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  • 1. OVERVIEW

    1.1 About YMCA Victoria

    YMCA Victoria is a community not-for-profit organisation. Our mission is to work with the community to empower young people, giving them the skills and confidence to lead positive and independent lives.

    We deliver programs and services at locations across Victoria and in other Australian States and Territories. These include:

    • children's programs (including early learning centres and OSHC (out-of-school-hours care) programs);
    • swimming schools and learn-to-swim centres (such as Kingswim);
    • skate parks and action sports;
    • camps (including accommodation and outdoor education programs);
    • recreational facilities and services (including swimming pool management, health and fitness services (including gyms), stadium sports, gymnastics, cafes and creches);
    • the Virtual Y; and
    • youth services (including maintenance programs, youth hubs and volunteer management).

    Find out more information about our programs and services.

    We work with a diverse range of partners who provide us with funding and assist us to deliver our programs and services (Partners). Our Partners include State, Territory and Federal Governments, Local Government Authorities, community organisations, businesses, philanthropic trusts and foundations.

    As a not-for-profit organisation, we rely on donations to continue providing our programs and services and to operate our organisation. We conduct marketing and fundraising activities to raise awareness of our work in the community and keep in touch with our supporters, donors and people who have used our services and programs.

    We also conduct other activities (such as advocacy and awareness raising) that are related to our core mission of working with the community to empower young people.

    1.2. Why do we collect and handle your personal information?

    We only collect, store, use and disclose personal information when it is reasonably necessary for us to deliver our programs and services, operate our organisation and perform our other functions.

    Some of our activities that typically require us to collect and handle personal information include:

    • planning, delivering and administering our programs and services;
    • processing donations;
    • verifying your identity, where this is required by or law or we consider it is reasonably necessary to do so;
    • personalising our programs and services for you to:
      • ensure that we meet any special needs or requirements you may have; and
      • better understand your preferences (this helps us to provide you with a more tailored experience of our services, programs and websites, and send you content about our programs and services that may be of interest to you);
    • considering you for a role with YMCA Victoria (whether as an employee, consultant or volunteer) and, if you are successful, administering your position with us;
    • meeting our duty of care obligations;
    • protecting the health, safety and security of our staff and customers;
    • operating, managing and securing our physical premises (such as our offices and facilities), our computer systems and our websites and apps;
    • keeping you informed of our services, programs and other activities (including through our newsletter and other forms of communication);
    • conducting our fundraising, marketing and advertising activities;
    • conducting community and stakeholder consultation to better understand what challenges the community is facing and how we can assist;
    • developing and improving our organisation and our products, services and activities, including by:
      • conducting staff training and quality assurance activities;
      • seeking feedback and conducting surveys on our programs and services (such as customer satisfaction and market research);
      • tracking, measuring and analysing the success of our services and programs and our fundraising, marketing and advertising activities;
      • sharing information with our Partners and other stakeholders; and
      • exploring opportunities to expand the range of Partners we work with;
    • contributing to research that is relevant to our mission, function and activities (or which otherwise contributes to the community);
    • engaging in our advocacy and awareness-raising activities;
    • complying with our legal and regulatory obligations;
    • investigating allegations of wrongdoing, misconduct or other behaviour that breaches our policies; and
    • handling and responding to issues and complaints.

    We may also collect and handle your personal information:

    • if you have given your consent; or
    • where it is for a purpose that you would reasonably expect (and which is related to the original purpose for which we collected that information); or
    • where we are required or authorised by law to do so.

    When we collect personal information we take reasonable steps to ensure that you are aware of why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.

    1.3 Can I remain anonymous?

    If you would prefer to interact with us anonymously or using a pseudonym, you can request to do so. We will do our best to accommodate these requests where possible.

    However, in many cases it will not be practicable (or lawful) for us to deal with you without knowing who you are. In those circumstances we will need to collect your personal information (such as your name and contact details) before we can assist you.

    If you choose not to provide the information that we request (or permit us to collect that information), this may impact the types of services, programs, products that we are able to offer to you and limit the ways that we can work with you.

