Policies

The type of information NAN Inc collects and holds includes (but is not limited to) personal information, including sensitive information, about: 

• contact details (e.g. name, address, telephone numbers, email)

• personal details (e.g. date of birth, gender)

• information regarding personal issues, experiences and relationships

• information regarding communication, environmental, sensory, regulation and social needs

• relevant health, medical or diagnostic information

• information about family background and supports in the community

• areas of interest

In some circumstances NAN Inc may be provided with personal or health information about an individual from a third party as part of a service or program the individual is participating in with NAN Inc. In such circumstances, NAN Inc will will inform you that this information has been collected and may provide you with further information regarding how the information will be used and disclosed.

NAN Inc will not use your health information beyond the consent provided by you, unless your further consent is obtained, or we are otherwise acting in accordance with applicable law. If NAN Inc uses your health information without specifically seeking your consent for research or statistical purposes, it will be de-identified if practicable to do so.

Under the Privacy Act the Australian Privacy Principles do not apply to an employee record. As a result, this Privacy Policy does not apply to NAN Inc’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between NAN Inc and employee. However, NAN Inc must provide access and ensure compliance with the Health Privacy Principles under the Victorian Health Records Act 2001.

The NAN Inc will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which you have consented.

In relation to direct marketing, NAN Inc will use your personal information for direct marketing where you have provided that information, and you are likely to expect direct marketing: only then you will be sent direct marketing containing an opt out. If we use your personal information obtained from elsewhere we will still send you direct marketing information where you have consented and which will also contain an opt out. We will always obtain your consent to use sensitive information as the basis for any of our direct marketing.

We may, on occasion, offer services at premises which use video surveillance for security purposes and the footage will be used only by NAN Inc and by the providers of the security services for security purposes. Surveillance videos will not be used by NAN Inc for other purposes and footage will not be publicly available. Surveillance cameras are not located in any bathrooms or change room facilities used by NAN Inc.

In relation to personal information of job applicants, staff members and contractors, NAN Inc’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be. 

The purposes for which NAN Inc uses personal information of job applicants, staff members and contractors include: 

• for insurance purposes; 

• to satisfy NAN Inc’s legal obligations, 

Where NAN Inc receives unsolicited job applications these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.

NAN Inc also obtains personal information about volunteers who assist in its functions or conduct associated activities, such as to enable NAN Inc and the volunteers to work together. 

NAN Inc treats marketing and seeking donations for the future growth and development of our mission as important.  Personal information held by NAN Inc may be disclosed to an organisation that assists in our fundraising.

NAN Inc may disclose personal information, including sensitive information, held about an individual to: 

• government departments; 

• people providing services to NAN Inc, 

• anyone you authorise NAN Inc to disclose information to. 

NAN Inc will not send personal information about an individual outside Australia without: 

• obtaining the consent of the individual (in some cases this consent will be implied); or 

• otherwise complying with the Australian Privacy Principles or other applicable privacy legislation. 

We do not use overseas providers of IT services including servers and cloud services.

In referring to ‘sensitive information’, NAN Inc means: 

“information relating to a person’s racial ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record, that is also personal information; and health information about an individual”.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law. 

NAN Inc’s staff and volunteers are required to respect the confidentiality of personal information and the privacy of individuals. 

NAN Inc has in place steps to protect the personal information we hold from misuse, loss, unauthorised access, modification, interference or disclosure by use of various methods including locked storage of paper records and passworded access rights to computerised records. 

NAN Inc endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. A person may seek to update their personal information held by NAN Inc by contacting the Privacy Officer at any time.

The Australian Privacy Principles and the Health Privacy Principles require NAN Inc not to store personal information longer than necessary. In particular, the Health Privacy Principles impose certain obligations about the length of time health records must be stored. 

You have the right to check what personal information NAN Inc holds about you. 

Under the Commonwealth Privacy Act and the Health Records Act, an individual has the right to obtain access to any personal information which NAN Inc holds about them and to advise NAN Inc of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation. To make a request to access any information NAN Inc holds about you, please contact the Privacy Officer in writing. 

NAN Inc may require you to verify your identity and specify what information you require. Although no fee will be charged for accessing your personal information or making a correction, NAN Inc may charge a fee to retrieve and copy any material. If the information sought is extensive, NAN Inc will advise the likely cost in advance. 

Under our destruction and de-identification policies, your personal information that is no longer required will be de-identified or destroyed. In many circumstances, however it will be kept for marketing purposes, as you will have consented to that in writing with us.

If you would like further information about the way NAN Inc manages the personal information it holds, please contact the Privacy Officer. If you have any concerns, complaints or you think there has been a breach of privacy, then also please contact the Privacy Officer. If we then have not dealt satisfactorily with your concerns we will meet with you to discuss further. If you are not satisfied with our response to your complaint within 30 days from this meeting then you can refer your complaint to the Office of the Australian Information Commissioner via:

• email:  enquiries@oaic.gov.au

• tel:  1300 363 992

• fax:  +61 2 9284 9666

NAN Inc will generally collect personal information held about an individual by way of phone calls, forms, emails, meetings etc. You do have the right to seek to deal with us anonymously or using a pseudonym, but in almost every circumstance it will not be practicable for us to deal with you or provide any services to you except for the most general responses to general enquiries, unless you identify yourself.