PRISON NETWORK PRIVACY STATEMENT
Introduction
In the course of our work, Prison Network (PN) collects personal information about donors, funders, program attendees, clients and their family members, and other members of the public who engage with us. Although PN is not bound by privacy legislation, PN greatly values privacy protection and it is committed to protecting the privacy of these individuals.
The purpose of this statement is to set out how PN collects, shares, uses and stores personal information, as well as how persons may access personal information stored by PN. Persons who engage with PN do so subject to this Privacy Statement.
A copy of this Privacy Statement is available on PN’s website (prisonnetwork.org.au).
This Privacy Statement is approved by PN’s Board. PN may occasionally update it to reflect changes in the law, policies of the organisation and/or feedback from stakeholders. If you regularly engage with PN, you are encouraged to periodically review these terms to stay informed as to how we are protecting your information.
What types of personal information do we collect?
PN collects personal information - meaning information or an opinion about an individual whose identity is reasonably identifiable from the information or opinion, regardless of whether or not the information or opinion is true and whether or not the information is recorded in a material form.
PN collects personal information of donors, funders, program attendees, clients and their family members, and other members of the public who engage with PN, including:
names, dates of birth, genders, home, business and/or mailing addresses, personal email addresses and contact phone numbers – and those of their families, nationality, ethnicity and language(s) spoken;
prison identification numbers (CRNs);
next of kin details (including place and date of birth of parents and siblings, family and relationship background information, name and contact details for significant others and relationship background information);
(for children of clients) guardian information;
Medicare numbers and other concession information; and
details of medical concerns or issues and any treating practitioners.
Some of the above information that is collected could constitute sensitive information, which generally includes information or an opinion such as health information (defined below) and information about a person’s criminal record, racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs and sexual preferences or practices.
PN may collect clients’ personal experiences and stories from time to time.
In limited circumstances (for example, when shared with us by clients or their families), PN may collect health information, which generally includes personal information about a person’s health, illness, injury or disability or about health services provided to an individual or about their expressed wishes about the future provision of health services to them or their family.
Specifically, PN collects health information about clients’ children, such as information about their allergies and other medical needs.
How do we collect information?
PN will only collect personal information:
where it is lawful to do so;
by fair and lawful means; and
not in an unreasonably obtrusive way.
Generally, you provide most of the personal information directly to us. Most of this personal information is collected when you:
provide your personal details to us over the telephone or via email, letter or social media (including if you comment on our social media accounts);
complete a contact form, whether on our website or otherwise;
register to become a donor or funder;
speak to a PN volunteer of staff member and they take notes;
engage with us on social media, including leaving posts or comments on our social media accounts;
if you are a client or program attendee, in your self-referral form, registration or onboarding documentation and throughout our engagement with you.
Sometimes, PN may collect personal information about you from a third party (for example, when you are referred to PN by an agency or if you request us to liaise with your legal representation). If so, we will take reasonable steps to inform you about the collection, unless it would pose a serious threat to the life or health of any individual or a breach of confidentiality to do so.
How do we use personal information that we have collected?
PN will not collect information from you unless it is reasonably necessary for one of our functions or activities.
PN collects and holds personal information for reasons including:
to provide its services and meet service delivery requirements;
to provide an historical account of its operations and activities to facilitate sound future decision-making;
for the purposes of accountability to funders through grant applications;
for reporting of statistics to Corrections Victoria or other entities;
to provide support for individuals and their families accessing PN’s services;
If applicable, to allow government agencies to audit the services provided by PN;
to link clients and their families to other services to enhance their quality of life and enable their inclusion in the everyday life of their communities;
to send receipts, invoices and correspondence;
to record program attendance;
providing support to you;
to provide updates via our social media accounts, website, annual reports, newsletters and grant applications (personal information is de-identified in these cases);
to provide support to children via our Keeping Kids Connected programs (including to ensure safety of children who are supported to attend school holiday camps and/or outings, and to provide transport for children to visit their mothers); and
to ensure safety of our clients and their children.
