Privacy

Overview

The Cora Barclay Centre respects the privacy of all Cora Barclay Centre people including members, employees, volunteers, our clients/beneficiaries, donors, business partners and online users, and is committed to safeguarding the personal information that is provided to us.

Purpose

The purpose of this privacy policy is to:

- Clearly communicate the personal information handling practises of the Cora Barclay Centre
- Enhance the transparency of Cora Barclay Centre operations, and
- Give individuals a better and more complete understanding of the sort of personal information that the Cora Barclay Centre holds, and the way we handle that information.

Scope

This policy and procedure applies to all Cora Barclay Centre members, volunteers, employees, clients/beneficiaries, donors, business partners and online users.

The Privacy Act and this privacy policy do not apply to acts or practices which directly relate to employee records of Cora Barclay Centre current and former employees.

Definitions  

- Online users refers to anyone that access the Cora Barclay Centre website: www.corabarclay.com.au
- Personal information as defined by the Privacy Act 1988 (as amended) is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
- Sensitive information as defined by the Privacy Act 1988 (as amended) is information or an opinion (that is also personal information) about an individual’s racial or ethnic origin, political opinions, 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 or criminal record or health, genetic, biometric information or biometric templates, that is also personal information.
- The website means the Cora Barclay Centre website: www.corabarclay.com.au

Overview of Cora Barclay Centre Programs and Services

The mission of the Cora Barclay Centre is to help children who are deaf or hearing impaired to learn to speak and reach their full potential through intensive early childhood intervention, school years and early adulthood support, psycho-social development and ongoing assessments. These outcomes are achieved through family-centred practice and professional expertise in listening and spoken language therapy.

In carrying out this mission the Cora Barclay Centre engages volunteers and employees and receives donations, funding and support from members of the community, corporations, groups and governments.

In addition to the services which we provide from funds donated by the public, the Cora Barclay Centre holds contracts to deliver State and Commonwealth government programs. In providing such services, we comply with the relevant state or national privacy principles and any additional obligations under the contract.

Outline of this policy

‘Part A – Personal Information Handling Practices’ explains our general information handling practices across the Cora Barclay Centre including information about how we collect, use, disclose and store your personal information.

‘Part B – Files’ offers further detail by explaining our personal information handling practices in relation to specific Cora Barclay Centre functions or activities such as the provision of rehabilitation services, audiology service, fundraising or marketing. Here you can find out what sort of records we keep and why. You may find this section helpful if, for example, you have made an enquiry to the Cora Barclay Centre and wish to know how we manage our enquiries files.

Children and Privacy

The Privacy Act does not specify an age after which individuals can make their own privacy decisions. The Cora Barclay Centre will make decisions on a case-by-case basis whether an individual under the age of 18 has the capacity to consent based on their understanding and maturity to understand what is being proposed.  In general, the Cora Barclay Centre will presume (subject to verification) that and individual aged 15 or over has capacity to consent.

Part A – Our Personal Information Handling practices  

Our obligations under the Privacy Act

This privacy policy sets out how we comply with our obligations under the Privacy Act 1988 Privacy Act 1988 (Privacy Act). We are bound by the Australian Privacy Principles (APPs) in the Privacy Act which regulate how organisations may collect, use disclose and store personal information, and how individuals may access and correct personal information held about them.

Collection of Personal and Sensitive Information

If you would like to access any Cora Barclay Centre Services on an anonymous basis or using a pseudonym, please tell us. If this is possible and lawful, we will take all reasonable steps to comply with your request. However, we may not be able to provide to provide the services in question if we are not provided with the personal information requested.

The nature and extent of personal and sensitive information collected by the Cora Barclay Centre varies depending on your particular interaction with the Cora Barclay Centre.

The Cora Barclay Centre collects personal and sensitive information from clients/beneficiaries, donors, business partners, Cora Barclay Centre people and online users. Further information about the kind of information collected from each of these groups and the usage of such information is detailed below.

Cora Barclay Centre Clients and Beneficiaries

Kind of information:

- Contact details (name, address, email etc.)
- Personal details including: date of birth, gender, next of kin
- Information on personal issues and experiences, relationships
- Family and cultural background
- Schooling details
- Health information and/or medical history.

