Playgroup Tasmania acknowledges and respects the privacy of individuals. This statement outlines Playgroup Tasmania's policy on the collection, use and management of personal information.
Playgroup Tasmania will make every effort to protect the privacy and confidentiality of all individuals associated with Playgroup Tasmania by ensuring that all records and information about children, families, playgroup participants, staff, volunteers and management are kept in a safe and secure place and are not divulged or communicated, directly or indirectly, unless strict criteria are met.
Playgroup Tasmania is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act and is compliant with the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
The purpose of this document is to set out:
If you would like to know more about the Privacy Act you can visit the website of the Federal Privacy Commissioner.
This policy applies to the following members of the Playgroup Tasmania community.This policy applies to all activities run by Playgroup Tasmania Inc. This includes all activities in the organisation which involve, result in or relate to contact with children.
|Employees and Volunteers (including leadership and trainees)
|Contractors/ Consultants (including employees of contractors)
|Playgroup Parents and Care Givers
This policy ensures that we comply with the National Privacy Principles and other related legislation. This policy ensures access to, and the collection and use of, personal information provided by individuals to Playgroup Tasmania is managed responsibly through a system of control.
The following guides the professional practice framework for all areas of activity within our organisation:
All individuals have the right to be informed on who has access to their information. Individuals have a right to challenge the accuracy of personal information recorded about them. At, or before, the time (or, if that is not practicable, as soon as practicable after) that we collect personal information about an individual, we must take reasonable steps to ensure that the individual is aware of:
The type of information Playgroup Tasmania collects and holds includes (but is not limited to) personal information, including sensitive information, about:
In general Playgroup Tasmania only collects information required to provide and facilitate playgroups and related programs, and the safety of the children in our care. The aim is to use fair and lawful ways of collection.
Personal Information you provide: Playgroup Tasmania will generally collect personal information held about an individual using forms filled out by families/care givers, face-to-face meetings and interviews and telephone calls. Occasionally people other than families and children will provide personal information. In these circumstances Playgroup Tasmania will use best endeavours to confirm the information is correct by contacting the individual concerned. We aim to ensure you know why we are collecting the information, to whom the information will be given and how we will use it or disclose it.
Playgroup Tasmania will use personal information it collects from you for the primary purpose for which it was collected, and for such other secondary purposes as are reasonably expected, or to which you have consented.
In relation to direct marketing, Playgroup Tasmania will use your personal information for direct marketing where you have provided that information, and you are likely to expect direct marketing: only then will you be sent direct marketing containing an opt out. If we use your personal information obtained from elsewhere, we will still send you direct marketing information where you have consented and which will also contain an opt out. We will always obtain your consent to use sensitive information as the basis for any of our direct marketing.
We may use video surveillance for security purposes and the footage will be used only by Playgroup Tasmania and by the providers of our security services for security purposes. Surveillance videos are not used for other purposes and the footage is not publicly available. Surveillance cameras are not located in any bathrooms or change room facilities.
Children & Families: In relation to personal information of children and families, Playgroup Tasmania’s primary purpose for collection is to enable Playgroup Tasmania to facilitate playgroups and provide families with information relevant to their needs. This includes satisfying both the needs of families and the safety and needs of the children throughout the period the family is a Playgroup Tasmania member.
The purposes for which Playgroup Tasmania uses personal information of children and families include:
Job applicants, staff members and contractors: In relation to personal information of job applicants, board members, staff members and contractors, Playgroup Tasmania’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be.
The purposes for which Playgroup Tasmania uses this personal information include:
Volunteers: Playgroup Tasmania also obtains personal information about volunteers who assist Playgroup Tasmania in its functions or associated activities to enable Playgroup Tasmania and the volunteers to work together in the best interests of children and families.
The purposes for which Playgroup Tasmania uses this personal information include to satisfy Playgroup Tasmania’s legal obligations, for example, in relation to child protection legislation.
Marketing and fundraising: Playgroup Tasmania marketing and fundraising is important for future growth and development to ensure that Playgroup Tasmania continues to be a quality environment in which children, families, staff and volunteers thrive.
All members of the wider Playgroup Tasmanian community may from time to time receive fundraising information. Playgroup Tasmania publications, like newsletters and magazines, which include personal information, may be used for marketing purposes.
Written consent will be obtained from families for the use of images, craft samples or information relating to themselves or their children in promotional material or on the Playgroup Tasmania website.
There are situations in which we may use or disclose information without an individual’s consent. These include where:
If we use or disclose information on these grounds we will make a written note of such disclosure.
It is expected that employees will exercise professional judgment in relation to how and when to explain the limits of privacy and confidentiality. Where confidential information is to be provided to other agencies, the preferred option is via written consent of the client using a consent form. However, it is also acknowledged that the nature of work may result in situations where it is not always possible to use a consent form. When such situations arise, verbal consent must be given by the individual and the employee is required to make a record indicating that verbal consent was provided.
Playgroup Tasmania may disclose personal information, including sensitive information when appropriate, held about an individual to:
Personal information regarding staff, volunteers or Board members will not be given to anyone without written permission, except in a medical emergency.
Lists of children's or families names, emails and phone numbers are deemed confidential and are not for public viewing and will not be issued to any other person or organisation without written consent.
