Privacy Policy

We value privacy and have appropriate policies and procedures in place to ensure that any information and details of our clients, volunteers, staff or others provided to us is only used for the purposes of providing our services. In addition, any information is stored securely. We are bound by the Australian Privacy Principles (APP), in the Privacy Amendment (Enhancing Privacy Protection) Act 2012. This new privacy legislation came into effect in March 2014. As MoW receives limited funding from the Australian Government’s Home and Community Care program, we are required to provide statistical information regarding the services we provide. Information does not identify individuals personally in any way. We may also need to share information with a client’s doctor or other health service provider if the client has authorised us to do so. If a person does not want any details disclosed e.g. gender, residence location and so on, please advise us by contacting our Central Office. People have a right to access information we hold about an individual. Any documents can be accessed by the individual concerned, on application which must be in writing, with appropriate authority. Requests will be processed within 30 days and a fee does apply.  Contact Meals on Wheels Central Office for more information. If you have any concerns about how we collect or use information, security, privacy or other matters please contact our Privacy Officer or our General Manager Service Operations on 8271 8700 or at PO Box 406 UNLEY 5061. Meals on Wheels SA (MoWSA) Privacy Policy for managing client information. We need to share some important information with you. So please take a few minutes to read our privacy statement. It’s designed to make sure our relationship with clients, volunteers, staff and others we work with is smooth and everyone is aware of what information we collect and what we do with it. Every day we need to collect and use information to make sure we are delivering the services we offer in the most efficient way we can to make sure they meet your needs. The Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Privacy Amendment Act) has made many significant changes to the Privacy Act 1988 (Privacy Act). These changes commenced on 12 March 2014. The Privacy Regulation 2013, made under the Privacy Act, also commenced on 12 March 2014.  This policy outlines MoWSA’s response to this new legislation and how we manage the information we collect in the course of our business. This policy seeks to clarify what information may be collected and retained by MoWSA, whether it is likely to be passed on to others and how a privacy matter of concern can be raised, addressed and resolved by MoWSA. The new legislation regulates the collection and handling of personal information through a set of 13 principles called the Australian Privacy Principles (APPs). These APP’s also provide definitions of personal and sensitive information as follows:

• Personal Information –information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
• Sensitive Information – personal information about an individual’s racial or ethnic origin, political opinion, membership of a political association, professional associations or a trade union, religious beliefs or affiliations, health status (either physical or emotional) and genetic information, disability, philosophical beliefs, credit history, bank accounts, sexual preferences or practices, or criminal record. It can also include photos.

Our Privacy Policy covers both personal and sensitive information – The things we need to know and how we manage it to make sure we are always clear, honest and transparent. The Policy explains how we collect information, what we do with it, and, critically, how we keep it protected. Why do we collect personal information? We collect personal information when it is reasonably necessary to conduct our business. To supply you with the services you have asked for and to provide the best possible service. Other reasons we might collect personal information are to:

• Understand you, and how we can meet your needs now and in the future.
• Develop or evaluate products and services.
• Develop communications and products that are more relevant to you.
• Manage our business with you.
• Comply with our legal obligations such as our government funding agreements funding agreements with the Commonwealth.

The type of information we collect: The information MoWSA might collect, depending on the type of relationship we have, may include:

• Name
• Contact information including address, entry/access, phone number/s and email address
• Emergency contact information
• Health status (mental and physical) and dietary needs
• Financial information (such as bank account/s)
• Feedback, complaints and resolutions
• Demographic information such as preferences and interests
• Other information relevant to MoWSA research or surveys

There are a few different ways we collect this information:

•  What we collect directly from you:

We collect most personal information directly from you. For example, in an interview with us, provided to one of our representatives in person or over on the phone, or you might fill out a form online. Naturally, you can choose not to provide your personal information or may just want to deal with us anonymously. If this happens, we may not be able to provide you with the service you’ve asked for.

• What we collect while you are with us:

We also collect personal information during our relationship with you. For example, we may collect personal information: o   When you pay for meals or other services. o   When you use services.

• What we collect online:

Our MoWSA website uses cookies and other digital identifiers. These include: Site performance identifiers: these give us information about how our websites or apps are used. This helps us provide you with a more user-friendly experience. Analytics cookies: we use these to gather statistics about our site and apps. For example, they help us monitor how many users are on the site or app, and what sections are most popular. Importantly you can clear cookies or digital identifiers from your computer or digital device and disable them for future use, by changing the security settings on your web browser. But, this might mean that our website may not work as it should.

