Privacy Policy
1. Purpose
Homelessness We Care Perth and branches (SJS), collectively referred to as HWCP are committed to ensuring the highest levels of privacy and security.
By law we comply with the Australian Privacy Act of 1988 (https://www.legislation.gov.au/C2004A03712/2023-10-18/2023-10-18/text/original/pdf) but follow the Australian Privacy Principles (https://www.oaic.gov.au/__data/assets/pdf_file/0006/2004/the-australian-privacy-principles.pdf) closely to ensure we are apply this privacy policy in the most practical but comprehensive way we can.
This privacy policy is a reflection of our commitment to our users, members and volunteers privacy and explain how:
(i) We securely collect, manage, use, store and protect your personal information;
(ii) You can access and request correction of any personal information we may hold on your behalf;
(iii) How complaints can be made about any potential breach of privacy.
2. Scope
This Policy applies to our current and prospective board members, volunteers, contractors, clients, donors and suppliers who handle personal information collected by HWCP our website and related entities from time to time.
By providing your personal information to us, you consent to the use, storage and disclosure of the personal information you provide to us as described in this Policy.
3. How we manage your Personal Information
We will:
(a) Take all reasonable steps to ensure we are open and transparent about the way we manage your personal information
(b) Maintain adequate security of personal information to seek to protect it from misuse, interference and loss from unauthorised access, modification or disclosure
(c) Establish reporting channels to receive privacy inquiries from you and for reports of privacy breaches to be received and acted upon
(d) Conduct risk assessment for all new and significant initiatives which may impact the way we manage privacy
(e) Provide an option for you to use a pseudonym or otherwise by anonymous unless it is impermissible, impractical or inhibits the adequacy or quality of service provided to you
(f) Appoint a Chief Executive Officer to oversee privacy governance processes, ensure compliance with the Australian Privacy Principles (APPs) and report on privacy issues to our Board
(g) Provide this Policy free of charge and in an appropriate form for public access
(h) Provide training and privacy awareness on how APPs apply to us and how they are reflected in privacy practices, procedures and systems
(i) Periodically review this Policy as well as the privacy practices, procedures and systems across our organisation to ensure that they remain appropriate to the changing environment we operate in and will notify you by, informing you in our regular communications or posting an updated version of this Policy on our website
(j) Notify you in the most practical manner of anything which may put the lives, health or wellbeing of anyone at risk.
4. Personal Information we collect and hold
4.1 Kinds of Personal Information
We will only collect information about you that is reasonably necessary for our functions or activities which are listed under point 4.3.
Generally, we will collect this information directly from you and with consent. This may include:
• your name, address and contact details for clients, volunteers, suppliers and donors
• your image or video recordings
• information associated with web browsing, email, text messaging, phone calls or other electronic interactions with you including your phone number and user name
• for donors, details relating to your donations and information relevant to the purpose of better identifying donor sources and taxation records
• for volunteers, details outlining your working with children and police clearance status
• for others, other information relevant to the purpose of providing services such as education qualifications, employment history, police clearances, working with children clearances, interests, feedback preferences, user names and passwords and service feedback and complaint details
• sensitive information about you that may include your gender, age, date of birth, physical and mental health information
• tax registration status, and other particulars required as part of our funding obligations and/or that are relevant for the proper provision of the services that we provide
• survey and questionnaire responses
4.2 How we collect and hold Personal Information
Where possible, personal information is collected directly from you with your consent at the time of your interaction with us. In some services, personal information is:
• received from third parties where you are transferred or referred to us for the services that we provide;
• received from third parties who obtain your personal information from publicly available sources; or
• transferred between our own services provided it relates to the primary purpose for which it was collected.
Personal information may be collected in hard copy form or electronic form. Hard copy records are required to be held securely. We hold electronic records in databases with security safeguards which include protection from unauthorised access, modification and disclosure. Some of those databases are government controlled while some are held by a third-party provider.
Where consent to collection is sought, it is sought voluntarily from you and we will inform you of what you are consenting to. Our consent agreements are current and specific to the services to be provided to you.
We will not collect sensitive information about you unless you have consented; it is required by law; or in other special specified circumstances, for example relating to services provision or public health or safety.
Sensitive information is afforded a higher level of privacy protection than other personal information. Where sensitive information is provided to HWCP, it will be collected in accordance with this Policy.
