Privacy and Confidentiality Policy

Purpose

Sakura Education Foundation (SEF) respects your right to privacy and is committed to safeguarding the privacy of all personal information we collect, hold and administer of our clients and website visitors. SEF is committed to providing quality services and this policy outlines our ongoing obligations in respect of how we manage your personal information, including sensitive health information.

In accordance with the Australian Privacy Principles 2014 (APP’s) contained in the Privacy Act 1988, the management of personal information is important. The APP’s govern the way in which we collect, use, disclose, store, secure and dispose of your personal information. A copy of the APP’s may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/australian-privacy-principles

This policy reflects these principles as they apply to our services. SEF provides a range of services to children, young people and their families.

Our practices are consistent with legislation and principles relating to privacy and personal information.

Scope

This policy applies to board members, executive leadership, employees, volunteers, students and contractors for all activities in the organisation which involve the collection, usage, storage, accessibility and any concerns relating to personal information.

Responsibilities

Board members, executive and non-executive leaders will ensure that:

  • All employees, volunteers, students and contractors understand, are aware and committed to their obligations, responsibilities and rights in relation to privacy
  • Any matter which does not comply with this policy is identified and addressed as promptly and sensitively as possible
  • Ongoing support and direction is provided to all paid and unpaid staff in relation to the privacy principles and practice
  • All employees, volunteers, students and contractors are aware of the SEF Privacy and Confidentiality Policy and the APP’s

It is the responsibility of all employees, volunteers, students and contractors to ensure they treat all personal and health information confidentially and follow the principles outlined in the SEF Privacy and Confidentiality Policy.

Definitions

Child/children: a person under 18 years of age.

Health Information:

  • Information or an opinion that is also personal information about:
    • The health/disability of an individual; or
    • An individual’s expressed wishes about the future provision of health services to him or her; or
    • A health service provided to an individual;
  • Other personal information collected to provide, or in the delivery of, a health

Personal information: is information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from that information or opinion. Examples of personal information we collect includes: names, addresses, email addresses and phone.

Sensitive information: a sub-set of personal information including:

  • Information or an opinion about an individual’s:
    • Racial or ethnic origin;
    • Political opinions or membership of a political organisation, membership of a professional or trade association or a trade union;
    • Religious beliefs or affiliations, philosophical beliefs;
    • Sexual orientation or practices; and
    • Criminal record
  • Health information about an individual
  • Genetic information or biometric information that is to be used for the purposes of automated biometric verification or biometric identification.

Policy

SEF will use all reasonable efforts to protect the privacy of individuals’ information and to comply with relevant regulations, standards and guidelines that describe and govern how personal information is managed. SEF will only collect personal information by lawful and fair means, and that which is necessary to support service delivery. We acknowledge that children, Aboriginal and Torres Strait Islander people, people with disability or people from diverse cultural backgrounds, may require special consideration.

Collection of Personal, Sensitive or Health Information

SEF will only collect personal, sensitive or health related information that is necessary for us to provide the services requested. SEF will collect your personal, health and/or sensitive information by fair, lawful and non-intrusive ways including completion of forms, interviews, case notes, clinical assessments, referrals, by telephone and facsimile, by email, through our website and from third parties. We don’t guarantee website links or policies of authorised third parties. We may also collect any other information you provide whilst interacting with us.

We collect your personal, sensitive or health related information for the primary purpose of providing our services to you, to provide you with information, updates and our services. We may also use your personal, sensitive or health related information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. A related secondary purpose may include evaluation, complaint handling, planning and accreditation activities.

We may use your personal information to improve our products and services, and better understand your needs.

We may contact you by a variety of modes, including but not limited to telephone calls, SMS, email or mail. You may opt out of our mailing/marketing lists at any time by contacting us in writing.

When we collect personal, sensitive or health related information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Disclosure of Information

SEF may not use or disclose personal information for a purpose other than the primary purpose of collection unless:

  • The individual has consented;
  • A closely related secondary purpose
  • We believe on reasonable grounds that the disclosure is necessary to prevent an imminent risk or threat to a person’s health or life, or a serious threat to public health or safety
  • Where required or authorised by

Security of Information

Your personal, sensitive or health related information is stored in a secure manner and we will take all reasonable steps to ensure personal, sensitive or health related information is protected from misuse, loss, unauthorised access, modification or disclosure. When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information.

Records will be kept and archived in accordance with legislation and SEF’s Records Management Policy and Procedures.

Access to your Information

A person may request details of personal information we hold about them in accordance with the provisions of the Privacy Act 1988 (Cth). If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at privacy@sakuraedfoundation.org.au

After determining the right to information, SEF can provide access to personal information. All information will de-identify staff or other persons referred to in the information. An administrative fee may be payable for the provision of information.

SEF reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. These include a serious threat to the life or health of a person, the request is frivolous or vexatious, others privacy may be affected, the information relates to existing or anticipated legal proceedings or access would be unlawful. This decision to refuse to provide information will be made in writing.

If we refuse to modify or update information, the person may make a request that we make a note on the person’s record that they are of the opinion the information is inaccurate, incomplete or misleading, whatever the case may be.

Maintaining the Quality of Information

SEF will take reasonable steps to ensure that personal information is accurate, complete and up-to-date. If a person believes the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records.

Privacy Policy Complaints and Enquiries

SEF takes complaints and concerns regarding privacy seriously. If you have any queries or complaints about our Privacy Policy please contact us at privacy@sakuraedfoundation.org.au We will then attempt to resolve any concerns in accordance with our Complaints and Feedback Policy.