Parkinson’s Queensland Inc. (PQI) is a state-wide, non-profit community-based organisation and registered Queensland charity, which provides information, access to counselling and support to people living with Parkinson’s disease, as well as engaging in related community awareness, fundraising, and advocacy activities.
The purpose of this policy is to provide information which:
• promotes a better understanding of the types of “personal information” (including the subcategory of “sensitive information”) that PQI handles
• communicates the practices of PQI in relation to its handling of personal information, including its collection, use, storage, disclosure
• sets out a transparent process for handling personal information within PQI, including for managing requests for access to and correction of personal information, and for making privacy complaints.
2. Policy statement
PQI values and respects an individual’s right to privacy and is committed to safeguarding the privacy of all persons who interact with PQI, including its members, volunteers, donors, employees and users of its electronic media (website, social media).
This policy explains the ways in which PQI handles personal information in the course of carrying out its services and functions, while recognising and safeguarding the right of individuals to have their information handled in ways they would reasonably expect and in ways that protect the privacy of their personal, financial and health information.
3. Legal obligations
PQI is not directly subject to the provisions of the Privacy Act 1988 (Cth), as it does not fall within the definition of the bodies (agencies, organisations and small business operators) to which that legislation applies. Similarly, PQI is not an “agency” for the purposes of the Information Privacy Act 2009 (Qld), and thus is not directly governed by that legislation.
However, PQI receives ongoing funding from the Commonwealth Department of Social Services (Commonwealth Home Support Programme) to assist in servicing people over the age of 65, living with Parkinson’s disease in Queensland. PQI also receives funding from the Queensland Department of Communities, Disability Services and Seniors (Community Care Program) to assist in servicing people under the age of 65, living with Parkinson’s disease in Queensland. Under the terms of the Commonwealth funding agreement, PQI is contractually required to comply with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth), in relation to the delivery of services funded under that agreement. Similarly, under the Queensland service agreement, either PQI is contractually obliged to comply with the Information Privacy Principles (IPPs) or the National Privacy Principles (NPPs) set out in the Information Privacy Act 2009 (Qld), in relation to the delivery of services funded under that agreement. When read together, the IPPs and NPPs are very similar to the APPs, and impose roughly equivalent obligations on PQI in relation to its handling of personal information.
Personal information means information or an opinion about an identified
individual, or an individual who is reasonably identifiable:
A. whether the information or opinion is true or not; and
B. whether the information or opinion is recorded in a material form or not.
Sensitive information means:
A. information or an opinion about an individual’s:
I racial or ethnic origin; or
II political opinions; or
III membership of a political association; or
IV religious beliefs or affiliations; or
V philosophical beliefs; or
VI membership of a professional or trade association; or
VII membership of a trade union; or
VIII sexual orientation or practices; or
IX criminal record;
X that is also personal information; or
B. health information about an individual; or
C. genetic information about an individual that is not otherwise health information; or
D. biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
E. biometric templates.
5. What kinds of personal information does PQI collect?
Depending upon your relationship with PQI (eg. as a member, financial supporter, service recipient, employee or volunteer), we may collect different types of personal information from you, including:
• contact details (name, address, telephone number, email address etc.)
• personal details including: date of birth, gender
• education and employment history; taxation details
• donation history
• credit card numbers or bank account details.
If it is reasonably necessary in the circumstances, we may also collect sensitive information such as health status (whether a sufferer of Parkinson’s disease or related neurogenerative condition; country of birth; date of diagnosis). However, we will only collect your health or other sensitive information if we obtain your consent, or are other otherwise permitted by law to undertake such collection. Where practicable, we will explain how your health or other sensitive information will be used or disclosed.
6. How PQI collects personal information
Information may be collected when you:
• make a financial donation to PQI
• subscribe to any PQI publication, including electronic publications
• provide details to PQI in an application, consent form, survey, feedback form or incident report
• contact PA in person or via telephone, mail or email, or engage with PQI via social media
• access the PQI website
• participate in any program, activity, competition or fundraising event run by PQI
• are elected or appointed to PQI’s Board of Directors, or a sub-committee thereof
• apply for employment or a volunteer position with PQI.
We may also collect personal information about someone else from you. For example, you may wish to:
• make an ‘in memoriam’ donation, and have confirmation of the donation sent to the family of the
Where you provide us with personal information about other people, you must have their consent to do this, and to provide it to PA on their behalf. If not, you must tell us at the time the information is provided.
Depending on the circumstances, some types of information will be required and others might be optional. If you do not provide some or all of the information requested, this may affect PQI’s ability to communicate with you or provide the requested products or services.
Anonymity and pseudonymity
Wherever it is lawful and practicable, you have the option not to identify yourself or to use a fictitious name when interacting with PQI. You can remain anonymous or use a pseudonym when using PQI’s website or interacting with PQI via social media. However, it may be necessary for PQI to collect your name in order to provide you with some services (eg. issuing of tax receipts for financial donations).
