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Privacy Safeguards Policy

1.0 INTRODUCTION
Guide Dogs WA respects, and is committed to protecting, the privacy of all the individuals with whom it engages for the conduct of its service, business and related operations. Guide Dogs WA undertakes to adhere to the Privacy Act 1988 and all related legislative instruments including the Australian Privacy Principles (APP).

2.0 INTENT
This document describes Guide Dogs WA’s legal compliance in the way it: collects; uses; discloses; stores; corrects and provides access to personal information about its clients; donors; customers; members; volunteers and job applicants.

3.0 SCOPE
a) This policy applies to all Guide Dogs WA workers.
b) Activities involving personal information about anyone aged under 18 years will be with the expressed consent of that person’s parent/legal guardian.

4.0 EXEMPTION
The records of current and past employees are exempt from the Privacy Act, having coverage under Workplace Relations legislation. However, wherever possible and practicable, Guide Dogs WA will treat employee records as if the provisions of the Privacy Act and Privacy Principles apply.

5.0 DEFINITION
a) Worker: any person who is undertaking Guide Dogs WA business, including: employees, volunteers, students on formal work placement, contractors, and committee members.\

b) Personal Information: information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable. Common examples are an individual’s name, signature, address, telephone number, date of birth, medical records, emergency contacts (e.g. next of kin, doctor), preferred correspondence format, financial and bank account details (for funding/payment arrangements), details related to any employment/volunteering applications and commentary or opinion about a person.

c) Sensitive Information: a type of Personal Information, which can include details about a person’s: racial or ethnic origin; political opinions; membership of a political association, professional or trade association or trade union; religious beliefs or affiliations; philosophical beliefs; sexual orientation or practices; criminal record; biometric information that is to be used for certain purposes; biometric templates; personal and family wealth details (regarding potential bequest, gift-giving capacity).

d) Health Information: any information about health or a disability, including: predictive genetic information; notes about symptoms or observations and opinions; prescriptions; results of medical tests; medical reports; dental records; hospital and day surgery admission and discharge records.

6.0 COLLECTION
6.1 Purpose
Guide Dogs WA will solicit and collect personal information only to the extent necessary to:

  • carry out its service delivery, direct marketing and fund raising operations; and
  • support these operations via such activities as monitoring, reviewing and quality assurance.

In the case of job applicants, the amount of the information collected is sufficient to assess the person’s suitability for the position. For the purpose of possible future recruitment, all applications are retained. They are secured within Guide Dogs WA’s recruitment portal and specific Human Resource email inbox, accessible to authorised personnel only.

6.2 Consent – Provided, Withheld, Withdrawn
Prior, during or as soon as practicable after the collection of an individual’s personal information, Guide Dogs WA makes every reasonable effort to obtain that person’s consent for its collection, intended use and related disclosure.

Any individual may initially withhold or later withdraw permission for his/her information to be used for:

  • service provision and/or
  • direct marketing and/or
  • fundraising and/or
  • related purposes

However, the withholding and/or withdrawing of consent for service delivery purposes, may limit Guide Dogs WA’s ability to provide services sought. Up to 14 working days should be allowed for any opt out requests to take full effect.

All such requests may be made via: email – info@guidedogswa.com.au; phone – main switchboard number (9311 8202) or feedback/comment line (9311 8219).

6.3 Type
The type of information collected might include: Personal, Sensitive or Health. The efficacy of Guide Dogs WA’s operations depends upon its receipt of all necessary, accurate and current personal information.

Wherever possible and practical, Guide Dogs WA will engage with an individual who wishes to be either anonymous or assume a pseudonym. However, given the nature of many of the organisation’s operations this is likely to limit the opportunities for interaction and receipt of service.

6.4 Methods and Sources
Where practicable, Guide Dogs WA endeavours to obtain personal information directly from the individual concerned. However, some information may be collected from a third party.

Collection is undertaken via a range of methods, sources and formats that might include:

a) personal interactions via face-to-face, telephone, video, print, audio, Braille or electronic (including website1 and other forms of social media);
b) newsletters, surveys, employment/volunteering applications or other requests for information;
c) referrals from service providers or medical/allied health practitioners;
d) representatives including family, friends, carers or advocates;
e) service contracts and interactions with business associates and other stakeholders;
f) purchase transactions with customers;
g) donor/fund-raising/sponsorship transactions (e.g. payments, donations) with a range of individual, group and corporate supporters;
h) commercial list providers – either pooled, swapped or purchased.

7.0 USE
Guide Dogs WA uses the personal information described above for the purposes of providing services as well as conducting its other business, marketing and fund-raising activities. This includes support activities such as internal reporting and monitoring functions for risk management, planning and quality improvement purposes.

