Information regarding our stance on Privacy
The VHIA has a Privacy Policy which sets out how we manage privacy in our organization.
Purpose of the Policy
VHIA takes its obligations under the Privacy Act seriously and has taken all reasonable steps in order to comply with the Act and protect the privacy of any personal information that we hold. This policy sets out how we do this.
Privacy and confidentiality
As a business organisation we appreciate the importance of confidentiality. Our privacy policy deals with any additional right to privacy and is independent of any contractual and ethical obligations.
VHIA may collect, use, and hold the following personal information:
· Your name
· Business Address
· E Mail Address
· Telephone / Fax Numbers
· Occupation
· Career history
· Career plans
· References
· Results of aptitude and other tests
· Other information which may be collected when you seek our assistance, visit our website to read or download information, which may include the nature of your enquiry, your server address, domain name, the date and time of your call/visit to our site, the pages viewed and the information provided or downloaded.
VHIA collects, uses and discloses the information in accordance with this policy.
Access to your personal information
VHIA, in the appropriate circumstances (ie for research, statistical analyses), will provide access to the personal information that we hold about you. Access will be provided in accordance with our Policy. If you require access to your personal information please contact Tanjil Wright, Privacy Officer at tanjilw@vhia.com.au
If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed please contact Tanjil Wright at VHIA.
Storage
We will take all reasonable steps to protect the security of the organizational and personal information that we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.
Collection Statement
VHIA will not collect personal information unless the information is necessary to enable us to undertake our activities. We will advise you when we are collecting personal information from you, for what purpose we are collecting it, and how we will use it
Personal information may be collected by staff of VHIA in the context of recruitment, provision of services, payment for services, organisation of conferences and other functions, employment placements, surveys and visits to the VHIA website.
Type of personal information collected
In most cases this will include contact details and information which may be collected when you telephone VHIA Officers or visit our website to read or download information, which may include your server address, domain name, the date and time of your telephone call or visit to our site, the pages viewed and the information provided or downloaded.
Use and disclosure
Personal information is collected for the purpose of:
· employment placements
· monitoring the services provided to VHIA members
· monitoring use of our website
· processing payments
· promoting VHIA training, conferences, and other functions
· recruitment
· selling you any products and services
VHIA will only usually disclose this information to:
· our accountants and auditors. We take measures to protect the information by contract obligations and arrangements
· our IT managers. We take measures to protect the information by contract obligations and arrangements
· our legal representatives
Legal reasons why we collect the personal information
We may collect information in order to comply with our legal obligations.
What happens if you choose not to provide the information
You are not obliged to give us your personal information. However, if you choose not to provide VHIA with personal details we may not be able to provide you with the service/ sell the product/process your payment in a particular way or process your application for employment.
Access
In the appropriate circumstances, you can gain access to the personal information that VHIA holds about you. If you wish to do so please refer to our Access Policy or contact our Privacy Officer.
Sources of information
Where possible, the VHIA will collect the information directly from you, particularly for an application for employment. However, in some cases we may receive personal information from referees or people that have worked with or are working with you. For example, a colleague may express to us that you could have potential in a position that we are recruiting for. If the personal information was collected not from the customer or candidate but from another party, VHIA will take reasonable steps to inform that individual of the Collection and provide the above Collection Statement.
Access Policy
This policy is directed to those individuals whose organizational or personal information is held by VHIA.
Purpose
The purpose of this Policy is to set out how VHIA will provide access to your information. The Policy is part of our Privacy Policy and our desire to provide for, maintain and give effect to our privacy obligations.
Overriding principles
At all times the conduct under this Policy will be governed by the following principles:
· All requests for access will be treated seriously
· All requests will be dealt with promptly
· All requests will be dealt with in a confidential manner
· Your request to access your organizational or personal information will not effect your existing obligations or effect the commercial arrangements between you and VHIA.
Form of Access
VHIA will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that VHIA holds about you. You can make your request in writing by contacting the Privacy Officer, VHIA.
