Privacy Policy

Introduction 

Aged & Community Care Providers Association Ltd trading as ‘Ageing Australia®’ ABN 19 659 150 786 (‘we’, ‘us’, ‘our’) is committed to protecting the privacy of its clients and stakeholders in accordance with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth) (Privacy Act) and any other statutory obligations as applicable. Ageing Australia reserves the right (at our discretion) to modify, amend or replace this Privacy Policy (Policy) from time to time and will post the new version of this Policy to our main website (https://staging.ageingaustralia.asn.au/privacy-policy). We recommend that you regularly review our Privacy Policy online or contact our office to request a copy. 

This Policy does not apply to our employees or employee records, as the handling of employee records by a private sector employer is exempt from the Privacy Act if it is directly related to the employee’s current or former employment relationship. However, if you do have questions regarding the handling of your employee records, you can contact our privacy officer (see below) for assistance. 

Purpose 

This Policy sets out Ageing Australia’s ongoing obligations to you in respect of the way in which we will collect, use, disclose, store, secure and manage your personal information and/or sensitive information. We collect and hold a range of personal information about our clients, job applicants, the contracts we engage and other people who interact with us. Ageing Australia remains committed to the responsible implementation and maintenance of processes and systems to ensure your information is secure. We recognise the essential right of individuals to have their personal information collected, used and disclosed in ways which they would reasonably expect, and with appropriate storage, protection and accessibility arrangements in place. These principles are reflected in and supported by our core values and philosophies. 

To ensure these standards are maintained, Ageing Australia will: 

• collect, use and disclose personal information only for our primary purpose or a related purpose, or for another purpose with the person’s consent 

• where possible, ensure that stakeholders are informed as to why we collect the information and how we use the information gathered 

• store personal information securely, protecting it from unauthorised access 

• provide stakeholders with access to their own information and the right to seek its correction 

• respond to any data breaches by reporting such breaches in accordance with the applicable laws 

• provide stakeholders with a clear process to address concerns or complaints with respect to a potential breach of their rights. 

Definitions 

Personal information  

Under the Privacy Act, ‘personal information’ means information (including images) or an opinion about an identified individual or an individual who is reasonably identifiable. Ageing Australia collects and holds a range of personal information, including some health and other sensitive information, about clients, members, associates, job applicants, volunteers, contractors, website users and other people with whom Ageing Australia ordinarily interacts. 

Sensitive information 

Some personal information is further classified as sensitive information, which is defined in the Privacy Act to include information relating to an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, membership of a trade union or other professional or trade association membership, philosophical beliefs, sexual orientation or practices or criminal record. It also includes health or genetic information about an individual and biometric information used for specific purposes.  

Why we collect personal information 

Ageing Australia collects personal information for the primary purpose of providing our services to clients, members and associates. We may also use personal information for secondary purposes related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.   

When we collect personal information, we will take reasonable steps to explain to you why we are collecting the information and how we plan to use it.   

What kinds of personal information we collect 

We collect a range of personal information about our clients, members and associates, and their employees, mainly consisting of contact information, such as: 

• names, email addresses and telephone numbers 

• position descriptions and business addresses 

• photographs, sound and/or video recordings, for example, recordings of events, phone calls or CCTV/surveillance cameras.  

We do not usually collect any sensitive information, such as racial or ethnic origin, health information, or whether you have a criminal record, unless it is relevant to the service being provided and we have obtained your consent or are otherwise permitted to collect that information by law. 

We also collect and hold certain personal information about applicants for employment with us and contractors wishing to supply products and/or services to us as well as their employees, including: 

• resumes, employment histories and qualifications 

• training records and competency assessments 

• sensitive information, such as police checks and other suitability checks 

• medical histories directly related to the individual’s ability to perform the inherent requirements of the position. 

How we collect personal information 

Ageing Australia collects personal information from a number of sources including: 

• forms (either physical or online), mail correspondence, emails and other electronic communications 

• feedback provided by our clients to us in relation to the services provided 

• telephone, email or in-person inquiries or discussions about us and/or the services we provide 

• publicly available sources of information 

• interactions with our social media channels that we offer or monitor 

• from job applicants and staff members 

• direct contact in the course of us providing services (including the administration of accounts established with us) 

• in the course of conducting market research, including customer satisfaction surveys, newsletters or other direct marketing materials 

• from current and prospective suppliers of goods or services to us 

• from companies about their employees and contractors 

• from companies about their customers and suppliers 

• from business associates and potential clients 

• from third party service providers on Ageing Australia’s behalf.  

Personal information may be obtained in many ways including but not limited to:  

• by correspondence 

• by telephone 

• in writing, by email 

• via web enabled forms on our websites  

• from other websites, media and publications, social media or other publicly available sources 

• when individuals register to participate in an Ageing Australia event, forum or training program 

• when organisations provide employee details when managing their Ageing Australia membership, affiliation subscription or other services delivered by Ageing Australia 

• where individuals are added to our newsletter subscription services or through registrations for meetings or consultations, lodgements of requests for advice and information. 

