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privacy
policy

Brite Services and Victorian Vocational Rehabilitation Association Privacy Policy

1. Introduction

Brite Services and Victorian Vocational Rehabilitation Association(“we” or “us”) value your privacy. We take reasonable steps to protect your personal information. We abide by the requirements of the Privacy Act 1988 (Cth) (“Act”) in relation to the collection, use and disclosure of your personal information and comply with other applicable laws protecting privacy including State and Territory health information legislation.

By accessing our website, engaging our services or providing personal information to us, you consent to our collection,
use and disclosure of that information on the terms of this privacy policy (Privacy Policy) and any other contractual or
other arrangements (if any) that may apply between us.

2. Scope of this Privacy Policy

This Privacy Policy describes how your privacy is respected and protected in accordance with the Australian Privacy
Principles. It applies to all information we collect about you through the use of our services. This includes personal
information collected in person, in forms completed by you or on your behalf, by telephone, through our website, via
other service providers and by other electronic communication channels (e.g. desktop, laptop, mobile phone or other consumer electronic device) to access our services.

3. Agreeing to these terms (use constitutes acceptance)

Your continued use of our website and/or our service indicates that you accept the conditions of this Privacy Policy, consent to the collection and use by us of any personal information you provide while using our services or our website site.

4. What is personal information?

Personal information is any information that can be used to identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

5. Why do we collect personal information?

We collect personal information that is necessary for us to undertake and provide our services and activities. Due to
the nature of our services, this may include sensitive information, including health information.

We also collect personal information so that we can improve and perform our business activities and functions, to
provide you with any products or services you may request, or to respond to any query or complaint that you may have.

6. When do we collect personal information?

Examples of personal information we may collect, and when we may collect it, include (but is not limited to) the following:

  • Providing services to clients – we collect our clients’, and their family members’ personal information, such as
  • names, addresses and other contact details. Information which we may collect from clients includes date of birth,
  • other information about our clients’ needs and circumstances (such as living arrangements), records of
  • communication and as otherwise required in order to provide our services. This information may include health
  • information about them. The specific information will depend on the type of service provided and will be collected
  • from the client before and during the provision of services.
  • Distributing publications and direct marketing – if we have met you or provided services to you we may collect and
  • store your personal information on our publication or direct marketing list (which may include name, address, email
  • address, and mobile phone number) in order to distribute newsletters and other communications in print and
  • electronic form from time to time. We will only use sensitive information (such as health information) for direct
  • marketing purposes with your express prior consent. You may opt-out of receiving direct marketing by contacting our
  • Privacy Officer (contact details below), or opting out by the mechanism provided.
  • Assisting with your queries – you may choose to provide us with your name or other contact details when you call us
  • by phone or write to us so that we can respond to your requests for information about our services or operations. If you choose to remain anonymous we may not be able to provide the full range, or any, services to you.
  • Conducting our general business activities – we collect personal information about individuals for our general
  • business operations. From time to time, we may collect, use and disclose your personal information for quality
  • assurance, risk management, billing and administrative purposes.
  • Research – If you agree to be contacted about research opportunities for which you may be eligible, we may place
  • your name and contact details onto our internal research database. You may opt-out of participation in research
  • activities at any time by contacting our Privacy Officer (contact details below).
  • Sensitive Information – we may collect sensitive information if it is relevant to the provision of our services. That
  • information will be treated in accordance with requirements of the Privacy Act and any state and territory health
  • information legislation.

7. How do we collect your personal information?

It is our usual practice to collect personal information directly from you or your authorised representative such as a
carer, guardian or other responsible person. We collect information from an authorised representative if you have
consented for us to collect the information in this way, or where it is not reasonable or practical for us to collect this
information directly from the client (such as in an emergency, because the client is not able to provide the information required or where collection in this way is a lawful, reasonable and efficient way to collect the information without inconvenience to the client).

If you choose not to provide certain personal information to us, we may not be able to provide you with the services you
require or communicate with you.

In addition to the means of collection set out above, we may also collect personal information:

  • when you provide information through our website;
  • from third parties such as from credit reporting bodies;
  • from any of our related companies;
  • from publicly available sources of information;
  • from third parties, where it is reasonably necessary or normal business practice, so that we can continue to provide
  • you with our services.

We also collect limited information about all visitors to our online resources which is used only to identify generic
behavioural patterns. We may use cookies, Google Analytics or other technology to track visits to our website to
monitor its effectiveness, maintain our server and improve our services. Types of data collected include:

  • server address;
  • top level domain name (for example .com, .gov, .au, etc.);
  • the date and time of your visit to the site;
  • the pages you accessed and documents downloaded during your visit;
  • the previous site you visited;
  • if you’ve visited our site before; and
  • the type of browser used.

These statistics will not identify you as an individual.

8. How do we use your personal information?

We use and disclose personal information we collect:

  • to provide and improve our services to our clients and their family members, including to:
    • identify and provide services required including those offered by third parties;
    • allow exchange of information between service providers with whom we deal with on behalf of clients;
    • assess the adequacy of, and our clients’ and their family members’ level of satisfaction with, our services;
  • to verify your identity;
  • to communicate with our clients and their family members and distributing our publications, conducting events and raising awareness about our services;
  • to undertake our general business activities, including interacting with contractors and service providers, billing and administration;
  • to administer and manage our services including charging and billing you for those products (as applicable);
  • to conduct appropriate checks for fraud;
  • to update our records and keep your contact details up to date;
  • maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
    and/or
  • for other purposes with your consent or as permitted by law.

