Privacy Policy

Holyoake respects your privacy and will ensure that your personal information is kept confidential. Holyoake believes privacy is an important right of individuals. Holyoake is committed to protecting personal information by complying with relevant laws and takes steps to protect your personal information from misuse and to use your information only in the ways described in this privacy policy and in accordance with the Privacy Act 1988 (Cth) (Privacy Act). This privacy policy outlines Holyoake’s personal information handling practices.

This privacy policy is intended to explain clearly how Holyoake collects, holds, uses and discloses personal information, how individuals may access and correct their personal information, and how privacy complaints may be made and handled.

Anonymity and pseudonymity

In most circumstances, it is impractical for people to communicate with us anonymously. We need to identify you to assist you effectively. However, in circumstances where it is lawful and practicable to do so, we will provide you with the option of not identifying yourself, or using a pseudonym, when entering into communications with us.

Collection of personal information

Personal information means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.

The personal information which we collect, store, use and disclose may include:

• your name;
• your contact details;
• your age or date of birth;
• your current occupation; and
• any other personal information provided by you during the course of your interactions or correspondence with Holyoake.

Some personal information is considered ‘sensitive information’ for the purposes of the Privacy Act. Where necessary, and in some circumstances, we may need to collect sensitive information about you to be able to provide an effective service. For example, where necessary to provide our services to you, this might include information about your:

• health,
• racial or ethnic origin
• criminal history.

We only collect personal information by lawful and fair means where reasonably necessary for our functions or activities as a not-for-profit organisation providing support to individuals, families and communities who are impacted by alcohol, other drugs and related mental wellbeing challenges.

When asking you to provide personal information, Holyoake will inform you of the purpose of gathering such information, the nature of the third parties to whom Holyoake may provide that information, and Holyoake’s contact details.

Holyoake may collect personal information directly from you, or from another person or organisation where this is authorised by you, required or authorised by law, or reasonably necessary for Holyoake to provide services safely and effectively. This may include collection during intake, assessment, counselling or support services, referral pathways, complaint handling, surveys, website enquiries, events, employment or volunteering processes, and other interactions with Holyoake.

Holding and security of personal information

Holyoake holds personal information in electronic systems, paper records and other secure business records. Holyoake takes reasonable steps to protect personal information it holds from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps may include role-based access controls, password protection, secure storage, staff privacy and confidentiality training, document handling controls, workspace audits, system and process reviews, and limiting access to personal information to those who need it to perform their role or function.

Because Holyoake provides services to people who may be experiencing complex needs and vulnerability, Holyoake recognises that it may hold highly sensitive information and that stronger safeguards may be required as the sensitivity of information increases. Holyoake will continue to review privacy and information handling risks across all Holyoake locations, not only individual sites, and will take reasonable steps to address identified risks.

Holyoake will take reasonable steps to destroy or de-identify personal information when it is no longer required for a lawful purpose, subject to legal, contractual, funding, clinical and recordkeeping obligations.

Use and disclosure of personal information

Holyoake collects, holds, uses and discloses personal information for purposes connected with its functions and activities, including providing services, managing referrals, supporting consumer safety and wellbeing, communicating with consumers and stakeholders, meeting legal and contractual obligations, managing complaints and feedback, quality improvement, reporting to funders where required, workforce management, governance, risk management, and service planning.

Holyoake will only use or disclose personal information for the purpose for which it was collected, for a related purpose that would reasonably be expected, with consent, or where otherwise required or authorised by law.

Accessing and correcting your personal information

You may request access to personal information that Holyoake holds about you, or ask Holyoake to correct information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading. Requests should be made to Holyoake using the contact details in this policy.

Holyoake will respond to access and correction requests within a reasonable period and in accordance with the Privacy Act. In some circumstances, Holyoake may refuse access or correction where permitted by law, for example where access would have an unreasonable impact on the privacy of others, would pose a serious threat to health or safety, or where another lawful exception applies. If Holyoake refuses a request, it will provide reasons where reasonable and lawful to do so, and will explain available complaint options.

Privacy complaints

If you are concerned that Holyoake has breached the Australian Privacy Principles, a registered APP code that applies to Holyoake, or this privacy policy, you may make a privacy complaint using the contact details in this policy.

Holyoake will acknowledge privacy complaints within a reasonable period, assess the issues raised, make any necessary enquiries, and provide a response. Where appropriate, Holyoake may take steps such as correcting records, changing practices or procedures, providing further information, staff training, an apology, or other appropriate action.

If you are not satisfied with Holyoake’s response, you may contact the Office of the Australian Information Commissioner. The OAIC can be contacted at www.oaic.gov.au or on 1300 363 992.

Social media and cookies

We use a range of tools provided by third parties, including Google, and our web hosting company to collect or view website traffic information. These sites have their own privacy policies. We also use cookies and session tools to improve a consumer’s experience when accessing our websites. The information collected by these tools may include the IP address of the device used and information about sites that IP address has come from, the pages accessed on our site and the next site visited.

We use the information to maintain, secure and improve our websites and to enhance a consumer’s experience when using them. In relation to Google Analytics you can opt out of the collection of this information using the Google Analytics Opt-out Browser Add-on.

We use social networking services such as LinkedIn, Facebook and Instagram to communicate with the public about our work. When someone communicates with us using these services we may collect their personal information, but we only use it to help us to communicate with the consumer and the public. The social networking service will also handle a consumer’s personal information for its own purposes. These sites have their own privacy policies.

Direct marketing

Unless you request otherwise, we may also use your personal information for marketing purposes to send you news, information about our activities and general promotional material which we believe may be useful or of interest to you. If you do not want us to use your personal information in this manner, please contact us with your request as soon as possible.

Disclosure to overseas recipients

Holyoake is not likely to disclose personal information to overseas recipients unless this is required or authorised by law, necessary to use a service provider or technology platform that stores or processes information overseas, or you have consented to the disclosure. Where Holyoake becomes aware that personal information is likely to be disclosed to overseas recipients, it will take reasonable steps to address the requirements of the Privacy Act and, where practicable, identify the countries in which such recipients are likely to be located.

Contact details

Privacy enquiries, access or correction requests, and privacy complaints may be directed to Holyoake by telephone, email, post or through the contact channels published on this, Holyoake’s website.