1. Purpose

St Joseph’s Affordable Housing Inc is committed to complying with its obligations under the Privacy Act 1988 (Cth)(Privacy Act), including the Australian Privacy Principles (APPs).St Joseph’s Affordable Housing Inc. is committed to respecting your privacy and protecting your rights with respect to your personal information.

2. Policy

This policy explains how St Joseph’s Affordable Housing Inc. manages and secures your personal information. It also describes the kinds of personal information that St Joseph’s Affordable Housing Inc. holds and for what purposes, and how that information is collected, held, used and disclosed.

This policy is available on St Joseph’s Affordable Housing Inc.’s website at http://sjah.org.au/ . You may request acopy of the policy by contacting the Privacy Officer in accordance with paragraph 13 of this policy.

Please read this policy carefully before you provide St Joseph’s Affordable Housing Inc. with any personal information.

3. Types of personal information that St Joseph’s Affordable Housing Inc. collects and holds

Personal information
St Joseph’s Affordable Housing Inc. may collect and hold the following types of personal information about you:

• identification information, including your name, postal address, email address, date of birth, Medicare number, driver’s licence, Centrelink number, passport and contact details;
• bank account details
• financial transactions relating to your dealings with St Joseph’s Affordable Housing Inc.;
• balances of accounts held at St Joseph’s Affordable Housing Inc.;
• tax file number;
• marital status; and
• any other information that St Joseph’s Affordable Housing Inc. considers to be reasonably necessary.

Sensitive information
St Joseph’s Affordable Housing Inc. may need to collect sensitive information about you. St Joseph’s AffordableHousing Inc. will only collect sensitive information about you if:

1. you consent to the collection of the information and the information is directly related to St Joseph’sAffordable Housing Inc.’s functions; or
2. the information relates:
   (i) to the activities of St Joseph’s Affordable Housing Inc.; and
   (ii) solely to the members of St Joseph’s Affordable Housing Inc., or to individuals who have regular contact with St Joseph’s Affordable Housing Inc. in connection with its activities; or
3. the collection is otherwise permitted under the Privacy Act.

The types of sensitive information that St Joseph’s Affordable Housing Inc. collects and holds about you may include:

1. information or an opinion about your race or ethnic origin, religious beliefs or affiliations, philosophical beliefs, membership of a profession or trade association, membership of a trade union, sexual orientation and/or practices;
2. criminal records; or
3. health information.

Information required by law
St Joseph’s Affordable Housing Inc. may also collect personal information about you because the collection of theinformation is required or authorised by law or a court/tribunal order.

4. Collecting your personal information

St Joseph’s Affordable Housing Inc. will, if it is reasonable and practical to do so, collect personal information directly from you.

St Joseph’s Affordable Housing Inc. may collect your information when you:

1. give St Joseph’s Affordable Housing Inc. information over the telephone;
2. interact with St Joseph’s Affordable Housing Inc. electronically or in person;
3. access its website; and
4. complete application forms.

On occasion St Joseph’s Affordable Housing Inc. may collect personal information about you from other sources where it is necessary to do so. Examples of other sources that St Joseph’s Affordable Housing Inc. may collect personal information from include, but are not limited to:

1. schools;
2. verify your identity.

If you do not provide St Joseph’s Affordable Housing Inc. with your personal information, it may not be able to:

1. provide you with the product or service you want; and
2. your relatives;
3. St Joseph’s Affordable Housing Inc.’s service providers; and
4. information that is publicly available on the electoral roll.

Unsolicited personal information
‍If St Joseph’s Affordable Housing Inc. inadvertently collects personal information about you that it did not ask for, St Joseph’s Affordable Housing Inc. will check whether it could have collected that information itself. If St Joseph’s Affordable Housing Inc. could have collected the information, St Joseph’s Affordable Housing Inc. will handle it in the same way it handles other information it collects from you. If:

1. St Joseph’s Affordable Housing Inc. could not have collected the personal information; and
2. the information is not contained in a Commonwealth record,

St Joseph’s Affordable Housing Inc. will destroy the information or de-identify the information provided it is lawful and reasonable to do so.

5. Storing personal information

St Joseph’s Affordable Housing Inc. stores your personal information in different ways, including paper and electronic form, via cloud and via Dropbox.

