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  • Ballarat Neighbourhood Centre

    Privacy Policy

Privacy Statement
Policy & Procedure Manual

3.14  Privacy

Policy Declaration

BNC will protect and uphold the right to privacy of BNC users, staff, CoM members, and representatives of agencies we deal with. In particular, BNC is committed to protecting and upholding the rights of our users and staff to privacy in the way we collect, store, and use information relating to them, their needs, and the services we provide to them.

Policy Description

Application:

This policy applies to anyone within BNC who receives or uses personal information to perform their duties and roles. It requires a consistent and careful approach in the way personal information is managed, including what is written and said about individuals, and how they decide who can see or hear this information.

Background:

In recent years, many individuals have experienced the theft of their personal information, hence creating a higher focus on how organisations collect and handle personal information. 

At BNC we will provide you with the relevant privacy notices and advise when your personal information will be passed onto or is collected by a third party. Should your personal information be compromised we will notify you as soon as we identify any breaches of this policy.

You can read more about privacy, on the Office of the Australian Information Commissioner’s (OAIC) website: https://www.oaic.gov.au/

Objectives:

In managing personal information, BNC will follow the Australian Privacy Principles (APP) as set out in the Privacy Act 1988 (Cth) (amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012) and Privacy and Data Protection Act 2014 (Vic) including the Information Privacy Principles (IPP).

In dealing with personal information, BNC will:

  • ensure people know what sort of personal information is held, for what purposes it is held, and how it is collected, used, disclosed, destroyed and who will have access to it.
  • ensure privacy for an individual when they are being interviewed or discussing matters of a personal or sensitive nature.
  • only collect and store personal information necessary for the functioning of the organisation and its activities.
  • use fair and lawful ways to collect personal information.
  • collect personal information only by consent from an individual.
  • ensure personal information collected or disclosed is accurate, complete, and up-to-date, and will provide access to any individual to review information or correct wrong information about themselves.
  • take reasonable steps to protect all personal information from misuse and loss and from unauthorised access, modification, or disclosure.
  • destroy or permanently de-identify personal information no longer needed and/or after legal requirements for retaining documents have expired.

 Related Policies and Procedures:

  • Refer to the full policy for a list of related policies and procedures

Related Documents:

Refer to the full policy for a list of related documents.

 

3.14.1  Privacy Procedures

Why We Collect Information Relating to a Person

Through its activities BNC engages with a broad cross-section of people, collecting and using personal information to perform its legal and operational functions. These functions include employing staff, processing financial transactions, delivering adult education, supporting volunteers, running events and activities, managing community development programs, and providing employment and other support services.

Personal information is usually collected directly from the individual concerned although in some cases BNC may receive such information from third parties who have been given consent to share this with us.

In addition, individuals may agree to receive information about BNC, such as via the website, upon registering to use the visitor wi-fi, or by completing hard copy or digital forms and surveys.

As required by the Australian Privacy Principles, BNC includes privacy collection notices at the time of collecting personal information, which explains how information may be used.

 How We Collect Personal Information

Important information to note:

  • BNC has protections in place to keep your personal information safe however personal information may be collected, stored and shared with third party providers. Therefore this Privacy Policy does not extend beyond BNC website, systems and processes.
  • When linking to and using other third party sites you should familiarise yourself with their website privacy statements as listed below.
  • By accessing the BNC website, providing information online or completing BNC registration documentation you are acknowledging your usage is subject to this Policy.
  • If you do not want your personal information being stored offshore or by a third party, please do not submit personal information to us.

When engaging in BNC activities or services an individual will provide personal information in the following ways.

Forms, surveys and other documents

BNC uses a variety of hard copy documents to capture personal information. These documents are generally completed by the individual, sometimes with the help of staff or a third party. Once completed, they are given to BNC staff who enter the information into our Customer Relationship Management (CRM) databases Depending on the purpose of the information provided, the original documents will either be stored in locked filing cabinets or digitised and then destroyed as per the Data Retention Policy.

CRM: Social Planet

Social Planet is an Australian online CRM where individuals enter their personal information directly into the database or BNC staff use hard copy documents to enter personal information into the database.

The personal information provided to Social Planet, a third party, (excluding any billing or credit card information) is disclosed by Social Planet to BNC, who have access to this CRM database using secure logins and passwords. The purpose of collecting this information is to ensure the individual is enrolled in a course or activity and, if the customer has agreed to receive information about BNC programs, events and activities, to send them information.

