- Last updated: December 2017
- VCV protects the privacy of personal information VCV collects;
- VCV may use such information and to whom such information may be disclosed; and
- individuals can request access to and correction of the personal information VCV holds, lodge complaints with VCV in respect of the manner in which VCV handles personal information or to make any related inquiry.
VCV requires that its staff comply with this policy in relation to any personal information they handle. VCV also uses its best endeavours to ensure that contractors comply with their obligations with respect to any personal information to which they may have access or which may be disclosed to them.
VCV may collect personal information from any individual with whom it may have contact, including job applicants, volunteers, representatives from current and prospective suppliers and its clients.
Types of information VCV collects and holds
VCV may also collect information about you when you access VCV’s website. The information collected from such access does not generally identify you, unless you specifically complete and submit a form to VCV using a form VCV makes available to you via the website.
Due to the nature of the Internet, the information collected about you when you access VCV’s website may contain details which may identify a particular individual (such as the IP address of the computer accessing the VCV website, the internet service provider the individual uses to connect to the Internet, the web-page directing the individual to the VCV website and the individual’s activity on the VCV website).
Dealing with VCV anonymously or pseudonymously
In accordance with the Privacy Act 1988 (Cth), you do not need to provide us with your personal information and you may interact with us on an anonymous and pseudonymous basis. However, if you choose to interact with us in this fashion, or if you do not provide us with personal information when requested, we may be unable to provide you with all of the services that you seek from us.
Further, we reserve the right to request your identity from you in certain circumstances, and to verify your identity if we consider that it is appropriate or reasonable for us to do so. For example, when you request that we provide certain services to you, we may need to identify you in order to liaise with other service providers and with Government agencies in relation to the services we provide to you and the services provided to you by other service providers and by Government agencies.
Additionally, when you request access to or correction of personal information we hold about you, or when you wish to make a complaint to us about the manner in which we have handled your personal information, we will request your name and contact details in order to facilitate our response to your request or complaint. We reserve the right to verify your identity against the information we hold about you.
If we are unable to verify your identity, or you continue to engage with us on an anonymous or pseudonymous basis, we may be unable to satisfy your request or complete our complaints-handling process.
How VCV collects personal information
VCV only collects personal information using lawful means. VCV may collect personal information about an individual from a variety of sources using a variety of means, including:
- a form (either physical or online) that is completed and submitted to us;
- a telephone, email or in-person inquiry or discussion about us or the services that we provide;
- a referral to us from another organisation, a medical practitioner or Government agency;
- mail correspondence, emails and other electronic means (including by accessing our website and the use of the “contact us” form on our website);
- through publicly available sources of information;
- from job applicants and staff members;
- direct contact in the course of us providing our services;
- in the course of conducting advocacy on behalf of our clients; and
- from current and prospective suppliers of goods and/or services to us.
To the extent reasonably practicable and reasonable for us to do so, we collect personal information about an individual directly from that individual. Additionally, we will only collect personal information when we specifically seek that information, except in circumstances where personal information is volunteered to us or otherwise supplied to us without us asking for such information.
What personal information does VCV collect?
VCV may collect personal information such as (but not necessarily limited to) an individual’s name, date and place and birth, street and postal addresses, email address, phone numbers and other contact details.
Additionally, VCV may collect personal information about an individual from third parties. For example, VCV may collect personal information about the services an individual has received from a third party service provider or from a Government agency, to the extent such information is relevant to the services VCV has been requested to provide or provides to an individual.
VCV may also collect information regarding your next-of-kin, your legal guardian and details for emergency contacts.
VCV may collect the following information:
- when an individual visited VCV’s website or contacted VCV either in-person or over the telephone;
- when an individual visits VCV’s website, the pages the individual accessed and the information downloaded;
- when an individual visits VCV’s website, the IP address(es) of the computer(s) used to access VCV’s website and the page from where the individual visited VCV’s website, the type of browser used and information about website(s) visited before the individual visited VCV’s website; and
- when an individual contacts VCV over the telephone, VCV may record the conversation for training purposes.
VCV may also collect data from its website using various technologies, including ‘cookies’. A ‘cookie’ is a text file VCV’s website transmits to an individual’s browser and which is stored on the individual’s computer as an anonymous tag identifying the individual’s computer (but not the individual) to VCV. The browser may be configured to disable cookies, but some parts of VCV’s website may not function properly or at all if cookies are disabled.
Where VCV collects personal information on an unsolicited basis, VCV will comply with its statutory obligations in relation to such personal information.
