- clearly communicate the personal information handling practices of National First Aid Training Institute (NFTI)
- provide individuals with a better understanding of the types of personal information NFTI holds and how to access or correct the personal information NFTI’s holds, and
- enhance the transparency of NFTI’s operations.
The Privacy Act 1988 (Privacy Act) is an Australian law that regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. The Privacy Amendment (Enhancing Privacy Protection) Act 2012 introduced the Australian Privacy Principles (APPs) that apply to the handling of personal information. As an organisation, NFTI is obliged to comply with relevant APPs.
3.1 Personal Information
Personal information is defined under the Privacy Act as 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.
Some examples of personal information include names, addresses, phone numbers and email addresses.
The definition of personal information only relates to ‘natural’ persons. It does not extend to other ‘legal’ persons, such as companies.
3.2 Sensitive Information
Under the Privacy Act, sensitive information is defined as:
- information or an opinion about an individual’s:
- racial or ethnic origin
- political opinions
- membership of a political association
- religious beliefs or affiliations
- philosophical beliefs
- membership of a professional or trade association
- membership of a trade union
- sexual orientation or practices, or
- criminal record
- that is also personal information; or
- health information about an individual
- genetic information about an individual that is not otherwise health information
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or
- biometric templates.
4.1 Solicited Information
Personal information (and sometimes sensitive information) is collected in order for NFTI to properly and efficiently carry out our functions. NFTI only collects such information for purposes that are reasonably necessary for, or directly related to, its functions or activities.
NFTI may also collect information in relation to recruitment, human resource management, and other corporate service functions.
Note that NFTI will only collect sensitive information from individuals if the individual consents to the collection, unless:
the collection of the information is required or authorised by or under an Australian law or a court/tribunal order
- a permitted general situation exists
- a permitted health situation exists, or
- the sensitive information is required for an enforcement related activity.
4.1.1 Information collected from an individual
NFTI generally collects personal information about an individual directly from the individual or their authorised representative.
An individual may, in some circumstances, such as lodging a complaint, prefer to remain anonymous, or to use a pseudonym, when interacting with NFTI. Individuals should be aware that doing so may make investigating complaints or providing specific information impracticable.
4.1.2 Information collected from a third party
Sometimes personal information is collected from a third party, or a publicly available source, but only if the individual consents to such collection, or collection is required or authorised by or under an Australian law or court/tribunal order, or it is unreasonable or impracticable to collect the information directly from the individual.
If NFTI collects personal information from a third party, NFTI will take reasonable steps to inform affected individuals that their personal information has been collected from a third party as soon as practicable after the collection has taken place.
4.2 Unsolicited Information
Sometimes NFTI receives personal information without prior request. In such cases, NFTI will determine if the information is required to carry out its functions.
If NFTI determines that the information is not required, and does not form part of a Commonwealth record, then it will destroy or deidentify the information as soon as practicable.
If NFTI determines that the information is required, then the information will be treated as solicited information as per 4.1 – Solicited Information.
5.1 Notifying the individual at collection
When collecting personal information directly from an individual, NFTI will take reasonable steps to notify, or otherwise ensure the individual is aware of:
- NFTI’s contact details
- the fact and circumstances of collection
- the purposes of collection
- the consequences if personal information is not collected
- NFTI’s usual disclosures of personal information of the kind collected
- whether NFTI is likely to disclose personal information to overseas recipients, and if practicable, the countries where they are located.
5.2 Notifying the individual if information is collected from a third party
In addition to the matters above, if NFTI collects personal information from someone other than the individual, or the individual may not be aware that the organisation has collected the personal information, reasonable steps will be taken to notify the individual, or otherwise ensure that the individual is also aware of the following matters:
- that NFTI collects or has collected the information
- the circumstances of the collection, including from whom the information was collected.
6. Use and Disclosure of Personal Information
NFTI will only use and disclose personal information for the primary purposes for which it was collected unless:
- the individual has consented to the information being used for a secondary use or disclosure
- the individual would reasonably expect NFTI to use or disclose the information for the secondary purpose and that purpose is related to the primary purpose
- the use or disclosure of the information is required or authorised by or under and Australian law or a court/tribunal order
- a permitted general situation exists in relation to the use or disclosure of the information, for example, if NFTI believes that the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or
- a permitted health situation exists in relation to the use or disclosure of the information.
NFTI will only use sensitive information for a secondary purpose if it is directly related to the primary purpose.
6.1 Disclosing personal information to other countries
NFTI will not disclose personal information or sensitive information to other countries.
6.2 Use of personal information for direct marketing purposes
NFTI may only use or disclose personal information for direct marketing purposes in limited circumstances, for example where the individual would reasonably expect NFTI to use their information in that way or the individual consents to such use or disclosure.
7. Data Quality
NFTI will take reasonable steps to ensure that the personal information they collect is accurate, up-to-date, and complete. These steps include maintaining and updating personal information when advised by individuals that their personal information has changed, and at other times as necessary. NFTI will also take reasonable steps to ensure the accuracy and completeness of the information prior to any use or disclosure of the information.
8. Data Security
NFTI takes all reasonable steps to protect the personal information they hold against misuse, interference, loss and unauthorised access, modification or disclosure.
When no longer required, personal information is destroyed in a secure manner, or deleted in accordance with NFTI’s Records Management Policy, in compliance with the General Disposal Authority issued by the National Archives of Australia.
9. Access and Correction
9.1 Access and correction under the Privacy Act
Under the Privacy Act, individuals may request access to personal information that NFTI holds about them.
Individuals may also request that NFTI correct any personal information about the individual that NFTI holds. NFTI will only update the information if it is satisfied the information it holds is inaccurate, out-of-date, incomplete, irrelevant or misleading. If so satisfied, NFTI will take reasonable steps to correct that information.
NFTI will provide a response to any request for access to or correction of personal information within 30 days. If refusing the request, NFTI will provide a written statement of the reasons for the refusal and remind the individual of the available complaint mechanisms, which are outlined below in 10 – Complaints.
NFTI will not charge individuals for requests for access to or correction of their personal information held by NFTI.
Members of the public should direct their requests to NFTI’s Privacy Contact Officer using the contact details set out below in 11 – Privacy Contact Officer.
If an individual wishes to lodge a complaint about how NFTI handles personal information, or if they feel NFTI has breached the APPs, they can do so by completing a complaint form available on the NFTI website.
Completed forms should be emailed to: firstname.lastname@example.org.
NFTI will provide a response to privacy complaints within 30 days of receipt.
If an individual is dissatisfied with NFTI’s response, they may submit their complaint to the OAIC for further investigation. Please note however that the OAIC may not investigate a complaint if the complainant has not firstly lodged their complaint with NFTI. The OAIC’s contact details are as follows:
Telephone: 1300 363 992
Post: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.
11. Privacy Contact Officer
If you have any questions about how NFTI collects, holds, uses or discloses your personal information or about any requests for access to or correction of your personal information or lodging a privacy complaint, please contact NFTI’s Privacy Contact Officer via:
Telephone: 1800 851 819
Post: Privacy Contact Officer, National First Aid Training Institute, GPO Box 5938, Maroochydore QLD 4558.