Introduction
Co-operation Housing is committed to protecting the privacy of personal information that the company collects, holds and administers. Personal information is information that directly or indirectly identifies a person.
Purpose
The purpose of this policy is to provide a framework for Co-operation Housing in dealing with privacy considerations in regards to service users.
Definitions
In this policy the term service users refers to applicants, tenants, Members, staff, contractors and business partners. Personal information includes details about someone's contact details, private circumstances, income, health and tenancy records.
Responsibility & Scope
Co-operation Housing acknowledges that it has a responsibility to respect the privacy of service users and to protect confidentiality, wherever possible. Confidentiality applies to verbal information, written information and information stored in electronic form. Co-operation Housing will ensure that affected individuals are aware of its Privacy Policy and its purposes.
Relevant Legislation
In handling personal information, Co-operation Housing is committed to complying with the National Privacy Principles (NPP) and the Privacy Act 1988.
Procedures
Collection
Co-operation Housing will:
• Only collect information that is necessary for the performance and primary function of Co-operation Housing;
• Ensure that service users are informed as to why Co-operation Housing collects the information and how it is administered;
• Ensure that service users are aware if any information provided will be accessible by third parties e.g. joint wait lists; and
• Notify service users that this information is accessible to them.
Co-operation Housing will take reasonable steps to ensure the information collected is accurate, complete, up-todate and relevant.
Use and disclosure
Co-operation Housing will:
• Only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose;
• Only release personal information about a person to a third party with that person’s written permission. The only exceptions to this will be: o where there is a legal obligation to divulge information; or o where failure to divulge certain information may lead to a serious and imminent threat to an individual's life, health or safety, or a serious threat to public health or safety.
• Ensure that written permission is obtained prior to any photographic, video or other identifying images of tenants or association members being taken and/or aired.
Where a person e.g. a tenant cannot give informed written consent to information being shared due to incapacity, Co-operation Housing will seek external expert advice relevant to:
• The reason for needing to share the information
• The nature of the information to be shared
• The 3rd party receiving the information
• The type and level of permanency of the incapacity
• Any guardianship arrangements in place.
Data security and retention
Co-operation Housing will:
• Safeguard the information collected and stored against misuse, loss, unauthorised access and modification;
• Store and destroy records in accordance with the Records Management Policy; and
• Only identify individuals in reports and correspondence where it is essential to do so. At all other times individuals will be identified by a number system, e.g. databases
Access and correction
Co-operation Housing will:
• Ensure that access to personal information is only allowed for legitimate purposes and on a 'need to know' basis; and
• Ensure individuals have access to information held about them and to correct this information if it is inaccurate, incomplete, misleading or not up-to-date.
Sensitivity
Co-operation Housing will:
• Ensure that information of a personal nature is collected in a suitable private place. This also applies to telephonic information gathering; and
• Not collect information in a manner that is unreasonably intrusive e.g. telephone surveys after 8.00pm at night.
Personnel
Co-operation Housing will:
• Ensure that all new staff, Board members, students and volunteers are advised of the company's Privacy Policy upon induction and sign a confidentiality agreement; and
• Ensure wherever possible that that only accredited interpreters are used by Co-operation Housing and that all interpreters are aware of privacy and confidentiality requirements.
Staff and Volunteer Confidentiality
Staff and volunteers will be exposed to, and working with, private personal information in carrying out their regular duties. Staff will keep private all information as defined in this policy. If staff are unsure about the privacy status of any information, they should consult the CEO before releasing information.
Induction and Training
To ensure all staff, volunteers and Board members are aware of the privacy policy, they will be educated about privacy at induction, including written information in the Board Induction Package and Staff and Volunteer Induction Package. Staff, Volunteers and Board Members will participate in Co-operation Housing’s internal training session on Privacy at least annually.
Agreement
All staff, volunteers and Board members are required to sign Co-operation Housing’s Privacy Agreement.
Dealing with alleged breaches of privacy
Any staff member or volunteer who is aware of a breach of privacy must report it to the CEO. If the breach involves the CEO the staff member must report it to the Board Chairperson. Any Board member who is aware of a breach of privacy must report it to the Chairperson. If the breach involves the Chairperson of the Board they must report it to the CEO for Board consideration. Any alleged breach of privacy by a staff member will be investigated and managed according to Co-operation Housing’s Performance Management Policy
Evaluation
The CEO will report all investigations of alleged breaches of privacy by staff members to the Board. When the Board reviews complaints to Co-operation Housing quarterly as per the Complaints and Appeals Policy, the Board will identify any complaints that involve breaches of privacy. The Board will review policies and procedures of Co-operation Housing
• when breaches are identified
• at the annual Board review process
to improve Co-operation Housing’s capacity to maintain appropriate privacy of personal information.