PNP Group Privacy Policy

We take your privacy seriously

The PNP Group and SDA B.O.O.T.S™ (from here on termed PNP) is committed to respecting your privacy. It is our priority that we protect your privacy and ensure that you control the way your information is used. We want to ensure you are fully informed about the way we collect, use and store your information and we want to handle your information in a way that respects and upholds your confidentiality and privacy.

PNP will only collect information that is reasonably necessary for the performance of our business activities and functions, and none of the information collated will be used for unlawful discrimination.

Definitions

We often use the terms “privacy” and confidentiality” interchangeably in our everyday lives. However, they mean distinctly different things.

  • Privacy is concerned with handling personal information: information that identifies the person to whom it relates. For example, Name, age, address, credit card details, or health information. Confidentiality is concerned with protecting information that is not intended to be public. It is an ethical duty that prevents certain people from sharing information with third parties.

  • Health information is any information about a person’s health, medical history or disability. Health information is sensitive and personal, which is why there are laws to protect your rights to keep your health information private.

  • Personal information includes information, or an opinion about a person, that could identify you. In this document, and unless we say otherwise, references to your information also include sensitive information (described in more detail below).

  • Privacy laws are all privacy and data protection laws that apply to us when we handle your information, including the Privacy Act 1998 (Cth) and the Australian Privacy Principles.

PNPs compliance with the Privacy Act means we:

  • Only collect the personal information we need.

  • Do not keep information that we no longer need.

  • Ensure your information is correct and up to date.

  • Seek your consent to keep your records and if required, to clarify records from other parties you may make known to us.

  • Seek your consent to share information.

  • Store your personal information securely.

Personal information we collect

  • general person information, including your name, contact details, date of birth, next of kin/guardian and email address;

  • Centrelink details if you choose;

  • details about your home and living arrangements we have provided to you or that you have enquired about, including any additional information necessary to deliver these;

  • information about your interactions with us, including any activity, messages, comments and other engagement;

  • information collected for our own benefit, including de-identified personal information used to analyse how our website is being used, and how our services may be improved to better client experience; and

  • additional information you provide to us, including any information you provide to us either directly through the website or indirectly through your use of our website.

If you are a tenant or a potential tenant of ours, we may also collect sensitive information about you, including:

  • medical records;

  • other forms of health information, including information about physical and mental health information;

  • guardianship details;

  • NDIS information, including your NDIS plan, participant number, address, goals, support needs, specialist disability accommodation (SDA) determination and SDA funding;

  • Centrelink information; and

  • other information related to relationships with family and friends, financial information and employment history, sexual health and sexual orientation, ethnicity and ethnic origin, memberships of association, political opinions and education.

Because sensitive information affords a higher degree of protection, we will always seek your consent by using a Consent to Exchange Information Form before we collect any sensitive information from you.

How we use your information

We collect, hold, use and disclose your personal information in the course of our ordinary business operations:

  • To provide suitable and appropriate housing.

  • To provide tenancy support and related services to sustain your tenancy.

  • To meet the duty of care requirements, as well as any other legal, SDA and National Disability Insurance Scheme obligations.

  • To keep tenants informed about community and housing related matters.

  • To share relevant information with your consent with support partners.

  • To maintain up to date records in order to identify respond and meet your needs.

  • For compliance with Government and other reporting requirements.

  • To develop our marketing and communications resources.

How we collect your information

We collect your personal information:

  • With your consent from Go Nest, The Housing Hub or the NDIS.

  • From you, by phone or email or face to face meeting.

  • From someone you have specified in the “consent to exchange information form.” This could include a social worker, support coordinator, occupational therapist or a family member.

  • From records you give us permission to access or send directly to us.

  • Through our website or through our various social media platforms.

  • In person at property inspections or meetings we have with you, or through other means of correspondence.

Who do we share your information with?

We may share your information with:

  • our employees and related companies;

  • third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);

  • professional advisers and agents;

  • our existing or potential support partners;

  • specific third parties authorised by you to receive information held by us; and/or

  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Where we store your information

PNP stores your personal information:

  • In hard copy files which are secured in a locked environment.

  • In electronic form on a secured server located in Australia.

For PNP Employees

The type of information we typically collect and hold about PNP employees ranges from personal to sensitive and is used to perform the normal business functions of an employer. Information may include:

·       Information submitted and obtained and other sources in your process of work application;

·       Information about career path and preferences;

·       Information about your work entitlements;

·       Tax File Number, Bank Details and other relevant payrolling information for the purpose of making payment;

·       Work performance information;

·       Information about incidents in the workplace;

·       Information submitted/obtained in relation to absences from work due to leave, illness or other causes.

Direct Marketing

We may use your personal information for the purposes of direct marketing except where you have specifically requested, we don’t. Where it is practicable to do so, we will obtain your consent, and you will be provided with the option to unsubscribe from direct marketing at any time. When it is not practicable to obtain consent, you will be provided with the option to unsubscribe from direct marketing once communications are sent. We market to our clients using a variety of methods including email, phone, SMS, and print.