St Joseph’s Affordable Housing Inc. treats all personal information as confidential. It will take reasonable steps to ensure personal information is protected from:

1. misuse, interference and loss; and
2. unauthorised access, modification and disclosure.

Some of the ways St Joseph’s Affordable Housing Inc. does this are:

1. confidentiality requirements for employees;
2. document storage facilities; security measures for access to systems;
3. security measures for access to systems;
4. only giving access to personal information to a person who is verified to be able to access that information;
5. control of access to buildings; and
6. electronic security systems, such as firewalls and data encryption, user identifiers, passwords or other access codes, antivirus, antispyware, backup and recovery of systems.

If St Joseph’s Affordable Housing Inc. no longer needs your personal information for any purpose, it will take reasonable steps to destroy or permanently de-identify the information, unless:

1. the information is contained in a Commonwealth record; or
2. St Joseph’s Affordable Housing Inc. is required by law, or a court/tribunal order, to retain the information.

6. Purpose for collecting, holding, using and disclosing information

St Joseph’s Affordable Housing Inc. collects, holds, uses and discloses your personal information for the following purposes:

1. to assess your account application;
2. to establish and administer your account;
3. to verify your identity;
4. to consider any other application made by you for products or services;
5. for customer relations purposes, including managing St Joseph’s Affordable Housing Inc.’s relationship with you;
6. to comply with any applicable laws, regulations or codes of practice;
7. to comply with any payment systems requirements;
8. for information technology systems development and testing where St Joseph’s Affordable Housing Inc.’s internal computer system is upgraded;
9. for St Joseph’s Affordable Housing Inc.’s internal operations, including record keeping, risk management, auditing, training, file reviews and account analysis;
10. to investigate, resolve and prevent complaints;
11. to make arrangements with other organisations to provide services in relation to St Joseph’s Affordable Housing Inc.’s products and services (for example, St Joseph’s Affordable Housing Inc. may arrange for mailing houses to distribute account statements);
12. to conduct fraud assessments;
13. for reporting and data analytics purposes, including for regulatory, management, statistical or research purposes;
14. direct marketing purposes; and
15. for any other purpose for which you have given your consent.

7. Use and disclosure of information

Personal information St Joseph’s Affordable Housing Inc. holds about you that was collected for a particular purpose will not be disclosed for another purpose, unless:

1. you have consented to the use or disclosure of the information for another purpose; or
2. the access, use or disclosure is otherwise permitted under the Privacy Act (e.g. you would reasonably expect St Joseph’s Affordable Housing Inc. to use or disclose the information for another purpose or the use or disclosure of the information is required or authorised by law or a court/tribunal order).

St Joseph’s Affordable Housing Inc. may disclose personal information about you to third parties. Examples of third parties that St Joseph’s Affordable Housing Inc. may disclose your personal information to include, but are not limited to:

1. St Joseph’s Affordable Housing Inc.’s service providers;
2. St Joseph’s Affordable Housing Inc.’s agents, contractors and external advisors (for example, Archdiocese’s lawyers, auditors and Catholic Development Fund Tasmania);
3. any person acting on your behalf, including your legal and financial advisers;
4. Government and other regulatory bodies, law enforcement bodies and courts as required or authorised by law;
5. external dispute resolution bodies;
6. other financial institutions; and
7. any other person where you have given your consent.

St Joseph’s Affordable Housing Inc. is not likely to disclose your personal information to any overseas recipients. Where your personal information is disclosed,

St Joseph’s Affordable Housing Inc. will seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.

8. Direct marketing

St Joseph’s Affordable Housing Inc. may use or disclose your personal information (excluding sensitive information) for direct marketing purposes. St Joseph’s Affordable Housing Inc. may conduct direct marketing via email, telephone, mail out or any other electronic means.

St Joseph’s Affordable Housing Inc. will only use your sensitive information for the purposes of direct marketing if you have consented to the information being used or disclosed for the purposes of direct marketing.

If at any time you decide you do not want to receive any more marketing material from St Joseph’s Affordable Housing Inc., you may:

1. contact the Privacy Officer in accordance with paragraph 13 of this policy; or
2. opt-out of receiving any more marketing material via any opt-out mechanism contained in St Joseph’s Affordable Housing Inc.’s marketing correspondence.

