Central Coast Community Legal Centre has obligations, and you have rights, under Commonwealth and privacy law in NSW. Protecting the privacy of the individuals we deal with is important to us. This policy explains how we manage personal information within our Centre.
The personal information we may collect
The personal information that we collect and hold about you will depend on how you interact with our Centre. Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not. It may include:
- Identifying information such as your name and date of birth;
- contact information such as your postal address, email address and telephone number;
- social media handles and other social media profile information that you make available to us or to the public;
- contextual information such as family type, country of birth, year of arrival in Australia, language spoken at home, occupation;
- sensitive information, such as racial or cultural background, criminal history and health information, English proficiency, need for an interpreter, or disability;
- records of our communications with you (including any messages you send to us);
- if you make a donation bank account, credit card or other financial details;
- where we provide you with legal advice, information about your case or situation including financial details and (if applicable) details of your guardian;
- if you make a complaint, details of your complaint and information collected in any investigation of the matter, and details of how the complaint was resolved;
- where you apply for a role with us, information you include in your application, including resume, contact details and references;
- where you attend a professional development, training program, or another event with us, your name, organisation, contact details, payment details (if applicable), and any dietary or accessibility requirements;
- where you register for a subscription to our publications, your name, organisation and contact details and details about the information you access in our publications; and
- where you participate in our surveys, your name, organisational contact details and your survey responses.
Without this information we may not be able to provide you with our services or respond to queries or requests that you send us.
How we collect personal information
We may collect personal information about you in the following ways:
- when you submit a query or request to us;
- when you provide us with information in relation to our services;
- when you respond to a survey that we run, attend an event or forum or fill in forms on our website;
- by tracking your use of our website (e.g., by logging server addresses, top level domain names, dates and times of visits, pages viewed, and documents downloaded, previous sites visited and browser type);
- from public sources;
- from third parties who are entitled to disclose that information to us (for example from a social worker, support worker or government department; and
- when you apply for a job with us.
Where we are providing legal advice to you, we must collect personal information relevant to the provision of legal advice under legal profession laws.
Where we collect personal information from you, we will generally do so directly ourselves. However, in some cases we may collect personal information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us.
How we use your personal information
We use the personal information that we collect for the following purposes:
- to enable us to provide legal services (including to assess whether you are eligible for assistance to assess your case and to refer or arrange non-legal assistance);
- to carry out education and training programs (including for staff and volunteers);
- to conduct research and statistical analysis relevant to our activities;
- to undertake fundraising and marketing activities (including seeking grants);
- to undertake law reform and policy work;
- to answer enquiries and provide information or advice about our services;
- to recruit staff, contractors and volunteers;
- to carry out planning and quality control activities and other internal business processes (including the creation of anonymous case studies, to administer our website and update records);
- for use in monitoring and evaluating our services, including as part of peer review of service, and reporting externally to funding providers;
- to process and respond to any complaints or issues;
- to keep you informed about our activities, including by sending out newsletters; and
- to comply with our legal and regulatory obligations.
We may also use and disclose your information for other purposes as authorised by you, or in accordance with your requests or instructions.
We do not direct market or provide personal information to other organisations for the purposes of direct marketing.
Disclosing personal information
We may disclose information about you to:
- people or organisations you have authorised us to interact with on your behalf;
- our staff (including volunteers and contractors) who need the information to discharge their duties;
- other community legal service providers for file audit purposes;
- our business providers and service providers (for example IT systems administrators);
- professional advisers who we engage to provide advice (for example other solicitors and barristers);
- any organisation for any authorised purpose with your express consent;
- our funding providers (although personal information will only be provided with your consent);
- a court for obtaining copies of documents relevant to your matter; and
- government authorities or other people where we are required by law.
In the case of any contracted service providers, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
We will not disclose your personal information to anyone outside Australia.
We will never sell your personal information to any third party.
Security and integrity of your personal information
We take reasonable steps to ensure that your personal information that we collect, use, and disclose is accurate, up to date, complete and relevant. These steps include promptly updating personal information when we are advised that the information has changed.
We store personal information for as long as it is needed for the purpose for which it was collected or as required by law. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.
The steps we take to secure the personal information we hold include:
- website protection measures (such as encryption, firewalls and anti-virus software);
- access restrictions to our computer systems (such as login and password protection);
- restricted access to our office premises; and
- staff training and implementation of workplace policies and procedures that cover access, storage and security of information.
While we endeavour to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone (02) 4353 4988 or post PO Box 246, Wyong, NSW 2259.
You can also help to protect the privacy of your personal information by letting us know as soon as possible if you become aware of any security breach.
Any links on our website to third party websites that are not operated or controlled by us are provided for your convenience. We are not responsible for the privacy or security practices of those websites. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.
Requesting access to and correcting personal information
If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g., because you think it is incomplete or incorrect), please contact us using the contact details below.
To protect the integrity and security of the information we hold, we may take steps to verify your identity. If you are a client, the Principal Solicitor will view the file and approve any copies of material to be given to you before access is provided. If access can be granted, a copy of the relevant part of the file will be made available to you as soon as practicable after this.
We will take reasonable steps to correct your personal information if we are satisfied that it is inaccurate, out of date, complete, irrelevant, or misleading. If we have provided your personal information to third parties, we will also notify them of the correction if you ask us to do so, unless it is impractical or unlawful.
There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know in writing why we cannot comply with your request and available complaint mechanisms.
We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we have managed your personal information or think we may have breached the Australian Privacy Principles, or any other relevant obligation, please contact us using the contact details below. Complaints must be lodged in writing. We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. You can also make a complaint to the Office of the Australian Information Commissioner (OAIC). Contact details can be found at the OAIC’s website: www.oaic.gov.au or, in some instances, other regulatory bodies, such as the NSW Information and Privacy Commission.
Changes to this policy
Questions regarding your privacy or this statement should be directed to our Executive Officer, Deborah Macmillan on (02) 4353 4988 or via email at firstname.lastname@example.org