At Vasey RSL Care Ltd (“Vasey RSL Care”), we recognise the importance of your privacy and understand your concerns about the security of the personal, health and other personally identifying information you provide to us.

This important notice is our Privacy Policy Statement which sets out how we manage your personal and other information. This Privacy Policy Statement tells you:

The kinds of personal and health information we may collect or hold from you or about you;
How we use it;
Who we share and disclose it with;
Your rights of access and correction; and
How to make a complaint.

Please read this Privacy Policy Statement carefully and let us know if you have any questions.

The main privacy laws applying to us

The main laws that govern Vasey RSL Care’s privacy and data protection practices include:

The Privacy Act 1988 (Cth) – which includes the Australian Privacy Principles (“APPs”); and
The Health Records Act 2001 (Vic) – which includes the Health Privacy Principles (“HPPs”).

The APPs and the HPPs detail how personal and health information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal and/or health information held about them.

There are also a range of other laws that are relevant to Vasey RSL Care’s privacy and data protection practices, and which specify what personal and health information we must or can collect from you or about you. These depend on the way we engage with you, your relationship with us and the type of services you receive from us. These other laws are referenced further below in this Privacy Policy Statement.

Definitions

Under the privacy laws:

“Personal Information” generally includes information or an opinion about an identified individual, or about an individual who is reasonably identifiable.
“Sensitive Information”, a subset of Personal Information, is information or an opinion about an individual’s racial or ethnic origin, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices or criminal record. It also includes health information and genetic information.
“Health Information” generally includes information or an opinion about an individual’s health or disability, the health services provided or to be provided to them, their expressed wishes for the provision of future health services, personal information collected to provide a health service, personal information collected in connection with organ and body-part donation, and predictive genetic information.

The kinds of information we collect

Vasey RSL Care collects a wide variety of personal, sensitive and health information which relates directly to our functions and activities. Vasey RSL Care’s functions and activities include the provision of residential and home care services, housing services, workforce planning, recruitment and selection, provision of a safe environment, student placements, learning and development, and raising awareness of the organisation as a service provider and employer. The information we may collect varies depending on how we interact with you.

Residents, program participants and service recipients

If you are a prospective or current resident in our tenancy or residential aged care facilities, a prospective or current participant in our in-home care programs, or a recipient of our other services, we commonly collect your name, address, date of birth, contact telephone numbers, email address, emergency contact, personal representative details, power of attorney details, next of kin, photograph and service history.

We also collect a variety of other personal information, depending on the facility or program you are in, and/or the services you receive. For example, in our tenancy, residential aged care and in-home care programs, we commonly collect:

Government-related identifiers: including your drivers licence, passport, Services Australia Customer Reference Number, Pension Number, Department of Veterans Affairs status, Care Recipient Identification Number and Medicare Number.
Financial information: including your income statements, bank summaries, superannuation statements, taxation records, Services Australia service records, Medicare service records, ACAT Assessment and bank account details.
Service records: DVA status and armed services records.
Health information: including your medical records, medication records, DVA and/or Medicare, dietary requirements, health assessments, referrals, previous service providers, allergies, vaccination, and influenza status.
Other information: including photographs, voice and image recording in care assessment, wellbeing / lifestyle and promotional activities.

We also collect information about your use of and/or participation in our programs and services. This can be:

For reporting purposes (eg, to report on the number of participants and manner of participation in our programs and activities);
For care and assessment purposes (eg, to identify safe practices for administration of medication); and
For promotional purposes (eg, if you provide works, photographic or video images or testimonials etc for Vasey RSL Care’s use).

Family members and general public

We collect personal information from or about the family members and friends of our residents and program participants.

Employees, vendors, contractors, students and volunteers

If you are a prospective or current employee, contractor (including contracted labour hire), student or volunteer to Vasey RSL Care, we commonly collect your name, address, date of birth, contact telephone numbers, email address, emergency contact and next of kin details, previous occupation/s, qualifications, eligibility and fitness to work in Australia, citizenship and/or visa status, background police, criminal and bankruptcy checks, dietary requirements, allergies, vaccination, and influenza status and other health or medical conditions relevant to your position. We may also collect other sensitive information relevant to your position and our workplace diversity initiatives etc. including spoken languages and personal identifiers such as gender or nationality/cultural identity.

For employees, vendors and contractors, we also collect relevant financial information (eg, for payment of wages, accounts and service fees, superannuation, and taxation etc).