9. When will we disclose your personal information?

We will not share any of your personal information with third parties without your consent except:

  • if we are required by law or we believe in good faith that such action is necessary in order to comply with law,
  • cooperate with law enforcement or other government agencies, or comply with a legal process served on the company (including other service providers or insurers) or court order;
  • if the disclosure of the information will prevent or lessen a serious and imminent threat to somebody’s life or health;
  • to our contractors, service providers and volunteers only to the extent necessary for them to perform their duties to
  • us; or
  • to our related companies;
  • to our professional advisers, including our accountants, auditors and lawyers;
  • to any governmental or semi governmental organisation who requests it (including but not limited to as part of any
  • application for a grant or other benefit under the NDIS);
  • if you are a client, to your family members or your health or other service providers if required for us, or other service
  • providers, to provide services to you;
  • if you are not able to provide us with consent, we may use and disclose your personal information with the consent of
  • a responsible person (as defined under the Privacy Act)
  • as otherwise permitted by law.

If we retain any sensitive information, that information will not be used, shared or disclosed without your express or
implied consent that is current, voluntarily given and obtained in accordance with the Privacy Principles. If you are
unable to give consent then we may use and disclose your personal and sensitive information with the consent of a
responsible person (as defined under the Privacy Act)

10. Security of your personal information

We regard the security of your personal information as a priority and implement a number of reasonable physical and
electronic measures to protect it. Staff and volunteers who may have access to your information may be required to
sign a confidentiality agreement and if contract service providers are used, they will be bound by our Privacy Policy.

We remind you, however, that the internet is not a secure environment and although all care is taken, we cannot
guarantee the security of information you provide to us via electronic means.

11. Data quality

We take all reasonable steps to ensure that the personal information we collect is accurate, up to date and complete.
This includes maintaining and updating personal information when we are advised it has changed and at other times as necessary.

12. Cross border data transfer

We operate only within Australia and will not provide your information to parties in any other country. We do from time
to time, however, use web-based programs for particular activities such as email broadcast which may be hosted
offshore, or cloud service providers but only when the supplier agrees with us to be bound by privacy laws or where the jurisdiction in which the data is located has laws that are equal to or better than Australian privacy laws.

13. What if there is a data breach?

We take all reasonable steps to prevent data breaches. However, if we suspect that a data breach has occurred, we will undertake a reasonable and expeditious assessment to determine if the data breach is likely to result in serious harm
to any individual affected. If so, we will:

  • take all reasonable steps to contain the breach;
  • where possible, taking action to remediate any risk of harm;
  • notify individuals and the Commissioner where an individual is likely to suffer serious harm (or if otherwise required
  • by law); and
  • review the incident and consider what actions can be taken to prevent future breaches.

Further, Brite is committed to protecting the privacy of personal, health and sensitive information about our employees with disability. If a breach of privacy occurs in relation to any of this data, Brite will immediately notify the Department of Health and Human Services (DHHS) when becoming aware of a breach, or possible breach under the Privacy and Data Protection Act 2014 or the Health Records Act 2001. The purpose of this is to ensure timely and effective
management of privacy incidents, and to learn from incidents to improve how client information is handled.

14. Accessing and correcting your information

You are entitled to view the information we hold about you and reasonable requests for access and correction will be
responded to as quickly as possible. Access to a large amount of information or information from various sources
within the organisation may take time before we can respond. If you wish to view the information we hold about you, please contact the Privacy Officer using the contact detailed set out below. If we refuse to give you access to your
personal information or to correct your personal information, we will give a reason for this decision. Generally, if requested, we will amend any personal information which you demonstrate is inaccurate, incomplete or not current,
and will remove any information that is not relevant. If we disagree with your view on these matters we will keep a note
on the file setting out your view of the information held.

15. On-line transactions

Our website may be enabled for online transactions using a certified secure payment gateway. However, despite the
security on the site, you should be aware that there are inherent risks in transferring information across the internet
and we cannot accept liability for any breaches. When an internet payment is made, your credit card number is used
only to make a debit and not retained by us.

16. Security measures for online payments (if relevant)

Payments made online on our website are processed in real time using a secure payment gateway. Payments are
processed in Australia (and for all other countries) in Australian Dollars. Our website has security measures designed to protect against the loss, misuse and/or alteration to your personal information under our control.

17. Links to other websites

Our websites may contain links to third party websites, and third party websites may also have links to our websites.
We do not endorse any of those Websites or links. This Privacy Policy does not apply to external links or other websites who may also collect your personal information. We encourage you to read the privacy policies of any website you link to from our website.

18. Effective date and updates

This is our current Privacy Policy. We may at any time vary this Privacy Policy by publishing an updated version on our
website. You accept that by using the website or continuing to use our services, provided you with sufficient notice of
the variation.

19. Changes to this Privacy Policy

We reserve the right, as it may be necessary, to review, revise or make changes to our Privacy Policy and will notify you
of those changes by posting those changes on our web site.

20. Complaints

If you wish to make a complaint about a possible breach of privacy, please provide full details of your complaint in
writing.

If your complaint relates to our failure to provide access to or to correct any personal information that we hold about
you, you may lodge a complaint directly with the Office of the Australian Information Commissioner (for more
information, please see www.oaic.gov.au).

If your complaint does not relate to these matters, you must first lodge a complaint with us in writing and provide us
with details of the incident so that we can investigate. We will treat your complaint confidentially, investigate your
complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any
event within the time required by the relevant privacy legislation, if applicable).

Individuals enquiring about their rights and remedies for breaches of privacy, can access detailed information at the
Office of the Australian Information Commissioner www.oaic.gov.au

21. More Information

If you would like more information about our Privacy Policy or the way we manage your personal information, you can
contact the Privacy Officer by:

[email protected]au
03 9301 7300
1-7 Belfast Street, Broadmeadows, VIC 3047

Alternatively, additional information on the Australian Privacy Principles can be obtained from
http://www.oaic.gov.au/

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