In accordance with clause 1.3 of Australian Privacy Principle 1 (open and transparent management of personal information), in Schedule 1 of the Privacy Act 1988 (the Privacy Act), this is the National LGBTI Health Alliance’s Privacy Policy. Effective as of 12 March 2014.

As the national NGO peak body for LGBTI health in Australia, the particular mission of the National LGBTI Health Alliance (Alliance) is to provide a national focus to improve health outcomes for LGBTI people through policy, advocacy, representation, research evidence and capacity building by:

• promoting the health and wellbeing of lesbian, gay, bisexual, transgender, intersex and other sexuality, sex and gender diverse people (LGBTI)
• supporting health and medical research in LGBTI communities
• developing health advice for LGBTI communities, health professionals and governments
• providing advice on ethical behaviour in health care and in the conduct of health and medical research in Australian LGBTI communities
• providing information and training to health professionals, service providers, businesses, the LGBTI community and the general public on the promotion of health and wellbeing for LGBTI people and the preventing and controlling of disease in LGBTI communities
• developing the capacity of Alliance members to promote the health and wellbeing of LGBTI people, including the development of health intelligence, networking opportunities, financial resources and workforce development
• publishing and distributing papers, journals, leaflets and other publications in any medium regarding LGBTI health and wellbeing.

The 13 Australian Privacy Principles (APPs) contained in Schedule 1 of the Privacy Act (as amended in 2012) cover the collection, use, disclosure and storage of personal information. They allow individuals to access their personal information and have it corrected if it is incorrect.

The Alliance also supports and abides by Principle 6: The Right to Privacy of the Yogyakarta Principles (2006) which states:

“Everyone, regardless of sexual orientation or gender identity, is entitled to the enjoyment of privacy without arbitrary or unlawful interference, including with regard to their family, home or correspondence as well as to protection from unlawful attacks on their honour and reputation. The right to privacy ordinarily includes the choice to disclose or not to disclose information relating to one’s sexual orientation or gender identity, as well as decisions and choices regarding both one’s own body and consensual sexual and other relations with others.”

The Alliance is of the view that these principles are an appropriate foundation upon which to build a sound and equitable privacy policy.

Importantly, the objective of Australian Privacy Principle 1 is to “manage personal information in an open and transparent way.”

In this privacy policy, personal information and sensitive information (a sub-set of personal information), have the same meanings as defined in subsection 6(1) of the Privacy Act, namely:

“personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
a. whether the information or opinion is true or not; and
b. whether the information or opinion is recorded in a material form or not.
sensitive information means
a. information or an opinion about an individual’s:
i. racial or ethnic origin; or
ii. political opinions; or
iii. membership of a political association; or
iv. religious beliefs or affiliations; or
v. philosophical beliefs; or
vi. membership of a professional or trade association; or
vii. membership of a trade union; or
viii. sexual orientation or practices; or
ix. criminal record;
that is also personal information; or
b. health information about an individual; or
c. genetic information about an individual that is not otherwise health information; or
d. biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
e. biometric templates.”

Alliance’s collection, holding, use and disclosure of personal information
The Alliance holds several classes of personal information (some of which include sensitive information). The Alliance may collect information from documents provided to it in correspondence, from submissions made through community consultation, on membership and subscription applications, and via its online and social media activities.

The information is held in, on or as:

• Database of members
• Alliance grants management records
• Reports about Alliance funded activities
• Correspondence to the Alliance, including responses to community/public consultations
• Government correspondence
• Complaint files including records generated by this policy
• Investigation records
• Records of Alliance Board, Committees and Work Groups
• Register of Members
• Finance records
• Request for Tender and contract information
• Personnel and staffing files
• Subscription databases and web forms

A detailed description of the types of personal information contained in the Alliance’s records is available in the Register of Records that Contain Personal or Sensitive Information.

This information covers Alliance records that contain personal or sensitive information, and the purposes for which the Alliance collects, holds, uses and discloses personal information.

No sale of personal information
Under no circumstances will the Alliance sell or receive payment for licensing or disclosing personal information provided to the Alliance.

Credit/Debit Card information
The Alliance outsources the collection of credit/debit card payments to third-party service providers and does not hold the credit or debit card information of persons who may pay monies or provide donations to the Alliance.

These third-party service providers are governed by their own privacy policies under the provisions of the Privacy Act. The Alliance encourages persons using the provided payment facilities to access and consult these companies’ privacy policies which are the sole responsibility of that third-party service provider.

Disclosure of personal information to overseas recipients
At this point in time, the Alliance does not participate in any international projects, activities or research which requires the disclosure of personal information to overseas recipients.

The servers the Alliance uses to store digital information are located in Australia and are subject to the laws of Australia.

