1. Policy statement
Cabrini Health Limited (ABN 33 370 684 005 trading as the Cabrini Foundation (Cabrini Foundation, We, Us) is committed to protecting the privacy of the personal information and sensitive information which We collect and hold. The Cabrini Foundation oversees and guides all fundraising activities on behalf of Cabrini, a not-for-profit, private, Catholic healthcare provider.
The Cabrini Foundation must comply with the Australian Privacy Principles under the Privacy Act 1988 (Cth), and other privacy laws (including the Health Records Act 2001 (Vic)) which govern the way in which We hold, use and disclose personal information (including your sensitive information).
The purpose of this Privacy Policy is to explain:
- the kinds of information that the Cabrini Foundation may collect about you and how that information is held;
- how the Cabrini Foundation collects and holds personal information;
- the purposes for which the Cabrini Foundation collects, holds, uses and discloses personal information;
- how you can access the personal information the Cabrini Foundation holds about you and seek to correct such information; and
- the way in which you can complain about a breach of your privacy and how the Cabrini Foundation will handle that complaint.
2. Definitions
In this Privacy Policy the following terms have the following meanings:
health information is:
- personal information or an opinion about:
- the health, including an illness, disability or injury, (at any time) of an individual;
- an individual's express wishes about the future provision of health services for themselves; or
- a health service provided, or to be provided, to an individual;
- other personal information collected to provide, or in providing, a health service to an individual;
- other personal information collected in connection with the donation, or intended donation, by an individual of his or her body parts, organs or body substances; or
- genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.
personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not;
sensitive information means:
- personal information or opinion about an individual's:
- racial or ethnic origins;
- political opinions or political associations;
- philosophical beliefs or religious beliefs or affiliations;
- membership of a professional or trade association or union;
- sexual preferences or practices; or
- criminal record; or
- health information about an individual;
- genetic information about an individual that is not otherwise health information; or
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
3. Collection and use of personal information
3.1 Types of personal information collected by the Cabrini Foundation
- Donors
The Cabrini Foundation collects information from you for the purposes of fundraising and managing donations. This includes collecting personal information such as your name and address, contact details and any other information required to process your donation, such as financial information.
Generally, your personal information can be used for direct marketing if you gave your details directly to Us, and if it’s reasonable to expect Us to use your information for marketing and fundraising purposes. - Opting out of direct marketing
You can opt out from receiving direct marketing and fundraising information from Us by indicating this on your patient registration form or upon discharge by contacting Cabrini Foundation on the details below.
P: 03 9508 1380
E: foundation@cabrini.com.au - Students, contractors and volunteers
The Cabrini Foundation collects information from you which is necessary to properly manage and operate its business. This includes collecting personal information such as your name, address and contact details, professional experience, qualifications and past employers, emergency contact, vaccination and health information and any other information which may be necessary to appropriately conduct its business. - Job applicants
The Cabrini Foundation collects information from you which is necessary to assess and engage job applicants. This includes collecting personal information such as your name, address and contact details, professional experience, qualifications, references and past employers, and any other information which is necessary to process your job applicatio
3.2 How we collect personal information
We will usually collect your personal information directly from you, however sometimes we may need to collect information about you from third parties, such as:
- past employers and referees (as applicable for job applicants); and
- related entities.
We will only collect information from third parties where:
- you have consented to such collection;
- such collection is reasonably necessary to enable us to appropriately manage and conduct our business; or
- it is legally permissible for us to do.
The Cabrini Foundation will only collect information which is necessary to appropriately manage and conduct our business.
3.3 How Cabrini Foundation uses your personal information
The Cabrini Foundation only uses your personal information for the purpose for which it was collected by the Cabrini Foundation (primary purpose), unless:
- there is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or the Cabrini Foundation has informed you, that your information will be used for that secondary purpose;
- you have given your consent for your personal information to be used for a secondary purpose; or
- the Cabrini Foundation is required or authorised by law to use your personal information for a secondary purpose (including for research and quality improvements within the Cabrini Foundation).
For example, the Cabrini Foundation may use your personal information:
- marketing: to communicate with you about donations, products, services, campaigns, causes and events;
- third parties for marketing purposes: we may provide your contact details to other like-minded organisations to contact you with information that may be of interest to you. From time to time, we participate in data collectives where we share your personal information (other than sensitive information) with other organisations;
- to process and record donations,
- to provide receipts, and
- to contact you about the Cabrini Foundation, our activities and to provide our newsletters, reports, invitations and requests for support, unless you opt out or we are prohibited by law.
We may not be able to do these things without your personal information. For example, we may not be able to contact you, provide services, issue receipts or offer employment to you.
We may also outsource certain tasks involving your personal information to third party service providers, including organisations that provide mail and delivery, auditing or technology services.
If you have applied for a position with the Cabrini Foundation, we may exchange some or all of your personal information with your referees, police, Centrelink and recruitment consultants, for appropriate purposes relating to considering your application including checking your criminal record where permitted by law.
