The Homelessness Advocacy Service (HAS) is a program of the Council to Homeless Persons (CHP). CHP is bound by the thirteen Australian Privacy Principles (APPs) from Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
Personal information is information or an opinion about you as an individual.
Personal information collected, used, stored and disclosed by HAS might include your name, address, nationality, demographic information (eg date of birth, country of birth, language), what area you live in and relevant contact details (eg phone number, email address).
The HAS Advocate will also take confidential case notes that record things such as: what service you are requesting, what outcomes you are seeking, what actions we agree to undertake, any contact with other services on your behalf, issues you might be experiencing (eg health) and what we do with and for you.
Sensitive information is information relating to a person’s gender, racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences, criminal record and health information about an individual.
A client might disclose sensitive information to the HAS Advocate that is relevant to the assistance they are receiving. For example they might contact HAS because they have been discriminated against because of a health issue or criminal record and would need to discuss these issues with the HAS Advocate to get support with them.
The HAS Advocate only needs – and will only collect – sensitive information that is directly relevant to your case and will record it in your confidential case notes, unless you ask them not to do so.
Personal and sensitive information collected for HAS is collected by a HAS Advocate. Information is usually collected over the phone when you call however can also be collected during office visits or via email or written correspondence. Sometimes, as part of the assistance we provide, we might collect some personal information about you from other agencies and people associated with you, for example when discussing your situation with a worker or agency you are being supported by.
HAS client information is entered and stored on a secure online client management system, the Service Record System (SRS). Information is stored, audited, and backed-up in a controlled and centralised way rather than being up backed up on CHP’s network.
SRS is a web-based system hosted by Infoxchange Australia that offers a secure web link for every session while it is being used by CHP. All SRS infrastructure hosted by Infoxchange is maintained in a secure environment which meets or exceeds the Australian Government Protective Security Protocols. SRS is not hosted in a public ‘cloud’ environment such as those provided by Microsoft, Google or Amazon and information is stored in Australia not overseas.
The collection, use and discloses of personal and sensitive information is a necessary and key element of the service HAS provides. In simple terms, the HAS Advocate needs information about you so they can help you.
However it is important to note that we only collect information that is directly related to the service we are funded to provide.
The collection of personal information (eg case notes) by HAS is a requirement of the Department of Human Services, who fund us and is a necessary element of meeting service quality standards we have to meet.
The collection of personal and sensitive information also supports our internal quality improvement processes (making our service better) and de-identified data assists us to improve the homelessness system more broadly (for example by analysing what people complain about).
Yes, but only if it is directly related to the service we are providing to you (eg support to make a complaint). The HAS Advocate only discusses things with another agency or worker if you have asked them to do so (eg to advocate on their behalf).
The HAS Advocate only discloses personal and sensitive information that someone contacting the service for assistance would reasonably expect to be disclosed. For example a person who contacted HAS because they needed advocacy support related to health issues might reasonably expect us to collect information about their health and disclose that information to an appropriate external service (eg housing service).
The HAS Advocate will advise you if they are going to disclose any personal or sensitive information (eg discussing case with an external agency, resolving a complaint) and get consent to do so unless it is not practicable (eg we cannot contact you). Similarly before making a referral on your behalf we will get your consent unless. If we can’t get in contact with you we would only make the referral if we thought you would expect us to.
The HAS Advocate will only disclose your personal information in the context of the service being provided. The HAS Advocate might discuss your situation with an agency you are working with, an organisation you want support to resolve an issue with or an agency a referral is being made to on your behalf. The HAS Advocate might also have confidential discussions with their Manager about your situation to get advice.
In rare circumstances the HAS Advocate may have to disclose personal information because they have serious concerns about the health or safety about someone or we are directed by a court or tribunal to do so.
No. People contacting HAS for assistance are under no obligation to disclose any information they don’t want to disclose. If you don’t want us to record any or all of the personal or sensitive information you disclose, please tell the HAS Advocate. However, not recording personal information may make it harder for the HAS Advocate to effectively assist you.
Yes. You have the right to remain anonymous or to use an alias should you want to.
Yes. CHP allows individuals access to the information it holds about them within a reasonable time after they have made a written or verbal request for access. To ensure all correspondence is documented, if it is possible requests for access to information should be in writing.
In rare instances, CHP may refuse to give an individual access to requested information, for example because it may put another person at risk. Unless CHP is unable to do so (eg we cannot contact you) it will provide the individual with the reason they have been refused access.
CHP may decide it can only provide limited information, for example if by providing complete information another person’s privacy may be breached. Unless CHP is unable to do so, it will provide the individual with the reason the request has been limited.
If you want to access your personal information please talk to a HAS Advocate. The HAS Advocate will discuss what information you would like access to, when you would like to access it and how you would like the information presented (eg hard copy, email etc). Every effort will be made to meet reasonable requests and to be sensitive to individual circumstances.
If you have concerns about the way in which we have handled your personal information or you think there been a breach of your privacy you can make a complaint.
If you want to make a complaint the CHP Complaints procedure should be followed. In simple terms, the complaint can be made verbally or in writing and can be directed to whoever you feel is the most appropriate CHP staff member. CHP takes any complaints very seriously and will endeavour to resolve them, as far as is possible, to the complainant’s satisfaction.
If a person needs any advice or assistance with issue relating to Privacy, such as determining what constitutes a breach of the APPs, they can contact the Office of the Australian Information Commissioner on 1300 363 992.
It is important personal information we hold about people is accurate, complete and up-to-date. If you think the personal information we hold about you is incorrect, please advise the HAS Advocate and they will correct it.