    1.4 Has YMCA Victoria collected any personal information about me?

    If you are unsure about whether YMCA Victoria has collected personal information about you, you can ask us to:

    • confirm whether we hold any personal information about you; and
    • explain the general nature of that information, the purposes for which we use that information, and how we collect, hold, use and disclose that type of information.

    You can do so by contacting our Privacy Officer (see contact details in section 11 of this Privacy Policy below).

    You also have the right to request to access or correct the actual personal information that we hold about you, if any (see section 9 of this Privacy Policy below).

    We will handle all requests in accordance with your rights under applicable privacy laws. In some circumstances we may be permitted (or required) to refuse your request.

    1.5 Which entities make up YMCA Victoria?

    For the purposes of this Privacy Policy, “YMCA Victoria” includes the following entities:

    Entity name Description
    The Young Mens Christian Association of Victoria Inc. (ABN 81 174 456 784) This is our main operating entity and is a community non-profit charity providing support to the community.
    Victorian YMCA Youth and Community Services Inc. (ABN 42 858 439 742) This entity manages our youth and community services, and provides benevolent access to programs and services for people in need.
    Victorian YMCA Accommodation Services Pty Ltd (ABN 94 081 270 706) This entity manages our student accommodation services.
    YMCA Aquatic Education Ltd (ABN 88 151 552 322) This entity operates our Kingswim learn to swim programs (www.kingswim.com.au).
    YMCA Aquatic & Event Services Ltd (ABN 16 148 092 148) This entity manages the South Australian Aquatic & Leisure Centre on behalf of the South Australia Government.
    YMCA Camping Ltd (ABN 77 606 062 793) This entity manages the camping facilities that we offer.
    Victorian YMCA Community Programming Pty Ltd (ABN 75 092 818 445) This entity operates our recreational and childcare services.
    YMCA Learning Communities Ltd (ABN 20 608 745 295) This entity operates a number of early learning, swim school and community hubs in partnership with YMCA Geelong and YMCA Whittlesea.
    Activating Communities Ltd (ABN 31 619 359 590) This entity previously managed our retirement living facilities but is not currently operating.
    The Y of Tasmania Ltd (ABN 56 654 311 985) This entity is not currently operating.

    This list of entities may be updated from time to time if there are changes to YMCA Victoria’s operating arrangements.

    Together, these entities operate the various programs and services described in this Privacy Policy. When you use these programs and services your personal information may be collected and handled by one or more of these entities, depending on which program or service you use.

    These entities manage personal information collectively, in accordance with this Privacy Policy. This means that your Personal information may be accessed by, and shared between, these entities for the purposes described in this Privacy Policy (for example, through the use of common IT systems, customer databases, business services and administrative functions that are shared across the group).

    Any privacy queries, requests or complaints regarding these entities can be submitted using the contact details in section 11 of this Privacy Policy below.

    Kingswim customers also have the option of contacting Kingswim directly using the Kingswim contact details in the Kingswim privacy policy.

  • 2. TYPES OF PERSONAL INFORMATION WE COLLECT

    2.1 General

    The types of personal information we collect may vary, depending on the nature of our relationship with you.

    In the ordinary course of business, we often collect personal information about:

    • our customers who use our services, participate in our programs or purchase goods from us;
    • our donors and supporters;
    • our volunteers, employees and other staff;
    • our Partners and their staff; and
    • our service providers and their staff.

    The types of information that we commonly collect include:

