PRIVACY STATEMENT
1. INTRODUCTION
1.1 In the course of conducting business in Australia, Homes for Young People Limited (HYP) collects personal information. This Privacy Statement has been developed to ensure that such information is handled appropriately.
1.2 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this Privacy Statement. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way that personal information must be treated.
1.3 As HYP operates in Queensland, New South Wales, Victoria, and Western Australia and often handles personal information of individuals, HYP is required to also comply with the following state-based legislation:
(a) Information Privacy Act 2009 (Qld);
(b) Privacy and Personal Information Protection Act 1998 (NSW); Workplace Surveillance Act 2005 (NSW);
(c) Privacy and Data Protection Act 2014 (VIC); and
(d) Freedom of Information Act 1992 (WA).
Who does the Privacy Statement apply to?
1.4 This Privacy Statement applies in respect of personal information we collect from contractors and agents who perform services on our behalf, prospective contractors and agents, as well as funders, investors and property tenants.
1.5 This Privacy Statement does not apply to:
(a) any person whose personal information is obtained under and governed by any other legislation, including but not limited to Child Protection Act 1999 (Qld); Children and Young Persons (Care and Protection) Act 1998 (NSW); Children, Youth and Families Act 2005 (VIC); and the Children and Community Services Act 2004 (WA); or
(b) any person or information that is exempted from the provisions of the Privacy Act, including but not limited to employment records.
What information does the Privacy Statement apply to?
1.6 This Privacy Statement applies to personal information. In broad terms, 'personal information' is information or opinions relating to a particular individual who can be identified.
1.7 Information is not personal information where the information cannot be linked to an identifiable individual.
2. HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?
2.1 We manage the personal information we collect in numerous ways, such as by:
(a) implementing procedures for identifying and managing privacy risks;
(b) implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
(c) implementing mechanisms to ensure any agents or contractors and agents who deal with us comply with the APPs;
(d) implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints; and
(e) appointing a privacy officer within the business to monitor privacy compliance.
2.2 We will take reasonable steps to destroy or de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
3. WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?
3.1 If you are a prospective contractor or agent, a prospective funder or investor, or a prospective tenant, we may collect and hold personal information about you, which may include:
(a) sensitive information (see below);
(b) contact information;
(c) date of birth;
(d) employment arrangements;
(e) licence details;
(f) banking details; and
(g) any other personal information required to engage you as our contractor or agent, or to establish and maintain relationships with our funders, investors, and tenants.
Sensitive information
3.2 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.
3.3 However, we may collect sensitive information from and about contractors and agents, and prospective contractors and agents, such as:
(a) bankruptcy; and
(b) criminal history.
4. HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?
4.1 Our usual approach to collecting personal information is to collect it directly from the individual concerned.
4.2 We may also collect personal information in other ways, such as from:
(a) our contractors and agents; and
(b) employment references.
5. HOW DO WE HOLD PERSONAL INFORMATION?
5.1 Our usual approach to holding personal information includes holding that personal information:
(a) physically, at our premises; and
(b) electronically, on secure servers; and
(c) in a private cloud.
5.2 We secure the personal information we hold in numerous ways, including:
(a) using security systems to limit access to premises outside of business hours;
(b) using secure servers to store personal information;
(c) using unique usernames, passwords and other protections on systems that can access personal information; and
(d) holding certain sensitive documents securely.
6. WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?
6.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected varies, depending on the particular service being provided or the individual from whom we are collecting the information but is generally as follows:
(a) in the case of contractors and agents – to assist us in providing our clients with high quality services;
(b) in the case of potential contractors and agents – to assess your suitability for engagement;
(c) in the case of prospective funders and investors and property tenants – to assess suitability and assist in managing the assets (capital or property), and complying with regulatory obligations.
6.2 Personal information may also be used or disclosed by us for secondary purposes that are within an individual’s reasonable expectations and that are related to the primary purpose of collection.
6.3 We may collect and use contractors’ and agents’ personal information:
(a) to conduct checks to ensure that the contractor or agent can perform and is performing the services to our standards; and
(b) for payment purposes.
6.4 We may disclose personal information to:
(a) contractors and agents;
(b) employers of individuals;
(c) government bodies;
(d) other service providers in order to assist our functions or activities; and
(e) any third party technology providers we may engage from time to time to carry out work on our IT systems.
6.5 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
7. HOW DO YOU MAKE COMPLAINTS OR ACCESS AND CORRECT YOUR PERSONAL INFORMATION?
7.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information
7.2 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
7.3 We will grant you access to your personal information as soon as possible, subject to the request circumstances.
7.4 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
7.5 We may deny access to personal information if:
(a) the request is unreasonable;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person; or
(d) there are other legal grounds to deny the request.
7.6 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed before it is levied.
7.7 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
Complaints
7.8 If you want to complain about any interference with your privacy, you must follow the following process:
(a) The complaint must first be made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
(b) If the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to contact
7.9 A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:
Postal Address: Level 19, 241 Adelaide Street, Brisbane, QLD 4000
Telephone number: 1300 497 042
Email address: privacy@homesforyoungpeople.com.au
8. CHANGES TO THE PRIVACY STATEMENT
8.1 We may update, modify or remove this Privacy Statement at any time without prior notice. Any changes to the Privacy Statement will be published on our website.
8.2 This Privacy Statement is effective from 12 August 2024. If you have any comments, please contact us using the contact details in section 7.9.