Privacy Policy | Healthy Cities

PRIVACY AT HEALTHY CITIES ILLAWARRA

1.1.PURPOSE

Healthy Cities Illawarra (HCI or the ‘Association’) is committed to protecting the privacy of information which the Association collects, holds and administers and will do so by:

Creating procedures that protect privacy with regard to the collection, storage and disclosure of personal information; and,
Complying with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (the Privacy Act).

Healthy Cities Illawarra recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – protected on one hand and made accessible to them on the other. These privacy values are reflected in and supported by the core values and philosophies of Healthy Cities Illawarra.

1.2.SCOPE AND DEFINITIONS

This policy applies to all employees, contractors and volunteers of Healthy Cities Illawarra. Personal Information Information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Sensitive Information Information or an opinion about an individual’s;

• racial or ethnic origin;

• political opinion, or membership of a political association;

religious beliefs or affiliations;

• philosophical beliefs;

• membership of a professional or trade association;

• membership of a trade union;

• sexual preferences or practices;

– criminal record; or

– health, genetic, biometric information or biometric templates

Worker A person who carries out work in any capacity for Healthy Cities Illawarra including permanent, temporary and casual employees, contractors and sub-contractors and their employees, labour hire company employees, trainees, persons gaining work experience and volunteers.

Privacy Policy Version 1.0 32. GUIDING PRINCIPLES

Healthy Cities Illawarra has adopted the following principles contained as minimum standards in relation to handling personal information. As such, Healthy Cities Illawarra will:

• Collect only information which Healthy Cities Illawarra requires for its primary function;

• Ensure that stakeholders are informed as to why information is collected and how the information gathered is administered;

• Use and disclose personal information only for primary functions or a directly related purpose, or for another purpose with the person’s consent;

• Store personal information securely, protecting it from unauthorised access;

• Provide stakeholders with access to their own information, and the right to seek its correction.

2.1COLLECTION, USE & DISCLOSURE

Healthy Cities Illawarra will:

• Only collect information that is necessary for the performance and primary function of the Association ;

• Notify stakeholders about why we collect the information and how it is administered;

• Notify stakeholders that this information is accessible to them;

• Only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose;

• For other uses, Healthy Cities Illawarra will obtain consent from the individual.

2.2DATA QUALITY, SECURITY & RETENTION

Healthy Cities Illawarra will:

• Take reasonable steps to ensure the information the Association collects is accurate, complete, up to date, and relevant to the functions we perform;

• Safeguard the information we collect and store against misuse, loss, unauthorised access and modification;

• Only destroy records in accordance with the Association’s Records & Information Management Policy.

2.3TRANSPARENCY, ACCESS & CORRECTION

Healthy Cities Illawarra will:

• Ensure stakeholders are aware of the HCI Privacy Policy and its purposes;

• Make this information freely available in relevant publications and on the organisation’s website;

• Ensure individuals have a right to seek access to information held about them and to correct it if it is inaccurate, incomplete, misleading or not up to date.

Healthy Cities Illawarra will:

• Give stakeholders the option of not identifying themselves when completing evaluation forms or opinion surveys.

• Only release information about a person with that person’s express permission. For personal information to be released, the person concerned must provide their permission in writing.

• Release information to third parties where it is requested by the person concerned.

The release of requested information that is not available on the Healthy Cities Illawarra website or in other publications will be decided within the guidelines of the relevant legislation, taking into consideration factors relating to public interest, exemptions and privacy.

3. ORGANISATIONAL AND WORKER INFORMATION

This Policy will be included as part of the induction/onboarding information provided to new starters to Healthy Cities Illawarra, inclusive of employees, contractors, volunteers and board members. In addition, workers will receive relevant training on a periodic basis as required and/or relevant to their role.

All workers will be required to sign a confidentiality agreement in relation to information gained due to their involvement throughout their engagement.

Workers will not give any worker details, including address and phone numbers to any participant, volunteer, member of the community or organisation unless with prior consent. Further, workers will not discuss with people outside the Association information concerning the financial and confidential arrangements of the Association unless it has been formerly authorised to do so.

4. MEASURING SUCCESS

In determining success of this policy it is anticipated that zero instances of a breach of confidentiality relating to Personal Information or Sensitive Information will be identified and 100% of all worker files, inclusive of employees, contractors, volunteers and board members will hold a signed confidentiality agreement and a completed privacy checklist (where applicable). As such, ongoing monitoring of worker files and breach registers will occur and will be managed by the CEO with assistance from the Business Manager as required, and reported to the Board to determine ongoing requirements and needs of the business.

5. Breaches of Policy

A breach of this policy will result in disciplinary action in line with the HCI Code of Conduct and related policies. Depending upon the severity of the case, consequences may include training, transfer, demotion, dismissal, or other forms of disciplinary action deemed appropriate.

Privacy Policy Version 1.0 5Where a breach does occur, the Board shall be notified of any as soon as possible and following appropriate investigation may decide to handle such in any of the following ways:

Where a breach involves: It will be dealt with:

A Board member In accordance with the Discipline of members under the Constitution (leading to the member’s possible expulsion from the Association).

An employee In accordance with the HCI Corrective Action & Disciplinary Process.

An employee and is deemed serious misconduct In accordance with HCI Code of Conduct and Corrective Action & Disciplinary Process and likely instant dismissal. a student or volunteer By the CEO and may decide to terminate their involvement with Healthy Cities Illawarra.

6. COMPLAINTS AND FURTHER INFORMATION

All complaints should be referred to the CEO for management in line with the HCI Complaints Handling Policy.