About this Policy
This policy sets out the principles adopted by the Village Retirement Group of Companies, hereinafter defined as VRG, in protecting your personal information during the conduct of our business.
The policy is in compliance with the Australian Privacy Principles as defined in the Privacy Act (1988) which defines how we must handle, use, and manage personal information.
Purpose of the Policy
Type of Information we collect
There are two classes of information defined under the Privacy Act – personal information and sensitive information, the latter of which includes health related information.
VRG will only collect either type of information if it is deemed reasonably necessary for our business needs and activities.
Personal information includes your contact details, information necessary for the payment of regular charges and services provided by us to you, and any other information necessary for our administration and effective business planning.
Sensitive information may include health related information, religion, race, or ethnic origins. We will not collect this information without consent from you. We may seek to collect this information where we provide, or propose to provide, health or community care related services to you.
VRG may also collect with your consent, health information from residents or prospective residents to verify our retirement villages are appropriate for an individual’s needs. We do not share that information other than within the terms of the consent given by you, or where an exception exists and we are able to do so; for example, in a medical emergency.
How we collect your information
VRG collects personal information (but not sensitive data) about people from a variety of sources. This includes, but is not limited to, Sales and Marketing, Business Development, Village Operations and Human Resources.
VRG prefers to collect information directly from our village residents or prospective residents, unless it is impracticable to do so. Our main method of information collection is via a resident information collection form, which is then maintained when you update your information with us.
If you do not consent to us collecting health or other sensitive information then we will not be able to do so, unless an exception applies. An exception may occur in the case of an emergency, where the collection of such information without a permission being reasonably obtained may reduce the risk to health, safety, or pose a life threatening situation. Alternatively, where collection of information is authorised or required under Australian law.
Marketing: collecting information about an individual for marketing purposes.
VRG may use or disclose personal information for direct marketing and contact purposes if it was collected from you and you would reasonably expect us to use the information for that purpose. You may contact us at any time should you wish to be unsubscribed from further direct contact or receive marketing material.
Where information is obtained about an individual indirectly, or when information is provided by an individual who would not reasonably expect the information to be used or disclosed, then we must first obtain consent before using that information. We are exempt from that requirement where it is impracticable to obtain such consent.
You may contact us at any time should you wish to be unsubscribed from our direct marketing programs.
What do we do with your information?
VRG will only use your personal information for the reasons we collected it or allied purposes as explained in this policy. For residents living in VRG retirement villages, we collect and use personal information so that we can effectively manage our retirement villages. Examples of how the privacy information we collect, hold and use are shown below;
- To keep a resident personal information record to assist us in contacting you as required
- To advise nominated next of kin or representatives authorised by you, of an emergency medical situation so that support can be provided
- To keep records of accidents or injuries in the village that you or others report to us for WHS review and insurance purposes
- To collect and store your bank account details so that we can arrange direct debit of your monthly fees and other charges authorised by you for collection
- To store your date of birth to verify you are eligible as a retirement village resident
- To assist VRG in the future planning of its business model
- To include, with your permission, your contact details in the village’s resident directory so other residents may contact you directly.
Use & Disclosure of Information
VRG will not use collected information other than for the purposes defined in this policy. Occasionally it may be necessary to pass information to external professionals and contractors. Where personal information is passed to a third party VRG will take all reasonable steps to ensure the information is treated in accordance with Australian Privacy Principles guidelines, and that confidentiality of your information is maintained.
VRG is unlikely to disclose your personal information to overseas recipients, except where exceptions apply or if required under Australian law.
We will not sell your personal information to other groups or organisations.
Safety of Privacy Information
VRG holds personal information via a combination of physical records and electronic database storage. The physical records are safely kept within secure office areas and accessed by VRG office staff who are trained and familiar with our privacy policies and procedures. Personal information stored by electronic means is protected by electronic security and software.
Maintaining the quality of Personal Information
We seek to ensure through all reasonable means, that the personal information we collect, store and use is accurate and up to date.
For residents in our retirement villages this is done by completion of the resident personal information form and then asking you to update it on a regular basis. This is usually annually.
If at any time we become aware that the information we hold is inaccurate or misleading, or you ask us to correct or update any information held, we will take all reasonable measures to rectify and ensure the information we hold is correct and accurate and does not misinform or mislead.
If a request to correct information held by us is refused, we will give you the reasons for our refusal and provide information on our complaints process should you wish to formally lodge a concern about our decision.
If we hold information about you then you are entitled, at any time on formal request, to ask for access to that information. We will respond to any requests in both a reasonable and practicable manner and time period. We are entitled to make a reasonable charge for providing access to your information.
You will be given access to your personal information, except where exceptions apply or where restrictions apply under Australian law. For example, where giving access would have an unreasonable impact on the privacy of other individuals.
If access to your information is refused we will provide a written explanation of the reasons for our decision and details of our complaints procedure if you wish to lodge a formal objection about our refusal.
Lodging a complaint
When you write to us you should provide;
- a brief description of your privacy concern
- what actions that you and we have taken to resolve your concern this far
- copies of any relevant documents and letters
We must respond within a reasonable time frame. If we take longer than 30 days to respond to your complaint, or if you do not agree with our decision, you can forward your concern to the Australian Privacy Commissioner. Further details can be found at www.oaic.gov.au
Village Retirement Group Privacy Officer
c/o Retirement Living Operations Manager
The Village Retirement Group
144 Arthur Street,
Fortitude Valley QLD 4005
Phone: (07) 3854 3777
Email : firstname.lastname@example.org