We also collect information about our functions and activities. This can be:

For workforce reporting purposes; and
For promotional purposes (eg, if you provide works, photographic or video images or testimonials etc for Vasey RSL Care’s use).

Donors

If you are a prospective or current donor to Vasey RSL Care, we commonly collect your name, address, date of birth, email address, payment information (eg, bank account and/or credit card details), and Will and bequest details.

Stakeholders

From our other stakeholders, we commonly collect your name, address, date of birth, contact telephone numbers, email address, qualifications, occupation and place of employment.

Website

We also collect personal information from you or about you when you browse our website, make a general enquiry, or engage with us on social media.

Our website may from time-to-time use cookies to analyse website traffic and help us provide a better website visitor experience. Cookies are very small files which a website uses to identify you when you come to the site and store details about your use of the site. Most web browsers automatically accept cookies. You can reject cookies by changing your browser settings but making this change may prevent you from taking full advantage of our website.

Our website may from time to time have links to other websites that are not owned or controlled by Vasey RSL Care. Links to third party websites do not constitute sponsorship, endorsement or approval of those websites. These links are for your convenience only, and Vasey RSL Care is not responsible for the privacy practices of such linked organisations.

How we collect information Personal and health information is collected in a number of ways including:

Directly from you (such as where you provide information to us when you complete an application form, send us an email or letter, sign an agreement, complete a survey, log in to our various service apps and portals, or engage with us on social media).
From your authorised representative, family member/s or friend/s (if it is unreasonable or impracticable to obtain the information from you).
From your participation in our programs and services.
From and related to your employment or engagement with us (eg, by direct application, through labour hire agencies, and/or universities and student placement services).
From third parties such as Aged Care Assessment Service, hospitals, doctors, allied health providers or other public or private referral agencies.
From Government sources such as Services Australia, the Department of Veterans Affairs, Medicare, My Aged Care and the State and Federal Police.
Via our website, when you subscribe to receive email or e-news.
Through images and recordings.

Vasey RSL Care collects sensitive information about an individual with the individual's consent; if that information is reasonably necessary for, or directly related to, one or more of our functions or activities. For example, we may ask about or receive from you information about your cultural and ethnic background, religious beliefs and affiliations and sexual orientation in our tenancy, residential aged care and in-home care applications. When undertaking assessments to develop a care plan, staff may also ask about cultural and ethnic background, religious preference, customs beliefs and sexual orientation, as we value individual interests and foster choice to support choice. We may also use this information to extend the support that we or other organisations may be able to provide to you. This is not an exhaustive list of the information we collect. We may ask for information about a pension number to obtain a pensioner discount or to obtain services or equipment on your behalf. You may also be asked to provide personal information about other individuals to us (e.g. contact details of your next of kin, preferred contact). If so, we rely on you to inform these other people that you are providing personal information to us and advise them about our privacy policy statement.

Consequences of not providing your information

You do not have to provide any personal information to us. However, if you do not provide all or any of the personal information we request, or if you do not consent (or if you choose to withdraw your consent at a later stage), then:

We may not be able to answer (or fully answer) your enquiry;
We may not be able to provide (or fully provide) the services you have requested from us; and/or
You may not be able to participate in any or the full extent of our services and programs.

For example, if you are a resident in our tenancy, residential aged care and in home care programs, the collection and use of your personal information and health is necessary to provide our services, to comply with government requirements, and to ensure that your care needs are met.

You can be anonymous or use a pseudonym when dealing with us, unless:

The use of your true identity is a legal requirement; or
It is impracticable for us to deal with you on such basis.

For example, you are able to make general enquiries about our programs and activities on a ‘no-names’ basis. However, enrolment into our facilities, programs and services does require the provision of the personal and health information detailed above.

How we hold information

Vasey RSL Care holds information in a number of ways which includes hard [paper] copy or electronic [digital] format. We also have storage facilities we own and operate ourselves. We take reasonable steps to maintain the security of your information and protect it from unauthorised disclosure, misuse, interference, loss, modification and unauthorised access.

These steps include security measures for electronic information and our storage facilities are locked. Strict confidentiality requirements are in place for our employees, volunteers and service providers.

Use and disclosure of information

Vasey RSL Care uses and discloses your personal and health information only for the purposes for which it was collected or for any other purpose that is otherwise directly related to our functions or activities or otherwise permitted by law. If information is required for another reason, we will ask for your (or your authorised representative's) permission.

