Privacy Policy

Purpose

This policy explains Avenues Australia Pty Ltd’s (Avenues Australia) commitment to protecting people’s privacy.

Avenues Australia collects information about people who have dealings with us, such as clients, carers, service providers, and email subscribers. Avenues Australia collects private information from clients or their representatives by lawful and fair means. This privacy policy explains how Avenues Australia collects, uses, discloses, and otherwise handles personal information.

Employees understand Avenues Australia’s Privacy Statement, which tells clients how their personal information is used, shared, and protected from misuse. Avenues Australia is committed to protecting privacy in accordance with applicable privacy legislation.

Failure to appropriately collect, store, use, and disclose information can leave Avenues Australia without key information to support clients efficiently and effectively and it also exposes customers to risk. This policy assists employees to:

• understand their obligations in relation to privacy and information security;

• become familiar with the relevant legislative and compliance frameworks, including how Avenue Australia will be monitored in relation to privacy and information security;

• develop a privacy aware culture through best practice information management;

• know where to get further information and resources.

Scope of Policy

This policy relates to all employees, contractors, volunteers, and students on placement responsible for collecting, storing, using, or disclosing individuals’ information on behalf of Avenues Australia.

Avenues Australia is generally exempt from the Privacy Act when it collects and handles employee records, and this privacy policy does not apply to that information. However, the Privacy Act still applies to personal information about job applicants, contractors, and volunteers, and the Health Privacy Principles still require Avenues Australia to protect the privacy of employee health information. This privacy policy will apply in those circumstances.

Legislation and Standards

Avenues Australia is currently a registered National Disability Insurance Scheme (NDIS) provider and is audited by the to the NDIS Quality and Safeguarding Commission and is required to comply to the NDIS Practice Standards and Code of Conduct, and as such is regulated against these standards. The following are the relevant legislation, NDIS Practice Standards and Code of Conduct applicable to this Policy:

Glossary

Any defined terms and abbreviations below are specific to this document.

Personal information means information or an opinion (whether true or not and whether recorded in a material form or not) about an individual who is identified or reasonably identifiable from the information. 

Sensitive/Confidential information is a subset of personal and confidential information that is generally afforded a higher level of privacy protection. Sensitive or confidential information includes, but is not limited to, name, addresses, emails, phone numbers, family members, service providers, bank information, identification documents identifying numbers, case notes, health and genetic information and information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, and biometric information etc.

Policy Statement

Personal and Confidential Information Collected by Avenues Australia

General

The kind of personal and confidential information that Avenues Australia collects about individuals depends on the type of dealings they have with Avenues Australia.  For example, if a person:

• is someone Avenues Australia supports or is connected to a person Avenues Australia supports (e.g. a family member, carer, advocate, or nominated representative), Avenues Australia may collect their:

  • name, address, telephone, and email contact details;

  • gender, date of birth, and marital status, information about their disability and support needs;

  • health and medical information;

  • NDIS number;

  • financial information and billing details including information about the services individuals are funded to receive, whether under the National Disability Insurance Scheme or otherwise;

  • records of interactions with individuals such as case notes and records of conversations individuals have had with Avenues Australia’s employees;

  • information about the services Avenues Australia provides to individuals and the way in which Avenues Australia will deliver those to individuals; or

  • reports from service providers and government agencies.

• registers for a subscription to an Avenues Australia’s newsletter, Avenues Australia may collect their name, organisation, and contact details and details about the information individuals access in Avenues Australia’snewsletters;

• attends an Avenues Australia event, Avenues Australia may collect their name, organisation, contact details, payment details (if applicable) and any dietary and accessibility requirements;

• participates in Avenues Australia’s surveys, Avenues Australia may collect their name, organisation, contact details, and their survey responses;

• sends Avenues Australia an enquiry, Avenues Australia may collect their name, contact details, and details of their query;

• visits Avenues Australia’s website, Avenues Australia will use ‘cookies’ and may use tools to track visits to the Avenues Australia website including how individuals arrive at the website and which pages they use. Avenues Australia may also collect data to enable Avenues Australia to personalise a webpage or pre-fill a form with their details;

• makes a complaint, Avenues Australia may collect their name, contact details, the details of their complaint, information collected in any investigation of the matter, and details of the resolution of the complaint;

• applies for a job or volunteer role at Avenues Australia, Avenues Australia may collect the information individuals included in their application, including their cover letter, resume, contact details and referee reports, their tax file number and other identifiers used by Government Agencies or other organisations to identify individuals, information from police checks, working with children checks (or similar), and information about their right to work in Australia; 

Sensitive or Confidential Information

Avenues Australia employees must only collect sensitive information where it is reasonably necessary for Avenues Australia’s functions or activities and either:

• the individual has consented; or

• Avenues Australia is required or authorised by or under law (including applicable privacy legislation) to do so.