    • your name and contact details (e.g. address, email and phone number);
    • your date of birth and next of kin information, where this is relevant to the service or activity you are participating in;
    • photos, images and videos (for example, when you participate in our services and programs);
    • your payment information (such as credit card, bank details and direct debit details), if you are making payments or donations to us;
    • information that we collect in order to provide you with the service, program or product you have requested (e.g. information to confirm that you meet any relevant eligibility criteria, and any special needs or requirements);
    • records about the services, programs and goods that we provide to you (such as your registration details, attendance details, purchasing records, receipts and invoices);
    • your membership or account details and records, if you create a membership or account with us for any of our services, programs or facilities;
    • details of any subscription that you have with us;
    • records of your donations to YMCA Victoria;
    • other information that you choose to provide to us (for example, when you contact us over the phone or in writing, when you apply for one of our programs or services, when you interact with us through our website or social media pages or when you respond to one of our surveys);
    • if you are a parent or legal guardian of a minor who uses our services, your emergency contact details;
    • if you are a YMCA Victoria volunteer, employee or other staff member, information relating to your role with us which may include (depending on the nature of the role) your qualifications, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles);
    • if you work for one of our Partners or service providers, information about you that is relevant to the work that we are doing with your organisation (for example, your work contact details);
    • if we need to verify your identity, we may ask to see appropriate identification (and, if reasonably necessary, take a copy of that ID);
    • if you call us we may record your call for quality control and training purposes; and
    • if you attend our offices or any facility or premises that we operate or manage, we may:
      • collect certain contact details that you provide to us, including the date and time of attendance, which we use to protect the safety and security of our facilities and premises and to comply with applicable laws (which may include public health directives); and
      • record your image and/or voice through the use of Closed-Circuit Television (CCTV) or other video surveillance systems, which we (and our security service providers) use for the purposes of managing security of our facilities and the health and safety of occupants and the public generally.

    Some of our services, programs and initiatives may require us to collect other types of information. In such cases we take reasonable steps to make you aware of the types of information that are being collected, and how such information will be handled. We may provide you with written or verbal privacy collection statements to explain these matters to you.

    Like most not-for-profits, we maintain various contact lists and databases for fundraising, marketing and advertising purposes. Please see section 7 of this policy for further information.

    If you visit our website, we may collect certain information about your visit and how you use our website. Please see section 8 of this policy for further information.

    2.2 Sensitive information (including health information)

    Sensitive information includes certain specific types of personal information such as health information, and information about a person's racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.

    We only collect sensitive information about you with your consent, or otherwise where permitted by applicable privacy laws. The main types of sensitive information we may collect include:

    • details of injuries (i.e. health information) that may occur at our facilities or in connection with any of our services or programs, which we collect in order to record the incident, manage the injury and handle any claim processes resulting from the incident (such as insurance claims);
    • details of any disabilities or allergies (i.e. health information) you notify us of so we can accommodate any special requirements (for example, when you attend our premises or participate in our services or programs);
    • information that you choose to share with us about yourself (such as your ethnicity, religious beliefs or sexual orientation) so that we can provide you with our services and programs in a culturally sensitive and appropriate manner;
    • details of your membership of professional associations and affiliations with relevant industry bodies or organisations, if this is relevant in the circumstances (for example, if they are relevant to an employment, consulting or volunteering role that we are considering you for); and
    • criminal record details, as part of background checks that we undertake (for example, when we are considering you for an employment, consulting or a volunteering role with YMCA Victoria).

    If you do provide sensitive information to us for any reason (for example, if you provide us with information about an injury or disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by applicable laws (including privacy laws).

    YMCA Victoria operates and manages various health services, including medical suites, massage services, physiotherapy services, sports medicine services, health and fitness clubs and recreation centres. This is the main scenario in which we collect health information. The types of health information we may typically collect (depending on the type of health services you use) include:

    • blood pressure;
    • body-mass index;
    • personal medical plans;
    • details of any previous and current injuries;
    • measures of your heart rate; and
    • records about your mobility and ability to perform certain activities.

    We collect this information so that we can provide you with the relevant health or fitness service that you have requested (for example, to monitor your progress, plan your sessions and provide you with advice).

    2.3 Government identifiers

    In some circumstances we may need to ask for your government identifiers, such as your Tax File Number or Medicare number.

    We generally only do this when it is necessary for us to verify your identity, where it is required or authorised by law, or where it is relevant and necessary for the particular service, program or role that you have requested.

    2.4 Information that is required or authorised by law

    We may collect, use and disclose personal information where required or authorised by law.

    Some of the services and programs that we offer are regulated by laws that require (or authorise) us to collect, use and disclose certain personal information. In such cases, we may not be able to provide you with these services and programs if you do not provide us with the required information.

    For example, our early learning, kindergarten and before / after school programs are governed by child safety laws that require us to collect certain information and report certain matters to child safety authorities.

  • 3. HOW WE COLLECT PERSONAL INFORMATION

    3.1 General

    The main way we collect personal information is when you provide it to us. We generally try to collect your personal information directly from you where this is reasonable and practicable.

