Your privacy is important
This statement outlines Distinctive Options’ policy on how Distinctive Options uses and manages personal information provided to or collected by it.
Distinctive Options is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act and is compliant with the Privacy Amendment (Enhancing Privacy Protection) Act 2012. Distinctive Options is also bound by the Victorian Health Privacy Principles which are contained in the Health Records Act 2001.
Distinctive Options may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the organisation’s operations and practices and to make sure it remains appropriate to the changing legal environment.
What kind of personal information does Distinctive Options collect and how does Distinctive Options collect it?
The type of information Distinctive Options collects and holds includes (but is not limited to) personal information, including sensitive information, about:
- Your name, address, telephone number and email contact details
- Your gender, date of birth and marital status
- Your disability and support requirements
- Your health and medical information
- Your living arrangements
- Your NDIS participation, including your funding information
- Your financial details
- Information about routines, goals and activities you participate in
- Information about other services you access
Personal Information you provide
Distinctive Options will generally collect personal information held about an individual by way of:
- Phone calls
- Forms (hardcopy, online and through website submission)
- Meetings
You have the right to seek to deal with us anonymously or using a pseudonym, but in almost every circumstance it will not be practicable for us to deal with you or provide any services to you except for the most general responses to general enquiries, unless you identify yourself.
Personal information provided by other people
In some circumstances, Distinctive Options may be provided with personal information about an individual from a third party, for example:
- The NDIA
- Another service provider
- An advocate
In relation to employee records
Under the Privacy Act, the Australian Privacy Principles do not apply to employee records. As a result, this Privacy Policy does not apply to the organisation’s treatment of employee records, where the treatment is directly related to a current or former employment relationship between the organisation and employee. However, Distinctive Options must provide access and ensure compliance with the Health Privacy Principles under the Victorian Health Records Act 2001.
How will Distinctive Options use the personal information you provide?
Distinctive Options will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which you have consented.
Participants
The purposes for which Distinctive Options uses personal information of participants or their support networks include:
- Provision of information about services and supports
- Service and support delivery
- Delivery of internal functions, including administration, training, accounting, audit and information technology
- Complaint and incident management
- Provision of surveys
- Participation in external audits by the NDIA
- To comply with laws and regulations and in reporting to funding and government bodies
Job applicants, staff members and contractors
In relation to personal information of job applicants, staff members and contractors, the primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be.
The purposes for which Distinctive Options uses personal information of job applicants, staff members and contractors include:
- Provision of recruitment and onboarding
- Provision of surveys
- For insurance purposes
- To comply with laws and regulations and in reporting to funding and government bodies
Where Distinctive Options receives unsolicited job applications these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.
Volunteers
Distinctive Options also obtains personal information about volunteers who assist the organisation in its functions or conduct associated activities, such as to enable the organisation and the volunteers to work together.
Marketing and fundraising
In relation to direct marketing, Distinctive Options will use your personal information for direct marketing where you have provided that information, and you are likely to expect direct marketing: only then you will be sent direct marketing containing an opt out. If we use your personal information obtained from elsewhere we will still send you direct marketing information where you have consented and which will also contain an opt out. We will always obtain your consent to use sensitive information as the basis for any of our direct marketing.
Personal information held by Distinctive Options may be disclosed to an organisation that assists in the fundraising.
Who might Distinctive Options disclose personal information to?
Distinctive Options may disclose personal information, including sensitive information, held about an individual to:
- Your support network
- People acting on your behalf, including nominated representatives, legal guardians and advocates
- Your other service providers
- Government and regulatory bodies, including the National Disability Insurance Agency (NDIA), the Department of Families, Fairness and Housing (DFFH) and the Australian Taxation Office (ATO)
- People providing services to Distinctive Options, such as web hosting partners
- Anyone you authorise Distinctive Options to disclose information to
Sending information overseas
Distinctive Options will not send personal information about an individual outside Australia without:
- obtaining the consent of the individual (in some cases this consent will be implied)
- otherwise complying with the Australian Privacy Principles or other applicable privacy legislation
We do not use overseas providers of IT services including servers and cloud services.
How does Distinctive Options treat sensitive information?
In referring to ‘sensitive information’, Distinctive Options means information relating to a person’s racial ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation or criminal record, that is also personal information; and health information about an individual.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.
Management and security of personal information
Distinctive Options’ staff are required to respect the confidentiality of personal information and the privacy of individuals.
Distinctive Options has in place steps to protect the personal information the organisation holds from misuse, loss, unauthorised access, modification, interference or disclosure by use of various methods including locked storage of paper records and passworded access rights to computerised records.
There are occasions where personal information about you may be collected on a mobile device that is not owned by Distinctive Options. In such circumstances, Distinctive Options reinforces the importance of removing information and images from personal devices as soon as the content has been transferred to Distinctive Options’ systems for appropriate storage.
We have a data breach response plan, which we would follow in the unlikely event of a privacy or data breach.
When you use our website, having your cookies enabled will allow us to maintain the continuity of your browsing session and remember your details when you return. We may also use web beacons, Flash local stored objects and JavaScript. If you adjust your browser settings to block, reject or delete these functions, the webpage may not function in an optimal manner. We may also collect information about your IP address.
Updating personal information
Distinctive Options endeavours to ensure that the personal information it holds is accurate, complete and current. A person may seek to update their personal information held by the organisation by contacting the Manager Corporate Services at any time.
The Australian Privacy Principles and the Health Privacy Principles require Distinctive Options not to store personal information longer than necessary. In particular, the Health Privacy Principles impose certain obligations about the length of time health records must be stored.
You have the right to check what personal information the Distinctive Options holds about you. Under the Commonwealth Privacy Act and the Health Records Act, an individual has the right to obtain access to any personal information which the organisation holds about them and to advise the organisation of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation.
To make a request to access any information Distinctive Options holds about you, please contact the Manager Corporate Services in writing. Distinctive Options may require you to verify your identity and specify what information you require. Although no fee will be charged for accessing your personal information or making a correction, Distinctive Options may charge a fee to retrieve and copy any material. If the information sought is extensive, Distinctive Options will advise the likely cost in advance.
How long will Distinctive Options keep my information?
Under our destruction and de-identification policies, your personal information that is no longer required by Distinctive Options or by law will be de-identified or destroyed. It may be kept for marketing purposes if you have consented to that in writing with us.
Enquiries and Privacy Complaints
If you would like further information about the way Distinctive Options manages the personal information it holds, please contact the Manager Corporate Services via email to info@d-o.com.au or phone at 9740 7100. If you have any concerns, complaints or you think there has been a breach of privacy, please contact the Manager Corporate Services who will first deal with you usually over the phone. If we then have not dealt satisfactorily with your concerns we will meet with you to discuss further.
If you are not satisfied with our response to your complaint within 30 days from this meeting, you can refer your complaint to the Office of the Australian Information Commissioner via email to enquiries@oaic.gov.au or phone at 1300 363 992.