Privacy Policy

Place (the Platform), owned and operated by Carrie's Place Domestic Violence and Homelessness Services Incorporated (ABN 29 918 379 160).

Policy Purpose

  • Carrie’s Place is committed to protecting and upholding the right to privacy of clients, staff, volunteers, Governance Committee members and representatives of agencies and donor organisations the Organisation deals with.
  • In particular, Carrie’s Place is committed to protecting and upholding the rights of its clients to privacy in the way information is collected, stored and used regarding them, their needs and the services provided to them.
  • Carrie’s Place requires staff, volunteers and Governance Committee members to be consistent and careful in the way they manage what is written and said about individuals and how they decide who can see or hear this information.
  • Carrie’s Place is subject to the Associations Incorporation Act, 2009 and the Associations Incorporation Regulation 2022.
  • Carrie's Place will follow the compliance requirements of the Australian Charities and Not-for-profits Commission (ACNC) which aligns with the guidelines of the Office of the Australian Information Commissioner (OAIC) on privacy for not-for-profits and the requirements of the Australian Privacy Principles in its information management practices.
  • Carrie’s Place will ensure that:
  • it meets its legal and ethical obligations as an employer and service provider in relation to protecting the privacy of clients and Organisational personnel;
  • clients are provided with information about their rights regarding privacy;
  • clients and Organisational personnel are provided with privacy when they are being interviewed or discussing matters of a personal or sensitive nature;
  • all staff, Governance Committee members and volunteers understand what is required in meeting these obligations; and
  • it will adhere to all requirements imposed under the Privacy Act 1988, including the requirements imposed by the Privacy Amendment (Notifiable Data Breaches) Act 2017, to strengthen the protection of personal information.

Scope

  • This Policy applies to all employees of Carrie’s Place and all persons performing work at the direction of Carrie’s Place [‘workers’].
  • This Policy applies to all records, whether hard copy or electronic, containing personal information about individuals, and to interviews or discussions of a sensitive or personal nature.
  • Carrie’s Place Inc. will be collectively referred to as [‘Carrie’s Place’], or [‘Organisation’].

Compliance

  • Carrie's Place seeks and encourages the commitment of all workers regarding this Policy and are dedicated to ensuring that all workers are aware of and understand all elements of this Policy and associated policies and procedures.
  • Workers must comply with the requirements of this Policy. Any breach of this Policy may result in disciplinary action including, but not limited to, termination of employment.
  • Carrie’s Place reserves the right to vary, replace or terminate this Policy from time to time.

Procedures

Dealing with personal information

  • Carrie’s Place holds a range of records in a variety of locations, for each different service function of the Organisation. This information is collected for the purpose of:
  • meeting reporting requirements of Carrie’s Place service level agreements;
  • monitoring and management of service to individuals (case files);
  • meeting legal requirements; and
  • service monitoring, evaluation and reporting (de-identified information only is used for this purpose).
  • Information considered personal and sensitive may include:
    • personal details – name, address, date of birth, contact details;
    • situation specific information – history of domestic violence / homelessness, legal, medical, child protection, etc.; and
    • documentation – case notes, referral documentation, legal documents, etc.
  • In dealing with personal information, workers will:
    • ensure privacy for clients, workers, volunteers or Governance Committee members when they are being interviewed or discussing matters of a personal or sensitive nature;
    • only collect and store personal information that is necessary for the functioning of the organisation and its activities;
    • use fair and lawful ways to collect personal information;
    • collect personal information only by consent from an individual;
    • ensure people are aware of the type of personal information held, what purposes it is held it for, how it is collected, used, disclosed and who will have access to it;
    • ensure personal information collected or disclosed is accurate, complete and up-to-date, and provide access to any individual to review information or amend incorrect information about themselves;
    • take reasonable steps to protect all personal information from misuse and loss, and from unauthorised access, modification or disclosure;
    • destroy or permanently de-identify personal information no longer needed and / or after legal requirements for retaining documents have expired;
    • notify individuals and the Office of the Australian Information Commissioner (OAIC) when there has been a data breach (or suspected breach) of personal information, if it is likely to result in serious harm to individuals whose privacy has been breached; and
    • if identifiable information about a client will be shared with another agency, the staff member will obtain the client’s consent for this.
  • Responsibilities for managing privacy
  • Workers are responsible for the management of personal information to which they have access, and in the conduct of research, consultation or advocacy work.
  • The Chief Executive Officer [‘CEO’] is responsible for content in Carrie’s Place publications, communications and website; and must ensure the following:
    • appropriate consent is obtained for the inclusion of any personal information about any individual including Carrie’s Place workers;
    • information being provided by other agencies or external individuals conforms to privacy principles; and
    • the website contains a Privacy Statement that makes clear the conditions of any collection of personal information from the public through their visit to the website.
  • The CEO is responsible for safeguarding personal information relating to Carrie’s Place workers, Governance Committee members, volunteers, contractors and Carrie’s Place members.
  • The Privacy Contact Officer is the CEO who is responsible for:
    • ensuring all workers are familiar with the Privacy Policy and administrative procedures for handling personal information;
    • ensuring clients and other relevant individuals are provided with information about their rights regarding privacy;
    • handling any queries or complaint about a privacy issue; and
    • ensuring Carrie's Place management review the scope of information collected every 6 months to ensure that only relevant information is being recorded.

