Privacy Policy
Privacy Policy
Purpose and scope
Women’s Legal Service Victoria is committed to ensuring that personal information is handled in accordance with Victorian and Federal privacy laws.
This policy explains how we collect, uses, discloses and manages personal, sensitive and health information. This policy applies to information about:
• clients and service users
• people who provide services on our behalf
• board members and staff
• donors.
Definitions
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Definition |
Meaning |
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Personal Information |
Information or an opinion (including information or an opinion forming part of a database), that is recorded in any form (whether true or not), about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. |
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Sensitive Information |
A category of personal information that refers to an individual’s: • racial/ethnic origin • political opinions/association • religious or philosophical beliefs • membership of a professional or trade association or union • sexual preferences or practices, or • criminal record. |
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Health Information |
Personal information that includes, among other things, information or an opinion about an individual’s health, disability, or genetic makeup. |
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Service users |
Anyone that receives a legal or non-legal service through Women’s Legal Service Victoria. |
|
Staff |
Employees, volunteers, secondees, personnel, contractors and sub-contractors |
Policy Statement
Women’s Legal Service Victoria will:
• only collect personal and health information necessary to fulfil our functions, or another purpose with your consent;
• seek to ensure you are informed about why we collect information and how we use it
• use and disclose personal and health information in accordance with the law;
• store personal and health information securely;
• provide you with access to your information where possible;
• take steps to correct inaccurate information.
When is information confidential
All personal and health information disclosed to our staff is treated as strictly confidential.
Legal professional privilege protects information disclosed to a lawyer for the dominant purpose of seeking legal advice. Social workers and financial counsellors have professional and ethical obligations to respect the rights of clients to a relationship of trust, to privacy and confidentiality. Social workers and financial counsellors are not subject to legal privilege
See further below for circumstances in which disclosure of confidential information may be required.
The information that we need depends on how you interact with our service. Without relevant information we may not be able to provide you with our services.
The main types of information we collect are:
- your name, date of birth and contact details
- financial information, such as income and Centrelink benefits
- gender or cultural identity
- domestic and lifestyle circumstances, such as occupation, relationship status, number of children
- health and/or disability information
- language barriers and/or need for an interpreter
- copies of identity documents such as a marriage certificate, birth certificate, drivers license
- visa information and passport copies
- education, employment history and referees for job applicants
- payment details and dietary requirements if you attend training or events
- security footage from our offices
- COVID-19 vaccination status
- IP addresses required to communicate via our webchat service
We may collect personal and health information where:
- you submit a query or request to us;
- you provide feedback about our services;
- you fill in surveys or forms on our website;
- you attend an event;
- a third party is authorised to share information about you with us;
- you use our website;
- you apply for a job with us.
We will generally collect information from you directly. However, in some cases we may collect information from a Government Department or other service provider. We will take reasonable steps to ensure that you are aware of any information provided to us.
We generally collect information in digital form. Copies of documents should be provided unless we have requested original documents. Source records (physical paperwork or media items) may be digitised and disposed of. Please let us know immediately if you want documents returned to you.
We use personal and health information to:
- provide legal and non-legal services (including to assess if you are eligible for legal aid)
- make referrals to other services
- carry out education and training programs
- undertake law reform and policy work
- answer enquiries and provide information about our services
- recruit, train and manage staff
- comply with our legal and regulatory obligations
- process and respond to complaints
- meet our reporting obligations to external funders
- undertake research and statistical analysis relevant to our activities
- undertake fundraising and marketing activities including seeking grants
- design and improve our services
- carry out planning and quality control activities
- conduct other internal business processes such as administering our website.
We may use or disclose information for another purpose at your request.
We may disclose information about you to:
- other people or organisations with your consent;
- our staff including volunteers and contractors;
- professional advisers we engage to provide advice (for example a barrister);
- a court so we can obtain relevant documents
- our business and service providers (for example IT support);
- our funding providers (although personal information will only be provided with consent);
- government authorities or other people where required by law;
We do not direct market or provide personal information to other organisations for marketing purposes. We will never sell your information.
