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Privacy

PRIVACY POLICY

 

 

Your privacy is important to IVA

This policy is intended to ensure that the privacy of individuals is protected in the collection, use, disclosure and storage of personal information by the Institute of Veterans’ Advocacy (IVA). This policy is addressed to our members, our staff, and to individuals outside of our organisation including veterans and their families, staff of Ex-Service Organisations and other services organisations, staff of Fee-For-Service (F4S) veteran advocacy providers, visitors to our offices, and visitors to our websites (together, ‘you’).

The IVA [ABN 39 685 699 085] is responsible for confidentiality, privacy, and security of personal information received by it. Personal information is protected and kept confidential in accordance with relevant Privacy legislation, including the Privacy Act 1988 (Cth) (the Privacy Act).

The IVA is public company limited by guarantee that supports the veteran community by supporting high quality veteran advocacy services. The IVA's primary functions include establishing competency and training standards, accrediting and registering advocates, and ensuring a code of conduct is adhered to. The IVA will also manage advocate registration, promote the availability of quality advocacy services, and address complaints about advocate performance or behaviour. The IVA will also support advocates in promoting and encouraging self-care practices to ensure their well-being and advocacy effectiveness.

The IVA’s primary purpose for collecting information is for the purpose of its primary functions. It may also collect information for secondary purposes, such as information on website activity, to improve how it offers services and performs its functions.

This policy may be updated from time to time to reflect changes in laws or in our processes and procedures on handling of personal or sensitive information.  The IVA recommends you read this policy carefully, and to check this page to review any changes it may make to the terms of this policy. All information about you which is held by the IVA, will be governed by the most recent policy.

What is personal information and what types of personal information does IVA collect and deal with?

‘Personal information’ is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or otherwise.

Personal information includes information such as:

  • Names and addresses
  • Banking details, including credit card information
  • Images
  • Information about a person’s individual opinions
  • Sensitive information including information or an opinion concerning an individual’s health, or other personal attributes such as racial or ethnic origin, religious beliefs and membership of political or trade associations.

The Privacy Act regulate how the IVA collects, uses, stores, accesses, and discloses your personal information. IVA refer to this as “dealing with” information.

The types of personal information the IVA deals with includes information about our members, staff (including volunteers), and service providers including their name, address and contact details, date of birth, the organisation they are associated with, their ABN, and information about their skills and qualifications.  

The IVA only collects sensitive information with consent or when required or authorised by law. The IVA will only deal with sensitive information reasonably necessary for one or more of IVA's functions or activities, such as investigating a complaint.  

How does the IVA collect my personal information?

The IVA collects personal information to enable it to operate its functions described above. It may collect personal information where you have consented or where authorised by law.

Information may be collected when you interact with the IVA website, complete any of IVA forms, or correspond with the IVA via email, mail, or telephone.

Sensitive information is more likely to be collected, held, used and disclosed in circumstances where a complaint is being made about services provided by an IVA member. Other than when provided directly by you, sensitive information is primarily provided to IVA through an IVA member.  

The IVA collects personal information from you through its dealings with you in relation to advocacy services and the personal information that is collected will depend on your interactions with the IVA. It may also depend on certain choices you make, including your communication preferences and whether you are communicating with us as a member or as a veteran or other person making a complaint. The IVA may collect your personal information when you:

  • Visit the IVA website and use IVA’s online services
  • Visit an IVA office
  • Attend a seminar or event hosted by IVA
  • Attend a meeting hosted by IVA, including the Annual General Meeting, a member meeting or a Board meeting.  

The IVA may also obtain personal information about you from third parties, this includes:

 

  • Obtaining information from the Department of Veterans’ Affairs (DVA), the Commonwealth Superannuation Corporation (CSC) or any other agency or any relevant training providers to verify your qualifications, experience and/or performance.
  • Obtaining information from an advocate about you where you have agreed to the IVA doing so as part of a complaints process.
  • Receiving information from other representatives authorised by you to act on your behalf (e.g. financial advisor, lawyer, power of attorney).

When the IVA collects personal information about you it will take reasonable steps to notify you (or ensure you are aware of) the following matters, at or before the time of collection, or as soon as practicable afterwards:

  • The purpose for collecting your information.
  • The circumstances in which your information may be disclosed to third parties.
  • How you can correct your personal information or make a complaint (by reference to this Privacy Policy).

How does the IVA protect my information?

The IVA takes reasonable steps to protect your personal information. These steps include:

  • Ensuring that personal information is accessed by authorised staff and personnel only.
  • Having secure access controls for the physical storage of any personal information (noting that IVA keeps minimal information in hard copy).
  • Utilising technology to protect information, including ensuring user logons, passwords and security provided by the IVA’s IT provider.
  • Only keeping information on an as required basis and minimising the collection of sensitive information (for example, the IVA will generally not request sensitive information if it is possible to review a complaint without this information).

 

When no longer required, personal information is destroyed, archived or deleted in accordance with obligations under the Privacy Act.

 Does the IVA disclose my information to third parties?

If you are in IVA member, some of your personal information will be disclosed on the IVA Register of Members as prescribed in the IVA Constitution. Because the constitution requires certain member information to be publicly available in the register, this information will not be treated as confidential. The Register is publicly available and will include the following particulars about Members and Organisational Members:

  • their full name
  • the category of membership (individual or organisation)
  • their address, being the postal address for an individual and the registered address for an organisation,
  • any alternate address nominated by the Member or Organisational Member for the service of documents,
  • the date the membership was entered onto the register,
  • for individuals, their accreditation status, including date that accreditation was gained,
  • if relevant, the date the membership ceased.