7. Use of personal information
PQI will use your personal information for purposes which are directly related to the reason you provided the information, and where you would reasonably expect us to use that information.
Depending upon the circumstances of its collection, we may use information for:
• processing donations and providing receipts
• administering our register of members
• seeking ongoing financial support for PQI, or recognising existing support
• extending invitations to upcoming events and activities
• providing follow-up information in response to questions or comments
• seeking feedback about PQI’s services and functions to monitor and evaluate existing activities, and plan for future service delivery
• providing information about research trials and other initiatives offered by external providers that may be of interest to PQI members or supporters
• facilitating and managing an individual’s employment or volunteer relationship with PQI
• complying with necessary business and accounting standards
We will not use your personal information for any other purpose unless you have given your consent or one of the exceptions under the Privacy Act 1988 applies.
Use for direct marketing
From time to time, we may use the information we collect from you to let you know via mail, email, telephone or online about PQI news, products or services, or to solicit donations. All such communications will include details regarding the recipient’s entitlement to ‘opt-out’ of receiving direct marketing communications from PQI, and PQI will comply with any such ‘optout’ request as soon as practicable. PQI will not sell, rent, share or disclose your personal information to any third party for direct marketing purposes.
8. Disclosure of personal information
Where necessary, PQI may disclose your personal information:
• to its professional advisers, including its accountants, auditors and lawyers
• to relevant Commonwealth and state government funding agencies
• in other circumstances permitted by law.
PQI does not normally send personal information out of Australia. Should we be required to send information overseas, we will undertake to protect your personal information, by ensuring that the country concerned has similar protections in relation to privacy or by entering into contractual arrangements.
9. Security of personal information
PQI holds personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in filing cabinets (locked where appropriate) or in archive storage boxes. PQIs policy is to take reasonable steps to protect the personal and sensitive information we hold against misuse, interference, loss or unauthorised access, modification and disclosure.
The steps we take to protect the personal information we hold include physical security for PAQI’s office premises, securing paper files in locked cabinet, relevant access control mechanisms for our IT resources (such as encryption, firewalls, anti-virus software and login and password protection), and personnel security and training and workplace policies.
When the personal information is no longer required, and can legally be disposed of, it is destroyed in a secure manner in accordance with PQI’s Record Retention and Disposal Policy.
PQI processes donations using EFTPOS and online technologies. PQI’s policy is to ensure that all transactions processed electronically meet industry security standards to ensure payment details are protected.
If an individual uses their credit card and the transaction is processed manually, the transaction record will be stored by PQI for the period that financial records are required by law to be retained, following which it will be destroyed in a secure manner.
Internet and social media security
While PQI strives to protect the personal information and privacy of users of its internet and social media sites, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact PQI by telephone or post (see contact details below).
You can also help to protect the privacy of your personal information by keeping your passwords secret, utilising anti-virus software, and by ensuring that you log out of the website or social media site when you have finished using it. In addition, if you become aware of any security breach on our internet or social media sites, please let us know as soon as possible.
Third party websites
10. Access to and correction of personal information
PQI will take reasonable steps to ensure that all personal information that we collect, hold, and use or disclose is accurate, up- to-date, complete, relevant and not misleading. You can also help us to keep your information up to date by letting us know about any changes to your personal information, such as your postal or email address or phone number.
You may request to access or correct your personal information at any time by contacting PQI’s Privacy Officer (see contact details below). We will give you access to the information unless one of the exceptions under the Privacy Act 1988 applies (eg. if providing access would be unlawful or denying access is authorised by law). If you request to access or correct your personal information, we will respond within a reasonable time (usually within 30 days). If your request is refused, we will give you a written notice setting out the reasons for refusal.
11. Complaints procedures
12. How to contact Parkinson’s Queensland
Telephone: 07 3209 1588
Email: [email protected]
Post: PO Box 4718, Eight Mile Plains QLD 4113
PQI will review this policy annually, and may amend or update it from time to time. If relevant privacy legislation and/or governance codes or contractual obligations are introduced or amended, the policy will be updated accordingly, and we will summarise any substantial modifications or enhancements in this section of the policy.
The current version of the policy will be posted on our website, and a copy may be obtained free of charge from our Privacy Officer (see contact details above).
14. Responsibilities / Delegations
Protection of privacy is a prime responsibility for all PA Board members, employees, volunteers and contractors working for the organisation. The following have further specific responsibilities:
• Parkinson’s Queensland Board Members for establishing and maintaining oversight of PQI’s privacy compliance regime
• PQI’s Privacy Officer for establishing and maintaining appropriate privacy training and awareness programs for PQI staff and volunteers, and for responding to privacy-related enquiries and complaints from members of the community who interact with PQI.
• PQI Employees, volunteers and contractors for exercising due diligence to prevent, detect and report any breaches of privacy or other matters bearing on the policy and privacy issues.