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Wombat Housing Support Services Incorporated (ABN 19 823 459 821) (‘Wombat,’ ‘we,’ ‘us’ and ‘our’) is committed to ensuring the confidentiality and security of your personal information.
This Privacy Policy outlines how we collect, use, disclose and protect your personal information, as required by the Privacy Act 1988 (Cth) (Privacy Act). It also outlines how you can access and change your information, ask a question or make a complaint.
For clarity, this Privacy Policy only applies to our handling of personal information relating to the platform available at [insert link] (the Platform). Please contact us if you would like further details in relation to how we handle information of a different nature.
The Platform includes a database that stores personal information relating to individuals in Victoria, Australia that are leaving out-of-home care who may be at risk of, or already experiencing, homelessness (Youth). The Platform is not directly accessible by Youth. Instead, support workers, employees and other users (Authorised Users) who are related to either Wombat or a participating organisation (Participating Organisation) enter Youth’s personal information into the Platform.
By providing personal information either directly to us, or to an Authorised User who is entering the information into the Platform on your behalf, you are agreeing to be bound by this Privacy Policy.
In addition, if you are an Authorised User, you agree to be bound by the Platform Terms of Use, which can be accessed at [insert link] (Platform Terms).
2.1 What is personal information?
Personal information is information that identifies you as an individual or from which your identity can be reasonably identified. The types of personal information we may collect depends on your relationship to us.
In all cases, your personal information may also include your name, date of birth, gender, email address, telephone number, other contact information, and your relevant preferences.
If you are a Youth, we may also collect information relating to your living arrangements, your interests, your skills, situation and competencies in respect of various matters – including your health and finances, and additional information relating to you that you may provide to us directly or indirectly.
If you are an Authorised User, we may also collect information relating to your relationship with a Participating Organisation.
2.2 What is the purpose for collecting personal information?
We know that your personal information is important, so we only collect personal information that is reasonably necessary for the Platform’s functions and our related activities. These functions and activities include:
(a)providing, or facilitating the provision of, support services to Youths, including by way of maintaining any information, documents or other materials that are accessible on the Platform in respect of a Youth (Youth Profiles); and
(b)preparing and publishing anonymous and aggregated research related to issues facing Youth, including but not limited to homelessness.
This may include using your personal information to run the Platform, provide services to you, contact you and allow you to contact us via the website, send you information, provide you with support, improve our services and website, sign you up to our services and verify your identity.
We may also use your personal information for ancillary purposes and generally in the process of providing a quality service and experience while you access or use our website and services, so long as we act in a manner consistent with what would be reasonably expected of a not-for-profit charity organisation working to provide housing support services.
In connection with these purposes, we may provide your personal information to third parties. We provide further details about this in section 3.1 below. We will take reasonable steps to ensure that any such third party treats your personal information in a manner no less restrictive than as set out in this Privacy Policy, and in accordance with the Privacy Act.
2.3 How do we collect personal and non-personal information?
We can only collect personal information about you in ways that are lawful and fair.
We may collect information from you directly, such as when you access the Platform, contact us, submit an enquiry, meet with Wombat personnel, set up an account on the Platform, or otherwise interact with us. You may optionally provide us with this information through third-party services such as search engines, social media, advertisements and websites used to access our site.
We may also collect your personal information indirectly from third parties such as support workers and other personnel from organisations with which Wombat has a relationship. Information collected indirectly may include any of the information set out in clause 2.1 above.
We may also collect your information via promotions, public records, mailing lists, contractors, staff, partners, and pixel tags. Pixel tags enable us to receive information about your use of our website and emails, such as when an email we have sent has been opened.
If we receive personal information about you which is not reasonably necessary for the purposes outlined in section 2.2 we will destroy or de-identify it.
For all visitors browsing our website, we use cookies, and may access your local storage through HTML Web Storage or other browser-based software, to collect information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Safari), the time of visit, pages visited and your IP address. We may also derive the general geographic area associated with an IP address. We also may use cookies to manage the Platform. If you have provided us with personal information by accessing the Platform, creating an account or completing an application form online, we may use cookies, HTML Web Storage or other browser-based software to collect information about how you access or use our websites, which can also identify you. If you would prefer not to be identified in this way, you can delete the cookies or reconfigure the cookie and local storage preferences on your browser.
3.1 Using and disclosing personal information
We only hold, use and disclose personal information about you for the purposes outlined in section 2.2, or for related purposes which might be reasonably expected, unless we otherwise obtain your consent.
