Introduction
The Song Room is committed to the protection of the privacy of all persons associated with The Song Room’s courses.
Purpose
The purpose of this policy is to outline the procedures and processes that will provide a framework to ensure that The Song Room 1. protects the privacy of persons associated with The Song Room and its courses and 2. complies with all relevant State and Federal legislation
Context
The Song Room provides programs for children and youth across Australia. In the development, implementation and evaluation of these programs a range of information is collected, stored and used for a variety of purposes.
General Principles
Song Room procedures and processes will comply with relevant State, Territory and Federal Privacy legislation.
The Song Room Privacy Policy is based on the following five privacy rights:
‘The right information
to the right people
for the right reason
in the right way
at the right time’
The Song Room will ensure that the following Information Privacy Principles (IPPs) are adhered to:
IPP 1 Collection Collect only personal information that is necessary for performance of functions. Advise individuals that they can gain access to personal information.
IPP 2 Use and disclosure Use and disclose personal information only for the primary purpose for which it was collected or a secondary purpose the person would reasonably expect. Use for secondary purposes should have the consent of the person.
IPP 3 Data quality Make sure personal information is accurate, complete and up to date.
IPP 4 Data security Take reasonable steps to protect personal information from misuse, loss, unauthorised access, modification or disclosure.
IPP 5 Openness Document clearly expressed policies on management of personal information and provide the policies to anyone who asks.
IPP 6 Access and correction Individuals have a right to seek access to their personal information and make corrections. Access and correction will be handled mostly under the Victorian Freedom of Information Act.
IPP 7 Unique identifiers A unique identifier is usually a number assigned to an individual in order to identify the person for the purposes of an organisation’s operations. Tax File Numbers and Driver’s Licence Numbers are examples. Unique identifiers can facilitate data matching. Data matching can diminish privacy. IPP 7 limits the adoption and sharing of unique identifiers.
IPP 8 Anonymity Give individuals the option of not identifying themselves when entering transactions with organisations, if that would be lawful and feasible.
IPP 9 Transborder data flows Basically, if your personal information travels, your privacy protection should travel with it. Transfer of personal information outside a State or Territory is restricted. Personal information may be transferred only if the recipient protects privacy under standards similar to these IPPs.
IPP 10 Sensitive information The law restricts collection of sensitive information like an individual’s racial or ethnic origin, political views, religious beliefs, sexual preferences, membership of groups or criminal record.
Guidelines
5.1 All staff and volunteers of the Song Room will take all reasonable steps to ensure that they adhere to the principles and guidelines detailed in this policy.
5.2 The Song Room provide information concerning its privacy Policy on all relevant public documents.
5.3 The Song Room will provide all staff and volunteers with information concerning this policy.
5.4 The Song Room Board and Management will ensure that all relevant procedures and processes comply with this policy.
5.5 The policy will apply to all recorded information or opinion whether true or not about an identifiable individual, including name, image or small pieces of information that when combined may identify an individual
5.6 Information in this policy includes written forms, notes or letters, photographs, databases, phone sms messages or images, faxes and emails
Policy Review
This policy will be reviewed as State, Territory or Federal legislation changes and as other circumstances warrant.
References
Commissioner for Privacy and Data Protection: https://www.cpdp.vic.gov.au/menu-privacy/privacy-what-is
Health records Act (Victoria): http://www.health.vic.gov.au/healthrecords
Federal privacy Law: http://www.privacy.gov.au/act/index.html
Privacy NSW: http://www.privacy.nsw.gov.au/
Tasmanian legislation: http://www.thelaw.tas.gov.au