Privacy Policy

The Compass Institute Inc (hereinafter referred to as “Compass”) respects the privacy of all Compass people including members, employees, volunteers, trainees, families, donors, business partners and online users and is committed to safeguarding the personal information that is
provided to us.

Purpose

The purpose of this privacy policy is to:

clearly communicate the personal information handling practices of Compass
enhance the transparency of Compass operations and
give individuals a better and more complete understanding of the sort of personal information that Compass holds and the way we handle that information.

Scope

This policy and procedure applies to all Compass members, volunteers, employees, trainees, donors, business partners and online users.
payment for services received)

The Privacy Act and this Privacy Policy do not apply to acts or practices which directly relate to employee records of Compass current and former employees.

Compass also holds a separate internal Confidentiality and Privacy Policy in its Policies and Procedures Manual regarding Compass’ practices around information of a sensitive nature relating to staff and trainees.

Definitions

Online users refers to anyone that accesses the Compass website www.compassinc.org.au

Personal information as defined by the Privacy Act 1988 (as amended) is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not.

Sensitive information as defined by the Privacy Act 1988 (as amended) is information or opinion (that is also personal information) about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record or health, genetic, biometric information or biometric templates, that is also personal information.

The website means the Compass website www.compassinc.org.au

Trainee/s refers to the clients/beneficiaries/people with a disability who receive a service from Compass

Overview of Compass Programs and Services

Compass is a Sunshine Coast based charity dedicated to providing real futures for young Queenslanders with a disability.

Compass provides services in the form of education and enrichment, lifestyle services, training and vocations to individuals with a disability in the community.

In carrying out this mission Compass engages volunteers and employees and receives donations, funding and support from members of the community, corporations, groups and governments.

Our Personal Information Handling Practices
Our obligations under the Privacy Act

This privacy policy sets out how we comply with our obligations under the Privacy Act 1988 (Privacy Act). We are bound by the Australian Privacy Principles (APPs) in the Privacy Act which regulate how organisations may collect, use, disclose and store personal information and how individuals may access and correct personal information held about them.

Collection of Personal and Sensitive Information

If you would like to access any Compass Services on an anonymous basis or using a pseudonym, please tell us. If this is possible and lawful, we will take all reasonable steps to comply with your request. However, we may not be able to provide the services in question if we are not provided with the personal information requested.

The nature and extent of personal and sensitive information collected by Compass varies depending on your particular interaction with Compass.

Compass collects personal and sensitive information from trainees, donors, business partners, Compass people (See pg. 4 for definition) and online users. Further information about the kind of information collected from each of these groups and the usage of such information is detailed below.

Compass Trainees (Clients/Beneficiaries/People with a disability)

Kind of information collected:

Contact details including: name, address, phone number, email etc.
Personal details including: date of birth, gender, etc.
Contact and personal details of emergency contact person(s)
Information on personal/behavioral issues and experiences
Country of birth, citizenship, residency and/or visa details
Family background and family information (including contact details, personal details etc.)
Supports clients may have in the community and other services accessed
Areas of interest, goals and family’s aspirations
Health information, disability related information and/or medical history
Abilities and support requirements
Emergency contact details
Funding details
Any other information considered reasonable to provide a service

How the information is collected:

Application for Service, Individual Support Plan, Progress Plan, Progress Notes and other information forms
Online applications and Expressions of Interest
Questionnaires and surveys
Telephone
Emails
Meetings and Progress Plans
Trial days
Communication book
Daily interaction
Interviews
Online registration

Purpose for which Compass uses the information:

To provide Compass services
To provide accurate feedback, reviews and reports to families
To provide Trainees with the most appropriate services for their needs
To meet any requirements of government funding for programs or any other government requirements
To monitor and evaluate existing services and plan for future services
To produce annual or other reports and for research purposes which may involve contracted organisations
To comply with legal obligations

Compass Donors

Kind of information collected:

Contact details including: name, address, phone number, email etc.
Personal details including: date of birth, gender etc.
Employment details (where the person works and position)
Areas of interest
Donation history
Any other information considered reasonable