How the information is collected:

- Membership application enrolment forms
Online registration
Assessment results.

Purpose for which Cora Barclay Centre uses the information:

- To provide Cora Barclay Centre services
To provide clients with the most appropriate services for their needs
To meet any requirements of government funding for programs
To monitor and evaluate existing services and plan for future services
To produce annual reports and for research purposes which may involve contracted organisations
- To comply with legal obligations.

Cora Barclay Centre Donors

Kind of information collected:

- Contact details (name, address, telephone numbers, email etc.)
Areas of interest
Donation history.

How the information is collected:

- Communications, email, flyers
Telephone.

Purpose for which the Cora Barclay Centre uses information:

- To process donations and provide accurate receipts
To facilitate on – going fundraising and marketing activities
To comply with legal obligations
To provide transparency relating to donated funds, particularly for Appeals for public donations.

Cora Barclay Centre Business Partners

Type of information collected:

- Contact person’s name, the name of the organisation which employs the person
Telephone numbers, fax number, street and postal address, email address and position title
Areas of interest by category and industry
Bank details ( if Cora Barclay Centre is to receive payment or make payment for services received)
Australian Business Number (ABN)
Type of support (eg. Workplace giving, goods in kind, program support, volunteering).

How the information is collected:

- Direct from Business Partners.

Purpose for which Cora Barclay Centre uses the information:

- To provide Cora Barclay Centre services
To pay for services
To establish and manage partnerships
- T
o receive services from you or the organisation which employs you
To manage the Cora Barclay Centre’s relationship with the business partner
To provide information about Cora Barclay Centre’s services
To update the company on Cora Barclay Centre appeals for public donations, programs and services.

The Cora Barclay Centre People (volunteers, employees, delegates) and candidates for volunteer work and prospective employees

Type of information collected:

- Contact details (name, address, telephone numbers, email etc.)
Personal details including personal details of emergency contact person(s)
Date of birth
Country of birth, citizenship, residency and/or visa details
Details of volunteer involvement

A police check may be required for some roles in the Cora Barclay Centre (particularly those involving children, young people and other vulnerable individuals). Individuals will be required to provide certain information for a police check. There are different arrangements for police checks in each state and territory of Australia. In some cases the police check will be received directly by the Cora Barclay Centre and then stored securely or destroyed.

Purpose for which the Cora Barclay Centre uses the information:

- To provide Cora Barclay Centre services
To process an application to become a member, volunteer or employee of our organisation
To facilitate a placement in an appropriate service or position
To assist with services whilst an individual is employed or engaged as a volunteer with the Cora Barclay Centre
To provide feedback on performance as a volunteer or employee
To meet legislative responsibilities to all volunteers and employees
To obtain feedback from individuals about their experiences
To assist the Cora Barclay Centre to review and improve its programs and services to keep individuals informed about Cora Barclay Centre developments and opportunities
To provide information about Cora Barclay centre services
To facilitate further involvements with the Cora Barclay Centre (eg. Disability supports, membership, donor).

Cora Barclay Centre Members

Type of information collected:

- Contact details (name, telephone numbers, email etc.)
Areas of interest

Purpose for which the Cora Barclay Centre uses the information:

- To provide Cora Barclay Centre services
To provide communication updates and ensure transparency
Relating to donated funds, particularly Appeals for public donations, and Cora Barclay Centre operations
To process donations and provide accurate receipts
To facilitate ongoing fundraising and marketing activities
To provide info about the Cora Barclay Centre
To receive invitations to upcoming events and activities
To recognise your support of the Cora Barclay Centre.

Online Users

To the extent that this privacy policy applies to online privacy issues, it is to be read as forming part of the terms and conditions of use for the Cora Barclay centre website.

Type of information collected:

- Contact details (name, address, telephone numbers, email etc.)
Non-personal information eg. Visitor navigation and statistics
Server address, browser type, date and time of visit.

