For the purposes of this document, any reference to The Company, Company, or Company People shall include all of Longevity Group Australia Ltd and its associated entities.
The Company has Privacy Policies which encompass the full range of our corporate activities. We have detailed Privacy Policies for:
- The Mornington Retirement Village
- Longevity Group Property Development
This policy is specifically for The Mornington.
The Company’s policies are regularly reviewed and monitored against industry benchmarks and regulatory requirements to enable the Company to maximise the protection of personal data.
In respect of the collection, use and disclosure of Privacy Information, the Company is subject to the 13 Australian Privacy Principles as laid out in the Privacy Act, and (where relevant) the Victorian Health Privacy Principles. All personal information received on behalf of the Company is at all times respected, including the protection and security of all personal records.
The Company is required to collect a range of personal information according to governing legislations, which is used to ensure the appropriate services are provided to residents.
A holistic approach to service delivery in partnership with residents and their representatives and other health providers is also taken into consideration. Information is only shared with team members such as medical and allied health professionals, pharmacist, podiatrist on a need to know basis.
People who contact The Company or provide The Company with privacy information may use their name or choose to remain anonymous or use an alias or pseudonym. However:
- Anonymity or a pseudonym is not acceptable for a resident where medical history may be essential for the provision of care; and
- Anonymity or a pseudonym is not acceptable for a retirement village resident where the Company provides a registered lease of property over the Title of Land.
- Any use of pseudonym must comply with the law.
This policy document makes reference to the following:
|Document Number||Document Name|
|C2003 Form||Collection Statement|
|Privacy Act Response Script|
|Document Number||Document Name|
|Staff Induction kit|
|Staff Induction Checklist|
|Collection Statement Consent Form|
|The Mornington Website Privacy disclaimer|
|Email Privacy Disclaimer/Statement|
|Board of Directors||Endorse, oversight, comply with and review policy. Assess performance of senior management.|
|MD||Comply with policy and implement policy. Assess and monitor management and staff.|
|Line Management||Comply with policy. Report and monitor staff.|
|All Staff||Comply with policy.|
Corporations Act 2001
Retirement Village Act 1986
Owners Corporation Act 2006
Privacy Act 1988
Privacy Amendment (Enhancing Privacy Protection) Act 2012
Australian Privacy Principles
6 Policy Principles
The Company’s policy is that:
- the Company primarily uses privacy information for the primary purpose for which it collected the information or a secondary purpose related to the primary purpose for which the individual would reasonably expect it to use the collected information.
- to collect privacy information directly, unless it is unreasonable or impracticable to do so.
- the Company will make parties aware of the purpose for which it collects their information by notifying them about all the relevant matters of that collection.
- the Company will not use information collected for an unrelated secondary purpose unless it obtains written consent or an exception applies, such as it is impracticable to obtain consent and we believe that collecting, using or disclosing privacy information is necessary to lessen a serious threat to the life, health or safety of any individual.
The Company collects information about people, mainly regarding residents and prospective residents, which falls into all three categories of privacy information under the Privacy Act – personal information, sensitive information and health information.
Below is a list of examples of the types of information the Company collects and the Collection Statement provides more information as to why the Company requires this.
The main need for the Company to collect this information is to deliver necessary and effective services to all its residents and to understand and forecast its business.
- Information concerning details of the appointment of attorneys or other alternative decision makers;
- Contact details for relatives of the individual;
- Progress notes;
- Medical reports from Individual’s medical practitioners and health care providers;
- A medical history;
- Details of the individual’s health insurance provider;
- Individual’s family contact details;
- Information concerning the individual’s religion and end of life arrangements and the location of a person’s will.
- Where the Company is required to by law.
The Company may collect privacy information from people through its marketing, business development, operational, human resources, research or other activities.
The Company has a general policy to collect privacy information directly, unless it is unreasonable or impracticable to do so.
Written consent is required to collect sensitive information (which includes health information) about individuals.