Sending information overseas: Playgroup Tasmania will not send personal information about an individual outside Australia without obtaining the consent of the individual (in some cases this consent will be implied) or otherwise complying with the National Privacy Principles.
We do not use overseas providers of IT services including servers and cloud services.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.
Sensitive information can only be recorded with the individual’s consent unless:
Playgroup Tasmania’s staff are required to respect the confidentiality of children’ and families’ personal information and the privacy of individuals.
Playgroup Tasmania has in place steps to protect the personal information it holds from misuse, loss, unauthorised access, modification or disclosure. This requires a range of processes such as:
Personal conversations with families about their children, or other matters that may be sensitive in nature, will take place in an area that affords them privacy.
Personal conversations with volunteers and staff about matters relating to their performance will take place in an area that affords them privacy.
Playgroup Tasmania endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. A person may seek to update their personal information held by Playgroup Tasmania by contacting the administration team. We will take reasonable steps to destroy or remove identifying features from personal information when it is no longer needed for any purpose including any requirement of law.
The National Privacy Principles require Playgroup Tasmania not to store personal information longer than necessary.
Under the Commonwealth Privacy Act, an individual has the right to obtain access to any personal information which Playgroup Tasmania holds about them and to advise Playgroup Tasmania of any perceived inaccuracy. There are some exceptions to this right set out in the Act. Children will generally have access to their information through their families.
To make a request to access any information Playgroup Tasmania holds about you or your family, please contact the administration team. In routine requests for access to personal information, the administration team will verify your identity and that you have the right to access that information.
In the event of a non-routine request for access to personal information, especially where the issues relating to the request are of a sensitive nature, the administration team will consult the CEO. Where there is uncertainty about the request, the CEO and Board can seek legal advice on behalf of Playgroup Tasmania.
Playgroup Tasmania may charge a fee to cover the cost of verifying your application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, Playgroup Tasmania will advise the likely cost in advance.
Playgroup Tasmania respects every parent or care givers right to make decisions concerning their child/ren.
Families may seek access to personal information held by Playgroup Tasmania about them or their child by contacting the administration team. However, there will be occasions when access is denied. Such occasions would include where release of the information would have an unreasonable impact on the privacy of others, where the release of the information would be against the law (i.e. care and protection orders; parenting orders; family violence orders) or where the release may result in a breach of Playgroup Tasmania's duty of care to the families or children.
Playgroup Tasmania may, at its discretion, on the request of a child, grant that child access to information about them held by Playgroup Tasmania, or allow to give or withhold consent to the use of their personal information, independently of their families. This would normally be done only when the maturity of the child and/or child’s personal circumstances so warranted.
Where it is lawful and practicable, we will allow individuals to enter into transactions with us on an anonymous basis.
The Notifiable Data Breach Scheme prevents the concealment of breaches if the breach is considered to result in serious harm to the affected person(s). Pursuant to section 26WE of the Act, an eligible data breach which would require notification, occurs in circumstances where:
Examples of circumstances which may meet the criteria of a Notifiable Data Breach, include when:
Notification to the Office of the Australian Information Commissioner (OAIC)
Once Playgroup Tasmania forms the view, based on reasonable grounds, that there has been a Notifiable Data Breach, it will:
The statement will set out:
Playgroup Tasmania will notify the contents of that statement to the affected individuals (children, families, staff etc.) as soon as practicable.
How long will the Playgroup Tasmania keep my information?
When your personal information that is no longer required (including as required under law), it will be de-identified or destroyed. If you have provided consent in writing to us then your information may be retained indefinitely for marketing purposes. The release of non-identifying information must be checked prior to release to ensure the information is truly non-identifying. Wherever it is lawful and practicable, individuals must have the option of not identifying themselves.
Enquiries and privacy complaints
If you would like further information about the way Playgroup Tasmania manages personal information, please contact the Privacy Officer. If you have any feedback, concerns, complaints or you think there has been a breach of privacy, then also please contact the Privacy Officer. If we do not deal satisfactorily with your concerns, we will meet with you to discuss further. If you are not satisfied with our response to your complaint within 30 days from this meeting, then you can refer your complaint to the Office of the Australian Information Commissioner via:
Privacy Officer contact phone: 03 6331 6599
Privacy Office contact email: email@example.com
This policy replaces and overrides all previous Privacy policies of Playgroup Tasmania.
For definitions of the terminology used in this policy please refer to the separate document – Playgroup Tasmania Data Dictionary.
Relevant legislation and standards
National Privacy Principles contained in Privacy Amendment (Private Sector) Act 2000
Commonwealth Privacy Act 1988
Work, Health and Safety Act 2011
Personal Information Protection Act 2004 (Tas)
Privacy Amendment (Enhancing Privacy Protection) Act 2012
The Playgroup Tasmania Board has responsibility and oversight of all policies and will review this policy in line with the Policy Review Schedule and any relevant change in legislation or standard practice.
The CEO of Playgroup Tasmania has ultimate responsibility for ensuring that appropriate and effective internal control systems are in place. The CEO will:
All staff, volunteers and board members at all levels will ensure that they are aware of the organisation’s policy, undertake actions consistent with it and where appropriate, suggest ways in which practices, systems, procedures and policy could be improved.
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