Privacy information for clients

  • At the initial point of contact with a client (i.e. intake assessment), clients will be told what information is being collected, how their privacy will be protected and their rights in relation to this information.
  • Under certain circumstances, Carrie’s Place may need to collect sensitive information about clients to enable provision of appropriate services. This may include information relating to sexual preferences, criminal records or health information.  This sensitive information will be collected only when client consent has been obtained, or as otherwise required or authorised by law, and appropriate measure will be taken to protect the security of this information.

Storage, use and disposal of identifiable data

  • All information collected about individual clients is stored electronically. Workers are responsible for maintaining files relevant to their own clients.
  • Disposal methods protect the privacy of individuals, and the confidentiality of Carrie's Place clients. Information storage and disposal is typically governed by and complies with the Department of Communities and Justice (DCJ) and Carrie's Place service level agreements.

Privacy for interviews and personal discussions

  • To ensure privacy for clients or workers when discussing sensitive or personal matters, the Organisation will:
    • ensure layout of at least one public space in Carrie’s Place venues allows for a private conversation between workers and client to occur;
    • ensure workers make use of private meeting rooms when making phone calls which discuss confidential client information;
    • ensure private interview spaces are made available for both workers and clients; and
    • when home visits are conducted, where possible, private conversations will be made possible at the request of a workers member or client.

Participants in research projects

  • People being invited to participate in a research project must be:
    • given a choice about participating or not;
    • given the right to withdraw at any time;
    • informed about the purpose of the research project, the information to be collected, and how information they provide will be used; and
    • given copies of any subsequent publications.
  • The collection of personal information will be limited to that which is required for the conduct of the project. Individual participants will not be identified.
  • Organisational participants in research projects will generally be identified in Carrie’s Place research, unless the nature of a particular project requires anonymity, or an organisation specifically requests it.

Other Records

  • Other Carrie’s Place records consist of the following:
  • Financial – maintained electronically and managed by the Finance Manager and CEO. Access is restricted to Carrie's Place management.
  • Personnel – maintained electronically and managed by the HR Specialist and CEO. Access is restricted to the HR Specialist and CEO.
  • Statutory documents related to the incorporation and governance of Carrie's Place – maintained electronically and managed by the Finance Manager and CEO. Access is restricted Carrie's Place management.
  • Contractual and other administrative documents, including insurance policies – maintained electronically and managed by Carrie's Place Administration staff. Access is restricted to administration and management.
  • Funded project files – maintained electronically and managed by the Special Projects Manager, Finance Manager and Strategy and Project Development Officer. Access is restricted Carrie's Place management.

IRIS Affirmations

Ownership and Development

  • Iris Affirmations is a mobile application [‘app’] owned and operated by Carrie's Place, a legally registered entity.
  • The app was developed by CIBIS International on behalf of Carrie's Place.
  • All rights, content and data associated with Iris Affirmations are the property of Carrie's Place, unless otherwise stated.

Related Resources

Related Documents