For residents who live in a residential aged care facility and consumers of the home care package program, we collect information to assess your requirements and to undertake care planning. As part of care planning, staff will talk to other internal and external service / health providers who are expected to disclose any concerns that may arise in carrying out your care plan. Staff may also need to consult your doctor, other health professionals and relevant service providers in order to monitor, plan, implement and evaluate your care needs. Vasey RSL Care may also be bound to comply with mandatory reporting and information sharing schemes to protect resident and program participant wellbeing.

Your information is used to provide services to you, to provide you with information about services and to assist you with enquiries. Information is also used to improve or develop our services, and to monitor and evaluate our quality and performance.

We also use the information you provide to administer and manage the services we provide to you, to charge and bill you for them (if relevant) and to collect any amounts you may owe to us.

Vasey RSL Care uses information:

For internal record keeping and to assist our organisation to operate;
For our workforce planning and management;
To monitor usage of, and participation in, our programs, activities and services and to better understand how our services and resources are being used by you and others;
To analyse your needs and improve your experience with us;
For advancing our lobbying, advocacy, patriotic and charitable purposes and interests;
To comply with our legal obligations.

In many instances, we are specifically authorised or required by law to collect and hold the personal and/or health information we seek from you and about you. These laws include for us to comply with tenancy, residential aged care, veterans support, health provider, taxation, workplace health and safety, site surveillance, education, superannuation, health insurance and other applicable laws.

Vasey RSL Care also discloses information to:

Your authorised representative with your consent or when you ask us to
Hospitals or other health care providers and health professionals
Professional advisers, including our accountants, auditors and lawyers.
Our contracted vendors and service providers (eg, our catering providers in our residential aged care facilities, our third-party services providers who manage our IT and marketing systems, and the organisations and agencies which conduct our fitness-to-work assessments)
Our insurers
Government departments and regulatory authorities (eg, Department of Veterans Affairs, Services Australia, the Australian Taxation Office)
Others who have this right by law (eg, accreditation bodies).

Reasonable steps are taken to make sure personal information and/or health information we collect, use or disclose, is accurate, complete and up-to-date. Reasonable steps are taken to protect data and personal information we hold from misuse, interference and loss; unauthorised access; unauthorised modification; and unauthorised disclosure. We take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose, subject to relevant legal requirements regarding document retention and deletion.

For applicants for employment, volunteering, student placement, traineeships and contractors, we collect personal and health information to consider you for these purposes. Your information is disclosed as advised to you as part of the application process or contracting process.

Where we wish to use or disclose your personal information for other purposes, we will obtain your consent.

Where we use your personal information for marketing and promotional communications, you can opt out at any time by notifying us. Opt out procedures are also included in our marketing communications.

We may also disclose your personal information to third parties (including government departments and enforcement bodies) where required or permitted by law.

Overseas Disclosure

Vasey RSL Care is from time to time affiliated with or uses the services of other businesses / organisations / people located overseas. For example, some of Vasey RSL Care’s IT systems are hosted “in the Cloud”, and some of Vasey RSL’s catering providers are part of multi-national groups. We will only disclose your personal information to overseas recipients where:

it is necessary to complete the transaction you have entered into; and
you have provided consent; or
we believe on reasonable grounds that the overseas recipient is required to deal with your personal information by enforceable laws which are similar to the requirements under the APPs; or
it is otherwise permitted by law.

Destruction and De-identification

Vasey RSL Care will retain your personal and health information whilst sit is required for any of our business functions and activities, or for any other lawful purpose. This includes retaining your information for certain periods of time even after we have completed our engagement with you, or you have departed our programs and services.

We use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed. Depending on the program or service you have engaged with:

Paper records containing confidential information are disposed of in confidential bins and are emptied into industrial shredder.
Electronic records are deleted from the files and back up storage.

Other

Marketing, recruitment and promotional activities

From time to time, we may contact you to provide you with information about other services offered by us that may be of benefit to you and your family. This includes information or services that can help improve your wellbeing. You may also wish to sign up to our e-newsletter or other publications. When we contact you, it may be via mail, phone, email or text-message. When you become a resident or consumer of Vasey RSL Care you consent to us using your personal information for direct marketing (as described in this document), unless you have contacted us to withdraw your consent. If you do not wish to receive marketing material from us, you can contact us at any time to let us know. See contact details at the end of this document. When you contact us to make this request, we will action your request within five working days.

If you request not to receive marketing material, please note we will still contact you in relation to our ongoing relationship with you. For example, we will still send you any bills, statements and notices that are relevant to the services we provide you.