For example, in order to provide Avenues Australia’s services to a client or to respond to a potential customer’s inquiries about services, Avenues Australia may be required to collect and hold their sensitive information including health and medical information and information relating to their disability and support requirements.

When Personal and Confidential Information Is Not Provided

The nature of the business carried on by Avenues Australia means that, generally, it is not possible for Avenues Australia to provide services to clients or otherwise deal with individuals in an anonymous way, and therefore require personal and confidential information to delivery services.

However, in some circumstances Avenues Australia allows individuals the option of not identifying themselves, or of using a pseudonym, when dealing with Avenues Australia (for example, when viewing Avenues Australia website, making general phone queries or providing an anonymous feedback or complaint). 

How Avenues Australia Collects Personal and Confidential Information

Methods of collection

Avenues Australia employees must only collect personal and confidential information by lawful and fair means as required by the Privacy Act. Avenues Australia employees must also only collect personal and confidential information directly from clients or their nominated representatives where this is reasonable and practicable. 

Avenues Australia collects personal and confidential information in a number of ways, including:

• through Avenues Australia websites;

• when individuals correspond with Avenues Australia (for example by letter, fax, email or telephone);

• on hard copy forms;

• in person;

• from referring third parties (for example, the National Disability Insurance Scheme or a service provider

• at events and forums;

• from third party funding and Government Agencies such as the Department of Health and Human Services and the Department of Education and Training.

Collection notices

Where Avenues Australia collects personal and confidential information about individuals, Avenues Australia employees must take reasonable steps to notify them of certain matters. Employees must do this at or before the time of collection, or as soon as practicable afterwards. 

Why Avenues Australia Collects Personal Information

Avenues Australia provides a wide range of support services for children and adults with a disability, their families, and carers. These essential, quality services include: support coordination and other NDIS services in the future. Avenues Australia also addresses disability related issues through policy work and education, using evidence from case work and the stories of Avenues Australia clients to promote Avenues Australia’s work and advocate in order to bring about change. 

The main purposes for which Avenues Australia collects, holds, uses, and discloses personal and confidential information are set out below.

Provision of Support Services:

• Providing individuals with information about Avenues Australia’s services and supports.

• Answering their inquiries and delivering service to clients.

• Administering Avenues Australia’s services and supports and processing payments.

• Conducting quality assurance activities including conducting surveys, research and analysis, and resolving complaints.

• Complying with laws and regulations and reporting to funding and Government Agencies.

Advocacy

• Carrying out law reform and policy work (for example, National Disability Insurance Scheme policy work on safeguarding people’s rights).

• Promoting Avenues Australia and its activities, including through events and forums.

• Conducting research and statistical analysis relevant to Avenues Australia activities (including inviting individuals to participate in research projects and activities).

• Preparing case studies of clients for use in advocacy work and in publications (individually identifying case studies will only be used with consent).

Education and Information

• Providing disability related information or resources.

• Running professional development / community training programs.

General Administration

• Recruiting employees, contractors, and volunteers.

• Processing payments.

• Answering queries and resolving complaints.

• Evaluating Avenues Australia work and reporting externally.

• Carrying out internal functions including administration, training, accounting, audit, and information technology.

Other Purposes

Avenues Australia may also collect, hold, use, and disclose personal and confidential information for other purposes which are explained at the time of collection, purposes which are required or authorised by or under law (including, without limitation, privacy legislation) or purposes for which an individual has provided their consent.

Information collected about individuals that does not identify individuals may be used for research, evaluation of services, quality assurance activities, and education. If individuals do not wish for their de-identified data to be used this way, they should contact Avenues Australia.

Virtual Meetings

Avenues Australia’s Virtual Meeting Privacy Policy relates to how we collect, use, disclose, and safeguard personal and confidential information when clients and staff participate in virtual meetings, webinars, and online conferences organised or hosted by Avenues Australia or using our virtual meeting platforms and services. Virtual meetings are formal and planned meetings discussing detailed and confidential subjects that are held on computers, tablets, smartphones or any relevant communication device requiring internet or phone connection. For the purposes of this policy, virtual meetings are not impromptu, unscheduled and informal phone calls.