3.4 Complete and accurate details
Where possible and practicable, you will have the option to deal with the Cabrini Foundation on an anonymous basis or by using a pseudonym. However, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the services or support to you are seeking, or deal with you effectively.
4. Disclosing your personal information
4.1 Disclosure of your personal information
The Cabrini Foundation will confine its disclosure of your personal information to the primary purpose for which that information has been collected, or for a related secondary purpose. This includes when disclosure is necessary to provide services to you, assist us in running our organisation, or for security reasons.
We may provide your personal information to:
- relatives and close friends for compassionate reasons (unless the Cabrini Foundation have been told otherwise);
- third parties contracted to provide services to the Cabrini Foundation;
- chaplains associated with Cabrini Foundation so that an individual may receive pastoral care;
- anyone authorised by you to receive your personal information (your consent may be express or implied); and
- anyone Cabrini Foundation is required or permitted by law to disclose your personal information to which may include the police and Privacy Commissioner.
4.2 Disclosure to External Service Providers
Where permissible under the privacy laws we may disclose personal information to external service providers who may use, process and store that information overseas.
5. Credit card transactions
[Donations made through our website are managed by a third-party payment gateway provider which is compliant with the Payment Card Industry Data Security Standard (PCI DSS) and utilises data encryption. Cabrini does not store any credit card information. If a credit card donation is received via post, Cabrini will process the donation using these details and then securely destroy the information.
6. Subscriptions
Our internet site provides the facility for users to subscribe to our supporter newsletter. To subscribe to this, service users must provide a valid email address.
7. Data storage, quality and security
7.1 Data quality
The Cabrini Foundation will take reasonable steps to ensure that your personal information which is collected, used or disclosed is accurate, complete and up to date.
7.2 Storage
All personal information held by the Cabrini Foundation is stored securely in either hard copy or electronic form.
Personal information that is captured and stored electronically by the Cabrini Foundation staff is stored on our centralised, onsite computer systems. Only authorised staff have access to these systems, which are used to help manage donor information. This access is stored and monitored in accordance with the Cabrini Foundation’s policies and procedures.
7.3 Data security
The Cabrini Foundation strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. The Cabrini Foundation reviews and updates (where necessary) its security measures in light of current technologies.
7.4 Online transfer of information
While the Cabrini Foundation does all it can to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with the Cabrini Foundation via an online process, it is at your own risk.
There are ways you can help maintain the privacy of your personal information, including:
- always closing your browser when you have finished your user session;
- always ensuring others cannot access your personal information and emails if you use a public computer; and
- never disclosing your user name and password to third parties.
8. Use of cookies
A 'cookie' is a small data file placed on your machine or device which lets the Cabrini Foundation identify and interact more effectively with your computer.
Cookies which are industry standard and are used by most web sites, including those operated by the Cabrini Foundation, can facilitate a user's ongoing access to and use of a site. They allow the Cabrini Foundation to customise our website to the needs of our users. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. However, cookies may be necessary to provide you with some features of our on-line services via the Cabrini Foundation website.
9. Links to other sites
The Cabrini Foundation may provide links to third party websites. These linked sites may not be under our control and the Cabrini Foundation is not responsible for the content or privacy practices employed by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.
10. Accessing and amending your personal information
You have a right to access your personal information which the Cabrini Foundation holds about you. If you make a request to access your personal information, you will need to:
- make a written application to the Privacy Officer; or
- complete the Request for Access to Information form available at www.cabrini.com.au. We will ask you to verify your identity and specify the information you require.
You can also request an amendment to any of your personal information if you consider that it contains inaccurate information.
You can contact Cabrini Foundation about any privacy issues as follows:
The Cabrini Foundation
foundation@cabrini.com.au
(03) 9508 1380
While the Cabrini Foundation aims to meet all requests for access to personal information, in a small number of cases and where permitted to do so by law, the Cabrini Foundation may not give access or may do so only under conditions.
Subject to applicable laws, the Cabrini Foundation may destroy records containing personal information when the record is no longer required by the Cabrini Foundation.
11. Complaints
If you have a complaint about the Cabrini Foundation information handling practices or consider we have breached your privacy, you can lodge a complaint with:
- the Cabrini Foundation, on the contact details listed in clause 10;
- the Office of Australian Information Commissioner at 1300 363 992 or enquiries@oaic.gov.au.
The Cabrini Foundation deals with all complaints in a fair and efficient manner.
12. General
The Cabrini Foundation reserves the right to amend this privacy policy at any time by publishing the amended policy on its website.
If you do not consent to the Cabrini Foundation collecting, using or disclosing your personal information, the Cabrini Foundation may be unable to interact with you, including accepting your donation or provide to you a receipt.
13. Review
This Privacy Policy will be reviewed every two years or as needed.
Executive Sponsor
Director of Cabrini Foundation – Megan Potter
Date: 21/03/2024