Such disclosure may include disclosure of your personal information to third parties who:
(a) are Participating Organisations, provided they have provided us with reasonable evidence that you have consented to us sharing your information with them;
(b) are our service providers (such as web hosting or data storage providers);
(c) are regulatory bodies, government agencies, law enforcement bodies or courts;
(d) introduce you to us (such as by way of a referral); or
(e) are your authorised agents, executors, administrators or legal representatives.
We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity.
On some occasions, we may be obliged to disclose your personal information by law, such as court orders or statutory notices pursuant to any legislation and to government authorities.
3.2 Direct communication
From time to time, we may use your personal information to contact you directly, such as to let you know about any new services or information which we think you may find relevant and interesting. If we do contact you in this way, it will only be in relation to matters that someone in your position would reasonably expect us to contact them directly about. We will ensure that such activities comply with applicable laws.
We may contact you by telephone, email, SMS, instant messaging or other communication methods for these purposes. We may also utilise third-party service providers (including, but not limited to, Microsoft products, Gmail from Google, Inc, and MailChimp from The Rocket Science Group LLC) to communicate to you and store your contact details. These service providers are located in the United States of America.
We will not sell your personal information to other third party organisations or allow them to contact you for direct marketing purposes.
If you no longer wish to receive any direct communication from us, please follow the instructions for unsubscribing in our communications. If there are no instructions, please contact us as set out in section 7 below.
3.3 Transferring your information overseas
Sometimes our third party agents, contractors or organisations are based overseas, or otherwise have data storage facilities overseas where your personal information will be stored. We may transfer information about you between countries if required for a relevant purpose described above.
We will take reasonable steps to ensure all overseas entities to whom we transfer your personal information take adequate safeguards for your personal information and do not breach the Privacy Act, including ensuring commercially reasonable and industry standard security measures are taken by those entities to protect your personal information from unauthorised access and use.
For further information on the safeguards that apply to international transfers of your personal information, please contact our Executive Officer using the contact details in section 7 below.
We have security measures in place to protect your personal information that we hold. We take reasonable steps to ensure your personal 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. We have security measures to ensure the physical security of personal information held on our premises and systems. When records containing personal information are no longer required, we delete the information or permanently de-identify it.
We use SSL encryption to store and transfer your personal information However, as our website is linked to the internet, we cannot provide any assurance regarding the security of transmission of information you communicate to us. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the Internet. Accordingly, any personal information or other information which you transmit to us is transmitted at your own risk.
5.1 Access
You are entitled by law to access the personal information we hold about you and, provided that it is reasonable and practicable, to do so in a manner that you request.
We will need to validate the identity of anyone making an access request, to ensure that we do not provide your information to anyone who does not have the right to that information.
We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances it may take longer.
If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.
We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs.
To contact us to access the personal information we hold about you, please use one of the methods outlined in section 7 below.
5.2 Correction
If you feel that any of the personal information we hold for you is incorrect, inaccurate or incomplete you can contact us at any time to request that we correct that information.
If you would like to do so please contact our Executive Officer using the contact details in section 7 below.
We will normally try to resolve correction requests within 30 days of you making a request, but in some circumstances it may take longer.
There will be no cost to you if we correct your personal information held by us.
If we do not agree that your personal information needs to be corrected or changed, then we will add a note to the personal information stating that you disagree with it.
If European Union data protection law applies to the processing of your information, you can exercise your right to request access to, update, remove, and restrict the processing of your information according to this Privacy Policy. We will retain your personal information unless and until you tell us that you would like it to be removed. You also have the right to object to the processing of your information or to export your information to another service.
This Privacy Policy sets out the legal grounds for the processing of your information, which are based on:
(a) your consent, which you may withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal;
(b) the legitimate interests we have in providing, maintaining, customising, marketing and improving services related to the Platform; and
(c) complying with our legal obligations.
If you believe that we have not complied with our obligations relating to your personal information, or if you would like access to your personal information, please contact our Executive Officer as follows:
By phone:
(03) 8327 2222 between 9am and 5pm (AEST) Monday to Friday.
By mail:
Executive Officer
Wombat Housing Support Services Incorporated
PO Box 1183
Kensington
3031
By email:
rebecca@wombat.org.au
We will investigate your complaint or request and respond within 30 days with a proposed resolution.
If you feel we have not properly dealt with a complaint, you may contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or on 1300 363 992.
If European Union data protection law applies to the processing of your information, you can lodge a complaint with your relevant supervisory authority (a list is available at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).
We may review and amend this Privacy Policy from time to time to address changes to laws and to reflect our current operations and practices.
You can obtain a copy of the current version on request.
Last updated: [10/09/2020]
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