• Connecting securely online is important, and the appointment will use regular internet service or data plans from Avenues Australia staff. Client’s and external organisations will use their own regular internet service and/or data plan. All internet and data plans used must comply with privacy, cyber security, confidentiality guidelines and the Australian Privacy Act.

• We may collect and store personal and confidential information such as names, email addresses, phone numbers, and company/affiliations when external parties register agree to have a virtual meeting.

• All content shared during the virtual meeting, including messages, files, documents, or other materials, may be collected and stored for the purposes of the meeting.

• Technical information about the participant’s device, such as IP address, browser type, operating system, and device identifiers, to ensure the smooth functioning of the virtual meeting may be collected.

• Staff will call clients or staff from external organisations from a private and confidential setting such as their office or a meeting room. It is advised that the client and other person from an external organisation is also in a private and safe location where they feel safe and grounded and are able to openly discuss private information. Staff are to ensure clients are in a safe environment for virtual sessions. If the client cannot find a private place for a virtual appointment, they should advise the staff member who will help them to reschedule or suggest a better location for the virtual appointment. Private locations for the client may include:

  •  a private room in their home;

  •  their car;

  •   private room in a friend or family’s home;

  •   outdoors ways from people; or

  •   a meeting room at a premises of another organisation.

• In order to mitigate the risk of unsafe virtual appointments, all parties including the client must:

  •   keep devices protected with updated antivirus software and/or highly secured devices;

  •   protect wireless connection with a password;

  •   make sure that participant’s name used to either log into or join the video conference platform used for the virtual appointment is the same name provided to Avenues Australia so it is instantly recognisable. This allows Avenues Australia to screen for unwanted and unsolicited guests.

  •  use a secure, private network to prevent eavesdropping. Public and/or unsecured Wi-Fi to access the virtual appointment is not permitted to be used by Avenues Australia staff. If other parities external to Avenues Australia use such a connection, a safe and secure online connection is not guaranteed;

  • avoid accessing virtual appointments on devices shared with people outside the client’s home or family;

  •  not set up a virtual appointment or share information with a provider or person who is unknown or with information not recognised. Call your regular person’s main phone number or email them to confirm their identity first.

  Direct Marketing

  Avenues Australia may use individuals’ personal and confidential information to keep them informed and up to date about Avenues Australia’s work, for example, changes to the National Disability Insurance Scheme or information about disability supports, either where Avenues Australia has their express or implied consent, or where Avenues Australia is otherwise permitted by law to do so. Avenues Australia may send this information in a variety of ways, including by mail, email, SMS, telephone, or social media.

  Where individuals have consented to receiving marketing communications from Avenues Australia, that consent will remain current until they advise Avenues Australia otherwise. However, individuals can opt out at any time, as explained below.

  Opting out

  Individuals can opt out of receiving marketing communications from Avenues Australia by:

• advising they have received a marketing call and that they no longer wish to receive these calls;

• using the unsubscribe facility that Avenues Australia includes in its commercial electronic messages (such as emails and SMSes) to opt out of receiving those messages; or

• contacting Avenues Australia by email at hello@avenuesaustralia.com, by phone on 1300 208 594 or by sending a letter to 2/255 Beaufort Street, Perth WA 6000.

   

  Avenues Australia’s Website Cookies

  Avenues Australia uses ‘cookies’ to manage and improve users’ experience on the Avenues Australia website. A cookie is a small text file that Avenues Australia’s site may place on their computer as a tool to remember their preferences. Individuals may refuse the use of cookies by selecting the appropriate settings on their browser.

  Avenues Australia uses tools that tell Avenues Australia when a computer or device has visited or accessed Avenues Australia content. This allows Avenues Australia to tailor advertising, both on Avenues Australia website and through advertising networks on other websites, based on their visits or behaviour through cookies on their device. Individuals can control how cookies are used and for what through the settings on their chosen browser.

  Avenues Australia also uses Google Analytics to track visits to the Avenues Australia website, using this information to track the effectiveness of the website. While this data is mostly anonymous, sometimes Avenues Australia will connect it to individuals, for instance in personalising a webpage, or pre-filling a form with their details. For more information on Avenues Australia’s analytics tools, read Google’s privacy policy.

Privacy Statement

Through Avenues Australia Privacy Statement clients and relevant others are also informed about how their personal and confidential information will be used and disclosed, including how their personal and confidential information is protected from misuse, loss, unauthorised access, modification and disclosure.

