This policy outlines how Evolve Housing Limited and its controlled entities (referred to as EHL Group or the Company) collects, uses, stores and discloses Personal Information in accordance with the Australian Privacy Principles 2014 (APPs) under the Privacy Act 1988 (Cth) (Act).
2. IN AND OUT OF SCOPE
This Policy applies to all individuals which EHL Group and its controlled entities will be collecting Personal Information from with the exception of Evolve Housing Vic Limited (which has adopted a separate policy akin to this Policy).
Individuals include, but are not limited to, EHL Group Clients, Directors, Employees and Employment Candidates.
3. POLICY STATEMENT
EHL Group is committed to respecting and protecting the privacy and rights of individuals.
3.1 Personal Information
Personal Information includes Sensitive Information (see section 4.7 of this Policy).
EHL Group may also collect information that is not Personal Information because it does not identify a particular individual. For example, Evolve Housing may collect anonymous answers / feedback to surveys or aggregated information about how users use the Evolve Housing website.
3.2 Collecting Personal Information
EHL Group collects Personal Information directly from the individual unless it is unreasonable or impracticable to do so, as well as through third parties. Evolve Housing can collect Personal Information in the following ways:
3.3 Purpose of Collecting Personal Information
EHL Group collects Personal Information to perform business activities and deliver services. EHL Group will not collect information unless it is for a proper and lawful purpose.
In most situations, individuals will be advised as to why Evolve Housing is collecting Personal Information and who else might receive this information. Evolve Housing may decide not to provide this advice to individuals if Evolve Housing is not legally required to provide the advice.
The purposes for collecting Personal Information from each category of individuals may include:
All Evolve Housing Clients
Employment Candidates, Volunteers and Students
Employees, Contractors and Directors
If an individual does not provide Evolve Housing with Personal Information when prompted, Evolve Housing may be unable to contact the individual or provide any services to the individual. In the case of employment candidates, Evolve Housing will not be able to consider applications for employment.
3.4 Unsolicited Personal Information
In the event Evolve Housing receives unsolicited Personal Information, Evolve will determine whether it could have been lawful for the Personal Information to be collected if it had been solicited. If it isn’t, Evolve Housing will destroy the information or ensure that the information is de-identified as soon as practicable and only if it is lawful and reasonable to do so.
3.5 Disclosure of Personal Information
Evolve Housing may disclose Personal Information for a purpose for which it was collected (as listed in 4.3) eg to arrange maintenance contractors for your residence.
Evolve Housing will only disclose Personal Information for another purpose:
3.5.1 Record of Understanding
Evolve Housing and the NSW Police may also exchange information through a Record of Understanding to:
Evolve Housing will also provide information to police when subpoenaed, unless the information is not in the public interest - in these cases, Evolve Housing may lodge an appeal not to provide the information.
3.5.2 Providing information to a third party
Where information is being disclosed to a third party, Evolve Housing ensures that the third party is also bound by the Privacy Act and has an obligation to keep Personal Information confidential and to take reasonable steps to keep the Personal Information secure from misuse, interference, loss, unauthorised access, modification or disclosure.
3.6 Storage of Personal Information
Evolve Housing is committed to protecting Personal Information and takes reasonable steps to ensure Personal Information is protected from misuse, interference, loss, and unauthorised access, modification or disclosure. Some of the security measures include:
3.7 Sensitive Information
‘Sensitive information’ is a subset of Personal Information. In short, it is Information about an individual’s:
It also includes an individual’s health information, genetic information, and biometric information.
Evolve Housing recognises that Sensitive Information is generally afforded a higher level of privacy protection under the APPs than other Personal Information. Evolve 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.
Evolve Housing 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 Evolve Housing.
3.8 Access and Correction of Information
Individuals have the right to request access to the Personal Information Evolve Housing holds about them, and request correction of any inaccurate, out-of-date, incomplete, irrelevant or misleading Personal Information. It is the individual’s responsibility to inform Evolve Housing of any corrections or changes to Personal Information. Individuals who would like to request access to, or correction of, their Personal Information held by Evolve Housing, must contact Evolve Housing using the details provided in Section 3.10 below.
There may be instances where a request to access could be refused if it falls under a category outlined in APP12, however on these occasions Evolve Housing will inform the individual in writing of the reason for the refusal and any avenues to make a complaint about that decision.
If an individual is concerned that Evolve Housing has not complied with applicable privacy laws, the individual may raise a complaint through Evolve Housing’s complaints process. The process is as follows:
Step 1: Let Evolve Housing know
The individual should contact our Privacy Officer using the details provided in Section 4.10 below. We will acknowledge the complaint within 2 working days.
Step 2: Investigation of Complaint
The complaint will be investigated by our Privacy Officer. A response to the complaint will be provided in writing within 20 working days.
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 5218
Sydney NSW 2001
Note: Complaints must be made in writing
3.10 Contacting Evolve Housing about Privacy
Individuals may contact Evolve Housing 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) Email: firstname.lastname@example.org
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) Email: email@example.com
Address: Privacy Officer, Henry Dodd House, 9-13 Argyle Street Parramatta NSW 2150
(a) information or an opinion about an individual’s:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual orientation or practices; or
(ix) criminal record;
(b) that is also personal information; or
(c) health information about an individual; or
(d) genetic information about an individual that is not otherwise health information; or
(e) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(f) biometric templates
This Policy is subject to change from time to time at the discretion of EHL Group. Any approvals required under this Policy will be granted in accordance with the EHL Group 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 firstname.lastname@example.org.
Document No: EHLG009 | Approved: 4 July 2022 | Version:2.0