All St Joseph’s Affordable Housing Inc.’s marketing correspondence will display a clearly visible and user-friendly opt-out mechanism. St Joseph’s Affordable Housing Inc. may imply consent to receive direct marketing material if you do not use the opt-out mechanism.

If you request to no longer receive direct marketing material St Joseph’s Affordable Housing Inc. will process your request within a reasonable period after the request is made.

9. Quality of personal information

St Joseph’s Affordable Housing Inc. will take all reasonable steps to ensure that any personal information it collects, uses or discloses is accurate, complete, up-to-date and relevant to St Joseph’s Affordable Housing Inc.’s functions or activities.

If you believe that your personal information is not accurate, complete or up to date, you should contact the Privacy Officer in accordance with paragraph 13 of this policy.

10. Access to personal information

You can access your personal information unless an exception in the Privacy Act applies.

You can request access to your personal information by contacting the Privacy Officer in accordance with paragraph 13 of this policy.

Depending on the nature of the request, St Joseph’s Affordable Housing Inc. may charge you a small fee for granting you access.

St Joseph’s Affordable Housing Inc. will respond to a request for access within a reasonable time (usually 30 days), and give access in the manner requested by you, if it is reasonable and practicable to do so.

Sometimes, it may not be possible for St Joseph’s Affordable Housing Inc. to give you access. If St Joseph’s Affordable Housing Inc. refuses to give you access, it will:

1. take reasonable steps to give you access in a manner that meets St Joseph’s Affordable Housing Inc.’s needs as well as yours;
2. provide you with written reasons for the refusal provided it is reasonable to do so; and
3. provide you with the mechanisms available to complain about the refusal.

11. Correcting personal information

If you think that any personal information St Joseph’s Affordable Housing Inc. holds about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request St Joseph’s Affordable Housing Inc. to correct the information by contacting the Privacy Officer in accordance with paragraph 13 of this policy.

St Joseph’s Affordable Housing Inc. will take all reasonable steps to correct that information to ensure that, having regard to the purposes for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

If St Joseph’s Affordable Housing Inc. corrects personal information that has been disclosed to another entity and you ask St Joseph’s Affordable Housing Inc. to tell the other entity about the correction, St Joseph’s Affordable Housing Inc. will take all reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.

If St Joseph’s Affordable Housing Inc. refuses to correct the personal information, then it will provide you with:

1. written reasons for the refusal provided it is reasonable to do so; and
2. the mechanism available to complain about the refusal.

St Joseph’s Affordable Housing Inc. must respond to a correction request within a reasonable time (usually 30 days).

12. Anonymity

You have the option to remain anonymous, or to use a pseudonym when dealing with St Joseph’s Affordable Housing Inc. where it is lawful and practical to do so.

13. Data Breach

A Data Breach is an incident where personal or confidential information, or non-personal information that could be sensitive or commercial is compromised, disclosed, copied, transmitted, accessed, removed, destroyed, stolen or used by unauthorised individuals, whether accidentally or intentionally.

St Joseph’s Affordable Housing Inc. is obligated under the Australian Privacy Amendment (Notifiable Data Breaches) Act 2017 to notify individuals whose personal information is involved in a data breach that could potentially result in serious harm.

14. Complaints or queries

If you:

1. have any issues about the way St Joseph’s Affordable Housing Inc. handles your personal information after reading this policy;
2. become aware of a potential breach of privacy; or
3. wish to make a privacy complaint,

you are requested to contact St Joseph’s Affordable Housing Inc. Privacy Officer at:

St Joseph’s Affordable Housing Inc. Privacy Officer
Email: sjah-privacyofficer@aohtas.org.au
Telephone: (03) 6208 6222
Post: GPO Box 62, Hobart, Tas, 7001
Visit: 35 Tower Road, New Town, Tas, 7008

If St Joseph’s Affordable Housing Inc.’s Privacy Officer is unable to resolve the matter, it will be escalated (internallyor externally) as appropriate to facilitate resolution.

If you are not happy with the outcome of St Joseph’s Affordable Housing Inc.’s Privacy Officer’s investigation, thenyou can raise your concern with the Office of the Australian Information Commissioner (OAIC):Office of the Australian Information Commissioner.
Telephone: 1300 363 992
Email: enquiries@oaic.com.au
Mail: GPO Box 5218 Sydney NSW 2001
Web: www.oaic.gov.au