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This policy describes how St Ives Group manages the collection, use and disclosure of personal information in an open and transparent way and protects the privacy of individuals regarding the personal information held.
The St Ives Group is committed to protecting the personal information it collects in accordance with the requirements of the APPs.
This policy allocates responsibilities for:
St Ives Group is committed to ensuring that:
The Policy Collection Statement can be found in the St Ives Group Privacy brochure or by contacting the St Ives Group as per Section 5.14.
St Ives Group will only collect and hold personal information about an individual that is reasonably necessary for our business functions, activities and the provision of services and advice related to that individual, or where the collection and storage is required or authorised by or under an Australian law or a court/tribunal order.
Our functions and activities include, but are not limited to:
The personal information collected and held will depend upon the nature of the services being provided by St Ives Group.
The types of personal information collected and held, having regard to the nature of the services provided by St Ives Group, include but are not limited to:
In the course of carrying out recruitment activities in respect of employees we may collect a wide range of information, including information regarding an applicant’s educational qualifications, career history, interests, hobbies and job interests and such other information as may be routinely included within a curriculum vitae.
St Ives Group will only collect personal information by lawful and fair means and not in an unreasonably intrusive way. Personal information will usually be collected directly from the individual (or their personal representative) unless St Ives Group receives authority from that person to obtain information from another source or other exceptional circumstances exist.
St Ives Group will only collect personal information from third parties if:
St Ives Group will take all reasonable steps to ensure that personal information collected is secure, accurate, complete and up-to-date and that the individual is aware:
Sensitive personal information includes information, or an opinion about matters like an individual’s health, criminal history or racial or ethnic origin. In limited circumstances, St Ives Group may need to collect this information from individuals where the collection is reasonably necessary for one or more of our activities or functions.
St Ives Group will not collect sensitive information about an individual unless the individual has consented, or such collection is required or authorised by law. In the case of health information, specific requirements are complied with, as outlined in the APPs.
Generally, we will only use or disclose personal information for the purpose for which it was collected (the primary purpose), including the purposes set out above.
However, we may use or disclose personal information for secondary purposes if we receive your consent to do so, or without your consent if you would reasonably expect us to use your information for the secondary purpose, or otherwise when the APPs permit us to do so.
For example, the APPs permit us to use and disclose personal information for a secondary purpose without an individual’s consent if the individual would reasonably expect us to use or disclose the information for a certain secondary purpose and the secondary purpose is:
We may collect, hold, use and disclose your personal information for the following purposes (amongst others):
The personal information collected is used to identify individuals within St Ives Group Information Technology (IT) systems and forms the basis for contracts entered into by St Ives Group external contacts.
Selected information is used to assess the suitability of individuals for admission to St Ives Group facilities and provision of services as appropriate.
St Ives Staff may access personal information, when necessary, during the course of their duties as do external health professionals such as the individual’s nominated General Practitioner (GP) and pharmacists.
St Ives Group will take all reasonable steps to ensure that personal information used or disclosed is accurate, up to date, complete and relevant, having regard to the purpose of its use and disclosure.
All organisations that St Ives Group may disclose personal information to are subject to strict guidelines on how they use the personal information.
At or before the time we collect personal information about an individual (or, if that is not practicable, as soon as practicable after), we will take such steps as are reasonable in the circumstances to notify the individual of the following information (“Collection Information”):
Circumstances may arise where it would be reasonable for us not to provide the individual about whom the information relates with notice of all or some of the Collection Information. This will often be the case when we are providing emergency ambulance services or similar.
We will endeavour to take reasonable steps to ensure that the personal information that we collect is accurate, up to-date and complete.
The reasonable steps described above that we may undertake include:
An individual may request access to their personal information that is held by St Ives Group by contacting us.
Individuals can request that their information is corrected if they are able to establish that the personal information held is not accurate, complete or up to date.