Third Parties Disclosures

Avenues Australia may disclose personal and confidential information to third parties where appropriate for the purposes set out above, including disclosure to:

• Government and regulatory bodies, including but not limited to, the National Disability Insurance Agency, Medicare, the Department of Social Services, Health departments, the Australian Taxation Office;

• people acting on their behalf including their nominated representatives, legal guardians, executors, trustees and legal representatives;

• the police, or to the Disability Services Commissioner, or to comply with compulsory notices from courts of law, tribunals or Government Agencies;

• referees whose details are provided to Avenues Australia a by job applicants; and

• Avenues Australia’s contracted service providers, including:

  • information technology service providers

  • invoice processing service providers

  • conference, function and training organisers

  • marketing and communications service providers including call centres

  • research agencies

  • freight and courier services

  • printers and distributors of direct marketing material including mail houses

  • external business advisers (such as recruitment advisors, auditors and lawyers).

In the case of these contracted service providers, Avenues Australia may disclose personal and confidential information to the service provider and the service provider may in turn provide Avenues Australia with personal and confidential information collected from individuals in the course of providing the relevant products or services. 

Cross Border Disclosure of Personal Information

Avenues Australia utilises technology infrastructure that makes use of cloud infrastructure or servers that are located interstate or located out of Australia. Other than this, Avenues Australia does not transfer personal and confidential information interstate or overseas.  By providing their personal and confidential information to Avenues Australia or using Avenues Australia’s services and supports, individuals are taken to have consented to this transfer.

If Avenues Australia transfers information overseas for other purposes, it will only do so with their consent or otherwise in accordance with Australian law. Avenues Australia will require that the recipient of the information complies with privacy obligations to maintain the security of the information.

Data Quality and Security

General

Avenues Australia holds personal and confidential information in a number of ways, including in hard copy documents, electronic cloud-based databases, email contact lists, and in paper files held in locked drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. 

Avenues Australia employees must take reasonable steps to:

• make sure that the personal and confidential information that Avenues Australia collects, uses and discloses is accurate, up to date and complete and (in the case of use and disclosure) relevant;

• protect the personal and confidential information that Avenues Australia holds from misuse, interference and loss and from unauthorised access, modification or disclosure; and

• destroy or permanently de-identify personal and confidential information that is no longer needed for any purpose that is permitted by the client, APPs, subject to other legal obligations and retention requirements applicable to Avenues Australia.

Unfortunately, there are inherent risks in the management of personal and confidential information and Avenues Australiacannot and does not guarantee that unauthorised access to individuals’ personal and confidential information will not occur.

Security

The steps Avenues Australia takes to secure the personal and confidential information Avenues Australia holds include website protection measures (such as encryption, firewalls and anti-virus software), security restrictions on access to Avenues Australia‘s computer systems (such as login and password protection), controlled access to Avenues Australia premises, policies on document storage and security, personnel security (including restricting the use of personal and confidential information by Avenues Australia employees) and training and workplace policies.

Website Security

While Avenues Australia strives to protect the personal and confidential information and privacy of users of Avenues Australia website, Avenues Australia cannot guarantee the security of any information that individuals disclose online, and individuals disclose that information at their own risk. If individuals are concerned about sending their information over the internet, individuals can contact Avenues Australia by telephone or post.

Individuals can also help to protect the privacy of their personal and confidential information by letting Avenues Australia know as soon as possible if individuals become aware of any security breach.

Third Party Websites

Links to third party websites that are not operated or controlled by Avenues Australia are provided for users’ convenience. Avenues Australia is not responsible for the privacy or security practices of those websites, which are not covered by this privacy policy. Third party websites should have their own privacy and security policies, which Avenues Australia encourages individuals to read before supplying any personal and confidential information to them.

How Avenues Australia Handles Information

Employee Training

All Avenues Australia employees must complete the e-learning training about privacy, data security and data quality requirements and learn how the Information and Health Privacy Principles apply to their day-to-day work.

Handling Personal Information

Avenues Australia employees must only access and use personal and confidential information for a valid work purpose. When handling personal information, employees should:

• confirm recipient details before sending faxes or emails

• always store any hard copies of confidential information that is not being used in a secure cabinet or room

• be aware of the surroundings and people nearby

• limit taking hard copy information away from secure sites

• secure information when travelling e.g. in briefcase, folder etc.