How the information is collected:

Communications, email, flyers
Forms
Online registration
Meetings
Interviews
Telephone
Daily interaction

Purpose for which Compass uses the information:

To provide Compass services
To process donations and provide accurate receipts
To facilitate on-going fundraising and marketing activities
To comply with legal obligations
To thank donors for their support
To provide transparency relating to donated funds, particularly for appeals for public donation

Compass Business Partners

Type of information collected:

Contact details including: name, address, phone number, email etc.
Personal details including: date of birth, gender etc.
Business details: the name of the organisation which employs the person and position title
Areas of interest
Bank details (if Compass is to receive payment or make payment for services received)
Australian Business Number (ABN)
Type of support (e.g. workplace giving, goods in kind, program support, volunteering)

How the information is collected:

Communications, email, flyers
Forms
Online registration
Meetings
Interviews
Telephone
Daily interaction

Purpose for which Compass uses the information:

To provide Compass services
To process donations and provide accurate receipts
To pay for services
To establish and manage partnerships
To receive services from you or the organisation which employs you
To manage Compass’ relationship with partners
To provide information about Compass’ services
To thank partners for their support
To update the organisation on Compass appeals for support, donations, programs and services

Compass People (volunteers, employees, delegates, student placements) and candidates for volunteer work and prospective employees

Type of information collected:

Contact details including: name, address, phone number, email etc.
Personal details including: date of birth, gender, etc.
Personal details of emergency contact person(s)
Country of birth, citizenship, residency and/or visa details
Details of current/previous employment or volunteer involvement
Skills and experience
Information about a person’s personality and traits
Languages spoken and written
Qualifications, driver’s license details and other identifying information
Information and opinions from referees for prospective employees and candidates for volunteer work
Personality preference details
A Police Check may be required for some roles in Compass (particularly those that work with people with a disability). Individuals in those roles will be required to provide certain information for a Police Check.
In some situations it is necessary for Compass to collect or receive information about an individual’s health. In this circumstance, Compass will advise why the information is being collected and whether and to whom it will be released.

How the information is collected:

Induction Material
Communications, email, flyers
Forms
Online registration and other online forms
Meetings
Interviews and performance reviews
Telephone
Daily interaction

Purpose for which Compass uses the information:

To provide Compass services
To process an application to become a member, volunteer or employee of our organisation
To facilitate a placement in an appropriate service or position
To assist with services whilst an individual is employed or engaged as a volunteer with Compass
To provide feedback on performance as a volunteer or employee
To meet legislative responsibilities to all volunteers and employees
To obtain feedback from individuals about their experiences
To assist Compass to review and improve its programs and services to keep individuals informed about Compass developments and opportunities
To provide information about Compass services
To facilitate further involvements with Compass (e.g. Disability supports, membership, donor)

Online Users

To the extent that this Privacy Policy applies to online privacy issues, it is to be read as forming part of the terms and conditions of use for the Compass website.

Type of information collected:

Contact details including: name, address, phone number, email etc.
Personal details including: date of birth, gender etc.
Non-personal information e.g. visitor navigation and statistics
Server address, browser type, date and time of visit
Personality preference details
Other information necessary if the person falls into the category of a donor, trainee, people, etc. (as specified above)

Purpose for which Compass uses the information:

To process donations, purchase orders, online bookings, purchases/ transactions (e.g. booking First Aid Health & Safety courses)
To transfer category specific information (e.g. trainee, donor, people etc., as specified above) to the appropriate files
To analyse website usage and make improvements to the website

Compass does not match the personal information collected with the non-personal information
Additional Information

The website may, from time to time, contain links to other websites.

Compass stresses that when an online user accesses a website that is not the Compass website, it may have a different privacy policy. To verify how that website collects and uses information, the user should check that particular website’s policy.