• What we collect from others:

Other people might give us personal information about you. For example, we might be given personal information by a health care professional, a hospital or similar service, or a government agency who might be assisting a client. We will take reasonable steps to make sure you know we have your personal information, how we got it and how we’ll handle it. Financial Information: We collect some types of personal financial information to assist with payment for meals. Insights from statistics and research: We collect, collate, aggregate and process some personal information to generate new insights about our products and customers, so we can provide the best possible service to our clients. This is de identified and viewed in aggregate. Examples would be the breakdown of locations, gender or age groups Sensitive personal information By sensitive information, we mean details about race, ethnicity, politics, religious or philosophical beliefs, sexual preferences, health, genetics or criminal record. Generally speaking, we don’t need to collect or store sensitive information about you – it’s just not usually relevant. However, there may be times when you tell us about health matters that relate to particular diets etc., Note that this kind of information will only be collected with your permission, and we will only use it for the purpose for which you provided it. MoWSA and who we need to work with: We work with a number of other organisations such as the Commonwealth and State governments and in certain circumstances we may be required to share personal information with them too. Again, this is de-identified and viewed in aggregate. Outsourcing: We do not need to work with third parties to provide services and customer support. Except for example at Christmas or Easter where we might ask another service provider such as RDNS to handle after hours calls from clients. They normally would not have access to systems that include your personal information. These companies are subject to strict controls that would protect your information from unauthorised use or disclosure, and limit their access to your personal information to the extent necessary to do their job. Example; Emergency contact details. Overseas access to personal information: We are not aware of any need to share or access information with a supplier who is offshore from Australia. Legal obligations and other exceptions to privacy access: We will give access to certain personal information where we are permitted and or obliged to by Commonwealth law. For example, to reduce or prevent a serious threat to life, health or safety, we may need to work with police, health department or similar statutory authorities. We may have to disclose personal information if directed to do so. Otherwise: We will only disclose personal information to others if you’ve given us permission, doing so relates to the main reason we collected the information and you’d reasonably expect us to do so. E.G. Emergency contact details. Marketing: MoWSA may use your personal information to send you information related to new services that may be of help to you. We advertise via a number of mediums such as mail, phone, email, text, and online via the internet. Opt out: We’ll make sure that any marketing we do, clearly tells you how you can opt out, or you can call us on 1800 854 453 to do so. Naturally we do need to send you some things that we can’t control on an individual basis, such as a general advice to all clients required by law or commonwealth agreement. Financial information:  As noted earlier, we might ask you for banking details when we are arranging direct debit meal payments. You can get access to credit related information we hold, ask us to correct it, or make a complaint, as outlined elsewhere in this policy. If our records do in fact need to be corrected we will do so. Security: Security of information we hold is paramount. Protecting your personal information is vital to both of us. Security measures we utilise may include:

• Firewalls and specialist access logging tools that help protect against unauthorised access to your data and our computer network.
• Secure office and work environments and systems designed to prevent unauthorised access, copying or release of your personal information.
• Secure computer servers and networks.
• Encryption of data whilst it is being sent from computer to central file etc.
• Software to regularly scan for viruses.
• Secure rights to access our systems so that only those who need to, can see your personal information.
• Ongoing updates, staff training and security analysis.

Whilst these processes offer some degree of security, risks do change. We will always be vigilant in protecting your personal information. Accessing your personal information: Please ask us if you have any issues or concerns.  We will endeavour to provide access to any personal information we hold about you once we have checked that we are speaking to the authorised person concerned. For access, Freecall us on 1800 854453, and let us know what you need and why. The new Australian privacy laws have some situations where we may not allow access to personal information. E.G. Access would be denied if it would be deemed to unreasonably affect or impact on someone else’s privacy or if access poses a serious threat to someone’s life, health or safety. There may usually be no cost for access to personal information we hold. However, if a request is unusual, complex or puts a strain on our limited resources, there would be a modest charge. Updating Personal Information: We need to keep our records current, so we need to update personal information we hold to ensure currency. We encourage all, clients, families, carers and volunteers; to update details with us should they change. So that people we work with (like emergency services) have access to the latest information they need to carry out their tasks. We will ask our branches to update volunteer records at least annually and we will conduct client reviews at least annually and will use these occasions to update information we need. However, your personal information is important to both of us, so please call if you have any queries, questions or concerns about our privacy policy and procedures. Additional: Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

1. Your data will be made available to our website provider
2. The data that may be available to them include any of the data we collect as described in this privacy policy.
3. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA.
4. They will store your data for a maximum of 7 years.
5. This processing does not affect your rights as detailed in this privacy policy.

How to get in contact us: You can contact us or find out more about our complaint process and complaint handling procedures, by: T Freecall 1800 854 453, or 8271 8700 F   8490 2309 E  info@mealsonwheelssa.org.au W www.mealsonwheelssa.org.au If you elect to make a complaint about a privacy issue, we will acknowledge receipt of your complaint, and investigate and respond to you within 30 days if possible. If you are unhappy with any outcome, we can advise how you might wish to take matters further. Updates: We’ll update our policy & procedures if we make a change. This document was prepared in March 2014 to coincide with new Australian Privacy Principles. Thanks: MoWSA would like to thank you for taking the time to view this statement and we trust that you remain assured that we take privacy matters seriously.