Purpose for which Cora Barclay Centre uses the information:

- To process donations, purchase orders, online bookings, purchases/transactions (eg. Booking First Aid Health & Safety Courses)
To analyse website usage and make improvements to the website
The Cora Barclay Centre does not match the personal information collected with the non-personal information.

Additional information

The website may from time to time contain links to other websites. The Cora Barclay Centre stresses that when an online user accesses a website that is not the Cora Barclay centre website, it may have a different privacy policy. To verify how that website collects and uses information, the user should check that particular website’s policy.

How We Collect Information

Where possible, we collect your personal and sensitive information directly from you. We collect information through various means, including telephone and in-person interviews, appointments, forms and questionnaires. If you feel that the information that we are requesting, either on our forms or in our discussions with you, is not information that you wish to provide, please feel free to raise this with us.

In some situations we may also obtain personal information about you from a third party source. If we collect information about you in this way, we will take reasonable steps to contact you and ensure that you are aware of the purposes for which we are collecting your personal information and the organisations to which we may disclose your information, subject to any exceptions under the Act. For example, we may collect information about you from a health care professional, such as your doctor.

Health Information

As part of administering Cora Barclay Centre services, the Centre will collect health information. For example, the Cora Barclay Centre collects health information (such as audiology history) from some clients participating in Centre programs. When collecting health information from you, the Cora Barclay Centre will obtain your consent to such collection and explain how the information will be used and disclosed.

If health information is collected from a third party (such as your doctor), the Cora Barclay Centre will inform you that this information has been collected and will explain how this information will be used and disclosed.

The Cora Barclay Centre will not use health information beyond the consent provided by you, unless your further consent is obtained or in accordance with one of the exceptions under the privacy Act or if further consent is obtained or in accordance with one of the exceptions under the Privacy Act or in compliance with another law. The Cora Barclay Centre uses your health information for research or statistical purposes, it will be de-identified if practicable to do so.

Use and disclosure of Personal Information

We only use personal information for the purposes for which it was given to us, or for purposes which are related to one of our functions or activities.

For the purposes referred to in this Privacy Policy (discussed above under ‘Collection of Personal and Sensitive Information’), we may also disclose your personal information to other external organisations including:

- Government departments/agencies who provide funding for Cora Barclay Centre services
Contractors who manage some of the services we offer you. Steps are taken to ensure they comply with the APP’s when they handle personal information and are authorised only to use personal information in order to provide the services or to perform the functions required by the Cora Barclay Centre.
Doctors and health care professionals, who assist us to deliver our services
- Other regulatory bodies, such as NDIS
Our professional advisors, including our accountants, auditors and lawyers.

Except as set out above, the Cora Barclay Centre will not disclose an individual’s personal information to a third party unless one of the following applies:

- The individual has consented
The individual would reasonably expect us to use or give that information for another purpose related to the purpose for which it was collected (or in the case of sensitive information – directly related to the purpose for which it was collected)
It is otherwise required or authorised by law
It will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety
It is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities
It is reasonably necessary to assist in locating a missing person
It is reasonably necessary to establish, exercise or defend a claim at law
It is reasonably necessary for a confidential dispute resolution process
It is necessary to provide a health service
It is necessary for the management, funding or monitoring of a health service relevant to public health or public safety
It is necessary for research or the compilation or analysis of statistics relevant to public health or public safety.
It is reasonably necessary for the enforcement of a law conducted by an enforcement body.

We do not usually send personal information out of Australia. If we are otherwise required to send information overseas we will take measures to protect your personal information. We will protect your personal information either by ensuring that the country of destination has similar protections in relation to privacy or that we enter into contractual arrangements with the recipient of your personal information that safeguards your privacy.

Security of Personal and Sensitive Information

The Cora Barclay Centre takes reasonable steps to protect the personal and sensitive information we hold against misuse, interference, loss, unauthorised access, modification and disclosure.

These steps include password protection for accessing our electronic IT system, securing paper files in locked cabinets, clean desk policies, safe handling practices outside the Centre and physical access restrictions within the Cetnre. Only authorised personnel are permitted to access these details.

When the personal information is no longer required, it is destroyed in a secure manner, or deleted.