How We Collect Information

Where possible, we collect your personal and sensitive in formation directly from you. We collect information through various means, including telephone and in-person interviews, meetings, forms and questionnaires. If you feel that the information that we are requesting, either on our forms or in our discussions with you, is not information that you wish to provide, please feel free to raise this with us.

In some situations we may also obtain personal information about you from a third party source. If we collect information about you in this way, we will take reasonable steps to contact you and ensure that you are aware of the purposes for which we are collecting your personal information and the organisations to which we may disclose your information, subject to any exceptions under the Act. For example, we may collect information about you from a health care professional, such as your doctor.
Health Information

As part of administering Compass services, Compass may collect health information. For example, Compass collects health information (such as medical history) from some trainees participating in Compass programs. When collecting health information from you, Compass will obtain your consent to such collection and explain how the information will be used and disclosed.

If health information is collected from a third party (such as your doctor), Compass will inform you that this information has been collected and will explain how this information will be used and disclosed.

Compass will not use health information beyond the consent provided by you, unless your further consent is obtained or in accordance with one of the exceptions under the Privacy Act or in compliance with another law. If Compass uses your health information for research or statistical purposes, it will be de-identified if practicable to do so.
Use and disclosure of Personal Information

We only use personal information for the purposes for which it was given to us, or for purposes which are related to one of our functions or activities.

For the purposes referred to in this Privacy Policy (discussed above under ‘Collection of Personal and Sensitive Information’), we may also disclose your personal information to other external organisations including:

Government departments/agencies who provide funding for Compass services
Contractors who manage some of the services we offer to you, such as distribution centres who may send information to you on behalf of Compass. Steps are taken to ensure they comply with the APPs when they handle personal information and are authorised only to use personal information in order to provide the services or to perform the functions required by Compass;
Doctors and health care professionals, who assist us to deliver our services;
Other regulatory bodies, such as WorkSafe;
Referees and former employers of Compass employees and volunteers and candidates for Compass employee and volunteer positions; and
Our professional advisors, including our accountants, auditors, lawyers etc.

Except as set out above,

Compass will not disclose an individual’s personal information to a third party unless one of the following applies:

The individual has consented
The individual would reasonably expect us to use or give that information for another purpose related to the purpose for which it was collected (or in the case of sensitive information – directly related to the purpose for which it was collected)
It is otherwise required or authorised by law
It will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety
It is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities
It is reasonably necessary to assist in locating a missing person
It is reasonably necessary to establish, exercise or defend a claim at law
It is reasonably necessary for a confidential dispute resolution process
It is necessary to provide a health service
It is necessary for the management, funding or monitoring of a health service relevant to public health or public safety
It is necessary for research or the compilation or analysis of statistics relevant to public health or public safety
It is reasonably necessary for the enforcement of a law conducted by an enforcement body.

We do not usually send personal information out of Australia. If we are otherwise required to send information overseas we will take measures to protect your personal information. We will protect your personal information either by ensuring that the country of destination has similar protections in relation to privacy or that we enter into contractual arrangements with the recipient of your personal information that safeguards your privacy.
Security of Personal and Sensitive Information

Compass takes reasonable steps to protect the personal and sensitive information we hold against misuse, interference, loss, unauthorised access, modification and disclosure.

These steps include password protection and role protection for accessing our electronic Information Technology system, securing paper files in locked cabinets and physical access restrictions. Only authorised personnel are permitted to access these private details.

When the personal information is no longer required, it is destroyed in a secure manner, or deleted according to our Records Disposal Policy.
Access to and correction of personal information

If an individual requests access to the personal information we hold about them, or requests that we change that personal information, we will allow access or make the changes unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make the changes.

Requests for access and/or correction should be made to the Privacy Officer (details of which are set out below). For security reasons, you will be required to put your request in writing and provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

In the first instance, Compass will generally provide a summary of the information held about the individual. It will be assumed (unless told otherwise) that the request relates to current records.

These current records will include personal information which is included in Compass databases and in paper files and which may be used on a day to day basis.

We will provide access by allowing you to inspect, take notes or print outs of personal information that we hold about you. If personal information (for example, your name and address details) is duplicated across different databases, Compass will generally provide one printout of this information, rather than multiple printouts.