Residents and prospective residents
The Company collects privacy information (including health information) directly on an ongoing basis when updating individual’s records.
The Company’s general policy is to collect information directly and not from third parties. However, in case it is unreasonable or impracticable to collect privacy information directly, the Company may need to collect privacy information from family members etc. To the extent this information is health information, the Company will ask for consent via the Collection Statement.
The Collection Statement also serves to notify residents and prospective residents of the Company’s direct and indirect collection of privacy information, the circumstances of that collection and other related matters.
If individuals do not consent to the Company collecting their health information then the Company will not be permitted to collect this information unless an exception applies. An example of an exception is an emergency where it is unreasonable or impracticable in the circumstance to obtain individuals’ consent and collecting that information would lessen a serious threat to life, health or safety.
Prospective employees, consultants and contractors
The Company collects privacy information from:
- the individual;
- referees proposed by the individual;
- from previous employers;
- police check upon the individuals’ provision of consent and identification information required to complete such a check
As a general principle, the Company only uses privacy information for the primary purpose for which the information was collected or a secondary purpose related to the primary purpose for which individuals would reasonably expect the Company to use the collected information.
The Company will make individuals aware of the purpose for which the information has been collected by notifying them about all the relevant matters of that collection.
The Company will not use this information for an unrelated secondary purpose unless written consent is obtained or an exception applies, such as it is impracticable to obtain an individual’s consent and we believe that collecting, using or disclosing an individual’s information is necessary to lessen a serious threat to the life, health or safety of any individual.
Residents and prospective clients
The Company collects, holds and uses privacy information for the primary purpose of managing the retirement village according to the terms of its agreement, or for a secondary related purpose, such as recording bank details for it to deduct monthly levies where applicable
The Company also collects and uses privacy information for some secondary purposes, only with written consent.
The following are examples of the purposes for which the Company collects, holds, uses, and deals with privacy information:
- To publicise an individual’s address, phone number and role within the village to other residents should they volunteer to be on a committee or assist with emergency procedures (e.g. Fire Warden).
- To receive and retain bank account details for the purpose of arranging the direct debit of monthly levies, where applicable, by authorised account staff.
- To list and store individuals date of birth for the purpose of recording their age.
- To keep a record of individual’s privacy information, as updated from time to time.
- To use privacy information to inform a nominated emergency contacts and/or next of kin of a medical condition for the purpose of enabling family and community support.
- To disclose health information to paramedics and health professionals in the event of a medical emergency.
- To disclose health information to your doctor and allied health service providers.
- To maintain a record of any pets owned in the village for the purpose of informing emergency contacts if the individual is unable to do so.
- To keep records of any accidents, injuries or incidents reported by or about individuals for insurance purposes.
- To use basic personal information, such as age and gender, for modelling and forecasting our business.
- To allow the Company to form a view as to whether the resident’s unit is suitable for the resident to reside independently in a retirement village.
- To enable the Company to contact any nominated person to lawfully inform of an individual’s health status.
- To lawfully liaise with the individual’s nominated representative and to contact family if requested or needed.
The Company also collects, holds, uses and discloses individual’s information for the following purposes:
- To improve its services through quality improvement activities such as audits, surveys and other quality improvement activities.
- To obtain professional advice.
10 Direct Marketing
Collecting information indirectly about an individual for marketing to that individual
If the Company plans to engage in direct marketing using or disclosing information collected:
- indirectly about that individual, or
- from the individual and the individual would not reasonably expect us to use or disclose the information for marketing purposes,
the Company must first obtain consent, unless an exception applies.
An example is the Company policy around direct marketing of the village to prospective clients. One way the Company’s services are offered to prospective clients is through the contacts of existing residents. Existing residents will sometimes refer the Company to a contact he or she thinks would be interested in a village tour. If an individual’s personal information is collected in this way the Company will call or write as soon as practicably possible to notify them about the collection and other relevant matters, as well as give them the opportunity to consent to opt-in to receive continuing communication from the Company about the village.
