1. COLLECTION OF YOUR PERSONAL INFORMATION
Woniora Management will collect and hold your personal information in a fair and lawful manner, and not in an unreasonably intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. However, in certain cases we may collect personal information from third parties, including from publically available sources.
We collect and hold personal information that is reasonably necessary for, or directly related to, one or more of our functions or activities as a company. This information may include (as well as other information) your name, date of birth and your contact details including residential address.
Woniora Management collects personal and sensitive information from several sources. Mostly, the personal and sensitive information we collect comes directly from residents when they register as a resident with us. We collect information on employees in relation to normal business practice, and also collect information on contractors including business details, insurance details and certificates/qualifications. The contact details of sales clients, residents, employees and contractors are saved on our CRM system.
2. SENSITIVE INFORMATION
Woniora Management recognizes there are additional concerns with sensitive information. “Sensitive information” is information or opinion about an individual which is:
- personal information which is also information or an opinion about the individual’s racial or ethnic origins, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices, or criminal record; or
- health, genetic or biometric information about the individual.
There are circumstances where Woniora Management collects sensitive information and is allowed or required to do so by law. These circumstances may include but are not limited to:
- when you register as a resident with us;
- where it is necessary to enable Woniora Management to exercise its legal rights, and/or perform its legal obligations;
- where necessary for or in connection with actual or proposed legal action, in order for Woniora Management to obtain legal advice or to establish, exercise or defend its legal rights;
- where the processing is of personal information relating to race, ethnic origin, religious or other beliefs, physical or mental health and is necessary to identify or keep under review the existence or absence of equality of opportunity or treatment at Woniora Management; and
- where an individual has given their explicit and fully informed consent.
We will only collect sensitive information about you with your consent, except where we are required or permitted by law to collect your sensitive information without your consent.
3. HOW WE HANDLE PERSONAL AND SENSITIVE INFORMATION
Our records about residents will generally include contact details and general health information. This health information is regarded as sensitive under the Privacy Act, and must be treated with a higher standard of care. Woniora Management only collects this kind of information if a resident provides it to us for a specific purpose, for example to inform us of particular health needs relevant to their general well-being.
As part of the service to our residents, Woniora Management managers regularly review and update health records on each resident in order to ensure proper assistance to residents in the event that medical assistance is required.
In handling personal and sensitive information with respect to residents, we only process this information for the purpose of providing the products and services that the resident has requested or, in the instance of an emergency, providing those services that the resident reasonably requires. We do not use or retain personal and sensitive information for any purpose other than the delivery of the product or service and for auditing or legal reasons.
4. USE AND DISCLOSURE OF YOUR PERSONAL AND SENSITIVE INFORMATION
We process personal and sensitive information relating to our residents to better understand their needs and to provide them with information about our products and services. Your personal and sensitive information is protected so that only those employees with a business requirement to have access to this personal or sensitive information will be granted access.
In the instance of a medical emergency, consent to supply sensitive information to a third party for the purposes of administering medical treatment will be deemed to have been granted by the resident.
Woniora Management generally explains how it will use or disclose personal and sensitive information at the time it collects the information. In general, we do not use or disclose your personal information for a purpose other than:
- a purpose you would reasonably expect;
- a purpose required or permitted by law; or
- a purpose otherwise disclosed to you to which you have consent.
5. OVERSEAS TRANSFER OF PERSONAL INFORMATION
We do not disclose any of your personal information overseas.
6. SERVICE PROVIDERS
Like most large organisations, we use a range of service providers to help us maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of Woniora Management, such as mail houses, will sometimes have access to personal information held by Woniora Management and may use it on behalf of Woniora Management. We require our service providers to adhere to strict privacy guidelines that require them not to keep this information or use it for any unauthorised purposes.
We will only provide these companies with the information which they need to carry out their jobs. They will only be allowed to use your information in the way in which we tell them, and they will not be entitled to use it in their own right.
We will take all reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations with respect to the protection of your personal information.
We do not provide resident’s sensitive information to service providers, except in the case of medical emergencies as outlined in (3) above.
7. MARKETING COMMUNICATIONS
Like most businesses, marketing is important to Woniora Management’s continued success. We believe we have a unique range of products and services that we provide to residents at a high standard. We therefore like to stay in touch with residents and let them know about new opportunities. We may provide you with information about new products, services and promotions.
We will not disclose your personal information to third parties for marketing purposes.
You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting our Privacy Officer.
8. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.
Woniora Management is not obliged to correct any of your personal information if it does not agree that it requires correction and may refuse to do so. If Woniora Management refuses a correction request, we will provide you with a written notice stating our reasons for refusing.
9. PROTECTION OF PERSONAL INFORMATION
Woniora Management maintains appropriate physical, procedural and technical security for its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information. This also applies to disposal of personal information.
Woniora Management further protects personal information by restricting access to personal information to those who need access to do their job.
10. RESOLVING PERSONAL INFORMATION CONCERNS
The Privacy Officer
Woniora Management Pty Ltd
Suite 219 / 838 Collins Street
Docklands VIC 3008
Once a complaint has been lodged, the Privacy Officer will respond to you as soon as possible.
You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or email:firstname.lastname@example.org.