1. AUTHORISING AUTHORITY
Audit & Risk Committee
2. PRINCIPLES AND PURPOSE
CHC’s commitment to individual rights and the maintenance of the highest standards of ethical behaviour and professionalism includes commitments to the appropriate collection, storage and use of information, and to the protection of the privacy of personal information.
In undertaking our normal business, CHC collects, stores and uses personal information. While CHC treats this information with the highest standards of confidentiality and privacy, there are occasions when CHC may disclose this information to third parties where required by law, or where necessary for the conduct of CHC’s business.
The overall responsibility for privacy at CHC resides with the CEO. The responsibility for day to day management has been delegated to the Compliance Manager as the Privacy Contact Officer (PCO). The PCO is the first point of contact for members of the public should the circumstance arise on privacy matters including general information, requests from staff or Directors to access and/or amend personal information, and for internal review and resolution of complaints.
CHC treats the handling of personal information very seriously. To that end, CHC has systems and procedures in place to protect privacy in relation to the handling of personal information.
CHC abides by the Australian Privacy Principles, which provide a scheme in relation to the collection, disclosure, use and storage of personal information. CHC’s objective is to handle information responsibly and to provide control over the way information is handled.
3. APPLICATION OF POLICY
This Policy applies to all employees, contractors and Directors of CHC whether full time, part time or casual, of any level of seniority and employed or engaged as an internal staff member of CHC. The policy applies to all the activities of CHC.
4.1 Consideration of Personal Information Privacy
(a) CHC receives personal information of individuals, including but not limited to those seeking tenancy in CHC properties,
and existing tenants. Such personal information may include:
Proof of Identity
Proof of Residency / Citizenship
Proof of custody
Rental & Employee References
Name, date of birth, contact details
Drivers licence, Passport and Passport details
Visa Entitlement Verification
Verification, Details of dependent children
Current rent/housing status, Residential preferences.
(b) CHC retains this information as required by law and for genuine operational purposes.
(c) The information from individuals is held on CHC systems for a period of 7 years, and in the case of financial
transactions, indefinitely, for reference purposes in the event of transactional disputes or discrepancies.
(d) Individuals seeking personal information held by CHC can make a request in writing to the PCO and will be responded
to in 30 days.
(e) If an individual has a complaint that CHC breached one of the Australian Privacy Principles (APPs), the complaint must
be made in writing to the PCO, and will be responded to in 30 days.
(f) CHC does not send personal information overseas under any circumstances unless it is specifically requested by the
owner of the information.
4.3 Collection of Personal Information
(a) CHC will not collect personal information of any individual unless it is reasonably necessary to, or related to CHC’s
functions or activities or as required by law.
(b) CHC will not collect sensitive information without the individuals consent.
4.4 Means of Collection
CHC will only collect personal information by fair and lawful means in line with this policy and the APP.
4.5 Dealing with Unsolicited Personal Information
(a) If CHC receives unsolicited personal information that may be included through communications with applicants or
tenants, CHC will destroy that information if it is not deemed reasonably necessary to maintain it for operational
(b) CHC will not distribute to other parties any unsolicited personal information under any circumstance.
4.6 Notification of the Collection of Personal Information
(a) When CHC collects personal information of an individual, CHC will notify the person prior to collecting the information.
(b) CHC will inform the individual of the consequences for not providing the information requested by CHC, which may
include CHC being unable to process housing requests.
(c) CHC will inform individuals of whom personal information is collected that should their information be requested by
third parties by law, the information will be provided to them (eg: Centrelink, court orders, ACAT etc).
4.7 Direct Marketing
CHC at times send CHC tenant newsletters to its existing tenants. Newsletters may contain information related to
community support services, CHC policies directly related to CHC tenants, or tenant related meetings such as the Tenancy
Advisory Group. Tenants may opt-out of these communications.
4.8 Cross Border Disclosure
Information sent outside Australia will be under the conditions outlined in section 4.1.
4.9 Government Related Identifiers
CHC will not collect or disclose an Individual’s Government Identifiers such as Tax File or Medicare numbers unless
required for a specific lawful purpose.
4.10 Integrity of Personal Information
CHC will ensure that all personal information CHC holds remains accurate and up to date.
4.11 Security of Personal Information
(a) All personal information in paper form will be kept in locked filing cabinets or safes.
(b) All electronic personal information will be held in secure files protected by passwords and firewalls.
CHC must give access to an individual’s personal information on request unless:
(a) CHC believes that giving access would pose a serious threat to life, health, safety, or wellbeing to any individual.
(b) Giving access would have an unreasonable impact on the privacy of other individuals.
(c) The request is frivolous or vexatious.
(d) The information relates to CHC or anticipated legal proceedings between CHC and the individual, and would not be
accessible by the process of discovery in those proceedings.
(e) Giving access would reveal the intentions of CHC in relation to negotiations with the individual in such a way as to
prejudice those negotiations.
(f) Giving access would be unlawful.
(g) Giving access would likely prejudice a law enforcement investigation.
(h) Giving the information would reveal a commercially sensitive decision making process.
4.13 Refusal of Access
If CHC refuses access under section 4.12, CHC must outline in writing to the individual:
(a) The grounds for refusing access.
(b) The mechanisms available to complain about the refusal.
(c) Any other matter prescribed by the regulations.
4.14 Correction of Personal Information
If CHC believes information it holds is out of date, incomplete, irrelevant, or misleading, CHC will take steps to
correct the information. CHC may refuse to make the correction if it is unreasonable to do so, and the individual is
notified in writing.
Officer of the Federal Privacy Commissioner 133 Castlereagh Street
Sydney NSW 2000
02 9284 9800
The Privacy Contact Officer,
CHC Affordable Housing
PO Box 6239
O’Connor ACT 2602
4.16 Further information and complaints:
If you require any further information about our management of personal information or have a complaint about our handling of your personal information, you should initially write to the Privacy Officer, who will respond to you within a reasonable time, usually 30 days.
If you are not satisfied with the outcome of your complaint you may contact us further to advise of your concerns and, if we are unable to reach a satisfactory resolution, you may write to the Office of the Australian Information Commissioner using the form available at this link for further review of your complaint.
This policy will be reviewed as required and when legislation dictates.
Version 2.0 8-Feb-2016