Receipt of unsolicited personal information
From time to time, we may receive personal information about an individual without specifically asking for that information. For example, we may receive misdirected mail or an employment application sent to us on the initiative of the job applicant and not in response to an advertised vacancy.
Additionally, we may receive unsolicited personal information from an individual when we ask the individual to provide us with personal information and the individual supplies us more than what we have requested from the individual.
The purposes for which VCV uses personal information it collects
As a general principle, and in accordance with VCV’s statutory obligations, VCV only uses personal information for:
- the primary purpose(s) for which the information was collected;
- any secondary purpose that is related to the primary purpose for which you would reasonably expect VCV to use the collected information; or
- as otherwise permitted or authorised by law (including the APPs).
VCV may use the personal information it collects about an individual for one or more of the following purposes:
- to facilitate VCV’s provision of goods and/or services to the individual or to a third party which may directly or indirectly benefit the individual;
- processing transactions and administering client accounts (including by processing of invoices, bills, statements of account and related financial matters necessary to enable VCV to provide goods and/or services under relevant contractual arrangements);
- addressing queries and resolving complaints;
- to send information updates, donation requests, marketing materials and newsletters to current and prospective supporters of and donors to VCV and any other individuals who have consented (either expressly or impliedly) to receive such information and provided that they have not opted out of receiving such information;
- to initiate contact with an individual if the individual has not engaged with VCV for an extended period of time (unless VCV is informed that the individual no longer wishes to be contacted by VCV or anyone on VCV’s behalf);
- to improve VCV’s products and services, its website and its other means of communication;
- carrying on business as a not-for-profit provider of homelessness, community, rehabilitation, family violence prevention, support, disability, financial counselling and related services to disadvantaged Australians; and
- to directly market VCV, its products and services to the wider public.
To whom may VCV disclose personal information it collects?
VCV may disclose personal information collected from individuals to third parties but only on an as-needs basis and in order to fulfil one or more of the purposes for which the information was collected, any secondary purpose related to the primary purpose of collection, or otherwise as required or authorised by law.
VCV may disclose personal information to the following third parties (without limitation):
- VCV’s agents and contractors (including, for example but without limitation, its agents and contractors in order to enable them to provide products or perform services on behalf of VCV, or to facilitate VCV’s provision of its products and services to its clients);
- VCV’s professional advisers; and
- related entities of VCV.
VCV may also disclose personal information about an individual when required by law or court order, or other governmental order to process to disclose, where VCV believes in good faith that the law compels VCV to disclose information, or where VCV is required to do so as a result or consequence of any obligations VCV owes under a contract.
VCV may disclose personal information about an individual to a third party if VCV considers it reasonably necessary to do so in order to identify, contact or bring legal action against a third party whom VCV suspects or knows is causing harm to, or interference with VCV’s products and/or services, VCV’s information technology systems and equipment, VCV’s staff and volunteers, or VCV’s property.
When VCV engages third parties to provide products and/or services to VCV, such third parties may have access to personal information VCV holds about individuals. VCV will use its best endeavours to ensure that those parties do not use any personal information VCV discloses to or allows access to by the third party for any purpose other than to facilitate the third party’s completion of its obligations owed to VCV.
Without limiting the foregoing, VCV may disclose individuals’ personal information to its related entities and to its advisers (including auditors, financial services or insurance companies) or to its professional advisers (such as its legal and accounting advisers) for them to complete their obligations owed to VCV under agreements that VCV has entered into for the purpose of undertaking or furthering its operations and activities.
Use of your personal information for the purpose of direct marketing
In accordance with the APPs, we may use or disclose your personal information for the purpose of directly marketing us, our products and services and to seek your support for the business and activities of VCV.
Where we have collected personal information about you from a third party then we will not use that personal information to directly market to you without your consent.
However, you may at any time unsubscribe or opt out from receiving the marketing materials we directly send to you from time to time by using the tools we make available or otherwise by emailing us. Once we receive your opt out notification, we will promptly remove you from our mailing list.
When directly marketing to you, we will also comply with other laws relevant to marketing, including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Competition and Consumer Act 2010 (Cth).
Disclosure of personal information overseas
VCV may store, process or back-up personal information it holds on servers (including servers offered through third party service providers under contract to VCV) that are located in a jurisdiction other than Australia.
Where VCV enters into a contract with a host provider for the hosting of information for and on behalf of VCV, VCV will use all reasonable endeavours to ensure that such contract reserves for VCV the right to control access to the personal information so hosted and to avoid the need for the host provider to access the information it hosts for VCV.