More generally, the IVA may disclose your personal information to third parties if you have consented to it or if required to do so by law. You can reasonably expect that personal information may be shared with IVA’s employees, staff, or volunteers assisting in the provision of IVAs services. It may also be shared or exchanged with:

  • Legal or regulatory authorities (for example the police, a fair trading regulator, a law society, or another professional association).
  • Anyone you authorise to act on your behalf.
  • Anyone you authorise the IVA to obtain information from.
  • Any Court if compelled to do so by law (for example if the IVA is validly subpoenaed or issued with a Notice by a court to provide information).
  • Any relevant training organisations, Department of Veterans’ Affairs (DVA), Commonwealth Superannuation Corporation (CSC) or any other agency if necessary to verify a member’s qualifications, experience and/or performance as an advocate.   
  • If required, the Office of the Australian Information Commissioner and the Commonwealth Ombudsman.

What about market research?

The IVA may conduct research to find out views on the services we deliver on on other matters relevant to the veteran advocacy sector. The IVA will do this in accordance with the Spam Act, Do Not Call Register Act and the Privacy Act. The results of this research helps IVA to improve the services we provide to members and informs any advocacy the IVA may engage in. IVA may contract with external companies to conduct this research and will ensure that any such company is required to keep you information secure and not use it for any other purpose than what they have been contracted to provide.

The IVA ensures that market research activities do not identify any participants. Whether or not you participate in market research, it will not affect the services you receive from IVA.

When conducting market research, the IVA will ensure that you have the right to opt-out of market research communications by using tools provided in each communication (e.g. an unsubscribe link).

Will the IVA give my personal information to overseas recipients?

The IVA does not disclose personal information to overseas recipients.

 

What information does the IVA collect from my website activity?

When you visit our website, certain information may be collected (via cookies or through analytics tools employed by the IVA’s website provider) to allow the IVA to improve the websites and online services. This might include information about when a page is visited, what page is visited, and how often the webpage is visited.

You may also use online services (such as member application forms) and provide information that the IVA collects. The IVA endeavours to provide a secure environment, though acknowledges there are risks associated with this. As such, you can contact the IVA to arrange for alternative ways of providing information if you require.

How does the IVA manage data breaches?

In the event of an eligible data breach, the IVA must notify the Office of the Australian Information Commissioner (OAIC) and affected individuals.  The IVA has internal procedures in place to ensure that reporting obligations are complied with.

How do I keep my personal information the IVA holds current?

The IVA endeavours to ensure that the personal information we have about you is accurate, up to date and complete. If your information changes, please contact the IVA so that the information held, and publicly disclosed where relevant, is kept up to date and accurate. Information on how to contact the IVA is available on the IVA website.

Under the Privacy Act you have the right to ask for access to any personal information that the IVA holds about you. You also have rights to ask that any incorrect information is corrected. To ask for access or correction, contact the IVA using the contact details on the IVA website and you will be responded to within 30 days.  

To request that your information is corrected, you should email IVA and set out the information that you consider is incorrect and specify what you request to be done to correct this information. IVA may need to verify your identity as part of this process.

If your personal information held by the IVA is incorrect, the IVA will take responsible steps to correct it unless there is a law that allows or requires us not to.

 

Further information for staff, job applicants, contractors and volunteers

Your personal information is protected by law and is collected by the IVA to determine your suitability to work with the IVA, either in a paid or unpaid capacity.

Personal information you provide will only be accessed by relevant IVA staff and any recruitment service provider we engage. The IVA may also disclose your personal information to third parties such as previous employers or organisations you have been associated with as part of pre-onboarding checks to establish your identity, eligibility and suitability to work with the IVA.  

Enquiries and Complaints

If you have any enquiries or concerns about information and data privacy or would like to make a complaint about a breach of your privacy, information on how to contact the IVA is available on the IVA website.

Where lawful and practicable, you may remain anonymous or use a pseudonym when interacting with the IVA. However, in most circumstances relating to membership, accreditation, or complaints, IVA will require your identity. If you do not provide personal information when requested, IVA may be unable to assess your accreditation or membership, process a complaint, update your records, or provide certain services.

The IVA will respond and seek to resolve your complaint as quickly as possible. Where you have made a complaint, the IVA will investigate the issues raised and may contact you for further information in order to seek to resolve the matter. The IVA will communicate outcomes with you and will also records your complaint and analyse it to identify any systemic issues it may point to.

You can obtain further general information about your privacy rights and privacy law from the Office of the Australian Information Commissioner (OAIC). If you are not satisfied with IVA’s response to your complaint, you may make a complaint to the OAIC. Further information about making a privacy complaint is available at www.oaic.gov.au.

Alternate versions

This policy can be requested in an alternate form, for example for accessibility reasons. Please contact IVA should you require an alternative version.

Review

This Policy will be reviewed triennially or as required, in light of relevant regulatory or Australian Government policy changes or any significant changes to IVA’s Constitution or business objectives. Reviews will consider any necessary or desirable amendments to ensure it remains current and consistent with best practice and applicable law.