1. General Privacy Information
Safe Steps undertakes its privacy and data protection obligations under the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and relevant State and Territory based laws seriously. Safe Steps takes all reasonable steps in order to comply and protect the privacy of the information that it holds.
Safe Steps is committed to the protection of personal, sensitive and health information in accordance with privacy laws in the provision of its integrated services.
In accordance with Safe Steps commitment to information provision, we aim to provide all service users and potential services users, including those who view and interact via our website and chat room, with information that relates to privacy and the use of their personal information.
Safe Steps recognises the critical importance of privacy and confidentiality when providing quality, trauma responsive and safe services.
In all circumstances Safe Steps will seek to safeguard the privacy of personal information, except in circumstances where:
- There is a serious and immediate risk of harm to an individual including a child
- An individual has provided specific informed consent to disclose information to a third party
- The Organisation has a legal obligation to disclose information
Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether that information or opinion is true or not, and whether the information or opinion is recorded in a material form or not
Sensitive information is a type of personal information that is afforded a higher level of protection by privacy laws. It includes health, genetic and biometric information as well as information about race or ethnic origin, political opinions, membership of political, professional or trade associations or trade unions, religious beliefs, sexual orientation or practices and criminal record. (source: Privacy Act 1988 (Cth) s 6(1) as cited https://www.oaic.gov.au/privacy/guidance-and-advice)
Health information is information collected by Safe Steps in the course of providing a service to an individual which relates to any information or opinion about their:
- Health or disability at any time (past, present or future)
- Expressed wishes about future health services
- Health services provided or to be provided
- Information collected in providing a health service
- Information collected in connection with the donation or intended donation of body parts and substances (source: Health Records Act 2001 as cited https://hcc.vic.gov.au/public/health-records)
References to personal information made by Safe Steps may refer to personal, sensitive and health information.
Safe Steps will only collect information that is necessary and relevant to the scope of services we provide and will only collect sensitive information where you have consented or as otherwise permitted under relevant legislation.
Safe Steps seeks to collect personal information directly from the individual concerned wherever and whenever it is reasonably possible to do so.
In the event that Safe Steps collect sensitive information about an individual this will, wherever practical and possible, be undertaken with the individual’s consent.
4. Disclosure of Personal Information
Safe Steps will never disclose personal information without consent from the individual unless they are required to by law or under a duty of care.
Personal information can only be disclosed for the particular purpose for which it was collected (known as the ‘primary purpose’) unless certain legislative exceptions apply.
Personal information can be disclosed for secondary or other purposes where Safe Steps have consent to do so, where it is reasonably expected to be disclosed for a related purpose, where required or authorised by law or a Court/Tribunal order, where reasonably necessary for enforcement purposes conducted by or on behalf of an enforcement body, or where ‘permitted general situations’ or ‘permitted health situations’ exist.
Any personal information provided to Safe Steps through any means including by phone, in person and electronically through channels such as our website, webchat or email will be used solely for the purpose intended.
Safe Steps support the right of an individual to raise questions and concerns about privacy, or the way Safe Steps manages their personal information.
Any individual has the right to make a complaint to Safe Steps if they believe there has been a breach of their privacy rights or that Safe Steps have not managed their personal information in the right way or according to relevant legislation.
A privacy complaint relates to any concern or dispute that you may have with our privacy practices as it relates to your personal information. This could include matters such as how personal information is collected, stored, used, disclosed or how access is provided.
All complaints regarding privacy can be submitted either in writing to the Safe Steps Privacy Officer, GPO Box 4396, Melbourne, Vic 3001 or via email at firstname.lastname@example.org
In circumstances where an individual is not satisfied with how Safe Steps have handled their complaint, they may contact the following external organisations:
- Office of the Australian Information Commissioner (OAIC) oaic.gov.au
- Commissioner for Privacy and Data Protection cpdp.vic.gov.au
- Health Complaints Commissioner hcc.vic.gov.au
6. Access to Personal Information
Individuals have a right to access the personal information that Safe Steps hold about them.