At times, when we collect personal experiences and stories from the clients we support, we may share those stories in public forums (such as in our newsletters or at events that PN is involved in). When we do so, we change the names in the story and ensure that all potentially identifying information is removed. At all times, we will prioritise the privacy of the individual whose experience or story we have chosen to share. Wherever practicable, PN will seek approval from those concerned before sharing any de-identified personal experiences or stories. If you are not comfortable with us sharing de-identified information about your experiences, please let us know.
When you donate, participate in our programs, or otherwise engage with PN online via our website or other platform, you agree for PN to extract your contact details from that data you supply so that we can contact you about future programs or other opportunities, usually by email or phone.
Sensitive information is only used for the primary purpose for which it was collected.
Can PN use my personal information in more than one way?
Where personal information has been collected for a specific purpose, PN will only use or disclose that information for that purpose (the original purpose). For example, if you provide us with your contact details to request information from us, we will use those details to supply the information.
However, PN may use or disclose your personal information for another purpose (the secondary purpose) if:
the law allows or requires it; and
you have consented to the use or disclosure of your personal information for the secondary purpose;
the secondary purpose is directly related to the original purpose and an individual would reasonably expect PN to use their information in that way; or
it is reasonably necessary to lessen or prevent a serious or imminent threat to an individual’s life, health, safety or welfare.
Can PN disclose my personal information to another person or organisation?
As above, PN may disclose your personal information to another person or organisation only where it is required by law, and on a limited basis. For example, clients who participate in PN’s services are requested to sign consent forms enabling PN to share specific information that they have provided to other agencies, family members, support workers or case workers if needed.
We will do our best to let you know if we need to disclose your personal information to an external party. We will also ensure that the external party agrees not to use your own personal information for any other purpose other than the purpose it is being provided by PN. We do not sell your information to anyone.
What about information I post on social media?
By posting comments on our social media accounts, you acknowledge that the comment may be published. Publishing of comments is entirely within our discretion, as moderators of the website and accounts. We may determine to edit comments or not publish them at all. Personal information included by you in the original comment may be published. You agree not to post any defamatory or offensive comments on our website or social media platforms (including Facebook and Twitter).
How do we store and protect information?
PN is committed to ensuring that the personal information it holds is stored securely and safeguarded from loss, misuse, unauthorised access and disclosure.
Personal information held by PN is accessible on a strictly need-to-know basis.
PN holds all personal information collected electronically in its secure cloud-based management systems Sharepoint and Salesforce. Only staff can access this data with a unique log-in and password and using other security protocols such as multi-factor authentication. Some data is also then restricted to specific staff only, as is appropriate.
Notes may be retained on staff’s computers which are password-protected.
All hard copy and archived data is stored securely at PN’s designated premises.
We will notify you if we become aware of data security breaches that may affect your personal information.
Other privacy statements
PN is not responsible for privacy practices or statements or other content on websites external to the PN website. If you link to another website from the PN website, we encourage you to ready the privacy statements of those websites.
How can you access your personal information?
You can request to access, update or correct your personal information held by PN by contacting:
The Privacy Officer
Address | PO Box 46, Kerrimuir, VIC 3129
Email | privacy@prisonnetwork.org.au
If you contact the Privacy Officer to correct or update your personal information, and are able to provide proof that the personal information currently held is incorrect, PN will take all reasonable steps to correct the information as soon as practicable and no later than 30 days of the request.
If you request copies of your personal information, a fee may apply.
PN reserves the right to refuse your request to access or correct your personal information where we are legally entitled to do so, and we will notify you of the reasons for refusal. For example, access may be denied where the release of the information to you may have an unreasonable impact on the privacy of others or if we reasonably consider the request to be frivolous or vexatious.
Any concerns?
If you have any concerns, questions or complaints about our handling of your personal information, please email the Privacy Officer at the contact details set out above or contact a relevant external complaints organisation.
Where a complaint is received, PN will:
determine whether there are simple or immediate steps that can be taken to resolve your complaint;
if not, investigate the complaint, engaging with the complainant and their representative (if any); and
document the complaint for auditing purposes and to identify opportunities for improvement.
Updated June 2024