We provide all clients the option to opt out of receiving marketing material from us. Upon receipt of this request their marketing preferences are updated on our systems. If you do not wish to have your personal information used for direct marketing purposes, you may contact us to request not to receive direct marketing communications from us, at which time your marketing preferences will be updated on our systems.

Web Browsing

When you come to our website (sdaboots.com), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

Cookies

We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. 

However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

Third party sites

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that PNP is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information. 

 When you look at our website, our website host makes a record of the visit and logs (in server logs) the following information for statistical purposes:

·       Your server address;

·       Your top-level domain name (for example .com, .gov, .org, .au, etc);

·       The pages you accessed, and documents downloaded;

·       The previous site you visited and;

·       The type of browser being used.

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet service provider's server logs.

We do not accept responsibility for the privacy policy of any other site to which our site has a hyperlink, and it is advisable to look at the privacy policy of other sites before disclosing personal information.

Emails

Our technology systems log emails received, sent, may include voting, read and receipt notifications to enable tracking. Our mass email technology systems also collect usage data such as receipts, bounce backs, open, open location and click-through rates and subsequent ochrerecruitment.com website actions. When your email address is received by us because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Call and Message Logs

Our telephone technology (systems and mobile phones) logs telephone calls, messages received and sent and enables call number display, which may include your profile picture if you have provided it. When your call number is received by us because you phone us or send us a message, the number (and profile picture) will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Database

We use a database to log and record communication operations. This database contains the information and documentation you have provided us. This database operates from servers that permit disclosure to cross-border recipients. Your information will only be used or disclosed as reasonably necessary for the performance of our functions and activities as a recruitment agency.

Mobile Access

Our staff use laptops, tablets, phones and other portable electronic devices that allow them to access, retrieve and store your personal information. This is used for recruitment purposes and will only be used or disclosed for the purpose for which you have provided it.

Security of your information

We generally hold information in our electronic databases, but we also store personal information in hard copy form and in various third-party cloud databases and platforms.

Our website and our working environment are built with integrated physical, electronic and managerial processes designed to safeguard your information and protect it from misuse, interference loss and unauthorised access, modification or disclosure.

We take reasonable steps (including a number of physical, administrative, personnel and technical measures) to protect your information from misuse, inference, abuse, unauthorised access and loss including:

Staff training – we train our staff about how to keep your information safe and secure.

Secure storage and handling – we use a combination of techniques to maintain the security of our website and to protect your account and your information.

Destroying or de-identifying information – we keep your information for as long as we need it, or as we are lawfully required to keep it.

Other measures include:

·       Password protection of cloud-based database and document storage system;

·       "Clean desk" procedures;

·       Secure office premises with restricted access;

·       Need-to-know and authorisation policies;

·       Policies on laptop, mobile phone and portable storage device security;

·       Document naming protocols for sensitive information;

·       Document culling procedures including shredding and secure disposal.

What about other information we tell you?

Further to Personal Information we explicitly seek, we will come to know each-other as individuals, you may choose to share more information about your circumstances that we have not explicitly sought. This could involve relationships with your family and friends, or financial information, and may include information about your sexuality, sexual health, personal history, ethnicity, previous employment, criminal records, mental health, racial or ethnic origin, memberships of associations, political opinions or education.

PNP treats this information as private. If any aspects of this indirect sharing with us requires further communication, consideration, filing, discussion, or storage, we will seek your specific consent to do so.

How to gain access to your personal information we hold

You have a right on request to access your own personal information held by us. You can request access to your personal information by request, or you can ask us to update your personal information if your circumstances change by contacting info@sdaboots.com.au

Confidentiality Complaints

We take our obligations under the privacy laws seriously. If you think we have breached the privacy laws or wish to make a complaint about the way we have handled your information, you can call us on 1300 767 462 or email us using info@sdaboots.com.au

Any complaint made will be investigated by our management team and the outcome of that investigation will be communicated to you as soon as we are able to.

If you are not satisfied with the outcome of any internal investigation we conduct, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at enquiries@oaic.gov.au or on 1300 363 992. More information is available on the OAIC’s website at https://www.oaic.gov.au/.

Changes to our privacy and information handling

We reserve the right to change this policy from time to time.

If this document changes, an updated version will be published as soon as possible.

Complaints

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.

How to complain

If you are making a complaint about our handling of your personal information, it should first be made to us in writing. You can make complaints about our handling of your personal information to 1300 767 462 or info@sdaboots.com

Future Changes

PNP may update this policy considering future changes to privacy laws, technology and business practice. It is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.

References and Related Documents

Australian Privacy Act (1988)

Australian Privacy Principles or APPs in the Privacy Act 1988