Requests made by individuals to access their personal information held by Safe Steps will generally be granted, unless certain (limited) circumstances apply. Those circumstances may include where it is reasonably determined that granting access would pose a serious threat to the life, health or safety of an individual or to public health or safety, where granting access would have an unreasonable impact on the privacy of other individuals, where the request is frivolous or vexatious, or where legal proceedings are underway. Safe Steps may also deny access in some circumstances where it is required to do so by law or access would be unlawful, where negotiations or decision-making processes may be prejudiced, where unlawful activity or serious misconduct is suspected, or where enforcement related activities may be prejudiced.
Individuals can request access to personal information held by Safe Steps by completing a Request for Information Form (PDF) and submitting it to the Safe Steps Privacy Officer via mail or email at the following addresses:
GPO Box 4396
Melbourne VIC 3001
Individuals are required to verify their identity in this process.
An acknowledgement of receipt of the request to access personal information will be provided within 7 days.
Safe Steps will process and formally respond to a request for access to personal information within 30 days, unless one of the following apply as permitted under the FOI Act:
- Extensions with the applicant’s agreement
- Extensions to allow the Safe Steps to consult a third party
- Extensions for complex or voluminous requests
- Extensions after the processing period runs out
Safe Steps will endeavour to provide access to an individual’s personal information in the manner they request, however, if that is not possible or it is considered unsafe to do so, Safe Steps will provide alternative means of access or discuss with the client how access can be provided through a mutually agreed intermediary.
Safe Steps will comply with any legislation that requires disclosure of personal information to an individual’s authorised representative or legal adviser.
If access is refused, Safe Steps will provide the individual a written notice which sets out the reasons for refusal, how to submit a complaint about the refusal and where it relates to a commercially sensitive decision-making process, the reasons for refusal which may include an explanation of the nature of the commercially sensitive decision.
7. Safe Steps Website
Safe Steps will endeavour to maintain a secure system for storing personal information and health information. Technological and operational policies and procedures are in place to protect personal information from misuse, loss and unauthorised modification or disclosure.
Safe Steps will securely dispose of personal information and health information where it is no longer necessary to fulfill the purposes for which the information was collected or as required by law.
When using the Safe Steps website users must be aware that no data transmission over the Internet can be guaranteed as totally secure and although Safe Steps strive to protect such information, we cannot guarantee the security of any information that you transmit to us over the internet is secure and you do so at your own risk.
Safe Steps do not collect personal information when individuals simply browse the Safe Steps website, however there are times when we may collect personal information that individuals choose to give via such things as online forms or by email.
When an individual accesses the Safe Steps website, a non-identifying record is made of the visit and Safe Steps logs the following information for statistical data collection purposes:
- The individual’s server address
- The individual’s top-level domain name (e.g. .com, .org, au)
- The pages the individual accessed, and documents downloaded
- The previous site the individual visited
- The type of browser being used
Safe Steps do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect server logs.
Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes. The cookies simply operate as a unique identifier, which help Safe Steps to know what its website users find interesting and useful. Data collected from the website use does not identify the user, allowing them to remain anonymous in Safe Steps data collection.
Most web browsers are set to accept cookies however, individuals who do not wish to receive any cookies may set their browser to refuse them. In some instances, this will mean that they will not be able to take full advantage of parts of the website that provides you with improved service.
When an individual closes their browser the session cookie set by Safe Steps website is destroyed and no personal information is maintained which might identify an individual should they visit the website at a later date.
9. Use and disclosure of Website information
Safe Steps only use personal information collected via its website for the purposes for which it was provided
Safe Steps do not share personal information about individuals with other organisations or anyone else unless one of the following applies:
- The individual has consented
- The individual would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies
- It is required or authorised by law
- It will prevent or lessen a serious and imminent threat to somebody’s life or health
- The disclosure is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.
10. Data Security
Individuals who choose to join Safe Steps email lists, complete online forms or lodge enquiries will have their contact details stored on secure databases.