Privacy Policy
1. DEFINITIONS
1.1
1.2
1.3
1.4 1.5
Board means The Board of Directors of WSCLC as constituted from time to time.
A director means a person who has been appointed as a Director of the Board.
Worker means any person engaged by WSCLC including employees, volunteers and contractors.
WSCLC means Western Sydney Community Legal Centre Limited.
The terms ‘personal information’ and ‘sensitive information’ assume the meanings given to them in the Privacy Act 1988 (Cth).
2. PURPOSE
2.1
3. SCOPE
3.1
This policy applies to all WSCLC Workers and Directors.
4. PRINCIPLES
4.1
Collection and Holding of Information
4.1.1
4.1.2
WSCLC collects and holds personal and sensitive information of clients that is necessary to help provide front line service delivery within its programs.
The type of personal and/or sensitive information WSCLC collects and holds generally includes:
4.1.2.1
4.1.2.2
4.1.2.3
4.1.2.4
4.1.2.5
4.1.2.6
Full name;
Date of birth;
Address;
Contact details (incl. telephone number)
A person’s purpose for contacting our service; and
The names of other person/s involved with the clients’ purpose for accessing our services.
4.1.3
The type of further information we may collect includes:
4.1.3.1
4.1.3.2
4.1.3.3
4.1.3.4
4.1.3.5
4.1.3.6
4.1.3.7
4.1.3.8
4.1.3.9
4.1.3.10
4.1.3.11
4.1.3.12
4.1.3.13
4.1.3.14
4.1.3.15
4.1.3.16
4.1.3.17
Country of birth and/or language spoken at home;
Income level and source;
Family type;
Gender and/or sexuality;
Criminal history;
Residence in a Regional, Rural or Remote (RRR) area;
Age
Status as a refugee and/or new migrant
Identification as being a victim of a serious crime
Identification as needing assistance with reading, writing and/or numbers
Status as multicultural
Status as Aboriginal or Torres Strait Islander
Experiencing, or risk of, family and domestic violence
Experiencing, or risk of, homelessness;
Experiencing, or risk of, social isolation;
A person with a disability; and
The carer of a person with a disability.
4.1.4
4.1.5
WSCLC may also collect document-based information relating to law and social justice such as contracts, forms, court orders, police records, that may relate to a persons’ purpose for accessing our services.
WSCLC mainly collects personal and/or sensitive information directly from the individual who contacts one of our programs by telephone, letter, email or an online form. From time to time we will be provided personal and/or sensitive information by a third party, such as when we are sent a referral from a court, tribunal or other organisation.
4.2
Use of Information
4.2.1
WSCLC uses the personal and/or sensitive information it collects to:
4.2.1.1
4.2.1.2
4.2.1.3
4.2.1.4
4.2.1.5
Determine a person’s eligibility for assistance from one of our nine programs;
Create a client profile for client management;
Provide services in a competent, targeted, appropriate and accessible manner;
Develop and evaluate our programs to better serve the community; and
For statistical purposes as required by our funding bodies.
4.2.2
If an individual does not provide us with some or all of the personal and/or sensitive information described above, we may not be able to provide any services, or certain services, appropriate to that individual’s personal circumstances.
4.3
Disclosure of Information
4.3.1
4.3.2
4.3.3
Personal and/or sensitive information collected by WSCLC is kept confidential and not disclosed outside WSCLC without consent, except as we are required or authorised under the law to do so.
Information provided to our funding bodies is statistical only and is de- identified before it is provided.
For insurance purposes, we may disclose personal and/or sensitive information to our insurer is a claim has been made against WSCLC.
4.4
Internal Procedures
4.4.1
Each of our programs is required to have necessary procedures in place to comply with this policy and the Privacy Act 1988 (Cth).
4.5
Storage
4.5.1
WSCLC takes reasonable steps to ensure personal and/or sensitive information is protected from misuse, loss, interference and from unauthorised access, modification or disclosure.
4.6
Client Requests
4.6.1
4.6.2
4.6.3
4.6.4
4.6.5
Individuals can request access or a correction to their personal and/or sensitive information held by WSCLC at any time at no cost.
Requests should be in writing and addressed to the Office Manager (in that person’s capacity as Privacy Officer). Individuals who cannot make the request in writing may speak to any WSCLC Worker over the phone, who must pass the request to the Office Manager (in that person’s capacity as Privacy Officer). The Office Manager must then pass on any requested to the CEO or Principal Solicitor as appropriate.
WSCLC will generally provide individuals with access to their personal and/or sensitive information unless there is an exception which applies under the law.
All requests will be treated confidential and responded to in a reasonable timeframe.
All requests will receive a written response from the CEO or Principal Solicitor as appropriate, confirming the outcome in relation to access or correction.
4.7
Questions and Complaints
4.7.1
4.7.2
4.7.3
4.7.4
WSCLC will keep its Privacy Policy accessible on its website.
All questions or complaints should be in writing and addressed to the Office Manager (in that person’s capacity as Privacy Officer). Individuals who cannot make the request in writing may speak to any staff member over the phone, who must pass the request to the Office Manager (in that person’s capacity as Privacy Officer).
Any questions or complaints received by WSCLC will be treated confidentially and responded to within a reasonable time frame.
Individuals can also direct complaints about how their personal and/or sensitive information is collected, use or disclosed to the Office of the Australian Information Commissioner (1300 363 992 or [email protected])
