The protection of personal information is important to Life Saving Victoria (LSV). This policy sets out the way in which LSV handles personal and sensitive information whilst performing its functions in accordance with the obligations under the Australian Privacy Principles (APP) in the Privacy Act 1988 (Cth), and the Health Records Act 2001 (Vic) (HR Act) and other applicable laws and contractual obligations.
This policy outlines:
- What personal and sensitive information LSV collects.
- How LSV collects personal and sensitive information.
- How LSV uses or discloses personal and sensitive information.
- How individuals can access or seek correction of information held by LSV.
- Who to contact regarding privacy issues and complaints.
This policy provides the way in which LSV may collect, use, store and disclose information. Third party commercial entities and subsidiaries, whether owned or acting on behalf of LSV or an affiliate (lifesaving clubs) or not may be subject to the same privacy laws and may be governed by their own privacy policies.
Commitment to privacy
- LSV is committed to respecting the right to privacy and protection of personal information.
- LSV will only collect personal information to achieve its objects and perform its functions.
- Personal information collected will be used for the primary purpose for which it was collected or as otherwise permitted by law.
- Personal information collected by LSV will be stored securely.
- Staff, contractors and volunteers will handle personal information in a confidential manner and not disclose personal information unless authorised to do so.
What personal and sensitive information does LSV collect?
Personal information is information or an opinion (including information or an opinion forming part of a database) from which it is possible to determine someone’s identity.
The personal information collected by LSV about a particular person will vary depending on the
circumstances of collection. It may include, but is not limited to, a person’s contact details (name, email and/or postal address, phone number), date of birth, gender, credit card details, driver licence number, passport number, insurance details, employment history, qualifications or communication history with LSV.
Sensitive information is a type of personal information that also includes information or an opinion about:
- racial or ethnic origin
- political opinions
- membership of a political association, professional or trade association or trade union
- religious beliefs or affiliations or philosophical beliefs
- sexual preferences or practices
- criminal record; or
health, genetic information or disability.
If it is reasonable and necessary in the circumstances, LSV may also collect sensitive information such as a person's medical history, nationality, their ethnic background or disabilities.
How does LSV collects personal and sensitive information?
Information may be collected when you:
- become a member of a lifesaving club, association or other body which is a member of, or affiliated with, LSV;
- subscribe to a publication of LSV or an LSV affiliate, including electronic publications;
- provide details to LSV or an LSV affiliate in an application form, consent form, survey, feedback form or incident report;
- enter personal information into, or agree to having your personal information entered into, one of LSV’s online systems;
- access the LSV website or LSV online shop;
- contact LSV via email, telephone or mail or engage with LSV via social media;
- participate in any training, program, activity, course, competition or event run by LSV or an LSV affiliate.
- purchase tickets to a lifesaving or sporting event from LSV or an authorised agent;
- purchase merchandise, products or services from LSV or an authorised agent or licensee;
- are elected or appointed to the Board or a council or committee of LSV or an LSV affiliate;
- apply for employment or a volunteer position with LSV or an LSV affiliate;
- enter into a contract, memorandum of understanding (MOU) or other similar agreement with LSV; or
- where LSV is required to do so by law (for education, VET training, child protection, Work health and safety laws, AVETMISS, charitable collections, Good Samaritan, Medical Treatment or other legislation in Australia).
Depending on the circumstances, some types of information will be required, and some might be optional. If you do not provide some, or all, of the information requested, this may affect LSV’s ability to communicate with you or provide the requested products or services.
By not providing requested information, you may jeopardise your ability to participate in programs or competitions or apply for employment or volunteer positions with LSV or an LSV- affiliate. If it is impracticable for LSV to deal with you as a result of you not providing the requested information or consents, LSV may refuse to do so.
Collection from third parties
LSV or an LSV-affiliate may collect personal information regarding a child from the parent or other responsible person associated with that child.
In some circumstances, LSV collects information from LSV-affiliates or other third-parties.
Information storage and protection
LSV stores information in different ways, including in paper and electronic form. Much of the information LSV collects from and about its staff, contactors, members, and the like, is stored in online platforms directly operated by LSV or third-party providers.
Security of personal information is important to LSV. LSV has taken steps to protect the information it holds from misuse, loss, unauthorised access, modification or disclosure. Some of the security measures LSV uses includes strict confidentiality requirements of employees, volunteers, LSV- affiliates and service providers, as well as security measures for system access and security measures for LSV’s website.