Information collected through the Alliance website
Subscriptions and web forms
The personal information of subscribers to any of the Alliance’s regular electronic publications provided via the subscription service form will be used solely by the Alliance and not be disclosed to any third party.

There are security risks associated with transmission of information via the internet. The Alliance has taken reasonable steps to safeguard against unauthorised access, use, modification or disclosure of personal information held electronically. Before deciding whether to use this facility users should make their own assessment of the potential risks to the security of their information.

By clicking on the warning/disclaimer tick box on the subscription service or web based forms, users acknowledge and agree that the Alliance will not be liable for any unauthorised access or for any loss or damage that the user may incur as a result of any unauthorised access to the Alliance’s website or to the information transmitted by the user or any other person.

Cookies and Clickstream Data
The Alliance uses ‘cookies’ for maintaining contact with a user through a website session. A cookie is a small file supplied by the Alliance and the web browser software on the user’s computer when accessing the Alliance website. Cookies allow the Alliance to recognise a user as an individual as they move from one Alliance web page to another.

All cookies will be immediately lost when a casual user (a non-logged in user) ends an internet session and shuts down their computer. This information is only used to help casual users to navigate the Alliance’s website systems more efficiently, not to track the user’s movements through the internet, or to record private information about a casual user.

A logged in user (a user with various assigned privileges) is a class of user restricted to Alliance staff members. The cookies for logged in users are retained by the site so that session data can be recalled the next time this class of user visits the site.

Any system on the Alliance website that records information about a casual user will specifically ask for permission first.

When a casual user visits the Alliance website, the Alliance makes a record of the visit and logs the following information for statistical or systems administration purposes:

• server address
• top level domain name
• the date and time of access to the site
• pages accessed and documents downloaded
• the previous site visited
• type of browser used

This information is analysed to show broken links in the website, bottlenecks, and other site problems. This information is used to maintain the site for everyone’s efficient use.

No attempt will be made to identify casual users or their browsing activities unless the Alliance is legally compelled to do so, such as in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet Service Provider’s log files.

Searches
Search terms entered when using the site’s search engine are collected, but are not associated with any other information that the Alliance collects. These search terms are used to ascertain what people are looking for on the site, and to improve the services that the Alliance provides.

Gaining access to personal information held by the Alliance, and requesting the correction of any errors
Persons who have provided personal information to the Alliance have the right to request access to any of their personal information held by the Alliance and to request corrections.

To request to access personal information of a person by that person, the person concerned can contact the Alliance’s Executive Director via any of the methods provided below.

If, after reviewing their personal information, the person concerned considers that it contains errors, or requires amendment, a request that these errors be corrected or amended can be made.

To do this the person concerned should contact the Alliance’s Executive Director, enclosing the relevant information and setting out the corrections or amendments sought, with appropriate supporting documentation. If there is any uncertain about how to set out such a request, or the supporting material required, the Executive Director will be able to assist.

Dealing with the Alliance anonymously or pseudonymously
A person can ask the Alliance to deal with them anonymously or pseudonymously (not in the person’s real name) unless the Alliance expressly identifies that it is not practicable to deal with the person on that basis.

In the case of applications for project, activity or research partners, it will not be practicable for the Alliance to deal with an applicant on an anonymous or pseudonymous basis, in light of the Alliance’s obligations regarding financial management and accountability and for good governance reasons. The Alliance will not accept a project, activity or research application or report that is anonymous or not in the concerned person’s real name.

Making a privacy complaint if there is a belief that the Alliance has breached the Australian Privacy Principles
If a person wishes to complain that the Alliance has breached one of the Australian Privacy Principles contact with the Alliance’s Executive Director can be made via any of the methods provided below.

The privacy complaint should be in writing setting out as much detail as possible and include any supporting documentation.

A privacy complaint can be made anonymously, or by using a pseudonym. However, the person concerned should realise that if they wish to communicate with the Alliance in this way, the Alliance’s ability to fully investigate and deal with the complaint may be restricted.

How Alliance will deal with a privacy complaint
The Alliance will usually respond to a privacy complaint within 30 calendar days and provide the person making the complaint with its response in writing.

If the Alliance takes more than 30 days to respond to the privacy complaint (without prior agreement), or the person is not satisfied with the Alliance’s response, then the privacy complaint may be taken to the Office of the Australian Information Commissioner (OAIC). A complaint can be made to the OAIC using the online form available at this link:

https://forms.business.gov.au/aba/oaic/privacy-complaint-/

Accessing a printed copy of this Privacy Policy?
To be provided with a printed copy of this Privacy Policy, please contact the Alliance’s Executive Director via any of the methods provided below.

Contacting the Alliance’s Executive Director
The Alliance’s Executive Director can be contact via phone on 02 8568 1120 or by email to [email protected] or by writing to the following address:

Executive Director
National LGBTI Health Alliance
PO Box 51, Newtown NSW 2042, Australia