Individuals are only able to view and correct their own information. The privacy of others will not be compromised to facilitate this.
A request to view or receive a verified copy of the personal information held by St Ives Group can be obtained by submitting the request, in writing to the St Ives Group Privacy Officer (refer Section 5.14).
Individuals will be required to provide St Ives Group with appropriate identification before a request for personal information will be attended to. A reasonable charge may apply to gain access to information, which will be advised upon receipt of a request.
St Ives Group will respond to all requests within ten working days. However, this is dependent on the nature of the request and the accessibility of the information (for example, information may be held in off- site storage premises). Individuals will be informed if there is a delay in providing the requested information and the reason for the delay.
If, with regard to the purpose for which it is held, we are satisfied that personal information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, or if the individual about whom the information relates makes a request, we will take reasonable steps to correct the information. However, as a matter of practice, when we receive personal information, we will hold the information for a period of time before we consider whether it is inaccurate, out-of-date, incomplete, irrelevant or misleading (unless we are informed otherwise).
If we correct personal information, we will take reasonable steps to notify any third party to whom we had previously disclosed the information, if the individual about whom the information relates requests as such and it is not unlawful or impracticable for us to do so.
In limited circumstances, St Ives Group may not allow an individual access to their personal information or may decline requests to correct some of their personal information held. If this occurs, St Ives Group will provide an explanation in writing setting out:
Examples of when St Ives group may decline access to personal information is if:
If we refuse to give access to the personal information in accordance with the APPs, or if we refuse to give access in the manner requested, we will take such steps (if any) that are reasonable in the circumstances to give access in a way that meets our needs and the needs of the individual. The individual may also request that we associate the information with a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. Where such a request is made, we will take reasonable steps to associate the statement so that it is apparent to the users of the personal information.
Where practical, individuals will have the option of remaining anonymous or using a pseudonym when dealing with St Ives Group, such us when making initial enquires into St Ives Group operations and the services provided.
However, we may elect not to deal with the individual anonymously or pseudonymously if:
(a) we are required or authorised by or under an Australian law, or a court/tribunal order, to deal with them in accordance with their identity; or
(b) it is impracticable for us to deal with them in this way.
Operational and legal obligations require that individuals identify themselves to St Ives Group once contractual discussions commence.
St Ives Group will advise if failure to provide personal information may jeopardise the delivery services to an individual.
St Ives Group may hold your information in either electronic or hard copy form. We will take all reasonable steps to ensure that any personal information collected is held securely and protected from misuse, interference and loss, unauthorised access, modification or disclosure, by ensuring the following are in place:
St Ives Group will only retain information that is necessary and relevant to our business operations.
As a general rule, personal information will be retained for at least seven years in order to meet legal and business requirements. Once the information is no longer required, personal information held by St Ives Group will be either destroyed in a secure manner or permanently de-identified so that the information cannot be linked to an individual (unless our compliance with the APPs or a law requires us to avoid taking such steps).
We may need to maintain records of health information in order to assist in providing medical and related services or ensuring that third parties can provide such services. Therefore, we may need to hold health information for longer periods of time than other kinds of personal information in order to carry out some of our functions and activities.
Unsolicited Personal Information is when St Ives Group receives personal information without taking any active steps to collect it.
If we receive personal information that we did not solicit, we will, within a reasonable period of receiving the information, determine whether we would have been permitted to collect the information to the APPs.
If we determine that we have received personal information that we would not have been permitted to collect pursuant to the APPs (and the information is not contained in a Commonwealth record), we will as soon as practicable and where it is lawful and reasonable to do so, destroy the information or ensure that it is de-identified. If the above cannot be determined, St Ives Group will destroy or de-identify the unsolicited personal information as soon as practicable, if it is lawful and reasonable to do so.
If we determine that we would have been permitted to collect the personal information pursuant to the APPs, we will ensure that the information is dealt with in a manner that complies with the APPs.