VCV may enter into contracts for the provision of hosting services with host providers located in Europe, the USA and/or other countries, as determined by VCV from time to time at its discretion.
VCV does not otherwise disclose or allow a third party located outside Australia to access the personal information VCV holds.
Security and retention of personal information
VCV takes the security of all personal information in its possession seriously. VCV takes reasonable steps to protect any personal information it holds from misuse, interference and loss. VCV also takes reasonable steps to protect the information VCV holds from unauthorised access, modification and disclosure.
VCV only holds personal information it collects from or about an individual as long as reasonably necessary to fulfil the purpose(s) for which the information was collected, as required by law or in accordance with VCV’s document retention policies. When the information is no longer required to be held by VCV then VCV will take reasonable steps to destroy or de-identify the information.
VCV takes reasonable steps to ensure that any third party to which VCV discloses personal information collected from or about an individual takes steps to protect the personal information so disclosed and to destroy or de-identify the information when the information is no longer required by the third party.
Links to third party websites
VCV’s website may contain links to third parties’ websites. Those other websites are not subject to VCV’s privacy policies and procedures. You will need to review those websites directly to view a copy of their privacy policies.
VCV does not endorse, approve or recommend the products or services provided by the operator of the relevant third party website, and the fact that VCV includes links to those third party websites should not be construed as an endorsement, approval or recommendation by VCV of either the website operator or the products or services so provided.
Accessing your personal information
In accordance with the APPs, an individual is entitled at any time (on request to VCV) to access the personal information VCV holds about that individual.
Where VCV receives a request to access the personal information VCV holds about an individual, VCV will comply with its statutory obligations and will respond to such an access request within a reasonable period of time.
Unless it is unlawful or impracticable for VCV to do so, VCV will generally provide access to the requested information in the manner requested.
Please note that VCV is entitled under the APPs to charge a reasonable fee to cover the costs VCV incurs in providing access to the personal information held about an individual.
Additionally, VCV reserves the right to refuse access to an individual’s personal information VCV holds where any of the statutory exceptions to the access right exist in the particular circumstances. Where VCV refuses an access request, it will explain the reasons for refusal in writing and provide details in relation to the relevant complaint process.
VCV also reserves the right to request information from the individual making the access request in order to verify the identity of the individual making the request, in order to ensure that VCV is not inadvertently disclosing personal information to an individual not entitled to access such information.
Further, VCV reserves the right to redact the information made available in response to an access request, to protect the privacy of other individuals.
Quality of the information VCV holds
VCV takes reasonable steps to ensure that the personal information it collects, uses and discloses is accurate, complete and up-to-date.
However, the accuracy, completeness and currency of the information VCV holds largely depends on the accuracy of the information supplied to VCV or which VCV collects.
If at any time you discover that any information VCV holds about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, please contact VCV to request correction of the information. VCV will handle a correction request in accordance with its statutory obligations. However, as noted above, VCV reserves the right to verify the identity of the person making a correction request before processing the request.
Lodging a complaint and how to contact VCV
If you wish to make a complaint to VCV about how VCV handles the personal information collected from or about you, the complaint should be made in writing to VCV and addressed to the attention of VCV’s privacy officer (details of whom are set out below).
VCV will promptly acknowledge receipt and will endeavour to deal with the complaint and provide a response to you within a reasonable time period following receipt (generally within 30 days of receipt).
Where the complaint requires a more detailed investigation, the complaint may take longer to resolve. If this is the case, then VCV will endeavour to provide the complainant with progress reports.
VCV reserves the right to verify the identity of the individual making the complaint and to seek (where appropriate or reasonable) further information from the complainant about the circumstances of the complaint.
Where required by law, VCV will provide its determination on the complaint to the complainant in writing.
VCV reserves the right to refuse to investigate or to otherwise deal with a complaint where permitted under law, where such circumstances apply. For example, without limitation, VCV may refuse to investigate or to otherwise deal with a complaint if VCV considers the complaint to be vexatious or frivolous.
If you are not satisfied with the outcome of your complaint, then you may write to us seeking an internal review of our decision. Such internal review would be completed by an officer not previously involved in the complaint.
If you still remain dissatisfied following the outcome of the internal review, you may escalate the complaint to the Office of the Australian Information Commissioner.
The Privacy Officer
Level 2, 452 Flinders Street
Melbourne VIC 3000
Phone: (03) 9611 9200
Facsimile: (03) 9611 9222