Name of Policy: Privacy Policy
Approval Authority: AusUnity Aid Committee of Management
Date effective: January 2025
Due to be reviewed: January 2027
Accountable Officer: President
Responsible Officer: Secretary
Policy applies to: AusUnity Aid Incorporated (ABN 26 106 679 210)

1. Purpose

1.1 The purpose of this policy is to outline how AusUnity Aid Incorporated ("AusUnity Aid", "we", "us", "our") collects, holds, uses and discloses personal information, and how we protect the privacy of individuals whose personal information we handle.

2. Scope

2.1 This policy applies to everyone who is part of AusUnity Aid, including our Committee members, staff, volunteers and contractors (collectively "Our People").

2.2 This policy applies to Our People whenever they are conducting AusUnity Aid business or activities.

2.3 This policy covers information and records relating to all individuals with whom AusUnity Aid interacts, including:

  • clients and residents receiving case management, accommodation or other support services;

  • Centrelink customers whose payments are processed through Centrepay;

  • donors, supporters and funders;

  • volunteers and students undertaking placements with us;

  • members of the Association; and

  • individuals who access, use or interact with our website or social media.

2.4 This policy does not apply to employee or employment records. The handling of employee records by AusUnity Aid, where directly related to a current or former employment relationship, is exempt from the Privacy Act 1988 (Cth). Nonetheless, AusUnity Aid will take reasonable care to keep employee personal information secure and handled in a manner consistent with the general principles in this policy.

3. Policy

Core Principles

3.1 AusUnity Aid is committed to meeting its legal responsibilities in relation to the collection, use, management and disclosure of personal information, and to keeping clients, staff, volunteers and other stakeholders informed about their privacy rights.

3.2 AusUnity Aid complies with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) in the handling of all personal information.

3.3 Clear and accessible information is available to everyone who interacts with AusUnity Aid about:

  • how we collect personal information;

  • how we obtain and record consent to the collection and use of personal information;

  • how we use personal information;

  • how we record and store personal information;

  • how, to whom, and in what circumstances we will disclose personal information, including when we can or must disclose it without consent;

  • the rights of individuals to access and correct information we hold about them;

  • how long we retain personal information; and

  • how we securely destroy information that is no longer required.

3.4 AusUnity Aid will take reasonable steps to protect the personal information it collects and stores from misuse, interference, loss, and unauthorised access, modification or disclosure.

Open and Transparent Management of Information and Consent

3.5 Individuals interacting with AusUnity Aid will be informed of their privacy rights, and of the extent and limitations of their consent, where it is safe, reasonable and appropriate to do so.

3.6 Where an individual wishes to remain anonymous or use a pseudonym, they may do so, but we will explain that this may limit our ability to provide some services, including Centrepay-related arrangements which require identifying information.

3.7 For consent to remain valid, AusUnity Aid will ensure that:

  • consent is reviewed regularly with clients while they remain engaged with our services;

  • the individual is adequately informed before giving consent;

  • consent is given voluntarily;

  • consent is current and specific; and

  • the individual has the capacity to understand and communicate their consent.

Collection of Personal Information

3.8 AusUnity Aid will only collect personal information for purposes directly related to our functions and activities, and we will be able to explain why any information is collected and how it will be used.

3.9 The primary purposes for which AusUnity Aid collects personal information are to:

  • provide, administer and improve our case management, accommodation and community support services;

  • assess applications for support, accommodation or assistance;

  • establish and administer Centrepay deduction arrangements on behalf of clients;

  • engage with donors, funders and supporters;

  • assess membership, volunteering and student placement applications;

  • supervise Work and Development Permit (WDP) activities as an accredited WDP sponsor;

  • meet our contractual, funding and regulatory obligations, including reporting to the ACNC, Services Australia and other relevant bodies; and

  • respond to queries, feedback and complaints.

3.10 AusUnity Aid may collect information about individuals who access or interact with our website or online services using standard technical tools, such as cookies or analytics software. Website users may decline the use of these tools through their own browser settings.

3.11 In most cases, AusUnity Aid will collect personal information directly from the individual it relates to.

3.12 We may collect information from a third party or a publicly available source only where the individual has consented to this, or would reasonably expect us to collect information this way (for example, from a referring agency or support worker).

3.13 Where we collect information from a source other than the individual, we will take reasonable steps to notify them that the collection has occurred and seek their consent to retain it.

3.14 AusUnity Aid will only collect sensitive information (such as health information) directly from an individual or their authorised representative.

Use and Disclosure of Personal Information

3.15 AusUnity Aid will only disclose personal information for a lawful and necessary purpose, and will disclose only the minimum amount of information required to achieve that purpose.