We will take all reasonable steps to provide access or the information requested within 14 days of your request. In situations where the request is complicated or requires access to a large volume of information, we will take all reasonable steps to provide access to the information requested within 30 days.

Compass may charge you reasonable fees to reimburse us for the cost we incur relating to your request for access to information, including in relation to photocopying and delivery cost of information stored off site. For current fees, please contact the Privacy Officer.

If an individual is able to establish that personal information Compass holds about her/him is not accurate, complete or up to date,

Compass will take reasonable steps to correct our records.

Access will be denied if:

The request does not relate to the personal information of the person making the request;
Providing access would pose a serious threat to the life, health or safety of a person or to public health or public safety;
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 would prejudice an action in relation to suspected unlawful activity, or misconduct of a serious nature relating to the functions or activities of Compass
Access discloses a ‘commercially sensitive’ decision making process or information; or
Any other reason that is provided for in the APP’s or in the Privacy Act.

If we deny access to information we will set our reasons for denying access. Where there is a dispute about your right of access to information or forms of access, this will be dealt with in accordance with the complaints procedure set out below.
Complaints Procedure

If you have provided us with personal and sensitive information, or we have collected and hold your personal and sensitive information, you have a right to make a complaint and have it investigated and dealt with under this complaints procedure.

If you have a complaint about Compass privacy practices or our handling of your personal and sensitive information please contact our Privacy Officer (details of which are set out below).

All complaints will be logged on our database.

A privacy complaint relates to any concern that you may have regarding Compass privacy practices or our handling of your personal and sensitive information. This could include matters such as how your information is collected or stored, how your information is used or disclosed or how access is provided to your personal and sensitive information.

The goal of this policy is to achieve an effective resolution of your complaint within a reasonabletimeframe, usually 30 days or as soon as practicable.

However, in some cases, particularly if the matter is complex, the resolution may take longer.

Once the complaint has been made, we will try to resolve the matter in a number of ways such as:

Request for further information: We may request further information from you. You should be prepared to provide us with as much information as possible, including details of any relevant dates and documentation. This will enable us to investigate the complaint and determine an appropriate solution. All details provided will be kept confidential.
Discuss options: We will discuss options for resolution with you and if you have suggestions about how the matter might be resolved you should raise these with our Privacy Officer.
Investigation: Where necessary, the complaint will be investigated. We will try to do so within a reasonable time frame. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.
Conduct of our employees: If your complaint involves the conduct of our employees we will raise the matter with the employee concerned and seek their comment and input in the resolution of the complaint.
The complaint is substantiated: If your complaint is found to be substantiated, you will be informed of this finding. We will then take appropriate agreed steps to resolve the complaint, address your concerns and prevent the problem from recurring.
If the complaint is not substantiated, or cannot be resolved to your satisfaction, but this Privacy Policy has been followed, Compass may decide to refer the issue to an appropriate intermediary. For example, this may mean an appropriately qualified lawyer or an agreed third party, to act as a mediator.

At the conclusion of the complaint, if you are still not satisfied with the outcome you are free to take your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au.

We will keep a record of your complaint and the outcome.

We are unable to deal with anonymous complaints. This is because we are unable to investigate and follow up such complaints. However, in the event that an anonymous complaint is received we will note the issues raised and, where appropriate, try and investigate and resolve them appropriately.
Changes to this Privacy Policy

Compass reserves the right to review, amend and/or update this policy from time to time.

We aim to comply with the APPs and other privacy requirements required to be observed under State or Commonwealth Government contracts.

If further privacy legislation and/or self-regulatory codes are introduced or our Privacy Policy is updated, we will summarise any substantial modifications or enhancements in this section of our Privacy Policy.
How to contact us

Individuals can obtain further information in relation to this privacy policy, or provide any comments, by contacting us:

Telephone: (07) 5457 3716
Post: PO Box 585, Palmwoods QLD 4555
Email: [email protected]