8.0 DISCLOSURE
Where consent has been provided or where legally permissible, Guide Dogs WA typically discloses information in ways which include the following:

  • internally for service delivery and directly related purposes such as management, funding/billing, service monitoring, planning, evaluation and complaint handling; or
  • internally for other approved purposes such as direct marketing or fund raising; or
  • to another agency in a formal, service delivery arrangement, such as a contractor or professional adviser (e.g. auditor, mailing house, delivery service); or
  • to another agency for insurance or legal purposes; or
  • government agencies for regulatory compliance reporting under service provision contractual funding agreements; or
  • via data swap or data pool arrangements with carefully selected, like-minded organisations, in order to reach more people who will provide financial gifts/support.

9.0 NON-DISCLOSURE
9.1 Overseas
Guide Dogs WA will not disclose personal information beyond Australia or an Australian external Territory, except:
a) when it is authorised or necessary in accordance with legal, external treaty or enforcement requirements – as permitted under APP 8: or
b) for the personal information it shares with commercial list providers – as per 6.4 h), which may be shared with trusted third parties and our service providers (and their directors, servants and agents), either in Australia or overseas.

9.2 Government Identifiers
Guide Dogs WA will not use, adopt or disclose an individual’s government related identifier, unless prescribed by regulation to do so and/or when referring an individual to another agency, that requires a particular identifier such as Medicare or Department of Veterans’ Affairs File Numbers.

10.0 SECURITY
Guide Dogs WA takes all reasonable steps to protect the personal information it holds from misuse, interference and loss, unauthorised access, modification and disclosure.

This is undertaken by secure:

  • physical storage, accessed via physical locks; and
  • electronic storage, accessible via passwords, within a system protected by firewalls, intrusion detection systems and virus scanning tools, using dedicated secure networks or encryptions for data transmission.

Information access is controlled to eligible personnel on a need to know basis, who are bound by the organisation’s privacy and confidentiality policies.

11.0 CORRECTION
If Guide Dogs WA becomes or is made aware that any personal information it holds is inaccurate, outdated, incomplete or misleading, it will take all reasonable steps to correct the information.

Corrections or updates must be given to a Guide Dogs WA staff member either by the individual concerned or by his/her authorised representative. Information will not be changed unless Guide Dogs WA staff are reasonably assured that the individual concerned consents to any change.

If Guide Dogs WA is unable to respond to an individual’s request for a change to his/her personal information, the reason will be formally provided to the individual.

Charges will not apply for any information corrections.

12.0 RETENTION
Personal information held by Guide Dogs WA that is no longer needed for any purpose or required to be retained under law or court/tribunal order will be either destroyed or de-identified.

13.0 ACCESS
Individuals have a right to request access to their personal information held by Guide Dogs WA. Requests to access personal information must be made in writing, either by email or in hard copy to the Administrative Officer, Corporate.

In accordance with the Privacy Act provisions, where reasonable and practical to do so, Guide Dogs WA will action a request within 20 working days, providing supervised access and/or document copies.

If significant resources are required to respond to an access request, a reasonable administration fee may be charged.

If Guide Dogs WA refuses an access request, in accordance with APP 12, it will write to the requestor conveying the reasons and providing information about the mechanism by which a complaint may be lodged.

14.0 COMPLAINTS AND ENQUIRIES
Guide Dogs WA’s Complaints Policy,  provides a means for complaints to be lodged and to have these addressed and appropriately resolved if at all possible. Complaints are seen to play an important role in contributing to Guide Dogs WA’s improved operations.

Complaints about this Privacy Safeguards Policy, also available via our website, or any matter related to personal information held by Guide Dogs WA may be lodged via: the telephone, either on the main switchboard number (9311 8202) or the feedback/comment telephone line (9311 8219); in person; in print; in Braille or electronic formats.

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[1] Analytical information is automatically collected. However, this is non-personal, general information about website visits and includes details such as the date, duration and landing page. Guide Dogs WA’s website uses “cookies”, which is a widespread practice. “Cookies” are used to store information on computers accessing the Guide Dogs WA and Guide Dogs WA websites. For example, cookies can be used to recognise a computer that is re-visiting a site and customise the site based on previous preferences and site behaviour. Cookies may also be used to manage security and to store information about the type of browser being used. Users can erase cookies from their computer, block all cookies, or receive a warning before a cookie is stored. Our website may contain links to third party websites, we are not responsible for the privacy policies of any third party website.

1/6/2017
Debra Barnes Effective Date
Chief Operating Officer

First Adopted 2002; Reviewed 2003, 2005, 2014, 2014

This policy has been formed from the amalgamation of:

  • Privacy Policy (Guide Dogs Tasmania)
  • Privacy Safeguards Policy (Guide Dogs WA)
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