• dispose unneeded copies of information securely

• ensure the information is available to people who need to access it

Sharing Personal Information

Avenues Australia employees may only share personal and confidential information as set out under this policy and in circumstances permitted under law. To minimise the risk of unauthorised disclosure, employees should:

• check with a manager and the client before sharing confidential information if the basis for sharing is not clear;

• not use Internet-based file sharing software to share confidential information (e.g. BitTorrent, Dropbox); or

When sharing information with authorised persons via email or phone, employees should do the following:

• Ensure that when information is shared with external persons or organisations, those persons or organisations have been nominated by the client in a formal consent form. Where formal consent is not documented, the employee must seek prior consent by telephone, text or email from the client or their nominated representatives.

• Enable encryption where available.

• Not include confidential information in the subject line or body of the email.

• Not send confidential information from free web-based email accounts such as Gmail, Hotmail or Yahoo!

• Not share or discuss confidential information on social networking applications such as Facebook and Twitter.

In the unlikely event of an emergency or crisis, the client’s information may be shared with relevant persons or organisations in response to the emergency or crisis, where it is deemed that Avenues Australia has a duty of care to safeguard the client or members of the community from harm or serious injury. This may include sharing confidential information to emergency services, government agencies, family members etc where consent was not explicitly given by the client or their nominated representatives.

Passwords

User IDs and passwords for access to computer services are for the sole use of the person to whom they are allocated.  Avenues Australia employees should:

• make passwords difficult to guess

• keep all passwords secret and not provide them to another person

• change passwords regularly

Downloading Software and Applications

Software and applications downloaded from the Internet can contain viruses that threaten the security of information stored on users’ computers. Employees should:

• not download unauthorised software from the Internet onto a computer

• lodge a formal request with a manager if software needs to be installed in order to complete work activities

Unsolicited and Suspicious Emails

Unsolicited emails can contain viruses that threaten the security of information stored on users’ computers. If an employee receives an email from an unknown sender and it looks suspicious, an employee should:

• not open the email or click on links contained in its subject line or body

• report the email to a manager and delete the email immediately.

Free Web-based Email Accounts and File Sharing Software

Free web-based accounts and file sharing software are often owned by international companies in foreign jurisdictions.  Information is stored on systems outside of Australia with differing legislation applied to the information. Examples of free web-based email accounts include:

• Gmail  

• Hotmail

• Yahoo!

Once information has been sent to web-based email accounts or uploaded onto file sharing programs it can no longer be controlled. personal and confidential information should not be sent:

• to or from a free web-based email account (unless it is the client and/or their representative’s email).

• via free internet-based file sharing software.

Clear Desks and Screens

Work environments should be clear of personal and confidential information when unattended. This means employees should:

• not leave documents containing confidential information unattended on photocopiers, fax machines or printers

• lock a computer’s screen when leaving it unattended

• only print documents when absolutely necessary

• store portable storage devices and hard copies of confidential information in a secure drawer or cabinet, not on a desk.

Information Disposal

Employees should ensure record retention requirements have been met prior to the disposal of any personal information according to the Privacy Act.

When disposing of personal information, employees should:

• place unneeded working documents or copies of information in secure bins or adequate shredders;

• ensure any electronic media including computers, hard drives, USB keys etc. are sanitised when no longer required;

When disposing of unauthorised access to confidential information from personal devices, employees must provide evidence that the document have been removed and sign a declaration.

Visitors

To help minimise the risks to the security of personal information, employees should:

• ensure all visitors are registered and accompanied at all times;

• be aware of unaccompanied people who are not known;

• notify a manager if an unauthorised person is present on premises.

Portable Storage Devices

Portable storage devices are usually small and capable of storing large amounts of information, and in some cases can be used to copy, transmit or share information.  Examples of portable storage devices include:

• removable media (e.g. SD Cards, CD-ROMs, DVDs, USB drives)

• laptops, tablet computers and slates (e.g. iPads)

• smartphones

Using portable storage devices to access, store or transport personal and confidential information involves considerable risk because:

• they can be easily lost or stolen, and then accessed by unauthorised people; and

• using portable storage devices in public or non-work premises increases the chance of accidentally disclosing personal and confidential information to unauthorised people.

To minimise the information security risks associated with using portable storage devices, employees should:

• only use encrypted portable storage devices to store personal information;

• avoid storing personal and confidential information on portable storage devices, where possible;

• secure portable storage devices when unattended e.g. lock in a drawer;

• be careful of what is said and what information is viewed in public; and

• report lost or stolen portable storage devices immediately to a manager.