To obtain access you will have to provide proof of your identity. This is necessary to ensure that information is provided only to the correct individuals and that the privacy of others is not undermined.
When will Access be denied?
Access will be denied if:
· the request does not relate to the organisational or personal information of the person making the request;
· providing access would create an unreasonable impact on the privacy of others;
· the request is frivolous and vexatious;
· the request relates to existing or anticipated legal proceedings
· providing access would prejudice negotiations with the individual making the request;
· access would be unlawful;
· denial of access is authorised or required by law;
· access would prejudice law enforcement activities;
· access discloses a commercially sensitive decision making process or information;
· providing access would pose a serious and imminent threat to life or health of a person; or
· any other reason that is provided for in the National Privacy Principles (NPPs) set-out under the Privacy Act.
Where possible, VHIA will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate intermediary.
Where there is a dispute about the right or forms of access these will be dealt with in accordance with VHIA’s Grievance Policy.
Time
We will take all reasonable steps to provide access within a reasonable time of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will provide information more quickly.
Costs and charges
VHIA may impose the following charges inclusive of GST:
· Photocopying $2 per page
· Delivery cost of information stored off-site - where information if stored off-site, the cost of obtaining access to the information - $30 per hour
· Access to electronic databases $30 per hour
· Postage Costs
Privacy Complaints: How we handle privacy complaints
VHIA sees the importance of privacy to the organisation, its customers and other stakeholders. As such VHIA is committed to protecting the privacy of the personal information that we hold. This is part of our organisation’s:
(a) Legal obligations under the Privacy Act 1988
(b) Ethical and business obligations
(c) Service to you
VHIA places high priority on effectively dealing with any complaints about privacy that you may have.
Overriding principles
At all times the conduct under this policy will be governed by the following principles:
(a) All complaints will be treated seriously
(b) All complaints will be dealt with promptly
(c) All complaints will be dealt with in a confidential manner
(d) Any privacy complaint will not effect your existing obligations or the commercial arrangements that exist between this organisation and you.
Who may complain under this policy?
If you have provided us with personal information you may make a complaint, have it investigated and dealt with under this policy.
What is a privacy complaint?
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
(a) How information is collected
(b) How information is stored
(c) How this information is used or disclosed
(d) How access is provided
(e) How accurate the information is that we hold.
What do I do if I have a complaint about privacy practices?
VHIA resolves grievances at the local level if possible. If you have a complaint about privacy please contact the Privacy Officer. All complaints will be logged on a database/complaints register. You may complain orally or in writing to the:Privacy Officer, VHIA.
Usually your contact with VHIA will be the appropriate person to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter will then be referred to the Privacy Officer, and then if necessary, the CEO.
Grievance procedure
The goal of this policy is to achieve an effective resolution of your complaint within a reasonable timeframe. Once the complaint has been made, the point of contact can then resolve the matter in a number of ways:
| 1. |
Request further information and investigation: Your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential. A complaint will be investigated. VHIA will try to do so as soon as possible. It may be necessary to contact others in order to proceed with the investigation. |
| 2. |
Discuss options: We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way. |
| 3. |
Refer to CEO: If your complaint is not resolved at the local level or with the Privacy Officer, it will be referred to the CEO. The CEO would be provided with the history and may discuss the complaint with the employees, or other parties that are involved. |
| 4. |
Resolution: You will be informed of the outcome and the reasons for the decision. If this does not resolve the complaint, the matter will be referred to a mutually agreed intermediary. |
| 5. |
If after the above steps have been followed you are still dissatisfied with the outcome you may refer the complaint to the Office of the Federal Privacy Commissioner. |
If after the above steps have been followed you are still dissatisfied with the outcome you may refer the complaint to the Office of the Federal Privacy Commissioner.
Records
VHIA will keep a record of your complaint and the outcome.
Anonymous complaints
VHIA is unable to deal with anonymous complaints as we are unable to investigate properly and follow-up such complaints. However, in the event that an anonymous complaint is received by VHIA, we will note the issues raised and try to resolve them appropriately.
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