    Some of the common situations where we may collect personal information from you include:

    • when you use or participate in our programs or services or purchase goods from us;
    • when you apply for a role with us;
    • when you subscribe to our mailing list;
    • when you engage with our fundraising, marketing or advertising campaigns;
    • when you provide us with feedback or otherwise participate in our surveys or community engagement / stakeholder consultation activities;
    • when you provide goods or services to YMCA Victoria;
    • when you submit an inquiry, request, application or complaint to us;
    • when you contact us through our websites or by telephone, e-mail, social media pages or other means; and
    • when you attend our premises or facilities or access our computer networks.

    To allow for the efficient management of our organisation we may keep records of our correspondence and other interactions with you.

    In certain cases we may need to collect personal information from publicly available sources or third parties. For example:

    • we may collect contact information from publicly available sources where permitted by law for use in our fundraising and community engagement activities;
    • if you are a minor, we may collect information about you from your parent or legal guardian;
    • if you apply for one of our programs that works on a referral-only basis, we may collect information about you from the agency that nominated or referred you; and
    • if you apply for a role with us, we may collect information from your referees, government bodies (e.g. police checks and working with children checks, if required), academic and professional bodies (e.g. to validate details and currency of qualifications).

    3.2 Technology services that we use

    Like many organisations, we use a variety of technology services in delivering our programs and services and performing our other functions and activities. These include technology services that are provided and operated by third party service providers.

    In some cases, we use these technology services to collect information from or about you. For example:

    • we use social media platforms such as Facebook and Twitter to keep in contact with the community;
    • we may use third party services to conduct our surveys;
    • some of our programs and services may require you (or give you the option to) download a third party app or use a third party website; and
    • when you visit our websites, we use cookies, web analytics and other similar technologies to collect information about how you interact with our website (see section 8 of this Privacy Policy for further information).

    The information that we collect via these third party technology services is used for the purposes explained in this Privacy Policy.

    Some of these technology services have their own privacy policies, which explain how the service provider handles and processes any personal information or other data that is collected by the service.

    If you choose to use social media platforms to communicate with us or with other YMCA Victoria customers or stakeholders, please be mindful that certain pages within these platforms may be publicly available. We encourage you to use the privacy settings available on each platform. If you would like to contact us privately, you can do so using the contact details in section 11 or via the general inquiry form.

  • 4. DISCLOSURES OF YOUR PERSONAL INFORMATION

    4.1 General

    Depending on the nature of the information we have collected and the purpose for which we have collected it, we may sometimes need to provide your information to other individuals or organisations.

    In general, we will only provide information about you to others:

    • where it is consistent with the primary purpose for which we collected that information (or for a related purpose which you would reasonably expect);
    • with your consent; or
    • where we are legally required or authorised to do so.

    When we engage a third party (such as a contractor) to handle your personal information on our behalf, we take appropriate steps to require them to protect your information and handle it securely.

    We do not sell your information to other organisations, and we take steps to ensure that we conduct our fundraising, marketing and advertising activities in compliance with applicable laws (including privacy, direct marketing and spam laws).

    4.2 Examples of how we share information

    The types of individuals and organisations that we commonly share information with include:

    • our staff (including employees, contractors and volunteers) who need access to that information for their particular role;
    • our service providers, including:
      • our IT service providers who provide us with web hosting, cloud services, IT support and cyber security services;
      • organisations who help us with our fundraising, marketing and advertising activities (such as call centres, mailing houses, online targeted advertising networks, social media platforms, professional fundraising organisations and data analytics providers);
      • our accountants, insurers, lawyers, auditors and other professional advisers; and
      • payment processors and other organisations that help us to process your purchases, donations and other transactions with us;
    • our Partners, who may:
      • provide us with funding for our programs and services;
      • provide us with equipment and facilities; or
      • assist us to deliver our programs and services (such as health service providers and other charities and community service organisations);
    • government agencies, regulatory authorities and law enforcement (if we are required to do so, or if we think that it is reasonably necessary and appropriate in the circumstances);
    • persons who are authorised or responsible for you (e.g. your parent or legal guardian, if you are a child or young person); and
    • universities and research organisations.

