Personal information, as defined in the Privacy Act, means any information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
Personal information can be in any format and may include images, such as photos, and sounds, such as voice or tape recordings.
If you have any questions or feedback about this policy or the way in which Summer Housing handles personal information or sensitive information you can contact us using the details provided under the heading ’Contacting Us’.
Collecting personal information
Summer Housing will:
- only collect personal information that is necessary for the proper functioning of Summer Housing
- notify stakeholders about why we collect the information, how it is administered, and that this information is accessible to them
- only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose
- obtain consent from the affected person for other uses
- unless otherwise required by law, only release personal information about a person with that person’s express consent. For personal information to be released, the person concerned must sign a consent form
- release information to third parties where the person concerned requests
- take reasonable steps to ensure the information the organisation collects is accurate, complete, up to date, and relevant to the functions we perform
- safeguard the information we collect and store against misuse, loss, unauthorised access and modification
- ensure stakeholders have a right to seek access to information held about them and to correct it if it is inaccurate, incomplete, misleading or not up to date
- give stakeholders the option of not identifying themselves when completing evaluation forms or opinion surveys
Types of personal information we collect
The types of personal information that we collect will depend on the type of dealings you have with us. For example, if you:
- apply for Summer Housing tenancy, we may collect your name, contact details, information about your circumstances, parts of your NDIS plan such as your participant number, goals, support needs, SDA determination and SDA funding and other relevant information to support your application
- become a tenant of Summer Housing, we will collect your name, contact details, emergency contact information, parts of your NDIS plan such as your participant number, goals, support needs, SDA determination and SDA funding and other relevant information to support your tenancy
- become a supporter of Summer Housing, we may collect your name, organisation, contact details and confirm whether you are a student
- make a donation to Summer Housing, we may collect your name, organisation, contact details, the amount and frequency of your donation and payment details
- attend a Summer Housing event, we may collect your name, organisation, contact details, payment details (if applicable) and any dietary and accessibility requirements
- send us an enquiry, we may collect your name, contact details, information about your circumstances and details of your query
- make a complaint, we may collect your name, contact details, the details of your complaint, information collected in any investigation of the matter and details of the resolution of the complaint
- apply for a role at Summer Housing, we may collect the information you include in your application, including your cover letter, resume, contact details and referee reports
- participate in a research study, survey or provide feedback, we may collect your comments and contact you for additional information
- participate in a case study for publication, we may collect and publish your views in our publications. Your views may be aggregated with other responses but should your individual views be published we will seek your consent before publication.
Some personal information, such as information relating to racial or ethnic origin, religious beliefs or affiliations, health information (including mental health information and information about a disability), genetic information and whether or not you have a criminal record is sensitive and requires a higher level of protection under the Privacy Act. We may collect your sensitive information when we have your consent and when the collection is reasonably necessary for us to properly carry out one or more of our functions or activities.
Sensitive information is generally relevant to an assessment of whether a person is eligible for our services.
Example – eligibility assessment
For many of our housing services for individuals, the personal circumstances of the individual are relevant to assessing whether that person falls within the eligibility criteria of that service. These services will need to collect information that is relevant to the eligibility criteria to make an assessment about whether a person is eligible to receive assistance or not. This might include information about whether a person has a mental illness, disability or substance abuse problem.
What if you don’t provide us with your personal information?
In some circumstances, we allow individuals the option of not identifying themselves, or of using a pseudonym, when dealing with us (for example, when viewing our website or making general phone queries). Donations may also be made anonymously, but in this case Summer Housing may not be able to issue a tax-deductible receipt.
The nature of the business carried on by Summer Housing means that, generally, it is not possible for us to provide services to our tenants or other individuals in an anonymous way.
How we collect personal information
We collect personal information in a number of ways, including:
- when you correspond with us (for example by letter, email or telephone)
- on hard copy forms
- on electronic forms
- in person (for example, at job interviews or where we meet with a tenant)
at events and forums
- from third parties who refer you to us for assistance with your consent
- from someone you have specified in the consent form. This could include a support coordinator, occupational therapist and / or another health practitioner
Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are set out below.
Providing housing services
- assessing whether tenants meet our acceptance criteria
- determining any specific special needs
- reporting to funding providers
- promoting Summer Housing and its activities, including through events and forums
- conducting research and statistical analysis relevant to Summer Housing’s activities
- preparing tenant stories for use in publications (tenants will not be individually identified without their consent)
- seeking funding and donations
- organising fundraising events
- reporting to funding providers
- recruiting staff, contractors and volunteers
- processing payments
- answering queries and resolving complaints
- evaluating our work and reporting externally
- for compliance with Government and other reporting requirements.
Who we disclose personal information to
The nature of the services provided by Summer Housing means that it may be necessary for us to disclose your personal information to other parties. Usually, you will be informed about how we use and disclose your information at the time we collect it. There may be practical reasons for information to be used or disclosed without prior notice, for example, to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety.
