It is the policy of Amélie Housing to comply with the Australian Privacy Principles (APP-2014) in the way we treat the collection, storage and management of personal information. This includes:
- what information Amélie Housing can collect
- how Amélie Housing collects information (verbally, in writing, electronically)
- how Amélie Housing stores and protects personal and health information in shared access systems such as the NSW Housing Register and
- the purposes for which your personal information is collected, held, used and disclosed
- how Amélie Housing can use and disclose your information include special protection for health and other sensitive information
- how you can find out what information we hold and correct it if it is wrong
- how you can complain or enquire about breaches of your privacy
- whether Amélie Housing is likely to disclose your personal information to any overseas recipients or another party
This policy applies to all staff, tenants, applicants, partner organisations and stakeholders involved with Amélie Housing.
Who do we Collect Personal Information From?
At Amélie Housing we collect personal information from applicants, tenants, and members of tenants’ households, job applicants, staff, volunteers and others including contractors, visitors and others that engage with our organisation.
It is noted that employee records are not covered by the Australian Privacy Principles or the Health Privacy Principles where they relate to current or former employment relations between our organisation and the employee.
What Kinds of Personal Information Do We Collect?
The kinds of personal information we collect is largely dependent upon whose information we are collecting and why we are collecting it, however in general terms we may collect:
- Personal Information including names, addresses and other contact details; dates of birth; next of kin details; financial information, photographic images and attendance records.
- Sensitive Information (particularly in relation to providing appropriate housing services and our work health and safety obligations) including where relevant religious beliefs, government identifiers, nationality, country of birth, languages spoken at home, family court orders and criminal records.
- Health Information (particularly in relation to providing appropriate housing services and complying with our work health and safety obligations) including medical records, disabilities, individual health care plans, and counselling reports,
How do we collect your personal information?
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible we have attempted to standardise the collection of personal information by using specifically designed forms (e.g. Application Form or a Health Information Disclosure Form). However, given the nature of our operations, we often also receive personal information by email, letters, notes, over the telephone, in face to face meetings, through financial transactions and through surveillance activities such as the use of CCTV security cameras or email monitoring
We may also collect personal information from other people (e.g. referring agencies, service providers including health service providers and partner agencies) or independent sources (e.g. a telephone directory), however we will only do so where it is not reasonable and practical to collect the information from you directly.
How we use personal information
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our primary uses of personal information include but are not limited to:
- providing housing, accommodation and related services;
- satisfying our legal obligations including our duty of care to tenants, workers, and child protection obligations;
- keeping tenants informed as to community housing matters through correspondence, newsletters and magazines;
- marketing, promotional and fundraising activities;
- helping us to improve our day to day operations including training our staff; systems development; developing new programs and services; undertaking planning, research and statistical analysis using de-identified information wherever practicable;
- administration including for insurance purposes;
- the employment of staff;
- the engagement of volunteers.
We only collect sensitive information reasonably necessary for one or more of these functions or activities. We also collect sensitive information if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety, or another permitted general situation (such as locating a missing person) or permitted health situation (such as the collection of health information to provide a health service) exists.
Storage and Security of Personal Information
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices including laptop computers, mobile phones, cameras and other recording devices.
The security of your personal information is of importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
These steps include:
- Restricting access to information on our databases on a need to know basis with different levels of security being allocated to staff based on their roles and responsibilities and security profile.
- Ensuring all staff are aware that they are not to reveal or share personal passwords.
- Ensuring where sensitive and health information is stored in hard copy files that these files are stored in lockable filing cabinets in lockable rooms. Access to these records is restricted to staff on a need to know basis.
- Implementing physical security measures around the buildings and grounds to prevent break-ins.
- Implementing computer security systems, policies and procedures, designed to protect personal information storage on our computer networks.
- Implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
- Undertaking due diligence with respect to third party service providers who may have access to personal information, including cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
- Requiring third party service providers to sign confidentiality and privacy undertakings where practicable.
Personal information we hold that is no longer needed is destroyed in a secure manner, deleted or de-identified as appropriate.
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
When we disclose personal information
We only use personal information for the purposes for which it was given to us, or for purposes which are related (or directly related in the case of sensitive information) to one or more of our functions or activities. We may disclose your personal information to government agencies, our service providers, agents, contractors, partner support agencies, business partners and other recipients from time to time, only if one or more of the following apply:
- you have consented;
- you would reasonably expect us to use or disclose your personal information in this way;
- we are authorised or required to do so by law;
- disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;
- where another permitted general situation or permitted health situation exception applies;
- disclosure is reasonably necessary for a law enforcement related activity.
Disclosure of personal information to overseas recipients
We may disclose personal information about an individual to overseas recipients in certain circumstances, such as storing information with a “cloud service provider” which stores data outside Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:
- We have the individual’s consent (which may be implied); or
- We have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime; or
- We form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or
- We are taking appropriate action in relation to suspected unlawful activity or serious misconduct
How we ensure the quality of your personal information
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up to date.
We maintain and update personal information when we are advised by individuals or when we become aware through other means that their personal information has changed.
Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up to date.
How to gain access to your personal information we hold
You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us.
If we do not agree to provide you with access, or to amend your personal information as requested, you will be notified in writing. Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
If you wish to make a complaint about a breach by us of your privacy (that includes the Australian National Privacy Principles) you may do so by providing your written complaint by email, letter, fax or by personal delivery to any one of our contact details as noted below. You may also make a complaint by phoning or face to face.
We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we may seek further information from you to provide a full and complete response.
Your complaint may also be taken to the Office of the Australian Information Commissioner or the NSW Privacy Commissioner.
How to Contact Us
You can contact us about this Policy or about your personal information by:
- Emailing [email protected]
- Calling 02 95680219
- Writing to our Privacy Officer at 2c West Street Lewisham NSW 2049
If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.
Changes to our privacy and information handling practices