For further information on Social Planet’s privacy policy, refer to: https://socialplanet.com.au/site/privacy

CRM: ETO

ETO is an American online case management system used by BNC staff to manage Jobs Victoria Work & Learning Centre (WLC) client registrations and compliance data.

When an individual agrees to become a WLC client they give permission for their personal information to be passed on to the Brotherhood of St Laurence (BSL), a third party, who own and operate the WLCs across Victoria with Jobs Victoria funding.

Only BNC staff working in the WLC team have ETO logins and passwords to access ETO. BSL staff managing the WLC program will also have access to BNC client personal information. BSL de-identifies personal information before passing this onto third parties.

Further information on how your personal information is handled refer to:

CRM: Microsoft Excel, Forms, Emails

BNC also collects and maintains personal information using Microsoft products including Excel, Forms, Sharepoint and Outlook. This information maybe stored on the BNC file server, desktop or laptop computers and/or online. The information collected is used for internal BNC purposes only by BNC staff who require security logins and passwords to access this information via BNC Microsoft 365 licences.

Technical support for our computer equipment and our Microsoft systems is provided by Ballarat Tech Help, a third party.  By default this may give them access to some personal information when providing this technical support to BNC staff. For more information on Ballarat Tech Help refer to their website: https://ballarattechhelp.com.au/

For information on how your online personal information is protected, refer to Privacy at Microsoft https://privacy.microsoft.com/en-ca

Electronic Direct Mail (EDM) & Newsletter Subscription

BNC uses both internal and third-party vendors to provide online communication services for some messaging, email campaigns and newsletter services. In subscribing to newsletters, you are providing BNC with personal information, which will not be disclosed for any other purpose without your consent.

Subscriptions supported by third-party vendors only share details to assist with managing delivery, technical issues and the prevention of fraud or security issues. They include but may not be limited to:

You can unsubscribe at any time and your email address will be moved to a 'do not contact' email database. To do this, click on the unsubscribe link within each email or newsletter type you have previously subscribed to.

National Police History and Working with Children Checks

National police history checks and Working With Children (WWC) checks are conducted on staff, contractors, tutors, volunteers, and in some cases clients. This is a requirement of BNC’s commitment to child safety.

When accepting a position, whether paid or unpaid at BNC, the individual is giving permission for their sensitive personal information to be used for a national police history check and to provide a WWC check. Access to relevant personal information is strictly limited to the Executive Officer and authorised BNC staff. BNC will retain the results of the checks in the individual’s records until they are no longer involved with BNC or in compliance with legislative requirements.

BNC uses Equifax online Fit2Work platform, a third party American based company, to perform its checks. For more information refer to the Equifax privacy policy: https://www.equifax.com.au/fit2work/sites/default/files/privacy.pdf

Accounting and Financial Transactions

BNC collects financial information from individuals and businesses as part of its daily operations. This information may be received in hard copy of electronically and is primarily kept in compliance with Australian Tax Office requirements, along with other government departments.

BNC uses Xero and MYOB online platforms to process and manage its financial systems, for further information on how these companies manage your personal information refer to their privacy policies:

Website

When using the BNC website you will provide personal information, including your location, IP address and in some cases your name and contact details. Personal details are maintained on secure servers. Sometimes BNC also invites people to submit comments, photos, or stories via forms on the website.

Although users are encouraged not to identify people, the stories may include some personal information. Whenever BNC collects such content, individuals are informed about the purposes for which their content will be used (for example, publication on the website).

The BNC website uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of our website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Our site uses cookies to make your experience of the site easier and more efficient. A cookie is a small data file placed on your hard drive by the web page server. A cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your email address. Note that the cookie will remain on your computer as a record for future visits to our website.

In using cookies BNC does not record any personal information or collect names or details of commercial transactions. In addition, BNC does not use cookies as the basis for direct marketing.

You can configure your browser to notify you when you receive a cookie, providing you with the opportunity to either accept or reject it. You can also refuse all cookies by turning them off in your browser or deleting all cookies from your computer if required.

For further information, please visit the Google Privacy Center https://safety.google/security-privacy/

The BNC website is managed by Virtual Bean, a third party, a web design company. For further information refer to their website: https://www.virtualbean.com.au/

 

What types of personal information do we collect and what is it used for

Bookings for course enrolments, volunteering, client support, venue hire, events, lunches and activities are regularly taken by BNC. The personal information collected and used by BNC is described below.

