The Humanitarian Group is committed to protecting and upholding the right to privacy of clients, staff, volunteers, Board members and representatives of other agencies. The Humanitarian Group is committed to protecting and upholding the rights of clients to privacy in the way The Humanitarian Group collects, stores and uses information about them and the services The Humanitarian Group provides to them.
The Humanitarian Group requires staff, volunteers and Board members to be consistent and careful in the way they manage what is written and said about individuals and how they decide who can see or hear this information.
The Humanitarian Group will follow the guidelines of the Australian Privacy Principles in its information management practices.
This policy conforms to the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles, which govern the collection, use and storage of personal information of clients, staff, volunteers, Board members and representatives of other agencies (Individuals).
This policy applies to all records, whether hard copy or electronic, containing personal information of Individuals, and to interviews or discussions of a sensitive personal nature with Individuals.
To ensure that:
The Humanitarian Group meets its legal and ethical obligations as an employer and service provider in relation to protecting the privacy of clients and organisational personnel;
clients are provided with information about their rights regarding privacy;
clients and organisational personnel are provided with privacy when they are being interviewed or discussing matters of a personal or sensitive nature; and
all staff, Board members and volunteers understand what is required in meeting these obligations.
What personal information does The Humanitarian Group collect and hold?
The Humanitarian Group may collect the following types of personal information from Individuals:
- mailing or street address;
- email address;
- telephone number;
- facsimile number;
- age or birth date;
- profession, occupation or job title;
- immigration, citizenship and visa status;
- health related information;
- information about an individual’s personal history and experiences;
- details of family members;
- any information the Individual provides to The Humanitarian Group through meeting with its representatives or completing client surveys;
- any additional information relating to the Individual that is provided to The Humanitarian Group directly through its website or indirectly through use of its website or online presence, through its representatives or otherwise; and
- any personal information about the individual provided to The Humanitarian Group with the individual’s consent from other organisations, including law enforcement agencies and other government entities.
How is personal information collected?
The Humanitarian Group collects personal information directly from the Individual unless it is unreasonable or impracticable to do so. When collecting personal information from the Individual, The Humanitarian Group may collect it in ways including:
- during conversations between the Individual and The Humanitarian Group representatives;
- via email, post or facsimile;
- through access and use of The Humanitarian Group website; or
- through information provided by other organisations or agencies, where the individual has provided either The Humanitarian Group or the other organisation or agency (or both) with permission to share personal information.
The Humanitarian Group may also collect personal information from third parties including law enforcement agencies and other government entities.
Dealing with personal information
In dealing with personal information, The Humanitarian Group personnel must:
ensure privacy for clients, staff, volunteers or Board members when they are being interviewed or discussing matters of a personal or sensitive nature;
only collect and store personal information that is necessary for the functioning of the organisation and its activities;
use fair and lawful ways to collect personal information;
collect personal information only by consent from an individual;
ensure that people know what sort of personal information is held, what purposes it is held it for and how it is collected, used, disclosed and who will have access to it;
ensure that personal information collected or disclosed is accurate, complete and up-to-date, and provide access to any individual to review information or correct wrong information about themselves;
take reasonable steps to protect all personal information from misuse and loss and from unauthorised access, modification or disclosure; and
destroy or permanently de-identify personal information no longer needed and/or after legal requirements for retaining documents have expired.
Responsibilities for managing privacy
All The Humanitarian Group personnel are responsible for managing personal information to which they have access, and in the conduct of research, consultation or advocacy work.
The Chief Executive Officer is responsible for content in The Humanitarian Group publications, communications and website and must ensure the following:
- consent is obtained for the inclusion of any personal information about any individual including The Humanitarian Group personnel;
- information provided by other agencies or external individuals conforms to privacy principles;
- clients and other relevant individuals are provided with information about their rights regarding privacy; and
- appropriate handling of any queries or complaints about a privacy issue.
What happens if The Humanitarian Group cannot collect personal information?
If the Individual does not provide The Humanitarian Group with the personal information described above, The Humanitarian Group may not be able to provide the requested services, either to the same standard or at all.
For what purposes does The Humanitarian Group collect, hold, use and disclose personal information?
The Humanitarian Group collects personal information about Individuals so that it can perform its functions and to provide best possible quality of service. The Humanitarian Group collects, holds, uses and discloses personal information for the following purposes:
- to provide its services and to access related resources;
- to update The Humanitarian Group’s records and keep Individuals’ contact details up to date;
- To comply with reporting requirements on Performance Indicators for funding purposes;
- To apply for external funding;
- to process and respond to any complaint made; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator.
To whom may The Humanitarian Group disclose personal information?
The Humanitarian Group may disclose an Individual’s personal information to:
- The Humanitarian Group’s staff and personnel, related bodies corporate, government entities, international organisations, contractors or service providers for the purposes of provision of The Humanitarian Group’s services and fulfilling requests by Individuals;
- the United Nations or other organisations, for the purpose only of assisting The Humanitarian Group in making a funding application or acquittals; and
- any organisation for any authorised purpose, with the Individual’s consent.
How can the Individual access and correct personal information?
Individuals may request access to any personal information The Humanitarian Group holds about them at any time by contacting The Humanitarian Group (see the details below). Where The Humanitarian Group holds information that the Individual is entitled to access, The Humanitarian Group will try to provide the Individual with suitable means of accessing it (for example, by mail or email). The Humanitarian Group may charge the Individual a fee to cover administrative and other reasonable costs in providing the information. The Humanitarian Group will not charge for simply making the request and will not charge for making any corrections to personal information.
There may be instances where The Humanitarian Group cannot grant access to the personal information. For example, The Humanitarian Group may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, The Humanitarian Group will give reasons for any refusal.
If the Individual believes that personal information The Humanitarian Group holds is incorrect, incomplete or inaccurate, then the Individual may request The Humanitarian Group to amend it. The Humanitarian Group will consider if the information requires amendment. If The Humanitarian Group does not agree that there are grounds for amendment then The Humanitarian Group will add a note to the personal information stating that the Individual disagrees with it.
What is the process for complaining about a breach of privacy?
If an Individual believes that his or her privacy has been breached, they may contact the The Humanitarian Group Privacy Officer using the contact information below, providing details of the incident so that The Humanitarian Group can investigate it. Complaints about breaches of privacy should be made in writing, so The Humanitarian Group can be sure about the details of the complaint. The Humanitarian Group may attempt to confirm the Individual’s understanding of the conduct relevant to the complaint. The Humanitarian Group will inform the Individual whether it will conduct an investigation, the name, title and contact details of the investigating officer and the estimated completion date for the investigation process. After completing the investigation, The Humanitarian Group will contact the Individual to advise the outcome.
Is personal information disclosed to anyone outside Australia?
The Humanitarian Group may disclose personal information to third parties located overseas for some of the purposes listed above. The Humanitarian Group takes reasonable steps to ensure that the overseas recipients of personal information do not breach the privacy obligations relating to personal information but cannot guarantee that these overseas organisations comply with the Australian Privacy Principles. The Humanitarian Group may disclose personal information to entities located outside of Australia, including the following:
- data hosting and other IT service providers; and
- the United Nations.
Contacting The Humanitarian Group
Post: Privacy Officer, The Humanitarian Group, 16b Sunbury Road, Victoria Park WA 6100