    Some of our programs and services are delivered by YMCA Victoria on behalf of (and using funding provided by) our Partners, such as Federal, State/Territory and local governments. In such cases we may be required to:

    • report to that organisation about how we have used the funding they provided; and
    • in some cases, transfer our records of the program or service (including records of your attendance or participation) to that organisation when the program or service is finished (or if requested by that organisation).

    Together with the YMCA associations in the other States and Territories, YMCA Victoria also provides aggregated and non-identifying statistical data about our programs and services to YMCA Australia (also known as “Y Australia”). This is to assist YMCA Australia with its role in co-ordinating the broader YMCA movement across Australia.

  • 5. HOW WE STORE, MANAGE AND SECURE PERSONAL INFORMATION

    YMCA Victoria takes reasonable steps to:

    • protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure; and
    • ensure that the information we have about you is accurate, complete and up-to-date.

    We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases.

    Our electronic records containing personal information are stored in secure, Australian-based data centres.

    Only authorised YMCA staff, volunteers and sub-contractors have access to personal information for approved purposes.

    If we hold any records about you that contain your personal information, we will take reasonable steps to destroy or de-identify those records when we no longer need them. The period of time for which we retain such records will depend on the nature of the information and the purpose for which we collected it.

  • 6. DOES MY INFORMATION STAY IN AUSTRALIA?

    Some of the third parties to whom we disclose personal information may be located outside Australia. The countries in which such third-party recipients are located will depend on the circumstances.

    In the ordinary course of business we may disclose personal information to overseas recipients in countries such as the United States, the United Kingdom and the European Union. These overseas recipients are typically IT service providers who provide YMCA Victoria with hosted data storage and various other cloud services. Please note that the use of overseas service providers to store personal information does not necessarily involve a disclosure of personal information to that overseas provider.

    Whenever we transfer your personal information outside of Australia, we will do so in accordance with the requirements of applicable privacy and data protection laws. We may disclose your personal information to overseas recipient without your consent where permitted by applicable Australian privacy laws (and, in such circumstances, we will comply with the applicable requirements in doing so).

    If you choose to communicate with us through a social media platform such as Facebook or Twitter, please be aware that the social media platform may use facilities located outside of Australia to collect and store your information.

  • 7. OUR FUNDRAISING, MARKETING AND ADVERTISING ACTIVITIES

    7.1 Overview

    Philanthropic support, fundraising, advertising and marketing activities are important to the future development and growth of YMCA Victoria and our programs.

    We may contact you from time to time to seek your philanthropic support for the YMCA, or to send you copies of our marketing and advertising materials. We may contact you by phone, post, email, SMS, Internet advertising or other means.

    We may add you to our mailing list and/or marketing databases if:

    • you have told us that you want to be added; or
    • we are otherwise permitted by law to send you marketing materials and advertising.

    7.2 E-mail analytics

    Like many organisations, we use e-mail analytics to track and measure the success of our e-mail newsletters, fundraising e-mails and other e-mail campaigns.

    We use various technologies (such as tracking pixels) to collect information such as: which of our emails you have opened, which links you have clicked, which email client you are using, whether you opened our e-mail on a computer or mobile device, and the geolocation of your IP address. We use this data to analyse and improve the performance of our e-mail campaigns.

    7.3 Internet advertising

    We may use online targeted advertising services to help our advertisements reach people who are more likely to be interested in them (such as our customers, the members of our fundraising and marketing databases, and other people who are similar to them). These services help us to show you our ads on other websites, apps and social media platforms that you visit.

    Examples of these services include:

    • retargeting – this helps us to show you our ads on other sites if you have previously visited our website;
    • behavioural advertising – this helps us to show you our ads based on your behaviour on our websites as well as other websites, apps and social media platforms that you visit; and
    • audience-based advertising – this helps us to show you our ads on other sites if you are an existing member of one of our databases (for example, our donor or customer database).

    Some of these services work by using non-identifying statistical data that has been collected through cookies and other tracking technologies. Other services require us to provide limited amounts of your personal information, which is used to target and deliver our ads to you.

    If we use any advertising service that requires us to use or disclose your personal information, we will only do so if we are permitted to do so by applicable privacy laws.

