Privacy Policy 

Independence Australia (Health Solutions, Mobility Aids Australia, Community Workforce Innovations and Community Solutions) respects every individual’s right to privacy. Independence Australia is committed to maintaining the privacy of your personal information. This policy sets out how we collect, use and manage personal information in accordance with the Australian Privacy Principles (APPs) outlined in the Privacy Act 1988 (Commonwealth) (Privacy Act) and any applicable state or territory legislation.Privacy law is regulated by the Australian Information Commissioner. Further information about privacy legislation can be obtained from the Office of the Australian Information Commissioner website at: www.oaic.gov.au 

Purpose

This privacy policy sets out how Independence Australia complies with its obligations under the Privacy Act regarding the collection, use, disclosure, storage, security and access of the personal information of clients, customers, students, donors, members, volunteers, job applicants and staff.

Policy

Collection of personal information
The Privacy Act defines personal information as “information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.” 

Independence Australia will only collect personal information necessary to deliver our services and conduct the business activities that support this. We may collect the following types of personal information:

- your name, address and contact details (eg phone, email and fax);
- details for next of kin or emergency contact;
- donor number;
- photographs, video recordings and audio records of you;  
- job applications;
- the product and services you have purchased or which you have enquired about, together with additional information necessary to deliver those products and services and to respond to your enquires;
- where required by the police or other government bodies to provide information;- payment details eg credit card details; and- other information relevant to the relationship of the individual with Independence Australia. 

We may also collect sensitive information such as:

- details of a complaint; 
- racial or ethnic origin; 
- health and wellbeing information where relevant to the services or the performance of the duties sought by the individual.

Methods of collecting personal information 

Independence Australia collects personal information through a variety of methods including:

- electronic or face to face interactions; 
- interaction with our website; 
- requests for information; and 
- provision of goods and services. 

We collect personal information directly from individuals or their authorised representatives; through referrals from other service providers; product order and deliveries; donations; campaigns; and via purchased lists.

Information collected on our website
In common with many websites we may collect aggregated information which tells us about visitors to the Independence Australia site but not the identity of those visitors. For example, we may collect information about the date, time and duration of visits and which pages of the Independence Australia website are most commonly accessed. This information is used by us to help to administer and improve the Independence Australia website. 

The Independence Australia website may use ‘cookies’. A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies are generally used on Independence Australia sites to: 

- Access online services – if you visit an Independence Australia website and log into our secure areas we will use cookies to enable us to authorise your access and save your preferences
- Manage advertising – we use advertising companies to deliver our online advertising. When you see one of our ads on a third party website, cookies are sometimes used to collect anonymous information about what pages you visit and the type of software you are using. 
- Monitor traffic – we use Google analytics to gather anonymous information about how people are using the Independence Australia site, this information includes times of visit, pages visited, and some system information about the type of computer you are using. We use this information to enhance the content and services offered on the site.

You can configure your browsers to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the “help” menu of your browser to learn how to change your cookie preferences). 

If you disable the use of cookies on your web browser or remove or reject specific cookies from Independence Australia website or linked sites then you may not be able to gain access to all of the content and facilities on those websites.  

Use of personal information
Independence Australia uses personal information to provide goods and services. We may also use personal information to notify individuals of information and opportunities they may be interested in. De-identified data may be used to meet regulatory and funding requirements or for the purposes of internal reporting and improvement of services. Where not previously requested, and in accordance with Privacy legislation, we may use personal information to communicate with individuals through emails, newsletters or direct marketing. All such communications will provide an option to opt out or unsubscribe. Requests to opt out or unsubscribe can also be directed to privacy@independenceaustralia.com or 1300 704 456. 

To whom we may disclose your information
The third parties we may disclose your personal information to include, but are not limited to:

- Our employees, contractors, or services providers for the purposes of operation of our website or our functions, fulfilling requests by you and to otherwise provide information, products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors and professional advisors such as accountants, solicitors’, business advisors and consultants. 
- Government departments/agencies who provide funding for Independence Australia services 

Security of personal information
Independence Australia will take reasonable steps to protect personal information from misuse, interference and loss, unauthorised access, modification or disclosure. Personal information held by Independence Australia is stored electronically in secure databases, or where retention of hard copy documents is required, in secure filing systems. Only authorised Independence Australia personnel are provided with access to an individual’s personal information. Where personal information is no longer required by the Independence Australia, or where required by law, Independence Australia will securely destroy or de-identify information in accordance with legal requirements for retention and disposal.

Access and correction
Individuals may request access to the personal information Independence Australia holds about them. Where reasonable and practicable to do so, and in accordance with the provisions of the Privacy Act, Independence Australia will provide supervised access to an individual’s personal information. 

Requests to access personal information must be made in writing, either by email or hard copy. In the event access to records requires a significant allocation of resources, we may charge a reasonable administration fee to cover costs. Corrections or updates to personal information supplied by clients or their authorised representatives must be made by the individual or their authorised representative. 

In all cases, Independence Australia staff must be satisfied changes are authorised by the individual in question. Requests to change personal information supplied by clients or their authorised representative will be actioned as a priority.

Disclosure of personal information overseas
In situations where Independence Australia may disclose personal information overseas, Independence Australia will take reasonable steps to ensure that the overseas entity will comply with the APPs. 

Use, adoption or disclosure of government related identifiers
Independence Australia will not use, adopt or disclose an identifier assigned to an individual by a Commonwealth agency unless required to by law or where reasonably necessary and in accordance with the APPs.

Anonymity and pseudonymity
Where practical, individuals may deal with Independence Australia anonymously or use a pseudonym. The majority of our services, however, will require collection of personal information to enable Independence Australia to provide the appropriate goods, services or response.

Notification
Notifying the individual at collection – When collecting personal information directly from an individual, Independence Australia will take reasonable steps to notify, or otherwise ensure that the individual is aware: 

- That Independence Australia privacy policy provides information about how to access and seek correction of the personal information, and about how to lodge a complaint. 
- If and/or when Independence Australia is likely to disclose an individual’s personal information to overseas recipients and, if it is practicable to specify, the countries in which those recipients are likely to be located. 

Notifying the individual if information is collected from a third party – If Independence Australia collects personal information from someone other than the individual, or the individual may not be aware that the organisation has collected the personal information, reasonable steps will be taken to notify the individual, or otherwise ensure that the individual is aware:
- That Independence Australia collects or has collected the information
Of the circumstances of the collection, including:
* From whom the information was collected and
* The law under which Independence Australia collected the information
- To whom Independence Australia may disclose the information, and
Of the consequence of Independence Australia not collecting the information.

Review and improvement
Independence Australia may update this Privacy Policy from time to time to reflect changes to legislation or internal process improvements. An up to date copy of this policy will be maintained on the Independence Australia website which can be accessed via this link: Privacy Policy. 

Complaints and enquiries 
Independence Australia takes all complaints seriously. To lodge a complaint, either complete the Complaints and Suggestions form on the Independence Australia website or you can direct your complaints or suggestions via feedback@independenceaustralia.com or by phoning call 1300 704 456. 

Requests or enquiries regarding this privacy policy or personal information held by Independence Australia can be made by email: privacy@independenceaustralia.com, or by phoning our Privacy Officer on 1300 704 456.