General contact information

At a minimum, the personal information usually collected would include name, phone number and email address. The purpose of collecting this information is to process a booking and to ensure an event or visit is properly coordinated.

This information is not used for any other purpose (such as unsolicited marketing) without the consent of the individual concerned. However, the information may be used to generate de-identified broad demographic data.

BNC maintains several databases with contact details of individuals who regularly engage with us who wish to receive regular information about our activities. This information is usually collected directly from the people who are interested in receiving information or from a representative of their organisation.

Personal information, including contact details, in the customer relationship management databases is used to:

  • enrol in courses and classes
  • register as a Jobs Victoria Work & Learning Centre client
  • register as a volunteer or Committee Member
  • become an employee, tutor or contractor
  • hire the facility, rooms or equipment
  • distribute information about BNC events and activities, including by email
  • maintain membership lists of friends, sponsors and donors
  • retain details of donations, and (with their consent) to publicly acknowledge those donors
  • access and help individuals with online government and other services
  • administer a booking for an event or activity
  • request and receive feedback about people’s experiences,
  • financial purposes including payment of accounts, funding applications and contracts, bank accounts signatories, etc and
  • generate invitation lists for BNC events.

Sensitive personal information

Sensitive information may be collected in relation to some individuals. For example, clients may formally identify as being culturally or linguistically diverse or being a person with a disability. Health information (for example medical reports or certificates) may also be collected by BNC where there is a workers’ compensation or other health-related matters affecting an individual. All records are stored in a secure file, with access limited to staff on a need-to-know basis.

Sensitive information is defined in the Privacy Act  and is a special subset of personal information which requires greater protection under the Privacy Act. Sensitive information is personal information that includes information or an opinion about an individual's racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information, and some aspects of biometric information.

Generally, sensitive information has a higher level of privacy protection than other personal information.

Information on Employees, Tutors, Contractors and Committee of Management members

BNC is required to collect personal information from employees, tutors, contractors and Committee of Management (CoM) members in order to meet its employment and legislative commitments. This information can be provided in hard copy or electronically form and is stored in locked filing cabinets or secure password protected systems within BNC offices.

By providing this personal information, an individual agrees to have their personal information shared with the relevant government departments who require it as a condition of their employment or appointment.

Internally, only the Executive Officer, senior delegated staff, and the Bookkeeper (a third party contractor) have access to this information. In some cases and with the consent of the individual, the CoM Chair may also be given access to personal information.

Information on Volunteers, including Vocational Placement Students

For Volunteers personal information is stored on Social Planet (Refer above to the CRM: Social Planet information) and only used for rosters, contact information, medical emergencies and as de-identified data for annual reporting to the Department of Families, Fairness and Housing (DFFH) via Neighbourhood Houses Victoria, third parties.

Vocational Placement Agreements, containing personal information, are stored on the secure BNC file server or in Microsoft 365 programs, including email and Sharepoint. (Refer above to the CRM: Microsoft Excel, Forms, Emails information)

Information on Adult, Community & Further Education (ACFE) Learners

For ACFE, sensitive personal information is collected to ensure our compliance to state government funding agreements and for medical details in case of emergencies.  We collect and store a range of socio-economic and demographic data in Social Planet  (Refer above to the CRM: Social Planet information)  for the Department of Jobs Skills, Industry and Regions (DJSIR), third party. This information is de-identified before being provided to DJSIR who use it for national and state based reporting purposes.

ACFE provide a detailed privacy notice each year which is included in enrolment processes and available won the BNC website.

For further information refer to the DJSIR Privacy Policy: https://djsir.vic.gov.au/privacy and DJSIR ‘How Training Data Is Used’  https://www.vic.gov.au/training-data-collection/m

Information on Jobs Victoria Work & Learning Centre (WLC) Clients

For WLC client’s sensitive personal information is collected to ensure compliance to state government funding agreements as we are required to collect a range of socio-economic and demographic data for Jobs Victoria, Department of Jobs Skills, Industry and Regions (DJSIR), third party.

