This Policy outlines how Evolve Housing Limited and its controlled entities, excluding Evolve Housing Vic Limited (collectively referred to as the “Company”) collects, uses, stores and discloses Personal Information in accordance with the Australian Privacy Principles 2014 (the “APPs”) and under the Privacy Act 1988 (Cth) (the “Act”).
This Policy applies to all individuals which the Company will be collecting Personal Information from. Individuals include, but are not limited to, Clients, Directors, Employees and Employment Candidates.
The Company is committed to respecting and protecting the privacy and rights of individuals.
When used in this Policy, the term “Personal Information” has the meaning given to it in the Act. Personal Information is any information held by an entity that can be used on its own or in combination with other information held by the same entity, to personally identify an individual. Personal Information collected and stored by the Company may include an individual’s:
- Email address
- Contact number
- Age or date of birth
- Country of origin
- Religious belief
- Employment history
- Income details
- Proof of identity, including passport, licence, medicare card or other official document
- Professionoccupation or job title
- Work experience
- Educational qualifications
- Centrelink information
- Credit information & other financial records
- Next of kin
- Public trustee details
- Bank statements
- Criminal history
- Tax File Number / Returns
- Tenant ledgers
Personal Information includes Sensitive Information (see section 2.7 of this Policy).
The Company may also collect information that is not Personal Information because it does not identify a particular individual. For example, the Company may collect anonymous answers / feedback to surveys or aggregated information about how users use the Company’s website.
The Company collects Personal Information directly from the individual as well as through third parties.
The Company can collect Personal Information in the following ways:
- Written forms;
- Over the phone or other messaging technology;
- Via the internet, including email or the Company’s website and social media platforms;
- Hardcopy documents provided by individuals;
- Use of an IT device the Company provides;
- Website cookies
- Property inspections
- Via a third party, e.g. government entities, law enforcement agencies, social workers, medical practitioners, previous landlords, personal referees, tenancy databases, recruitment agencies, etc.
The Company collects Personal Information to perform business activities and deliver services to you. The Company will not collect information unless it is for a lawful purpose.
In most situations, individuals will be advised as to why the Company is collecting Personal Information and who else might receive this information. The Company may decide not to provide this advice to individuals if the Company is not legally required to provide the advice.
The purposes for collecting Personal Information from each category of individuals may include:
- to provide suitable housing arrangements through assessing applications and allocating appropriate properties etc.
- to provide tenancy related services including repairs and maintenance to properties
- to provide other related services through assessing applications, case planning and management etc.
- for communication purposes
- to facilitate community engagement
- to assist with the design of residential construction projects
- to engage in direct marketing
- to seek feedback and improve on services
- to comply with reporting requirements to government agencies, regulators etc.
- to provide information to support partners and health providers who participate in information sharing
|Employment Candidates, Volunteers and Students
- to assess suitability for employment or to undertake other roles within or for the Company
|Employees, Contractors and Directors
- for identification
- for human resource purposes including payroll
- for conflict of interest purposes
- for regulatory, governance and related purposes
If an individual does not provide the Company with Personal Information when prompted, the Company may be unable to contact the individual or provide any services to the individual. In the case of employment candidates, the Company will not be able to consider applications for employment.
In the event the Company receives unsolicited Personal Information, the Company will determine whether it could have been lawful for the Personal Information to be collected if it had been solicited. If it isn’t, The Company will, if it is lawful and reasonable to do so, destroy the information or ensure that the information is de-identified as soon as practicable.
The Company may disclose Personal Information for a purpose for which it was collected (as listed in section 2.3) (the “Primary Purpose”) e.g. to arrange maintenance contractors for your residence.
The Company will only disclose Personal Information for another purpose (a “Secondary Purpose”):
- If the disclosure is related to the Primary Purpose for which the information was collected or, in the case of Sensitive Information, directly related to the Primary Purpose and the person would reasonably expect the Company to use or disclose the Personal Information for the Secondary Purpose;
- Where the person to whom the information relates to has provided informed consent to a secondary use or disclosure;
- If a permitted general situation exists, as defined in the APPs, in relation to the use or disclosure of the Personal Information for a secondary use;
- If the Company reasonably believes that the secondary use or disclosure is reasonably necessary for enforcement related activities carried out by, or on behalf of, an enforcement body;
- If lawfully authorised or required to do so under the Act, APPs, by legislation or court or tribunal order
The Company may disclose Personal Information (other than Sensitive Information) to a Related Body Corporate.
The Company and the NSW Police may also exchange information through a Record of Understanding:
- To maintain law and order in and around The Company properties;
- Where there is an emergency that poses an imminent threat to life or property;
- In the investigation of an alleged criminal offence;
- To develop and implement crime prevention and community safety strategies.
The Company will also provide information to police when subpoenaed, unless the information is not in the public interest. In these cases, the Company may lodge an appeal not to provide the information.
Where information is being disclosed to a third party, the Company will take steps to be satisfied that the third party has an obligation to keep Personal Information confidential and to comply with the Act and the APPs. This includes where the third party is an international recipient.