3.16 AusUnity Aid may use and disclose personal information to:

  • provide, administer and improve our services;

  • identify and support individuals who may need referral to other services;

  • administer Centrepay deduction authorities and reconciliation with Services Australia;

  • verify identity for system access and account management purposes;

  • comply with lawful requests from police, courts, government agencies or lawyers in connection with suspected fraud, misconduct or unlawful activity; and

  • meet our funding, contractual and regulatory obligations, including to the ACNC, Fines Victoria and the Registrar of Housing Agencies.

3.17 AusUnity Aid may use personal information to provide updates or communications to donors and supporters. All individuals may opt out of these communications at any time, and this will be respected.

Security of Personal Information

3.18 AusUnity Aid stores and manages personal information in accordance with the Australian Privacy Principles, and takes reasonable steps to maintain safe systems, processes and staff/volunteer training to protect personal information.

3.19 Personal information is stored in a manner that allows it to remain accessible and readable for as long as it is required to be retained.

3.20 Access to client records and personal information is limited to Committee members, staff and volunteers who require it to perform their role.

3.21 AusUnity Aid will not input personal information into any open-access or unsecured artificial intelligence tool, and will take reasonable steps to prevent personal information being included in any dataset or otherwise placed at risk of inadvertent disclosure.

3.22 If a data breach involving personal information occurs, AusUnity Aid will take prompt steps to contain, assess and remediate the breach, and will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) where required under the Notifiable Data Breaches scheme.

Disposal of Personal Information

3.23 Personal information will be retained only for as long as necessary to fulfil the purpose for which it was collected, or as required by law (including under the Associations Incorporation Reform Act 2012, which requires certain financial records to be kept for at least 7 years).

3.24 Where an individual sends AusUnity Aid unsolicited personal information that we would not otherwise have been entitled to collect, and that we have no purpose for, we will destroy or de-identify it as soon as reasonably possible.

3.25 When personal information is no longer required, AusUnity Aid will ensure it is destroyed or de-identified securely, completely, and in a manner that is recorded.

Access to Personal Information and Right to Correction

3.26 Individuals are entitled to confirm whether AusUnity Aid holds personal information about them, and to request access to that information.

3.27 Requests for access will be responded to within 30 days, unless a lawful exception applies, for example where giving access would pose a serious threat to health or safety, would be unlawful, or would unreasonably impact the privacy of another individual.

3.28 Personal information can be corrected if it is inaccurate, out of date, incomplete, irrelevant or misleading. Where AusUnity Aid identifies information meeting this description, we will take reasonable steps to correct it. Individuals may also request a correction at any time.

4. Complaints About Privacy

4.1 An individual who believes AusUnity Aid has breached their privacy, or who has a concern about how their personal information has been handled, may make a complaint in accordance with our Complaints Handling and Resolution Policy.

4.2 If a complainant is not satisfied with our response, they may refer the matter to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

5. Definitions

Personal Information
Any information or opinion about an identified individual, or an individual who can reasonably be identified from the information or opinion. This may include a person's name, address, phone number, email address, date of birth, signature, banking details, or Centrelink Customer Reference Number (CRN). It includes health information and sensitive information.

Sensitive Information
Personal information including information or opinion about an individual's health, disability, race, genetics, political opinion, religion, philosophical beliefs, trade union membership, sexual orientation, or criminal record.

Data Breach
An event where personal information is lost, or subjected to unauthorised access, modification, use or disclosure, or other misuse — whether through a malicious act such as hacking, or through internal error.

Unsolicited Personal Information
Personal information that AusUnity Aid receives without taking any active step to collect it — for example, misdirected mail, or information volunteered beyond what was requested on an application form.

6. Related Documents

  • Complaints Handling and Resolution Policy

  • AusUnity Aid Constitution

  • Centrepay Complaints and Deduction Authority procedures

7. Legislative and Regulatory Framework

This policy supports AusUnity Aid's compliance with:

  • Privacy Act 1988 (Cth)

  • Australian Privacy Principles (Schedule 1 to the Privacy Act 1988 (Cth))

  • Spam Act 2003 (Cth)

  • Privacy and Data Protection Act 2014 (Vic)

  • Health Records Act 2001 (Vic)

  • Associations Incorporation Reform Act 2012 (Vic)

8. Policy Review

This policy will be reviewed at least every two years, or earlier if required by changes to relevant legislation or AusUnity Aid's operations, including its obligations under the Centrepay Policy for Businesses and Centrepay Terms of Use.

Privacy Policy