In order to raise awareness about VRSLC as a service provider and/or employer, VRSLC regularly releases information and imagery about organisational news and events online, in print media or via other channels. This enables VRSLC to engage with existing and potential consumers, employees, volunteers and its wider community. Content can include photos, video recordings, poems, story, artwork, testimonial, mentioning an individual’s name, quoting an individual in an article, content provided for external publications e.g., other website or magazine article, activities including taking photos or recordings, or collecting other material such as interviews, artworks, prose or testimonials. You [or your legal representative] will be asked to provide consent for use your performance, image, voice and photographic or other likeness (as applicable), in whole or in part for this purpose.

For volunteers, students, employment applicants, and other persons who have provided their details to us in relation to this, we may contact you regarding future job and volunteering opportunities and VRSLC news and events. You may opt out of this process via the VRSLC recruitment website or choose the unsubscribe options available on the communications when you receive them. Alternatively, you can opt out by contacting the Privacy Officer.

For donors, we will contact you to request your participation in one-off and ongoing donation initiatives, bequests and campaigns. You may opt out of or cancel your donations to Vasey RSL Care at any time. We will still contact you as required by law (eg, to provide invoices for taxation purposes).

CCTV and Surveillance

Vasey RSL Care has installed or may install surveillance devices in communal spaces of its residential aged care facilities and community halls of the ex-service accommodation. In these cases, signage is in place at the entry of the facility which states surveillance devices are used in common areas of the establishment and / or in the outside vicinity. Surveillance feed from communal or outside vicinity is only reviewed if there is a complaint or an incident to assist with investigation. If additional or further surveillance in communal spaces or outside a building is to be installed, you will be informed of this change. Vasey RSL Care does not allow surveillance equipment to be installed in a resident's room due to the intimate and private acts performed, for example showering, bathing, and to do so would compromise the resident's dignity.

Access and correction of information

Individuals have the right to request access to the personal information held about them. These access rights are subject to exemptions and exceptions recognised by law.

We have procedures in place for receiving, assessing and responding to your requests to access personal and/or health information. We may need to verify your identity before progressing your request. We will not charge for the lodgement of an application to access personal and/or health information. We may however charge you for providing access to the personal and/or health information. Those charges will not be excessive and will be consistent with specific legal requirements regarding charges for records access.

Should you wish to access or correct any of the personal or health information collected by Vasey RSL Care, please see the contact details at the end of this statement.

Individuals also have a right to request personal information be corrected.

We have procedures in place for receiving, assessing and responding to your requests to correct personal information. We will take reasonable steps to correct information that is not accurate, complete, relevant or up to date. If Vasey RSL Care and the individual cannot agree as to whether the information is accurate, complete, relevant or up to date, we will, on request, record a statement of the dispute. We will also take such further steps as are required by the relevant privacy legislation.

If we deny an individual access to his or her personal and/or health information or we refuse to correct personal and/or health information that is in our possession, we will endeavour to provide reasons for that decision. We will also outline how you can object to that determination.

Privacy complaints

If you feel that Vasey RSL Care has not complied with its privacy obligations in relation to the handling your personal information, we ask that you contact us directly first to attempt to resolve the matter. You may speak to the manager of the facility/service, complete a Privacy Complaint form, provide a written letter or contact the Vasey RSL Care Privacy Officer.

We take complaints very seriously. If you lodge a complaint about privacy this will be acknowledged and an estimated time frame for when you will receive a response to the complaint will be provided.

Vasey RSL Care Privacy Officer

PO Box 209

HAWTHORN, 3122

Ph: 9810 5500

Email: privacyofficer@vaseyrslcare.org.au

If Vasey RSL Care is not able to resolve your privacy complaint, you have other options to escalate your complaint, depending on the personal and/or health information involved. This includes lodging a complaint with:

Australian Information Privacy Commissioner

Office of the Australian Information Privacy Commissioner

GPO Box 5218

Sydney NSW 2001

http://www.oaic.gov.au/privacy/privacy-complaints

Ph: 1300 363 992

Email: enquiries@oaic.gov.au

Health Complaints Commissioner

Level 26, 570 Bourke Street

Melbourne, Victoria 3000

https://hcc.vic.gov.au/make-complaint

Ph: 1300 582 113

This Privacy Policy Statement has been issued by Vasey RSL Care Limited, effective as at 25/07/2023. From time to time, we may need to change this Privacy Policy Statement. If we do, we will post the updated version on our website www.vaseyrlscare.org.au and it will apply to all of your information held by us at that time.