Personal Information is stored by the Company, in both hard copy and electronic form, a manner that reasonably protects it from misuse, interference, loss, and unauthorised access, modification or disclosure. Some of the security measures include:
- Physical, electronic, and procedural safeguards in line with industry standards (such as passwords and physical locks on cabinets);
- Secure server and closed network environments;
- Limited access to Personal Information (e.g. only relevant employees who require an individual’s Personal Information to carry out his / her normal line of duties are allowed access);
- Controlled access to information assets based on business and security requirements;
- Management of access privileges, and regular review of the privileges; and
- Destroying or de-identifying Personal Information pursuant to the law and record retention policies.
Some Personal Information, held electronically, may be accessed overseas for the provision of IT services or stored overseas using electronic storage services. Where this is the case, the Company will take steps to be satisfied that the storage and access of the data complies with the Act and the APPs. This includes where the third party is an international recipient.
Sensitive information’ is a subset of Personal Information. Sensitive Information is defined in the Act as information or an opinion about an individual’s:
- racial or ethnic origin;
- political opinions or membership of a political association;
- religious beliefs or affiliations, or philosophical beliefs;
- membership of a professional or trade association or trade union;
- sexual orientation or practices; or
- criminal record,
that is also Personal Information, or information about an individual’s health, genetics or biometrics.
The Company recognises that Sensitive Information is generally afforded a higher level of privacy protection under the Act and the APPs than other Personal Information. The Company recognises that inappropriate handling of Sensitive Information can have adverse consequences for an individual or those associated with the individual, including discrimination, mistreatment, humiliation, embarrassment or the undermining of an individual’s dignity.
The Company may collect Sensitive Information about an individual, but only where the individual has provided consent and where the information is relevant to the services provided by the Company.
Individuals have the right to request access to the Personal Information the Company holds about them, and request correction of any inaccurate, out-of-date, incomplete, irrelevant or misleading Personal Information.
Individuals who would like to request access to, or correction of, their Personal Information held by the Company, must contact the Company using the details provided in Section 2.10 below. The Company will respond to the request for access within a reasonable period and give access in the manner requested by the individual, if it is reasonable and practicable to do so. Evolve may charge for its reasonable costs in providing the Personal Information and any such costs will be notified to the individual at the time it seeks that information. Costs will not be charged to the individual to consider a request or correct information. Information will not be provided to individuals if they are unable to provide identification documentation to confirm their identity.
The Company may refuse a request to access Personal Information if it falls under a category outlined in Australian Privacy Principle 12 of the APPs. On these occasions the Company will inform the individual in writing of the reason for the refusal and any avenues to make a complaint about that decision.
It is the individual’s responsibility to inform the Company of any corrections or changes to Personal Information. Individuals may lodge a request to correct Personal Information held by the Company, following which the Company will take such steps (if any) as are reasonable in the circumstances to correct the information to ensure that it is accurate, up-to-date, complete, relevant and not misleading.
If the Company believes that the Personal Information should not be corrected or changed the Company will provide the individual with a written notice explaining the reasons for its decision and how to raise a complaint if they’re unhappy with the Company’s decision.
If the Company refuses a request to correct or change Personal Information, the individual may ask the Company to attach a statement to the information stating that the information is inaccurate, outof-date, incomplete, irrelevant, or misleading.
If an individual is concerned that the Company has not complied with applicable privacy laws or this Policy, the individual may raise a complaint through the Company’s complaints process. The process is as follows:
Step 1:Let the Company know
The individual should contact our Privacy Officer using the details provided in Section 2.10 below. We will acknowledge the complaint within 2 business days.
Step 2: Investigation of Complaint
The complaint will be investigated by our Privacy Officer. A response to the complaint will be provided in accordance with the Company’s Complaints Policy
Step 3: It is expected that Evolve’s procedures will deal fairly and promptly with a complaint. However, if the individual remains dissatisfied, they can also contact the Office of the Australian Information Commissioner as follows:
Office of the Australian Information Commissioner (OAIC)
GPO Box 5288 Sydney NSW 2001
Facsimile: +61 2 6123 5145 www.oaic.gov.au
Note: The OAIC requires:
- an individual to first complain to the Company, with the complaint to be escalated to the OAIC only where a response is not received within 30 days or the individual is unhappy with the Company’s response; and
- complaints to be made in writing.
Individuals may contact the Company with regards to the following matters:
||Contact Details and Options
|• To access, update or correct Personal Information
• To opt out of receiving newsletters or Evolve Housing related direct marketing material
|Telephone: 1800 MY EVOLVE (1800 693 865)
Address: Henry Dodd House,9-13 Argyle Street Parramatta NSW 2150
|• To seek more information about anything contained in this policy
• To make a privacy related complaint or feedback
|Telephone: 1800 MY EVOLVE (1800 693 865)
Address: Privacy Officer, Henry Dodd House, 9-13 Argyle Street Parramatta NSW 2150
- Australian Privacy Principles 2014
- Privacy Act 1988 (Cth)
- Privacy Amendment (Enhancing Privacy Protection) Act 2012
- Office of the Australian Information Commissioner – www.oaic.gov.au
This Policy is subject to change from time to time at the discretion of the Company. Any approvals required under this Policy will be granted in accordance with the Company Delegations of Authority Policy. Further information on this Policy and other topics, is available on the Evolve Housing website www.evolvehousing.com.au. If you have any specific questions regarding this Policy, please contact Evolve Housing on 1800 693 865 or email your enquiry to email@example.com.