St Ives Group will not pass on unsolicited personal information received without the prior consent of the sender.
St Ives Group may transfer personal information between countries, if required, for a relevant purpose in circumstances where St Ives Group suppliers, contractors or agents are based overseas, or otherwise have data storage facilities overseas where personal information will be stored.
In some cases, a third party may utilise data storage facilities located in Australia in the ordinary course of business, but reserve the right to transfer data offshore, whether for data safety, or maintenance reasons, or due to available space or data link speeds, or otherwise. In such circumstances, St Ives Group will not necessarily have control over the third party’s movement of data.
In all cases, St Ives Group will take such steps as are reasonable in the circumstances to ensure that the overseas recipient complies with the Privacy Act in relation to that information, unless the APPs do not require us to do so.
We will not be required to take the steps described above if:
St Ives Group may use personal information collected for market research to better understand the needs of individuals with the aim to provide access to a relevant range of St Ives Group products and services.
We may use or disclose personal information (other than sensitive information) for direct marketing if:
(a) we collected the information from the individual concerned;
(b) the individual has consented to, or would reasonably expect us to, use or disclose the information for that purpose; and
(c) we provide the individual with a simple means by which they may easily request not to receive direct marketing communications from us and they have not made such a request to us.
St Ives Group will not:
Do Not Call Register Act 2006 (Cth) and the Spam Act 2003.
Individuals may choose to opt out of St Ives Group marketing activities at any time by contacting St Ives Group directly or via the unsubscribe function or other contact information provided in any marketing you receive.
We may collect personal information about you when you use and access our website, including any additional website features such as a ‘live chat’ function.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.
St Ives Group will not use any personal identifiers issued by a state or Commonwealth agency (e.g. Medicare number or tax file number) as a means of identification within the St Ives Group records systems. Where necessary, a unique code will be used to identify external contacts of St Ives Group.
An individual may make a complaint if they believe that there has been a breach of privacy or if they do not agree with a decision made by St Ives Group regarding access to their personal information.
Complaints can be made either verbally or in writing and St Ives Group will endeavour to resolve the complaint by following the St Ives Group Compliments and Complaints policy and procedure relevant to the Business Area providing the St Ives Group service.
If an individual is not satisfied with St Ives Group’s decision regarding a complaint, a formal written complaint can be directed to the Australian Information Commissioner at:
Office of the Australian Information Commissioner:
Mail: GPO Box 5218
SYDNEY NSW 2001
Telephone: 1300 363 992
TTY: 133 677 then ask for 1300 363 992
St Ives Group Privacy Officer:
Mail: PO Box 4014, WEMBLEY WA 6913
Telephone: 1300 20 20 01
Facsimile: (08) 9284 0888
Personal information, including sensitive information, will be ‘collected’ if it is included in a record or generally available publication.
You can give consent either:
Includes stakeholders, competitors, visitors, residents, clients, guests, customers or partners of St Ives Group.
Personal information is defined in the Privacy Act. In summary, personal information is information or an opinion about an identifiable person, or a reasonably identifiable person no matter whether:
Some examples of personal information include a person’s name, address and date of birth.
Sensitive information refers to additional personal information that includes details about an individual’s racial or ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, or health information.
St Ives Group
St Ives Villages Pty Ltd (trading as St Ives Retirement Living), Blaxland Pty Ltd (trading as St Ives Realty) and our related bodies corporate.
St Ives Staff
Includes St Ives Staff, contractors or sub-contractors, consultants, labour hire employees, apprentices or trainees and volunteers involved with the activities of St Ives Group. It also includes St Ives Board Members, Directors and any person serving St Ives Group on a committee or advisory capacity.
Unsolicited Personal Information
Personal information that St Ives Group receives but has taken no active steps to collect:
We will review this policy from time to time to make sure it’s up-to-date. If we make changes, we’ll post the latest version here.
This Policy was last updated on: 19th December 2018