LSV is required to comply with the Federal Government Notifiable Data Breaches Scheme (NDBS). When LSV has had a data breach that could result in serious harm, LSV will notify the individual(s) that is/are affected. LSV, when notifying the individual(s) and any relevant regulatory authorities including the Australian Information Commissioner, will also outline what steps will be undertaken in response to the breach. A review of the breach will be undertaken, and action(s) implemented to prevent a future breach.
How does LSV use and disclose personal and sensitive information?
a. verify your identity;
b. complete background checks;
c. enable you to participate in programs, activities and events;
d. respond to emergency situations involving or requiring medical treatment;
e. keep you informed of news and information relating to various lifesaving events, activities and opportunities via various mediums.
LSV may use health information to ensure that programs it operates are run safely and in accordance with any special health needs participants require. Health information may also be kept for insurance purposes. In addition, LSV may use de-identified health information and other sensitive information to carry out research, to prepare submissions to government or other regulatory bodies, or to plan events and activities.
LSV may disclose your personal information to a range of organisations including, but not limited to:
a. LSV affiliates and other organisations involved in lifesaving and emergency management;
b. companies LSV engages to carry out functions and activities on LSV’s behalf, including direct marketing;
c. LSV’s professional advisers, including LSV’s accountants, auditors and lawyers;
d. LSV’s insurers;
e. national bodies including Surf Life Saving Australia (SLSA) and Royal Life Saving Society Australia (RLSSA);
f. LSV companies, subsidiaries and affiliates;
g. relevant government departments and authorities in emergency services and management, sport, education and training as well as law enforcement bodies; and
h. in other circumstances permitted by law.
In some circumstances, personal information may also be disclosed outside of Australia. In such circumstances, LSV will use its best endeavours to ensure such parties are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are suitably similar to the APP.
Any disclosure will be on such terms and conditions as LSV determines, taking into account the circumstances of the disclosure, but always in the best interests of the parties whose personal information is being disclosed.
LSV will assume consent to use non-sensitive personal information to provide to you better services and marketing purposes (including disclosure of such information to service providers).
Every person whose data is collected by LSV has the option to refuse e-mail, SMS or posted offers. You may do this via the opt-out procedures included in any communication from us (information relating to the option to unsubscribe from those communications may be retained).
If you are still not satisfied at the communication you are receiving, you can also write to LSV via the contact details set out below in Section 5.7.
In addition, LSV may also disclose personal information:
a. with your express or implied consent;
b. when required or authorised by law;
c. to an enforcement body when reasonably necessary; or
d. to lessen or prevent a threat to an individual or public health or safety.
When users visit the LSV website, LSV’s systems may record certain information about their use of the site, including the web pages visited and the time and date of their visit. LSV uses this information to help analyse and improve the performance of the LSV website.
Websites linked to the LSV website are not subject to LSV’s privacy standards, policies or procedures. LSV does not take any responsibility for the collection, use, disclosure or security of any personal information that you provide to a third-party website.
Data quality, access and correction of information held by LSV
LSV will take all reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, complete and up-to-date. However, LSV relies on the accuracy of personal information as provided to it both directly and indirectly.
LSV also relies on employees, affiliates and volunteers to enter data and make their best endeavours to ensure data is accurately recorded.
LSV encourages all users to regularly review and update their personal information on LSV’s online portals and systems.
Individuals may also request access to their personal information held by LSV by making a request via the contact details set out below. LSV will respond to your request for access within 14 days and endeavour to provide the requested information within 30 days. If you find that the personal information LSV holds about you is inaccurate, incomplete or out-of-date, please contact LSV immediately and LSV will see that it is corrected.
LSV will take all reasonable steps to comply with privacy requirements when conducting research and working with partners on research related activities.
Resolving privacy issues and complaints
Any issues or complaints in relation to the collection, use, disclosure, quality, security of and access to your personal information may be made to the LSV Privacy Officer at this address:
200 The Boulevard
PO Box 353
South Melbourne DC
LSV will respond to your complaint within 30 days and try to resolve it within 90 days. If LSV is unable to resolve your complaint within this time, or you are unhappy with the outcome, you can contact the Office of Australian Information Commissioner via its enquiries line 1300 363 992 or website www.oaic.gov.au to lodge a complaint.
For further information on LSV’s management of personal information, please contact LSV.
Changes to this policy
LSV may amend this policy from time to time. The current version of this policy will be published on LSV’s website, and a copy may be obtained at any time by contacting LSV.