Your Privacy is Important
The Adelaide Benevolent Society (‘ABS’) is a registered charity with the Australian Charities and Not-for-Profit Commission (Australian Charities and Not-for-Profit Commission Act 2012 (Cth)) and has DGR taxation status. The objects are in out constitution, and the primary object is to relieve disadvantage through the provision of subsidised housing and financial assistance to those in need.
This Policy is published on our website and may be updated from time to time.
What is your “Personal Information”
“Personal Information” has a specific meaning under the Act. Broadly, it is any information which can be used to personally identify you. We may collect and hold a range of different personal information about you. This may include, but is not limited to, your name, age, date of birth, contact details (including mailing or street address, email address and telephone number), profession, occupation or job title, driver’s licence number, income, assets and information in relation to your tenancy history and living circumstances. Where possible, we will collect personal information directly from you.
What is your “sensitive information”
“Sensitive Information” has a specific meaning under the Act and includes information about your physical and mental health; criminal record; racial and ethnic origin; sexual orientation; and health information.
The ABS will only collect sensitive information with your consent and where it is reasonably necessary and relates to the provision of housing and financial assistance or other ABS activity or function. If sensitive information is provided by you without our request and is not reasonably required to undertake our activities and functions, it will be destroyed by deleting the correspondence or disposing of the paperwork in a confidential disposal bin.
If your personal or sensitive information is not provided
If you choose not to provide us with certain personal or sensitive information, we may not be able to assist you.
Anonymity and Pseudonymity
The ABS recognises that the Act allows individuals to deal anonymously or via a pseudonym with organisations where such interaction is lawful and practicable.
This principle has only limited application to the main function of ABS in providing subsidised housing to those in need. This is because its charitable status and compliance with its Constitution requires ABS to assess the applications for housing based on need. This cannot be done anonymously.
Enquiries and complaints may be made anonymously or via pseudonym. If made in that manner the ABS may be limited in the detail of the response it can provide.
How we collect and hold your personal and sensitive information
We collect personal information from you directly unless it is not reasonable or practicable to do so. We may collect information from you in a number of ways:
- When you complete a housing application.
- Through accessing and using our website.
- During conversations or communications between you and our employees or representatives.
We may also collect personal information from third parties including:
- A social worker, support work, or other person who applies for housing on your behalf.
- Public third party sources such as social media sites.
- Where you have provided specific consent, we may also collect and exchange information with Government agencies, funding partners or organisations for whom we are a service provider.
Sensitive information can only be collected with your consent.
To whom we may disclose your information
We may disclose your personal information to our employees, Board members, agents, contractors, our contracted service providers, workers from an agency who supplied your housing application, professional advisors, IT system administrators, partner organisations with whom we have a commercial relationship and with your express consent, any organisation or person for any authorised purpose.
Specific purposes for which we may use or disclose personal information include the purposes of providing you with housing, marketing and developing our services, monitoring our service provision, the operation and administration of accounts, carrying out certain checks (for example, in relation to housing history), interacting with companies or organisations with whom we have a business relationship, complying with our obligations under agreements with third parties and carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.
How we use your information
We collect personal information so we can perform the primary function of the ABS of providing housing assistance to those in need. This may include updating our records, responding to a complaint, to provide your information to our contractors or service providers or comply with any law, rule or regulation or other legal requirement of a regulator or government body. The purpose for which we use and disclose personal information will depend on the circumstances in which it is collected.
We will only hold your personal information for the particular purpose for which we collected it. It will not be shared, sold, rented or disclosed other than in accordance with this policy. Sensitive information will be used for the primary purpose that it was collected. It will only be used for a secondary purpose where:
- You consented to the secondary purpose; OR
- You would reasonably expect the secondary use or disclosure and it directly relates to the primary purpose; OR
- The secondary use or disclosure is required by an Australia Law, Court or Tribunal; OR
- A permitted general situation exists, such as serious threat to life, health or safety, locating a missing person and disputes and claims.
Security of Your Information
We take reasonable steps to ensure your personal and sensitive information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form.
Retention of Your Information
Where information held by us is no longer required to be held, and its retention is not required by law, then we will destroy such personal and sensitive information by a secure means. Hard copies of tenant applications are generally only held for 12 months, and hardcopy files of exiting tenants are generally not retained for any longer than 6 years. Electronic files and records are retained for longer than 6 years.
How can you access and correct your information
You can gain access to your personal and sensitive information, subject to certain exceptions contained in the Act. To request access to your information, or to update or correct that information, please send a written request to Chief Executive Officer, 17 Morialta Street, Adelaide, SA, 5000. We will check the identity of individuals making requests and make a determination as to whether the request will be met. A response will be provided, usually in writing, to advise of the outcome.
We may send you marketing communications to advise of housing vacancies, provide a newsletter to supporters or as otherwise permitted under the Act and other relevant laws. If you do not wish to receive such communications, please contact us via email at firstname.lastname@example.org or follow the opt-out instructions contained in each marketing communication. We do not provide your information to other organisations for the purpose of direct marketing.
What is the process for complaining about a breach of privacy
If you are concerned there may be a breach of your privacy in the way in which we collect, hold, use or disclose your information please send written details of your complaint to Chief Executive Officer, email@example.com or 17 Morialta Street, Adelaide, SA, 5000. We will check the identity of the individuals making requests and make a determination as to whether the request will be met. A response will be provided, usually in writing, to advise of the outcome.