    For information about the types of tracking technology that we use on our websites, please see section 8.2 of this Privacy Policy below.

    7.4 Opt-out requests

    If you would like us to stop sending you direct marketing communications and/or stop using your personal information for targeted advertising, you can request this by contacting our Privacy Officer (see contact details in section 11 of this Privacy Policy).

    There are certain types of communications that you may not be able to opt-out from, such as communications that we are required or permitted by law to send you.

    Additionally, you can opt out of certain online targeted advertising networks by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

  • 8. OUR WEBSITES

    8.1 Overview

    YMCA Victoria collects various information (including personal information) through our websites and e-commerce systems. We protect our websites through the use of industry standard SSL encryption. Your data is encrypted so any unauthorised third party intercepting your data will not be able to make sense of it.

    When you visit our website, we collect:

    • information that you choose to provide us through the website (e.g. inquiries that you submit using a "contact us" form, or content that you post to a section of our site that allows sharing); and
    • other information that we collect automatically through cookies, web analytics and other similar technologies (see section 8.2 below).

    8.2 How we use cookies, web analytics and other similar technologies

    When you visit our websites, we use cookies and other tracking technologies to collect non-identifying information to help us manage the websites and provide you with a more personalised experience. You will remain anonymous unless you provide us with your details by completing a web form or signing in.

    The types of information we collect include:

    1. the date and time of your visit to our website;
    2. the pages you viewed;
    3. the device, operating system, and browser you use;
    4. your geo-location and IP address;
    5. address of referring website (your previous website visited); and
    6. any information you download from our website.

    Our websites use cookies to provide secure, personalised services. A cookie is a small data file stored on the browser on your mobile device or computer. They are used for a range of purposes to enhance your experience, including security and personalising content.

    Cookies are used to obtain information regarding the use of the website and to deliver relevant information to you. By using the website you agree to YMCA Victoria’s use of technology of this type. Most internet browsers are set to accept cookies, however you can configure your preferences and options in your browser to reject all cookies. Rejecting cookies may limit the functionality of our website and your personalised experience.

    YMCA Victoria uses “session” cookies for analytical purposes. These cookies gather visitor behaviour information for analytical purposes, using tools like Google Analytics. This information is not used to track a visitor, but is instead reported in aggregate to help improve our websites. If the visitor is registered as a member on our website, they are allocated a unique tracking identification code, however, a third party cannot identify that visitor from the tracking identification code. Google offers an opt-out browser add-on if you wish to prevent your data being used by Google Analytics.

    Our websites also uses tags such as the Facebook advertising pixel, which are tiny bits of website code that allow us to measure traffic and visitor behaviour, and to understand the impact of online advertising, use remarketing and audience targeting. These tags do not collect any personally identifiable information. We use Google advertising and other third-party ad services. These vendors, including Google, use cookies to serve ads based on your visit to our website. We also embed content from third party websites like YouTube, Facebook, and Google Maps. Cookies from those websites may also be placed on your device. You can manage cookies through your browser settings.

    8.3 Links

    Our websites have links to other websites and third party providers. We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices and procedures.

    We encourage you to read the relevant privacy policies or terms and conditions governing these linked third party sites to ensure that you are comfortable with their privacy practices and procedures.

  • 9. ACCESSING, CORRECTING AND TRANSFERRING YOUR INFORMATION

    9.1 Your rights to access and correct your information

    The Privacy Act 1988 (Cth) gives you the right to ask us to:

    • provide you with access to personal information that we hold about you; and/or
    • correct errors in any personal information that we hold about you.

    You may also have additional access and correction rights under the privacy and freedom of information laws of your State or Territory.

    If you ask us to provide access to your information or correct your information, we will handle that request in accordance with the requirements of the applicable laws.
    In some circumstances the law may require or permit us to refuse your request. If this happens we will provide you with a written notice that explains our reasons for refusing your request.

    The law may also permit us to provide you with access or correction in a manner that is different from the one that you initially requested. In such cases we will usually discuss this with you when we respond to your request.

    9.2 How to make an access or correction request

    You can make an access or correction request by contacting our Privacy Officer (see the contact details in section 11 of this Privacy Policy below). If we need further information our Privacy Officer may ask you to complete a 'Personal Information Request Form'.