Access to and correction of personal information

If an individual request access to the personal information we hold out to them, or requests that we change that personal information, we will allow access or make the changes unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make the changes.

Requests for access and/or correction should be made to the privacy Officer (details of which are set out below). For security reasons, you will be required to put your request in writing and provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

In the first instance, the Cora Barclay Centre will generally provide a summary of the information held about the individual. It will be assumed (unless told otherwise) that the request relates to current records. These current records will include personal information which is included in Cora Barclay Centre databases and in paper files, and which may be used on a day to day basis.

We will provide access by allowing you to inspect, take notes or print outs of personal information that we hold about you. If personal information (for example, your name and address details) is duplicated across different databases, the Cora Barclay Centre will generally provide one printout of this information, rather than multiple printouts.

We will take all reasonable steps to provide access or the information requested within 14 days of your request. In situations where the request is complicated or requires access to a large volume of information, we will take all reasonable steps to provide access to the information requested within 30 days.

The Cora Barclay Centre may charge you reasonable fees to reimburse us for the cost we incur relating to your request for access information, including in relation to photocopying and delivery cost information stored off site. For current fess, please contact the Privacy Officer.

If an individual is able to establish that personal information the Cora Barclay Centre holds about her/him is not accurate, complete or up to date, the Centre will take reasonable steps to correct our records.

Access will be denied if:

- The request does not relate to the personal information of the person making the request;
Providing access would pose a serious threat to the life, health or safety of a person or to public health or public safety
Providing access  would create an unreasonable impact on the privacy of others;
The request is frivolous and vexatious;
The request relates to existing or anticipated legal proceedings;
Providing access would prejudice negotiations with the individual making the request;
Access would be unlawful;
Denial of access is authorised or required by law;

Access would prejudice law enforcement activities;

- Access would prejudice an action in relation to suspected unlawful activity, or misconduct of a serious nature relating to the functions or activities of the Cora Barclay Centre
Access discloses a ‘commercially sensitive’ decision making process or information; or
Any other reason that is provided for in the APP’s or in the Privacy Act.

If we deny access to information we will set our reasons for denying access. Where there is dispute about your right of access to information or forms of access, this will be dealt with in accordance with the complaints procedure set out below.

Complaints Procedure

If you have provided us with personal and sensitive information, or we have collected and hold your personal and sensitive information, you have a right to make a complaint and have it investigated and dealt with under this complaints procedure.

If you have a complaint about Cora Barclay Centre privacy practices or our handling of your personal and sensitive information please contact our privacy officer (details of which are set out below).

All complaints will be logged on our database.

A privacy complaint relates to any concern that you may have regarding Cora Barclay Centre privacy practices or our handling of your personal and sensitive information. This could include matters such as how your information is collected or stored, how your information is used or disclosed or how access is provided to your personal and sensitive information.

The goal of this policy is to achieve an effective resolution of your complaint within a reasonable timeframe, usually 30 days or as soon as practicable.

However, in some cases, particularly if the matter is complex, the resolution may take longer.

Once the complaint has been made, we will try to resolve the matter in a number of ways such as:

- Request for further information: We may request further information from you. You should be prepared to provide us with as much information as possible, including details of any relevant dates and documentation. This will enable us to investigate the complaint and determine an appropriate solution. All details provided will be kept confidential.
Discuss options: we will discuss options for resolution with and if you have suggestions about how the matter might be resolved you should raise these with our Privacy Officer.
Investigation: Where necessary, the complaint will be investigated. We will try to do so within a reasonable time frame. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress to your complaint.
Conduct of our employees: If your complaint involves the conduct we will raise the matter with the employee concerned and seek their comment and input in the resolution of the complaint.
The complaint is substantiated: If your complaint is found to be substantiated, you will be informed of this finding. We will then take appropriate agreed steps to resolve the complaint, address your concerns and prevent the problem from recurring.
If the complaint is not substantiated, or cannot be resolved to your satisfaction, but this Privacy Policy has been followed, the Cora Barclay Centre may decide to refer the issue to an appropriate intermediary. For example, this may mean an appropriately qualified lawyer or an agreed third party, to act as a mediator.
At the conclusion of the complaint, if you are still not satisfied with the outcome you are free to take your complaint to the Office of the Australian information Commissioner at www.oaic.gov.au
We will keep a record of your complaint and the outcome.
We are unable to deal with anonymous complaints. This is because we are unable to investigate and follow-up such complaints. However, in the event that an anonymous complaint is received we will note the issues raised and, where appropriate, try and investigate and resolve them appropriately.

