Privacy Policy

Air Force Association (WA Division) Incorporated, trading as RAAFA, is committed and will use all reasonable efforts to protect the privacy of individuals’ personal information and to comply with the obligations imposed by the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs), the Associations Incorporation Act 2015, the Aged Care Act and the Aged Care Principles.

Purpose of information collection

We will routinely collect and use personal and sensitive (including health) information required to perform core business functions during the course of the relationship with the individual.

We collect personal and sensitive (including health) information for the purpose of:

Membership to Air Force Association (WA Division) Inc., including determining your eligibility;
Residency in RAAFA’s Retirement Village or Residential Care Facility;
Determining your eligibility and/or provision of appropriate services and care;
Administrative purposes to meet our State/Commonwealth legal and contractual obligations;
Enabling contact and lawful liaison with your nominated person;
Monitoring quality and effectiveness of our services provided;
Determining your suitability of employment with us; and
Conducting research – in the event your personal information is used for research purposes, we will seek consent from you and provide the opportunity to opt out at any time.

If you choose not to provide some or all of the information requested, we may not be able to provide the services and/or care required.

Collection of information

We will only collect personal and sensitive information by lawful and fair means and will only collect personal information that is necessary for one or more of our organisation’s functions or activities. Where reasonable and practical, personal information will be obtained in the following ways:

Directly from you and/or your authorised representative; and/or
From your previous/current health care provider and/or assessment agency (i.e. Doctor, the Aged Care Assessment Team, hospital, allied health professional); and/or
Where relevant, from Government departments/agencies.

The collection of information will be undertaken when it is reasonably necessary for, or directly related to one or more of our functions/activities and:

You have consented to the collection of this information; or

The collection of the information is required, or authorised by, or under an Australian law, or court/tribunal order; or
As a not-for-profit organisation, the information relates only to the members of RAAFA, or to individuals who have regular contact with RAAFA.

Unsolicited personal information

In the event we receive unsolicited personal information, unless retaining the information is permitted as per the APP Guidelines, we will destroy or de-identify the information as soon as practicable, if it is lawful and reasonable to do so.

Closed Circuit TV (CCTV)

CCTV recording devices are in place at our Retirement Living (external grounds) and Residential Care Facilities (external grounds and internal common areas) to ensure the safety and security of residents, visitors and staff. CCTV footage remains the property of RAAFA.

Notification

We will at, or prior, or as soon as practicable after the collection of personal information from you, take all reasonable steps to ensure that you are notified of the purpose for the collection of personal information and the identity of other entities or persons to whom we usually discloses personal information to.

Security of information

We are committed to securely managing all personal information collected in secure storage within the premises of RAAFA, and in some cases, an external service provider within Australia. We will take all reasonable steps to ensure the personal information it holds in paper and electronic form (including IT servers which may include cloud storage), is protected from misuse, interference, loss, from unauthorised access, modifications or disclosure.

In the event of a data breach that is likely to result in serious harm, we will notify the person(s) whose personal information is involved and the Office of the Australian Information Commissioner as soon as practicable.

We will take all reasonable steps to destroy or de-identify your personal information once it is no longer required for any use or disclosure as per the APPs and applicable information management policy.

Use and disclosure of information

We will primarily use personal and sensitive (including health) information for the purpose of assisting you in the provision of health and other services. When required, we may disclose personal and sensitive information about you to authorised external health care professionals (e.g. nominated GP, site pharmacist) or external organisations for administrative purposes (e.g. government agencies for funding purposes). We may disclose your health information about to an authorised person if:

You are incapable of giving / communicating consent;
Disclosure is necessary to provide appropriate care or treatment; and
Disclosure is not contrary to any wish previously expressed by you of which we are aware or of which RAAFA could reasonably be expected to be aware and disclosure is limited to the extent reasonable and necessary for providing care or treatment.

We will not use or disclose your personal information other than the primary purpose of collection, unless:

You have consented;
Secondary purpose is related to the primary purpose and you would reasonably expect use or disclosure;
Health information collected is necessary for research, relevant to public health or safety or it is impractical to obtain consent;
Disclosure is necessary to prevent or lessen a serious imminent threat to your life and/or public health or safety;
Use or disclosure is part of our investigation or reporting to relevant persons or authorities in the event we suspect unlawful activity; or
Use or disclosure is required or authorised by Australian law and/or court/tribunal order.

We will not disclose personal information about you to an overseas recipient (other than the person to which the information relates to) unless consent is provided and specific requirements are met.

We may use general contact information to provide organisational service information, updates about RAAFA and new services. You may “opt-out” of receiving further similar material at any time.

Direct marketing

We will not use or disclose personal information it holds for the purpose of any third party commercial direct marketing unless:

You would reasonably expect us to use or disclose personal information for the purpose of direct marketing; and
We have provided you with means to ‘opt-out’ and you have not opted out.

Government related identifiers

We will not adopt, use or disclose government related identifiers (e.g. Medicare numbers, Centrelink Reference numbers, tax file numbers), unless required by law.

Access and correction of information

You may request access to and/or correct your personal information held by us provided that we are able to confirm the request is made by you or your authorised representative. Requests for access to personal information should be addressed to the Estate/Facility Manager. Access to your personal information may result in administrative fees.

We aim to ensure the personal information we hold is accurate, complete and up-to-date. If you believe that the information held about you is inaccurate, incomplete, out-of-date, irrelevant or misleading, we will take reasonable steps to correct the information.

In the event access/amendment/annotation to your personal information is not granted, we will provide written notice of the reason(s) for refusal.

Anonymity and pseudonymity

You may remain anonymous or assume a pseudonym during some interactions with us (e.g. admission/service queries, employment queries, customer feedback) provided that it is lawful and practicable.

Feedback and complaints

In the event you are dissatisfied with how we have managed your personal information or consider we have not complied with the Privacy Act and the APPs, notification may be made in person, by phone, fax, email or in writing to the Estate/Facility Manager or RAAFA’s Privacy Officer.

If you are not satisfied with the investigation and/or the outcome, a further complaint may be made to the:

Chief Executive Officer, AFA (WA Division) Incorporated

18 Bowman Street, South Perth WA 6151

T: +61 8 9288 8400 F: +61 8 9288 8441

E: enquiries@raafawa.org.au W: www.raafawa.org.au

Office of the Australian Information Commissioner

GPO Box 5218, Sydney NSW 2001

T: 1300 363 992 F: +61 2 9284 9666

E: enquiries@oaic.gov.au W: www.oaic.gov.au

Online: http://www.oaic.gov.au/privacy/making-a-privacy-complaint

How to contact us

If you wish to contact us about any matters in relation to privacy, please do so by contacting:

Privacy Officer, AFA (WA Division) Incorporated

18 Bowman Street, South Perth WA 6151

T: +61 8 9288 8400 F: +61 8 9288 8441

E: privacy@raafwa.org.au W: www.raafawa.org.au