The personal information provided by a WLC client to BNC is recorded in ETO (Refer above to the CRM: ETO information). By registering as a client of the WLC, a client is giving permission to share their personal information with Brotherhood of St Laurence (BSL) and for their name, phone number and email to be subscribed to the BNC community newsletter. (Refer to the Electronic Direct Mail & Newsletter Subscription section on how to unsubscribe.)

The information provided to BSL is not de-identified giving BSL full access to a clients’ personal information in compliance with our funding agreement to deliver employment services for Jobs Victoria, DJSIR.

BNC will de-identify this personal information if using it for BNC reporting and compliance requirements, unless permission from the person is given to share some or all of their information.

Information for room bookings and hire agreements

We collect personal information from those hiring BNC equipment and the facilities / rooms at Ballarat South Community Hub, Delacombe Community Hub, and the ArtBox. This information may be collected via a hard copy agreement, our online booking systems (email and website) or verbally over the phone.

This information is used internally to manage the bookings and is passed onto the following third parties for the processing of invoices and receipt of payments:

Information for administrative and financial records

In order to perform its daily operational activities, BNC collects personal information from businesses, community organisations, government departments and other individuals who provide services and products to BNC.

This information may include bank and other financial details required to process invoices and receipt payments. This information is used internally, but is also passed onto the following third parties:

  • BNC contract bookkeeper
  • BNC Auditor, CountPro - https://countpro.com.au/services/
  • Government departments and other philanthropic organisations for legislative reasons or as funding compliance may require copies of invoices and payments as proof of compliance.

Information on Participant Testimonials and Research Projects

If BNC is using personal information for a testimonial, case study or as part of a research project, the individual will be given:

  • a choice about participating
  • information about the purpose of the research project, why it is being collected, and how it will be used
  • the choice to have their identify or personal information de-identified
  • the right to withdraw at any time
  • copies of any subsequent publications.

The collection of personal information will be limited to what is required for the conduct of the project. Organisational participants in research projects will generally be identified in BNC research, unless the nature of a particular project requires anonymity, or an organisation specifically requests it. 

Information used for assisting with government services or other support

BNC helps community members access government and other support services, including MyGov and Services Victoria. To do this, individuals may share sensitive personal information with BNC staff who are assisting them with their registrations, applications and enquiries.

This personal information is not stored or used by BNC for any other purpose other than what it is provided for. Any hard copy documents will be returned to the individual or destroyed upon completion of the assistance. Any soft copy documents will be archived in accordance with the Data Retention Policy.

 Disclosure of personal information

BNC will not disclose personal information to anyone outside BNC unless the individual concerned has given their consent, or disclosure is otherwise permitted by the Australian Privacy Principles. Examples of exceptions include disclosure being necessary to prevent a serious threat to a person’s life, health or safety, or for law enforcement purposes.

 PROTECTION OF PERSONAL INFORMATION

We have in place, policies and information protection procedures, including (where appropriate):

  • physical secure file storage (including locked cabinets and offices)
  • private meeting rooms and spaces
  • password protection of electronic databases and systems
  • the provision of information to staff on a ‘need to know’ basis.

 How long do we store the personal information and how do we destroy it

Security of personal information is maintained in a number of ways. Where an electronic database containing personal information has been created, BNC takes steps to ensure the database may only be accessed by people who need access to perform their duties.

System access is granted to staff only on authority of an appropriate delegate, for the purposes of performing their work. Guidance is provided to staff about safeguarding electronic information (including the secure transfer of that information) in BNC’s information technology policies and procedures.

Disposal of records containing personal information is performed in accordance with the relevant disposal authority under supervision of the Executive Officer and in accordance with the BNC Data Retention Policy.

THE PRIVACY CONTACT OFFICER

The Privacy Contact Officer is the Executive Officer (EO). The EO will:

  • ensure all staff are familiar with the Privacy Policy and administrative procedures for handling personal information.
  • ensure BNC users and other relevant individuals are provided with information about their rights regarding privacy.
  • handle any queries or complaint about a privacy issue.

How to gain access to your personal information

If you wish to enquire about the use of your personal information or you believe your personal information is incorrect, in the first instance speak to the BNC staff member who manages your information. They will work with you to make the necessary corrections to your personal information.

If the information is not corrected; or you wish to have your personal information removed from BNC systems, contact us by providing sufficient information for us to identify your records at:

Executive Officer
Ballarat Neighbourhood Centre Inc
PO Box 540W, Ballarat. 3350
(03) 5329 3273

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