When collecting personal information, Ageing Australia will not do anything, or engage in any practice, that contravenes the APPs. In particular, Ageing Australia will not: 

• collect personal information unless the information is collected for a lawful purpose that is related to a function or activity of Ageing Australia, and is reasonably necessary for that purpose or 

• collect personal or commercial information by any unlawful means. 

How we store and secure personal information 

Ageing Australia strives to maintain the security of the information we collect. We hold personal information in both secure electronic and hard copy formats. The information we hold is generally stored in Australia, but where necessary, may be held on a cloud service provider’s server, which may be situated outside Australia. Ageing Australia takes reasonable steps to ensure that personal information we hold is protected from misuse, loss, unauthorised access, modification or disclosure. 

This includes both technical measures, such as securing our premises, securing physical storage of documents and maintaining network and communications controls, and organisational measures, such as training employees on data protection, quality systems procedures and policies for securing personal information and confidentiality. 

Ageing Australia will keep information for as long as it is required to provide the intended service(s) or to meet our statutory and regulatory obligations. We will take reasonable steps to permanently de-identify or securely destroy personal information that we no longer require for any purpose except in limited permitted circumstances. 

How we use personal information 

Ageing Australia generally only uses personal information for the primary purpose for which it was collected or a related secondary purpose that you would reasonably expect. These primary purposes include but are not limited to: 

• quality assurance, risk management and continuous improvement activities 

• contacting you in relation to any matter relating to you or the services provided to you 

• carrying out internal functions such as administration, accounting, quality assurance and information technology 

• resolving complaints 

• evaluating services 

• administering invoices 

• maintaining your organisation’s Ageing Australia membership or associate subscription and appropriate records (for members and associates only) 

• communicating with you to provide your organisation’s membership or associate benefits, including but not limited to key Ageing Australia and industry news via eCommunications 

• responses to your queries by our employees or contractors 

• advice of upcoming Ageing Australia events, workshops, forums and training opportunities 

• advice to member representatives of key company information, including but not limited to, director election and general meeting related documentation 

• support your organisation with advice and expertise on key sector issues 

• providing you with access to various collaborative forums and communities of practice with your peers and Ageing Australia employees 

• delivering business services on behalf of our clients (e.g. payroll services, claims and billing services) 

• undertaking market research, member satisfaction and other surveys and member data analysis 

• providing you with promotional information about our products and services that may be of interest 

• providing you with information to support your learning outcomes and information regarding our courses 

• providing you with updated information on events you have registered for 

• providing you with access to promotions and discounts from time to time 

• processing applications or nominations for director and committee positions or for positions on external Boards 

• monitoring whether you have opened eCommunications 

• delivering business products and services requested by you 

• tailoring and enhancing our products and services to you and our members 

• administering and supporting our service delivery, including billing and debt collection 

• processing and administering applications for employment as part of our recruitment function 

• to train and improve artificial intelligence (AI) models deployed within enterprise-grade solutions only. We do not use personal information to train AI models that are made available to the general public 

• managing the working and administrative arrangements for our employees and contractors 

• communicating with you. 

We may also use your personal information: 

•  for such other purposes as are subsequently agreed between Ageing Australia and you 
• where we have engaged a third-party service provider or partner to perform legitimate functions on our behalf (and where this occurs, the third-party service provider will only use the information collected in the circumstances outlined within this Policy) 

• for such additional purposes as are authorised by law. 

Sensitive information will only be used: 

• with your consent, for the primary purpose for which it was obtained or for a secondary purpose that is directly related to the primary purpose or 

• where otherwise required or authorised by law. 

How we disclose personal information 

We may disclose your personal and/or sensitive information to third parties where necessary for the purposes referred to above. 

When we disclose your information to a third party who is providing services to us, we will require the third party to protect your information in accordance with the Privacy Act and treat it confidentially, through the contract of service we sign with them. Such third parties may include, but are not limited to: 

• third party software platforms 

• government agencies 

• auditors 

• superannuation entities 

• insurers 

• legal advisors 

• external organisations we partner with, or who have been contracted to deliver a service on our behalf, including but not limited to publishing and mailing houses, including magazines and journals 

• independent returning officers appointed for election purposes 

• consultants and contractors engaged to undertake services requested by you on your behalf 

• debt collection agencies. 

In the delivery of our consultancy services, any consumer information in our reports to our client is de-identified (via use of initials only).   

Disclosure to overseas recipients 

We may disclose personal information to overseas recipients, for instance, if a client requests us to do so. However, we will not send personal information outside Australia without obtaining the consent of the individual concerned (in some cases this consent will be implied) or otherwise complying with the APPs and other applicable privacy legislation. 