Privacy Incidents

Privacy incidents may result from unauthorised people accessing, changing or destroying personal information. Examples of situations from which incidents may arise include:

• an employee saving confidential information on the following personal assets: computers, emails, phones, portable devices, hard drives, cloud software. A privacy Incident also occurs if an employee has been found to printing of document for personal use (usually at the conclusion of employment or for personal interests during employment).

• accidental download of a virus onto an agency computer;

• discussing or sharing of confidential information on a social networking website such as Facebook, and in other informal environment where our clients or staff have not approved for the information to be shared;

• loss or theft of a portable storage device containing personal and confidential information;

• non-secure disposal of hard copies of personal and confidential information (i.e. placing readable paper in recycle bin or hard waste bin);

• documents sent to the wrong fax number or email address; and

• documents sent to a free web-based email account such as Yahoo!, Gmail or Hotmail.

Privacy incidents can:

• occur due to accidental or deliberate actions;

• result from human error or technical failures; or

• apply to information in any form, whether electronic or hard copy.

Incident Reporting

It is vital all privacy incidents are reported as soon as possible so that their impact may be minimised. Employees should be aware of:

• how to identify potential privacy incidents;

• the reason for reporting incidents is so their impact can be minimised - not to punish individuals;

• the need to report all incidents to their manager as soon as they become aware of them;

Avenues Australia must report all client related privacy incidents after becoming aware of, or being notified of a possible privacy incident, or within two business days of an allegation being made of a potential breach by completing the Privacy Incident Report Form.

A breach of customer privacy may have a major impact, a non-major impact, or be a near miss or an incident with no apparent impact on a customer. In each case, the incident has to be reported as a client incident. 

Access and Correction

Individuals have a legal right to request access or correction of their personal and confidential information held by us. Avenues Australia may ask individuals to verify their identity before processing any access or correction requests, to ensure that the personal and confidential information Avenues Australia holds is properly protected.

Requests for information are generally managed under the Freedom of Information Act 1992 (WA). However, some requests for personal and confidential information may be dealt with informally Individuals can contact their Avenues Australia contact or Avenues Australia’s Privacy Officer (details below) to discuss their requirements.

Freedom of Information requests need to be in writing stating as precisely as possible what information is required or needs correction. Avenues Australia has a Freedom of Information request form which is available on request.

Any Freedom of Information requests should be addressed to:

Information Officer
Mail:           2/255 Beaufort Street, Perth WA 6000
Phone:       1300 208 594
Email:         hello@avenuesaustralia.com

Complaints

If individuals have a complaint about how Avenues Australia has collected or handled their personal information, please contact Avenues Australia’s Privacy Officer (details below).

Avenues Australia will ask individuals to explain the circumstances of the matter that they are complaining about, how they believe their privacy has been interfered with and how they believe their complaint should be resolved. 

Avenues Australia will complete a review of their complaint in accordance with its Serious Incident Policy. This may include, for example, gathering the relevant facts, locating and reviewing relevant documents and speaking to relevant individuals. 

Avenues Australia will try to resolve their complaint in a fair and reasonable way. In most cases, Avenues Australia expects that complaints will be investigated, and a response provided within 21 days of receipt of the complaint. If the matter is more complex and the investigation may take longer, Avenues Australia will write and let the complainant know, and tell them when Avenues Australia expects to provide a response.

If the person is unhappy with Avenues Australia’s response, they can refer their complaint to the Office of the Australian Information Commissioner or, in some instances, other regulatory bodies, such as The Information Commissioner.

Avenues Australia’s Contact Details

Clients and relevant others for whom Avenues Australia holds information can contact Avenues Australia if they have any queries about the personal and confidential information that Avenues Australia hold about them or the way Avenues Australia handles that personal information. Avenues Australia’s contact details for privacy queries are set out below.

Avenues Australia’s Privacy Officer
Mail:           2/255 Beaufort Street, Perth WA 6000
Phone:       1300 208 594
Email:         hello@avenuesaustralia.com

Changes to This Policy

Avenues Australia may amend this Privacy Policy from time to time. The current version will be posted on Avenues Australia’s website and a copy may be obtained from Avenues Australia’s Privacy Officer.

Responsibilities

All managers and employees are responsible for compliance with this Privacy Policy when collecting, managing, releasing and storing personal and confidential information relating to any client, family member, donor, employee, volunteer, contractor or student on placement.

The Chief Executive Officer is responsible for fulfilling the role of Privacy Officer and for compliance with this policy.