Changes to this Privacy policy

The Cora Barclay Centre reserves the right to review, amend and/or update this policy from time to time.

We aim to comply with the APPs and other privacy requirements required to be observed under State or Commonwealth Government contracts.

If further privacy legislation and/or self-regulatory codes are introduced or our Privacy Policy is updated, we will summarise any substantial modifications or enhancements in this section of our Privacy Policy.

How to contact us

Individuals can obtain further information in relation to this privacy policy, or provide any comments, by contacting us:

Telephone

08 8267 9200

Post

Elizabeth Forwood House
185 Melbourne Street
North Adelaide SA 5000

Email

reception@corabarclay.com.au

Note: these calls can be made for a local call cost from fixed residential landlines anywhere in Australia, but calls from mobile and pay phones may incur higher charges. Check with the service provider for costings from mobile and pay phones. Please refer all privacy matters to the General Manager.

Part B – Files: how we handle specific types of files that contain personal information Public Awareness and Education Files

Purpose

The purpose of public awareness and education files is to record details of public awareness and educational activities, such as contact with media, speeches, event management, surveys and publication preparation.

The limited personal information in public awareness and education files relates to organisations, individuals, media representatives, event attendees, service providers and events calendar listings which appear on our website.

Collection

It is our usual practice to collect personal information in public awareness and education files directly from individuals.

Sometimes we may collect personal information from an individual’s representative or from publicly available sources such as websites or telephone directories.

Use and disclosure

We only use the personal information in public awareness and education files for the purposes of undertaking public awareness and education initiatives and managing public relations.

The personal information on public awareness and education files is not disclosed to other organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to those organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data quality

We maintain and update personal information in our public awareness and education files as necessary, or when we are advised by individuals that their personal information has changed.

Data security

Public awareness and education files are stored in either password protected electronic media or in locked cabinets in paper form. When no longer required, personal information in public awareness and education files is destroyed in a secure manner or deleted accordance with our Records Disposal Policy.

The following staff members have access to public awareness and education files on a need to know basis:

- Directors
Policy staff
Corporate Affairs staff.

Access and correction

For information about how to access or correct personal information in public awareness and education files see ‘Access and correction’ in Part A of this document.

Contacts Lists

We maintain contacts list which include contact information about individuals who may have an interest in deaf and hearing impaired services. We use these contacts lists to distribute information about our activities and publications.

Collection

It is our usual practice to collect personal information in contacts lists directly from individuals, for example, where they have asked to be added to a contact list.

Sometimes we collect personal information from a third party or from a publicly available source such as a website or telephone directory. We usually only collect personal information in this way if the individual would reasonably expect us to, or has given their consent. For instance, we might collect this information if we thought that the individual (or the organisation they work for) would like to receive information about services we are carrying out, or that they might be likely to consider information about disability care useful in the work they do. We would only contact this individual in their work capacity.

Use and disclosure

We only use personal information in contacts lists for the purpose of managing stakeholder relations.

We do not give personal information about an individual to other organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to those organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data quality

We maintain and update personal information in our contacts lists when we are advised by individuals that their personal information has changed. We also regularly audit contacts lists to check currency of the contact information. We will remove contact information of individuals who advise us that they no longer wish to be contacted.

Data security

The personal information in the contacts lists is stored in either password protected electronic media or in locked cabinets in paper form. When no longer required, personal information in contacts lists is destroyed in a secure manner or deleted.

Routine access to contacts lists is limited to the database operators who have responsibility for maintaining the contacts lists. Other staff members have access to the personal information in contacts lists on a need to know basis.

Access and correction

For information about how to access or correct personal information in our contacts lists see ‘Access and correction’ in Part A of this document.

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