We may use online or cloud service providers to store or back up personal information and to provide services to us that involve the use of personal information, such as services relating to email and data storage. This personal information may be stored in the cloud which means that it may reside on a cloud service provider’s server which may be situated outside Australia.  

If we disclose your personal information to an overseas recipient, we will take reasonable steps to ensure the overseas recipient does not breach the APPs. These steps include contractual obligations, security due-diligence and ongoing monitoring. 

Our websites 

Our websites contain links to other third party controlled websites. You should take care in providing personal information to external websites linked to our websites. We are not responsible for the privacy practices of any external websites. 

We collect standard web server/visitor traffic information, commonly referred to as aggregate information, regarding overall website traffic patterns. Normally, web servers collect this type of basic information as part of their web log processes. We only use this information for statistical, reporting and website administration and maintenance purposes. It is not used in a way that individually identifies you and we do not report on individual users. 

Cookies  

Ageing Australia uses cookies on its websites. Cookies are a small file that is placed on your computer by a web server when you access a website. They collect user information and data for statistical and analytic purposes, but do not identify the individual user, and are not linked in any way to personal identification details. 

Websites often use cookies. Most internet browsers accept cookies by default. You can control the use of cookies by configuring the preferences and settings in your browser and/or firewall. However, if you decide not to display cookies, then you may not be able to gain access to all the content and facilities of our websites. 

Direct marketing 

Ageing Australia may contact you to provide you with information about other services offered by us. If you do not wish to receive marketing material from us, you can contact us at any time to let us know. Our contact details are outlined below. 

Where we collect information about you from a third party, we will not use that information to directly market to you unless you consent to this. Such consent may be express or implied. 

You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or by using the ‘unsubscribe’ link on bulk email communications. If you request not to receive marketing material, we will comply with this request as soon as reasonably possible. Please note that we will still contact you in relation to our on-going relationship with you, including to send you any statements and notices that are relevant to the services you receive from us. 

Automated decision-making 

Ageing Australia uses various computer programs to streamline our internal functions and service delivery. From time to time, we may use your personal information in the operation of a computer program to assist us to make decisions. However, those computer programs will always be subject to oversight by human decision-makers.  

Data breaches 

Ageing Australia has statutory obligations to report certain data breaches to the Office of the Australian Information Commissioner and notify any impacted individuals when a data breach has occurred that is likely to result in serious harm to those individuals whose personal information is the subject of the breach. 

An eligible data breach occurs when: 

• there is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that Ageing Australia holds  

• that is likely to result in serious harm to one or more of those individuals 

• Ageing Australia has not been able to prevent the likely risk of serious harm with remedial action. 

Ageing Australia has a Data Breach Response Plan in place to manage any potential breach. 

Access and correction of personal information 

You have a right to reasonable access to any personal information that Ageing Australia holds regarding you. It is also important that the information we hold about you is accurate. Ageing Australia will take reasonable steps to ensure that the personal information it collects, uses and discloses is accurate, correct and up to date. To request access, a correction or amendments to any personal information we hold, please contact us (our contact details are outlined below).  

At the time of making such a request, we may ask that relevant forms be completed. We reserve the right to charge for providing access to certain information, as authorised by law and this information will be provided at the time of making the request. We will endeavour to meet a request for access or correction within a reasonable timeframe. However, in some circumstances we may decline a request for access to information, such as, where we no longer hold the information, we are unable to verify your identity or where denying access is permitted or required by law. If we are unable to give access to the information requested, we will provide written reasons for this decision when we respond to the request.  

For any concerns about the refusal, please contact us for further information. 

To access or correct your personal information, please contact the Ageing Australia Privacy Officer via: 

Phone: 1300 222 721 

Email:  

Post: Ageing Australia Privacy Officer 

Level 2, 176 Wellington Parade  

East Melbourne VIC 3002 

Enquiries and complaints 

If you have any queries regarding privacy at Ageing Australia or would like to enquire or make a complaint about a breach of your privacy, please contact the Ageing Australia Privacy Officer at the above address.  

We will promptly acknowledge receipt of your complaint, and we will endeavour to deal with your complaint and to provide you with a response within a reasonable timeframe following receipt of your complaint (generally within 30 days of receipt). Where a complaint requires a more detailed investigation, it may take longer to resolve. If this is the case, then we will provide you with progress reports. 

We reserve the right to verify the identity of the person making the complaint and to seek (where appropriate) further information from the complainant in connection with the complaint. 

Please note that we may refuse to investigate or to otherwise deal with a complaint if we consider the complaint to be vexatious or frivolous. 

If you are not happy with our response, or if you do not feel your complaint has been resolved, you may contact the Office of the Australian Information Commissioner: 

Phone: 1300 363 992 

Postal Address: GPO Box 5288 Sydney NSW 2001 

Website: www.oaic.gov.au