The Shrine of Remembrance understands the importance the community places on confidentiality of individuals' personal and/or sensitive information. This extends to the collection and management of information held in our records regarding individuals.
The Information Privacy Act (Vic) or IPA, sets out guidelines that regulate how organisations should treat personal and/or sensitive information they collect, use, handle or store.
These guidelines set minimum standards for:
- collection, use and disclosure of personal information which could identify a person
- quality, security and storage of that information
- giving an individual access to their information
- transferring information offshore, and
- special categories of information such as 'sensitive' information and 'health' information
What is personal information?
- Information or an opinion about an individual whose identity is apparent or can be ascertained from that information or opinion.
- This includes names, addresses, telephone numbers, age and email address.
What is sensitive information?
This includes information about:
- racial or ethnic origin
- political opinion or association
- trade union or professional association membership
- religious beliefs or philosophical beliefs
- sexual preferences
- criminal record
- health information
IPA Information Privacy Principles
The IPA establishes 10 principles to which an organisation must comply in regard to personal and sensitive information:
- Data Collection
- Use & Disclosure
- Data Quality
- Data Security
- Access & Correction
- Transborder data flows
- Sensitive Information
1. Data collection
Personal and sensitive information is only collected as is reasonably necessary to enable Shrine of Remembrance to maintain its activities and deliver services to the community.
- Personal information about an individual should only be collected with the individual's consent.
- Collection will be undertaken by a method which is fair, lawful and not unreasonably intrusive.
- Individuals from whom personal information is collected are to be made aware of:
- The Shrine of Remembrance’s contact details
- the primary purpose for which the information is collected
- any possible secondary purpose for which the information may be used
- the names of the organisations or types of organisations to which we disclose information of any nature (if any)
- the ability of individuals to access the information held on themselves.
2. Using and disclosing information
- Information will only be used or disclosed for the primary purpose for which it was collected. In some instances, information provided by individuals may be used to keep them better informed about Shrine of Remembrance activities and services, such as by way of a newsletter. Individuals have the right to opt out of receiving such additional mailings.
- Personal information about an individual will not be used or disclosed for a secondary purpose unless:
- the purpose is closely related to the primary purpose and the individual would reasonably expect the information to be used in that way; or
- the individual has consented; or
- the Shrine of Remembrance has a legal obligation to disclose personal information which overrides the provisions of the primary legislation.
- The Shrine of Remembrance will not sell or exchange or release personal information about an individual for commercial gain.
3. Data quality
Reasonable steps will be taken to ensure information collected and used is complete, accurate and up-to-date.
4. Security of information
- Reasonable steps will be taken to protect personal information from misuse, loss, unauthorised use, modification or disclosure.
- Personal information will be destroyed or permanently de-identified when it's no longer needed for the purpose for which it was collected.
- The Shrine of Remembrance website uses secure technology for online transactions to protect credit card information.
- Our websites contain links to other websites. Shrine of Remembrance does not accept responsibility for the privacy practices or the content of linked websites.
5. Openness of information
- Reasonable steps will be taken to allow any person, on request, to ascertain generally what sort of personal information is held, for what purpose, how it was collected, stored and used.
6. Accessibility of information
Information held on individuals is accessible to them on request (except where frivolous and vexatious) and will generally be available free of charge. Reasonable steps will be taken to ensure the information provided is accurate and up-to-date.
Identifiers used will be unique to the Shrine of Remembrance.
To the extent possible, individuals will be given the option of not identifying themselves when dealing with the Shrine of Remembrance.
9. Transborder data flow
The Shrine of Remembrance will not sell, exchange or release personal information except where necessary for the purposes of collaborative work directly related to the original reason for the provision of information.
10. Sensitive information
The Shrine of Remembrance doesn't collect sensitive information about individuals unless:
- we have the consent of the individual; or
- the information is collected in the course of Shrine of Remembrance activities where the individual is in regular contact in relation to those activities and the individual understands that the information will not be disclosed without consent
- Personal and/or sensitive information will be collected and maintained on confidential databases maintained by the Shrine of Remembrance in support of its activities and service provision.
- Staff and volunteers who may have access to personal and/or sensitive information in the course of their duties will respect its confidentiality and not disclose the information to any third party.
- Breaches of confidentiality by staff will be dealt with in accordance with the conditions of appointment to the staff of the Shrine of Remembrance.
Grievance procedure relating to the Privacy Act
- Complaint registered by an individual. This must be in writing.
- Complaint given to the Manager, Administration & Finance for assessment and investigation in consultation with the Chief Executive Officer.
- Written response sent to individual within 7 days of complaint being received.
- If our response is found to be unacceptable to the individual, we may suggest conciliation or arbitration on the matter.
- If the individual makes a formal complaint to the Privacy Commissioner, the Chief Executive Officer is to be the respondent on behalf of the Shrine of Remembrance.
Internet use risk
You should be aware that there are risks in transmitting information across the internet. However, we take reasonable steps to protect any personal information from unauthorised access once that personal information comes into our possession.
The Shrine of Remembrance may contain hyperlinks to pages contained on external websites (third party websites). Unless otherwise indicated, the Shrine of Remembrance:
- does not endorse or authorise the content of any third party website;
- is not affiliated or associated with the owner or operator of any third party website;
- assumes no responsibility or liability for the condition or content of any third party website or for the operation or function of any service or facility offered on any third party website.
Website personalisation features of the Shrine of Remembrance
A cookie is a small piece of data that is presented by a website to a web browser. The browser stores this piece of data and then returns it to the website that provided it in the first place with each subsequent requests for pages and images. Cookies can tell the difference between different browsers and store anonymous information that can be used at a later time.
The Shrine of Remembrance website uses first party cookies to enable users to use certain features of the website. A first party cookie is that which is created by the web site you are currently visiting – in this case the Shrine of Remembrance. If you do not allow cookies to be used within your browser, then you may not be able to use all the features of this website.
Web measurement service used by the Shrine of Remembrance
The Shrine of Remembrance currently uses Google Analytics web measurement services.
While the anonymous statistical data the Shrine of Remembrance collects may be aggregated and used in broader statistical analysis by the Shrine of Remembrance or the State of Victoria, at no time can we personally identify you as the source of that data.
Reviewed 19 June 2020