Common third parties we might need to disclose your personal information to include:
- our investors (although personal information will only be provided with your consent)
- financial institutions for payment processing
- the legal providers that give legal assistance to Summer Housing and our tenants
- referees whose details are provided to us by job applicants
- our contracted service providers which include:
- appointed property and tenancy managers
- information technology service providers
- conference and function organisers
- marketing, communications and research agencies
- freight and courier services
- external business advisers (such as recruitment advisors, auditors and lawyers)
- your other service providers i.e. Supported Independent Living (SIL) Providers
- a court (for obtaining copies of documents relevant to your matter)
Where we are contractually required to provide tenancy data to our investors for reporting purposes, unless consent is provided, tenant data is de-identified.
The following internal Protocol is in place to ensure that tenant data is protected.
Any de-identified tenant data that is to be provided to an external party must be reviewed by a line manager or one of the following:
- Chief Executive Officer
- Chief Financial Officer
- General Manager Governance and Compliance
To ensure completeness of the Protocol throughout the organisation, de-identified tenant data that is being sent out by a member of the Executive also requires a review and consent to release by another member of the Executive.
Information requested by investors
Our investors sometimes request information about our tenants. This type of request is generally in four categories as outlined below.
- If the requested information relates to the physical dwelling, we will respond with factual data, such as:
- address of the dwelling
- whether it is tenanted or vacant
- the commencement date and ending date of the tenancy
- the rental amount and SDA payment
- the condition of the dwelling, including defects and maintenance
- special features such as Assistive Technology and storage facilities
- size and location of tenant parking bays and visitor parking bays
- common area facilities such as a pool hoist
- details of embedded networks, if any
- financial data such as council rates, property taxes and depreciation schedules
- Personal data regarding the tenant will not be provided to Investors unless the tenant requests in writing that we provide personal data such as:
- NDIS number
- details of the specific disability or health issues
- Aggregated and de-identified data about the tenants can be provided to the Investors to assist them to understand the impact their investment is having, such as:
- demographic profile
- disability profile
- summary data from tenant satisfaction surveys
- summary data from tenant complaints
- impact reporting
- Public or consented information about the tenants, such as case studies approved by the tenant, can be provided to Investors.
Cross border disclosures
We may disclose personal information to our contracted information technology service providers that are hosted in the cloud.
Storage and security of information we hold
We hold personal information mainly in electronic formats and less often in hard copy. Paper files are stored in secure cabinets onsite. In rare instances, they may also be archived in boxes and stored offsite in secure facilities.
If you are a tenant, upon request we will return to you any of your original hard copy documents that we have when our relationship with you ends i.e. when your tenancy ends. Electronic copies of your documents will remain on your file with us and will generally be kept for seven years. Hard copies will be destroyed securely.
The security of your personal information is important to us and we use the recommended industry standards when storing and dealing with your personal information.
The steps we take to secure the personal information we hold include:
- website protection measures (such as encryption, firewalls and anti-virus software)
- access restrictions to our computer systems (such as login and password protection)
- restricted access to our office premises
- staff training and implementation of workplace policies and procedures that cover access, storage and security of information
While Summer Housing strives to protect the personal information and privacy of users, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact Summer Housing by telephone or post (details under ‘Contacting Us’).
You can also help to protect the privacy of your personal information by letting us know as soon as possible if you become aware of any security breach.
Third party websites
Summer Housing is not responsible for the privacy or security practices of any third party websites. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.
Access and correction to personal information
We will take reasonable steps to provide you with access to your personal information.
We will take reasonable steps to correct your personal information if we are satisfied that it is inaccurate, out of date, incomplete, irrelevant or misleading. If we have provided your personal information to third parties we will also notify them of the correction if you ask us to do so, unless it is impracticable or unlawful.
Requests to access and correct your information should be made by email, post or phone using the details provided under the ‘Contacting Us’ heading. Note that we will need to verify your identity before processing your request. We will endeavour to respond to your request within 30 days.
If we do not agree with your request to access or correct your information, we will provide you with written reasons for our decision and available complaint mechanisms.
If you have a complaint about how Summer Housing has collected or handled your personal information, please contact our Company Secretary using the details provided under the heading ‘Contacting Us.’
We will ask you to complete a Complaint Form, which provides us with the details we need from you to assess your complaint. We can assist you with completing the Complaint Form if required.
We will endeavour to respond to your complaint within 30 days of receipt of the Complaint Form (whilst complex cases may take longer to resolve, we will keep you updated on the progress of your complaint).
If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information) or, in some instances, other regulatory bodies, such as the Victorian Privacy Commissioner (see here), the New South Wales Privacy Commissioner (see here) or the Victorian Health Complaints Commissioner (see here).