All subsequent direct marketing individuals receive will include an easy opt-out procedure if at any time they wish us to cease sending them information.
Collecting information directly about an individual for marketing to that individual
If the Company collects information about an individual and they would reasonably expect the Company to use or disclose the information for the purpose of marketing, the Company will use an opt-out procedure in all its marketing communications. This means individuals will be able to easily unsubscribe from all future marketing communications.
Depending on the category of information, withholding of personal information from the Company might mean we are unable to perform some essential functions of managing a retirement village including one or all of the purposes listed above in Section 9.
In the event the Company engages in cross border transfer of information, such as routing or storing information on cloud servers located overseas, it will ensure that adequate security mechanisms are in place to protect your information. For example, it will enter into a contract with the cloud service provider that ensures the information is for the limited purpose of storing and managing the personal information.
The Company does not currently or plan to make cross border disclosures of privacy information to entities overseas.
This section explains how the Company holds privacy information, how individuals can access their privacy information, update privacy information, complain about an alleged breach of the Australian Privacy Principles (APPs) or make any related enquiry.
Maintaining currency of Privacy information
The Company relies on accurate and reliable information to deliver necessary and effective services. If the Company is satisfied that any of the information it holds about an individual is inaccurate, out-of-date, irrelevant, incomplete or misleading, or the individual requests the Company correct any information, the Company will take reasonable steps to ensure the information held by it is accurate, up-to-date, complete, relevant and not misleading.
The practical measures by which the Company avoids having an incorrect record of a resident’s information include asking individuals to complete the appropriate forms upon arrival at the village and requesting that they periodically update this information in writing.
If the Company discloses privacy information that is later corrected, we will, or else the individual may ask us to, notify the entity that received the incorrect information about that correction.
Should the Company refuse to correct the information, it will explain the reasons for refusal. The Company will also show the individual the complaint procedure if they wish to lodge a formal complaint about the refusal.
Safety of Privacy information
All privacy information is securely stored using appropriate physical and/or electronic security technology, settings and applications, and by ensuring the staff dealing with privacy information are trained in the Company’s privacy policies and procedures.
These policies are designed to protect privacy information from unauthorised access, modification or disclosure; and from misuse, interference and loss.
In the event that the Company ceases to operate, or the business is sold or transferred the Company will ensure that adequate mechanisms are in place to protect individuals’ privacy information. The Company will take all reasonable steps to notify individuals of the transfer or closure of the business or practice, including publishing a notice in a local newspaper that is circulated in the locality of the business.
The Company may elect to retain an individual’s privacy information or transfer it to the company that takes over the business or practice. In circumstances where the Company elects to retain privacy information, it will be secured or lawfully destroyed.
15 Accessing personal information or lodging a complaint
Accessing and correcting information
Individuals are entitled at any time, upon request, to access their privacy information held by the Company. The Company will respond within a reasonable time after the request is made and give access to the information in the manner requested by the individual, unless it is impracticable to do so. The Company is entitled to charge a reasonable administrative fee for giving access to the information requested.
Should an individual be refused access to their information, the Company will explain the reasons for refusal – any exceptions under the Privacy Act or other legal basis relied upon as the basis for such refusal – and, if the individual wishes to lodge a formal complaint about the refusal, the Company will explain the complaint procedure.
Lodging a complaint
The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.
Longevity Group Australia
First Floor, 785 Toorak Road
Hawthorn East, Vic 3123
Phone: (03) 9275 8000
|Privacy information||includes personal information and sensitive information.|
|Personal information||includes information that is capable of identifying an individual such as name, address and date of birth.|
|Sensitive information||includes information relating to health or religion, racial or ethnic origin.|
|We, us and our||refer to the Company.|
|APPs||refer to the Australian Privacy Principles in the Privacy Act 1988 (Cth).|
|The Company||Longevity Group Australia Ltd|
|Company People||Directors, management, employees, secondees, contractors, consultants and visitors engaged in any Company related activities|