suspected data breach reported to us will be assessed to determine whether it is likely to result in serious harm, and as a result require notification.
HOW YOU CAN CONTACT OUR STATE OFFICE