4.3 Purposes for which we collect, use and disclose Personal Information
We collect, hold and use personal information only for the primary purposes for which it was collected or as set out below including:
• to provide services which may include volunteering, learning and development and fundraising. Personal information may be shared between more than one legal entity within HWCP to provide, expand or improve the services we provide to you or assist with more efficient service delivery
• to comply with the requirements of funding bodies as part of a funding agreement with us
• to operate fundraising and charitable activity in support of our objectives
• to provide customer service functions, including handling customer enquiries, complaints and feedback
• to facilitate proper governance processes such as risk management, incident management and external audits
• to gather feedback from you and other individuals about the quality of services that we provide so that the services we provide can be continuously improved
• undertake marketing, fundraising and promotional activities, including activities to better identify donor sources, events and conferences organised and held by us
• to satisfy legal obligations, comply with applicable laws and meet the requirements of bodies which regulate the services we provide
• to understand, through aggregated information, trends and patterns which we use for research and advocacy
• to fulfil other purposes to which you have consented
4.4 Disclosure to third parties
We will not disclose your personal information to other external organisations except:
• As required by funding agreements
• As required by law
• For transfer to another service provider in accordance with funding agreements
• Where we have your consent to do so through your acceptance of this Policy and the disclosure relates to the services we provide to you
• For a purpose permitted by this Policy; or
• If you request us to do so
Examples of organisations and/or third parties that your personal information may be provided to include:
• a government agency, as required by our funding agreements (which may be for example by portal directly into the agency’s database system)
• third party service providers who assist us with the delivery of services or who provide services to or partner with us to enable us to deliver services, or in undertaking quality assurance of our services
• third party service providers who assist us with fundraising activities or strategy, identifying donor sources or analysis of our fundraising activities, strategy or patterns
• third parties who assist us with co-ordination of volunteers, community activities and advocacy
• government or non-government agencies where we have a reasonable concern regarding your safety or wellbeing
• third parties who collate and/or analyse de-identified information for the purposes of research and advocacy
• third parties for the electronic storage of information.
Whilst we seek to ensure through our contracts with external parties that they comply with the Act regarding the use of your personal information, we have limited control around how some external parties (for example, government agencies) use your personal information.
4.5 Information relating to a current or former board members, volunteers, donors or clients
The Privacy Act does not apply to an act done or practice engaged in by HWCP in relation to:
• a current or former work relationship between HWCP and the individual; and
• a work relationship record held by HWCP relating to the individual (which includes personal information relating to the relationship and may include information such as recruitment/termination information, terms and conditions of the working relationship and health).
This exemption does not apply to applicants who are unsuccessful in securing a volunteer role at HWCP. In those cases, HWCP will take all necessary steps to ensure proper collection, use, storage, disclosure of and access to information in accordance with the Privacy Act and other applicable laws.
4.6 Opt-outs
If you do not wish to receive marketing or promotional communications from us, you should “unsubscribe” online where a link is provided. In other circumstances, you should contact us on the email addresses below and we will cease the relevant marketing and/or promotional communication:
For donors: privacy@hwcp.org.au
For other individuals: privacy@hwcp.org.au
Where we are providing services to you, we need to be able to communicate with you in relation to those services.
5. How you can access and correct your Personal Information
5.1 Access
You are entitled to request access to the personal information held by us about you.
This is generally provided upon request subject to completion of our verification and risk processes and to access restrictions imposed or permitted by law.
Requests are made to the same point of contact to whom you have provided your personal information. In cases where this is not known, the email HWCP Privacy email address can be used (privacy@hwcp.org.au).
We may decline a request to access your personal information in certain circumstances in accordance with the APPs. For example where your identity cannot be wholly verified or a partial identification prevents you accessing the requested information.
5.2 Correction
Where you inform us that information held by us about you is inaccurate, out‐of‐date, incomplete, irrelevant or misleading, we will correct it where we agree with you and are able to ascertain your right to update.
Notices by you to us to amend information held about you are made to the same point of contact to whom you provided your personal information. After receiving a notice to amend from you, we will take reasonable steps to correct your information.
If, having received and considered an application from you to amend your information, we do not consider that the information should be amended in accordance with the APPs, we will not amend it but we will include a note with the information that you consider that it should be amended, and advise you accordingly.
6. Retention of personal information
We will retain your personal information in accordance with applicable laws or requirements of any government or other funding body’s record-keeping requirements.
7. Mandatory Notifiable Data Breaches
We will comply with the notification and other requirements of the Act where your personal information held by us has been inadvertently lost or disclosed or improperly accessed and that loss, disclosure or access may result in serious harm to you.
8. What to do if you have a privacy enquiry or complaint
If you have an enquiry or a complaint concerning collection, use or management of your personal information, please direct your enquiry or complaint to the staff member who is your ordinary contact.
A HWCP board member will outline options regarding how your enquiry or complaint may be resolved. We will aim to respond and resolve your enquiry or complaint in a timely and appropriate manner. If we don’t, you may:
• make contact with our Chief Executive Officer via (ceo@hwcp.org.au) for consideration of alternative action.
We will treat your enquiry or complaint confidentially. You may contact the Australian Information Commissioner wherever you believe that your rights to privacy have been breached by us on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
9. Changes to this Policy
From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.
You may obtain a copy of our current policy from our website or by contacting us at the contact details above.
10. Website Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies are temporary in nature and contain no personal information.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
Other interactions on our website, such as donations, volunteer registrations or similar may introduce additional cookies that contain no personally identifiable information for the purposes of maintaining session or ensuring the interaction is secure.
11. Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.