Privacy Policy

Converge International (Converge) is committed to ensure compliance with the policy requirements of the Privacy Amendment (Private Sector) Act 2000 through a range of policies and procedures which protect its clients, personnel, the organisation and other parties with whom it has relationships.

Privacy is a different notion to confidentiality. This Act deals with information privacy only and covers all types of personal information not commonly available. The purpose of the Act is the protection of the individual with regard to the processing of personal data and the free movement of such data.

Central to the legislation are the ten National Privacy Principles which establish minimum standards for organisations to comply with relating to the collection, storage and security of personal information.

Converge is committed to and abides by the National Privacy Principles and Guidelines endorsed by the Office of the Federal Privacy Commissioner.

Converge is committed to protecting the privacy of all personal information collected.

Personal information is defined as information or an opinion that can identify a person.

All personnel engaged by Converge are required to be aware of the Privacy Act and their obligations under this legislation.

1. Information Collection
1.1 Converge will routinely collect only that information that is required to perform its core business functions. Any collection will be by lawful and fair means. (Note: Fair is defined by the Privacy Commissioner as “without intimidation or deception”.)

1.2 When personal information is collected about an individual, Converge personnel will take all reasonable steps to ensure that the individual is aware that their information has been collected, how it will be used, that the individual may access information held about them and the likely consequences of failing to provide the information. This applies even if the information is collected from someone else.

2. Use and Disclosure
Converge will not use or disclose personal information for reasons that are not consistent with the primary, or related purposes, of its collection, unless:
i. the individual has consented to its use or disclosure for a secondary purpose; or
ii. Converge has fully complied with the relevant National Privacy Principle for the specific purpose (eg use of personal information for research, statistics or direct marketing).

3. Data Quality
Converge will take all reasonable steps to ensure that personal information collected is accurate, complete and up-to-date.

4. Data Security
Converge will take all reasonable steps to protect the information it holds from misuse or unauthorised access.

Every area within Converge is responsible for ensuring that personal information (of individual clients and Converge personnel, including external service providers) is kept physically secure and only able to be accessed by authorised personnel. This includes information kept on computer databases or that which is transmitted electronically. Information that is no longer needed will be destroyed or permanently de-identified.

5. Openness
Converge will make this policy available to any interested person upon request. In addition, a summary of the key points is available:-
i. in the Converge privacy brochure, and
ii. on the Converge web site.

Converge will, on request, provide details about the type of personal information which is held and what is done with it.

6. Access and Correction
An individual may request access to personal information which Converge holds about him/her provided that:-
i. such access would not pose a serious threat to the life or health of any individual;
ii. access would not have an unreasonable impact on the privacy of other individuals;
iii. the request is not frivolous or vexatious;ie
. Trivial and made for amusement’s sake; or
. Made as a means of pursuing some unrelated grievance against the organisation;
. Repeated requests for access to the same personal information.
iv. the information does not relate to existing or anticipated legal proceedings;
v. the information would not prejudice negotiations with the individual (eg commercial);
vi. there is not another legal requirement for denying access as specified in the National Privacy Principles.

Individuals are only able to view their own information. The privacy of others will not be compromised to facilitate this.

If an individual is able to establish that personal information held by Converge is inaccurate, incomplete or out-of-date, Converge will take all reasonable steps to correct the information.

Exception: information collected prior to 21/12/01. Requests for access to exempted information will be considered according to individual circumstances.

7. Identifiers
Converge will not use identifiers issued by Commonwealth agencies (eg Medicare numbers, tax file numbers, Social Security numbers) for identification of any individual.

Note: an individual's name or ABN (as defined in A New Tax System (Australian Business Number) Act 1999) is not an identifier.

8. Anonymity
Individuals may remain anonymous during interactions with Converge (eg enquiries regarding Converge's services) provided that this is lawful and practicable.

9. Transborder Data Flows
Converge will not transfer personal information about an individual to someone in a foreign country unless certain requirements are complied with, as outlined in the National Privacy Principles.

i. It is reasonably believed that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the National Privacy Principles;
ii. the individual consents to the transfer; or
iii. the transfer is necessary for the performance of a contract between the individual and the organisation, or for the implementation of pre-contractual measures taken in response to the individual's request; or
iv. the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between the organisation and a third party; or
v. all of the following apply:
(a) the transfer is for the benefit of the individual;
(b) it is impracticable to obtain the consent of the individual to that transfer;
(c) if it were practicable to obtain such consent, the individual would be likely to give it; or
vi. reasonable steps have been taken to ensure that the information transferred will not be held used or disclosed by the recipient of the information inconsistently with the NPPs.

10. Sensitive Information
Sensitive information is a subset of personal information. It means:
i. information or an opinion about an individual's:
(a) racial or ethnic origin;
(b) political opinions;
(c) membership of a political association;
(d) religious beliefs or affiliations;
(e) philosophical beliefs;
(f) membership of a professional or trade association;
(g) membership of a trade union;
(h) sexual preferences or practices;
(i) criminal record.
that is also personal information; or
ii. health information about an individual.

Converge will not collect sensitive information about an individual unless the individual has consented or such collection is required by law or in the case of health information, specific requirements of the NPPs are complied with.

In the course of its activities as a not-for-profit religious organisation, Converge may collect sensitive information about individuals whose services it engages but undertakes not to disclose this information without the individual's consent.

reviewed February 2008