PRIVACY POLICY

1. Purpose

Backpack Bed for Homeless is required by law to comply with the Privacy Act 1988 (Cth) (the Act), including the Australian Privacy Principles (APPs). We take our privacy obligations seriously and this Policy outlines our privacy practices. It explains how:

(a)  we collect and manage your personal information

(b)  you may access and request correction of any record containing your personal information

(c)  you may make a complaint about a breach of privacy.

2. Scope

The Policy applies to our staff, volunteers, contractors and suppliers who handle personal information collected by Swags for Homeless Ltd trading as Backpack Bed for Homeless (we, us, our).

It applies to personal information for individuals that are external to us such as donors, clients and suppliers (you, your).

By providing your personal information to us, you consent to the use, storage and disclosure of that information as described in this Policy.

3. How we manage your Personal Information

We will:

• take all reasonable steps to ensure we are open and transparent about the way we manage your personal information.
• maintain adequate security of personal information to seek to protect it from misuse, interference and loss from unauthorised access, modification or disclosure.
• establish reporting channels to receive privacy inquiries from you and for reports of privacy breaches to be received and acted upon.
• appoint a Privacy Officer to oversee privacy governance processes, ensure compliance with the APPs and report on privacy issues to our Board.
• provide this Policy free of charge and in an appropriate form for public access.
• periodically review this Policy as well as the privacy practices, procedures and systems across our organisation to ensure that they remain appropriate to the changing environment we operate in and will notify you by posting an updated version of this Policy on our websites.

4  Personal Information we collect and hold

4.1 Kinds of Personal Information

We will only collect information about you that is reasonably necessary for our functions or activities which are listed under point 4.3. This may include:

• your name, address and contact details.
• information associated with web browsing, email, text messaging, phone calls or other electronic interaction with you including your phone number and user name.
• for donors, details relating to your donations.
• for others, other information relevant to the purpose of providing homeless services including survey and questionnaire responses - such as gender, age, health, mental health, ethnic origin, your image, video and sound recordings and other particulars that are relevant for the proper provision of the services that we provide.

4.2 How we collect and hold Personal Information

Where possible, personal information is collected directly from you with your consent at the time of your interaction with us.

• Personal information may be collected in hard copy form or electronic form.
• Hard copy records are required to be held securely. We hold electronic records in databases with security safeguards.

4.3 Purposes for which we collect, use and disclose Personal Information

We collect, hold and use personal information only for the primary purposes for which it was collected or as set out below including:

• to provide homeless services.
• to operate fundraising and charitable activity in support of our objectives
• to provide customer service functions, including handling customer enquiries, complaints and 
feedback
• to facilitate proper governance processes such as risk management, incident management, internal audit and external audits.
• to gather feedback from you and other individuals about the quality of services that we provide so that the services we provide can be continuously improved.
• to undertake marketing, fundraising and promotional activities and events organised and held by us.
• to satisfy legal obligations, comply with applicable laws and meet the requirements of bodies which regulate the services we provide.
• also to understand, through aggregated information, trends and patterns which we use for research and advocacy.

4.4 Disclosure to third parties

We will not disclose your personal information to other external organisations except:

• as required by funding agreements
• as required by law
• where we have your consent to do so through your acceptance of this Policy and the disclosure relates to the goods or services we provide to you
• for a purpose permitted by this Policy
• if you request us to do so.

Examples of organisations and/or third parties that your personal information may be provided to include:

• third party service providers who assist us with the delivery of services or who provide services to or 
partner with us to enable us to deliver services, or in undertaking quality assurance of our services
• third parties service providers who assist us with fundraising activities or strategy or in analysis of our 
fundraising activities, strategy or patterns (including data collectives)
• third parties who assist us with co-ordination of volunteers, community activities and advocacy.
• third parties who collate and/or analyse information for the purposes of research and advocacy
• third parties for the electronic storage of information, some of which may be overseas

4.5 Opt‐outs

If you do not wish to receive communications from us, you should ‘unsubscribe’ online where a link is provided. In other circumstances, you should contact us on the email addresses below and we will cease the relevant marketing or promotional communication:

hello@BackpackBed.org

Where we are providing homeless services to you, we need to be able to communicate with you in relation to those services.

5  How you can access and correct your Personal Information

5.1 Access
You are entitled to request access to the personal information held by us about you. This is generally provided upon your request subject to completion of our verification and risk processes and to access restrictions imposed or permitted by law. Requests are made to the same point of contact to whom you provided your personal information.

5.2 Correction

Where you inform us that information held by us about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will correct it where we agree with you. Notices by you to us to amend information held about you are made to the same point of contact to whom you provided your personal information. If, having received and considered an application from you to amend your information, we do not consider that the information should be amended, we will not amend it but we will include a note with the information that you consider that it should be amended, and advise you accordingly.

6  Overseas Disclosure

We may store personal information that we collect about you with third parties who store it overseas for our use. We do not disclose personal information about you overseas without your consent. However, we may use overseas or cloud-based data hosting facilities which may result in personal information provided to us being transferred to, and stored at, a destination outside Australia, including but not limited to United Kingdom, New Zealand, Canada, China, Singapore, Hong Kong and United States of America. You are taken to expressly agree and consent to the transfer, storing or processing of your personal information outside of Australia in submitting it to us. In providing consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection requirements as Australia in relation to personal information.

If you do not agree to the transfer of your personal information outside Australia, you should contact
Backpack Bed for Homeless, Privacy Officer at:
Email: privacy@BackpackBed.org
Phone: 1300 AUS HELP / (03) 9764 9422  / (07) 3286 9834
Post: Backpack Bed for HomelessPrivacy Officer, PO BOX 1211 Cleveland QLD 4163

7  Retention of personal information

We will retain your personal information in accordance with applicable laws or requirements of any government or other funding body’s record-keeping requirements.

8  Mandatory Notifiable Data Breaches

We will comply with the notification and other requirements of the Act where your personal information held by us has been inadvertently lost or disclosed or improperly accessed and that loss, disclosure or access may result in serious harm to you.

9  What to do if you have a privacy enquiry or complaint
If you have an enquiry or a complaint concerning collection, use or management of your personal information, please contact us.

Email: privacy@BackpackBed.org
Phone: 1300 AUS HELP / (03) 9764 9422  / (07) 3286 9834

We will aim to respond and resolve your enquiry or complaint in a timely and appropriate manner. If we don’t, you may take it to a more senior manager.

• Where none of the above approaches by you has resolved the issue, your enquiry or complaint should be put into writing and forwarded to:
  Backpack Bed for HomelessPrivacy Officer, PO BOX 1211 Cleveland QLD 4163
• We will treat your enquiry or complaint confidentially. You may contact the Australian Information Commissioner wherever you believe that your rights to privacy have been breached by us.