    We may need to verify your identity before we can process your request. If you are making a request in relation to another person’s personal information (for example, your child or someone who is under your care) we may also need to confirm that you are authorised to access or correct that person’s information.

    We will not charge you for making a request to access or correction your information. However, if we will need to incur costs in order to provide you with access to your information (e.g. retrieval and copying costs), then we may ask you to pay a reasonable fee to cover those costs.

    We are not obliged to make a correction to your personal information if we don’t agree that it requires correction. If this happens, we will provide you with a written notice stating our reasons for refusing. We will not charge you for any actions that we take in response to a correction request.

    We will respond to all requests for access to or correction of personal information within a reasonable time.

    9.3 Parents and legal guardians

    If you are a parent or a legal guardian for a child (under the age of 18) who has used our programs or services, you may request access to the information that we hold about them. However, there may be some circumstances where we refuse to provide the requested information. For example, we may refuse to provide you with access where it would:

    • be unlawful;
    • pose a serious threat to the life, health or safety of that child or another individual; or
    • unreasonably impact on the privacy of another person.

    9.4 Accessing and transferring your health records

    If you are a customer or patient of one of our health services (e.g. medical suite, massage service, physiotherapy service, sports medicine service, health and fitness club, recreation centre), you may request to access your customer / patient records by contacting us (see section 9.1 above).

    If you would like us to transfer your records to another provider, please complete a "Personal Health Information Transfer Form". You can obtain this form by contacting our Privacy Officer - see contact details in section 11 below.

    We will handle your access or transfer request in accordance with all applicable laws. In some States and Territories, you may have specific rights in relation to your health records.

    If we close down, sell, transfer or lease a YMCA-managed health service, we will handle your customer / patient records in an appropriate manner and in accordance with applicable laws. This may include publishing information about how we propose to deal with any health records that are held by that health service.

  • 10. MAKING A COMPLAINT

    10.1 How to submit a complaint

    If you wish to make a complaint about how we have handled your personal information, please submit your complaint in writing by contacting our Privacy Officer using the contact details in section 11 of this Privacy Policy below.

    10.2 How will we handle your complaint

    We take all privacy complaints seriously. We handle privacy complaints in accordance with our "Customer Feedback Policy".

    Once we receive your complaint, we will respond to your complaint within a reasonable period (and in accordance with any timeframes required by law). We ask that you cooperate with us during this process and provide us with any relevant information that we may need to help us investigate and respond to your complaint.

    Our usual process is to appoint a designated officer who will review your complaint, discuss with relevant parties, and then decide what steps (if any) are appropriate for YMCA Victoria to take in response to your complaint.

    We will then contact you (usually by phone) to inform you of our decision. We may also offer to meet with you to discuss the matter further if you are not satisfied with this initial call. If you are still unsatisfied once we have confirmed our decision, you have the right to refer your complaint to our privacy regulator. This is explained further below.

    10.3 What if I am unsatisfied with YMCA Victoria’s response?

    Our primary privacy regulator is the Office of the Australian Information Commissioner (OAIC). If you are not satisfied with our response to your complaint, you can refer your complaint to the OAIC.

    The Privacy Act 1988 (Cth) requires complaints to be submitted to the OAIC in writing. You can do so via e-mail or the OAIC’s online web form:

    You can also contact the OAIC by telephone (1300 363 992), but the OAIC may require you to confirm your complaint by submitting it in writing.

    In some circumstances you may also have additional rights to complain under State and Territory privacy laws. If there is a more appropriate State or Territory regulator to hear your complaint, the OAIC may re-direct your complaint to that regulator. Alternatively, if you already know which regulator you would like to refer your complaint to you, you can submit your complaint directly to that regulator.

  • 11. CONTACTING US

    The contact details for our Privacy Officer are as follows:

    Postal address:

    YMCA Victoria Privacy Officer
    502/990 Whitehorse Rd, Box Hill, Victoria, 3128

    Email

    Vicoffice.Reception@ymca.org.au

    Our Privacy Officer can assist with privacy queries, complaints and requests for access or correction of personal information.