In rare circumstances our lawyers may be compelled by law to disclose confidential information, for example:
- Where we receives a subpoena and the information is not covered by legal privilege;
- Where there is an imminent risk of serious harm to you, including suicide;
- Where there is an imminent risk of harm to another person;
- For the purpose of avoiding a serious crime
Social workers and financial counsellors must adhere to professional standards. They may have to disclose confidential information sometimes, for example where an actual, identifiable risk of harm to a specific person or persons can be prevented.
Our practitioners will advise you of the limits of confidentiality when you first engage with our service. You are welcome to discuss confidentiality with the person assisting you at any time. If we are required to disclose confidential information, we will take steps to obtain your consent first, where permitted by law.
We may share de-identified information or data with other organisations to improve service delivery, or for the purposes of research, evaluation and law reform. We only do this where the law allows and where possible, will seek your consent first.
We store personal information for the purpose for which it was collected for as long as it is needed or required by law. We use a range of security measures to protect personal information including:
- website protections (such as encryption, firewalls and anti-virus software);
- access restrictions on our computer systems and mobile devices;
- external client management systems that have strict privacy controls;
- restricted access to our office premises;
- staff training and security procedures.
Our staff are required to handle information with care, and only access information necessary to perform their role. All staff and board members are required to sign a confidentiality agreement.
We legally disposes of inactive information as authorised, or de-identify information when it is no longer required in accordance with the Public Records Act 1973 (Vic).
Transfer of information outside of Victoria
Women’s Legal Service Victoria will only transfer personal information outside of Victoria if:
• the individual consents to the transfer
• we reasonably believe the person receiving the information is subject to similar requirements to Victorian privacy law, or
• we have taken reasonable steps to ensure the information will not be held, used or disclosed inconsistently with Victorian Privacy Law.
We will not disclose your personal information to anyone outside Australia without your consent.
Use of unique identifiers
We create a client number for clients who accesses our services. This unique identifier helps us record services provided, make referrals, and avoid conflicts of interest.
How to access and correct your personal information
We take steps to ensure the information we have about you is accurate. Please let us know if your personal circumstances change, so we can update our records. To protect the integrity and security of personal information, we may ask to verify your identity. We will correct information if we are satisfied that it is inaccurate. We will notify third parties of the correction at your request, where possible.
You can request electronic copies of documents by contacting the staff member who has assisted you. A copy of the relevant part of your file will be provided as soon as practicable. There may be cases where we are unable to provide information, for example where it would interfere with the privacy of others. We will let you if we cannot comply with your request as well as available complaint mechanisms.
Information collected through our website
We use Google Analytics to analyse how our website is used to help us make it better. We do this using cookies. Cookies are small files placed on a user’s computer to help remember their preferences. Most internet browsers allow the user to disable cookies altogether – please refer to the browser’s help menu to find out how to do this. While a service user will still be able to browse our websites with cookies disabled, some website functionality may not be available or may not function correctly. We do not use this information to identify service users.
We use Eventbrite to manage training and event registrations. When registering for an event, a user may be required to give Eventbrite personal information including name and contact details. The service user may also be required to provide financial information, including credit card number and expiration date, if they make a payment for an event. Eventbrite may share with us some of the user’s personal information, including information about whether a particular registered individual has made payment, but we do not receive the financial information. Eventbrite has its own privacy policy which can be read here.
We use Campaign Monitor to email information about our events, training, organisational updates and fundraising activities. Campaign Monitor has its own privacy policy. The policy can be found here.
We use LinkedIn and Twitter to communicate with the public about our work. When people communicate with us using social media platforms we may collect their personal information, but we only use it for communication purposes. Social media platforms have their own privacy policies which we encourage you to read.
Any links on our website to third party websites that are not operated or controlled by us are provided for the users’ convenience. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying personal information to them.
Data Breaches
A data breach occurs when information is lost, disclosed to, or accessed by, an individual or third party without authorisation. This could happen because of a malicious action such as theft, phishing or hacking, or accidental disclosure. If a data breach occurs, we will take immediate action to neutralise and contain the breach. If we assess that the breach is likely to result in serious harm, we will promptly notify you and the Australian Information Commissioner (OIAC).
Privacy enquiries and Complaints
If you have questions, concerns or feedback about how we manage your personal information, you can contact us in writing or verbally.
Written complaints should be sent by email to [email protected]. We will always endeavour to resolve any complaint , however, if you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner (www.oaic.gov.au).
Please refer to our Feedback and Complaints page for more information.