PRIVACY POLICY

ROAM Geelong is a cultural event owned, managed and promoted by the City of Greater Geelong (ABN 18 374 210 672) of Wurriki Nyal, 137-149 Mercer Street, Geelong, Victoria, 3220 Australia (the City, we, us or our).

The City values the privacy of every individual and is committed to handling personal information in accordance with the privacy principles contained in the Privacy and Data Protection Act 2014 and the Health Records Act 2001.

SCOPE

The scope of this policy includes personal information of persons both internal and external to the City.

The policy applies to both the City as an organisation, and elected Councillors in their capacity as a person holding office. This means that the policy applies to all employees of the City, as well as individual Councillors representing their constituents.

External contractors that have been engaged to provide a service or perform a function on behalf of the City will have the same obligations as the City under this policy.

The City is bound by the 10 Information Privacy Principles (principles) that outline how we manage an individual’s personal and health information in regard to their interactions with the City. Protecting the privacy of individuals by handling their personal information in accordance with the principles is an important aspect of the City’s activities. How the City will comply with each of these privacy principles is explained below.

INFORMATION PRIVACY PRINCIPLES AND HEALTH PRIVACY PRINCIPLES PRINCIPLE 1 – COLLECTING INFORMATION (IPP1/HPP1)

Collection notice

When collecting personal or health information, the City will take reasonable steps to advise the individual of what information is being sought, for what purpose, whether any law requires the collection of the information and the main consequences, if any, of not providing the information. They City will also advise of the types of persons and organisations to which such information would usually be disclosed.

This information is set out in a collection statement, which is included on relevant forms, including registration forms and any other document or mechanism used to collect personal or health information.

Information that may be collected

The City will only collect personal information that is necessary for carrying out its functions or activities.

The City will endeavour to ensure that it only collects personal and health information that is necessary and relevant to the statutory functions, duties, powers, and administration of the City and the municipality under the Local Government Act 2020 and other Acts.

If it is reasonable and practicable to do so, personal information will be collected directly from an individual, however, there are situations where the City may need to collect an individual’s information from someone else.

Photographs

Photographs are at times taken on the City’s premises and in public places. The photographs may be used by the City for publicity or for enforcement purposes.

Where practicable consent will be obtained through a photo release and permission form. When photographs are taken in a public space (e.g. during a community event) and obtaining the individual consent via the forms is not practicable, the City will use other methods to inform individuals that photographs are being taken and how they will be used. The other methods could include signs or a public announcement. These methods will inform the individual that the photo may be taken, and the individual has the opportunity to approach and advise City staff or the photographer that they do not want the photos to be used.

Anonymity on the web

Individuals can visit the City’s website anonymously because the site does not collect or record personal information other than information individuals choose to provide by email or internet forms.

PRINCIPLE 2 – USING AND DISCLOSING INFORMATION (IPP2/HPP2)

Using information

Staff members are required to handle all personal and health information with discretion and to comply with the provisions of the Privacy and Data Protection Act 2014 and Health Records Act 2001.

Disclosing information

We will not use or disclose an individual’s personal information other than for the primary purpose for which it was collected, unless one of the following apply:

  • For a secondary purpose that you would reasonably expect
  • Where we have the individual’s consent
  • For law enforcement purposes and to protect safety; or
  • Where the City is otherwise required or authorised by law to disclose the information

Disclosure

  • The City may be required by law (including under the Freedom of Information Act 1982) to make information available to the community. In this case the City will comply with the relevant legislation in doing so. This includes disclosing information to the City’s contracted service providers who perform various services for, and on behalf, of the City.
  • Personal information in applications for employment with the City may be supplied to agencies such as Victoria Police, as part of a background check. Such checks will only be carried out with the individual’s written authorisation and the results will not be disclosed to a third party unless authorised by

PRINCIPLE 3 – KEEPING INFORMATION ACCURATE (IPP3/HPP3)

The City takes reasonable steps to ensure the information it holds is accurate, complete, and up-to-date. The City relies on individuals to provide accurate and current information in the first instance, and to inform the City of changes to their details.

PRINCIPLE 4 – KEEPING INFORMATION SECURE (IPP4/HPP4)

The City uses several procedural, physical, software, and hardware safeguards. Together with access controls, secure methods of communication, back up and disaster recovery systems to protect information from misuse and loss, unauthorised access, modification, and disclosure.

PRINCIPLE 5 – OPENNESS (IPP5/HPP5)

This principle requires organisations to have a Privacy Policy. The policy details the City’s management of personal and health information.

PRINCIPLE 6 – ACCESSING AND CORRECTING INFORMATION (IPP6/HPP6)

The City of Greater Geelong is subject to the Freedom of Information Act 1982 (Vic) (FOI Act). Access to an individual’s personal information is managed under this legislation.

Under the FOI Act, the individual is entitled to seek correction or amendment of a document containing their personal information, where the individual believes the information is inaccurate, incomplete, out of date, or would give a misleading impression.

Requests for amendment must be made in writing and addressed to privacy@geelongcity.vic.gov.au The request for amendment must:

  • Specify an address or email address to which a decision notice can be sent.
  • Specify the personal information the person making the request believes is incomplete, misleading, or inaccurate; and
  • Specify the amendments to be

There is no application fee for amendments to personal information.

PRINCIPLE 7 – UNIQUE IDENTIFIERS (IPP7/HPP7)

A unique identifier is defined in the Privacy and Data Protection Act 2014 as the number assigned by an organisation to an individual uniquely to identify that individual.  The City will assign an identifier to a record only if it is necessary to enable the City to carry out a function efficiently.

PRINCIPLE 8 – ANONYMITY (IPP8/HPP8)

Where practicable and lawful, individuals may choose to remain anonymous when contacting the City e.g. when making general inquiries about services. In some cases, if individuals wish to maintain anonymity, the City may not be able to provide services or respond to complaints.

PRINCIPLE 9 – TRANSBORDER DATA FLOWS (IPP9/HPP9)

If the individual’s personal information travels outside of Victoria, the protection of the individual’s privacy should travel with it.

The City will only transfer the individual’s personal information outside of Victoria where:

  • the individual consents
  • the recipient of the information is subject to a law, binding scheme or contract similar to the principles of the Privacy and Data Protection Act 2014; or
  • the disclosure is otherwise authorised by law

PRINCIPLE 10 – SENSITIVE INFORMATION (IPP10/HPP10)

The City will not collect sensitive information about the individual except in circumstances outlined in the Privacy and Data Protection Act 2014.

 

HOW TO MAKE A COMPLAINT OR ENQUIRY CONCERNING PRIVACY

Any individual has a right to make a complaint if the individual believes the City has breached their privacy or if the individual has any concerns about the way the City has applied the Act.

A privacy complaint can be made through the following link. Alternatively, you can email your enquiry or complaint to privacy@geelongcity.vic.gov.au or by mail to:

Privacy Officer, City of Greater Geelong PO Box 104, Geelong VIC 3220