PURPOSE 

This policy outlines how Evolve Housing Vic Limited (EHVL) and the entities described in clause 3 of this policy (collectively referred to as “the Company”) collect, use, store and disclose Personal Information in accordance with the Australian Privacy Principles 2014 (APPs) and under the Privacy Act 1988 (Cth) (Act). 

1. SCOPE

This policy applies to all individuals which the Company will be collecting Personal Information from. Individuals include, but are not limited to Clients, Directors, Employees and Employment Candidates. 

2. POLICY STATEMENT

The Company is committed to respecting and protecting the privacy and rights of individuals. 

2.1 Personal Information

When used in this Privacy Policy, the term “Personal Information” has the meaning given to it in the Act. Personal Information is any information held by an entity that can be used on its own or in combination with other information held by the same entity, to personally identify an individual. Personal Information collected and stored by the Company may include an individual’s: 

• Name
• Address
• Email address
• Contact number
• Age or date of birth
• Gender
• Ethnicity
• Country of origin
• Religious belief
• Employment history
• Income details
• Proof of identity
• Photographs
• Profession, occupation or job title
• Work experience
• Educational qualifications
• Centrelink information
• Credit information and other financial records
• Next of kin
• Public trustee details
• Bank statements
• Criminal history
• Tax File Number / Returns
• Tenant ledgers

Personal Information includes Sensitive Information (see section 2.7 of this Policy).

The Company may also collect information that is not Personal Information because it does not identify a particular individual. For example, the Company may collect anonymous answers / feedback to surveys or aggregated information about how users use the Evolve Housing website.

2.2 Collecting Personal Information

The Company collects Personal Information directly from the individual as well as through third parties. The Company can collect Personal Information in the following ways:

• Written forms
• Face-to-face
• Over the phone or other messaging technology
• Via the internet, including email or Company’s website and social media platforms
• Hardcopy documents provided by individuals
• Use of an IT device a company provides;
• Website cookies;
• Property inspections; and
• Via a third party, e.g. government entities, law enforcement agencies, social workers, medical practitioners, previous landlords, personal referees, tenancy databases, recruitment agencies, etc.

2.3 Purpose of Collecting Personal Information

The Company collects Personal Information to perform business activities and deliver services. The Company will not collect information unless it is for a proper and lawful purpose.

In most situations, individuals will be advised as to why The Company is collecting Personal Information and who else might receive this information. Evolve Housing may decide not to provide this advice to individuals if Evolve Housing is not legally required to provide the advice.

The purposes for collecting Personal Information from each category of individuals may include:

Individuals	Purposes
All Company Clients	to provide suitable housing arrangements through assessing applications and allocating appropriate properties etc. to provide tenancy related services including repairs and maintenance to properties to provide other related services through assessing applications, case planning and management etc. for communication purposes to facilitate community engagement to assist with the design of residential construction projects to engage in direct marketing to seek feedback and improve on services to comply with reporting requirements to government agencies, regulators, rental providers, financiers etc. to provide information to support partners and health providers who participate in information sharing
Employment Candidates, Volunteers and Students	to assess suitability for employment or to undertake other roles within or for the Company
Employees, Contractors and Directors	for identification for human resource purposes including payroll for conflict of interest purposes for regulatory, governance and related purposes

If an individual does not provide the Company with Personal Information when prompted, the Company may be unable to contact the individual or provide any services to the individual. In the case of employment candidates, the Company will not be able to consider applications for employment.

2.4 Unsolicited Personal Information

In the event Evolve Housing receives unsolicited Personal Information, the Company will determine whether it could have been lawful for the Personal Information to be collected if it had been solicited. If it isn’t, the Company will destroy the information or ensure that the information is de-identified as soon as practicable and only if it is lawful and reasonable to do so.

2.5 Disclosure of Personal Information

The Company may disclose Personal Information for a purpose for which it was collected (as listed in 2.3) (the “Primary Purpose”) e.g. to arrange maintenance contractors for your residence.

The Company will only disclose Personal Information for another purpose (a “Secondary Purpose”) if:

• the disclosure is directly related to the Primary Purpose for which the information was collected or, in the case of Sensitive Information, directly related to the Primary Purpose and the person would reasonably expect the Company to use or disclose the Personal Information for the Secondary Purpose;
• Where the person to whom the information relates to has provided informed consent to secondary use disclosure;
• If a permitted general situation exists, as defined in the APPs, in relation to the use or disclosure of the Personal Information for a secondary use; 
• If the Company reasonably believes that the secondary use or disclosure is reasonably necessary for enforcement related activities carried out by, or on behalf of, an enforcement body; and 
• If lawfully authorised or required to do so under the Act, APPs, by legislation or court or tribunal order

The Company may disclose Personal Information (other than Sensitive Information) to a Related Body 

Corporate. 

2.5.1 Record of Understanding

The Company and the VIC Police may also exchange information:

• To maintain law and order in and around the Company properties; 
• Where there is an emergency that poses an imminent threat to life or property; 
• To develop and implement crime prevention and community safety strategies. 

The Company will also provide information to police when subpoenaed, unless the information is not in the public interest. In these cases, the Company may lodge an appeal not to provide the information.

2.5.2 Providing information to a third party

Where information is being disclosed to a third party, the Company will takes steps to be satisfied that the third party has an obligation to keep Personal Information confidential and to comply with the Act and the APPs. This includes where the third party is an international recipient. 

2.6 Storage of Personal Information

Personal Information is stored by the Company, in both hard copy and electronic form, in a manner that reasonably protects it from misuse, interference, loss, and unauthorised access, modification or disclosure. Some of the security measures include: 

• Physical, electronic, and procedural safeguards in line with industry standards (such as passwords and physical locks on cabinets)
• Secure server and closed network environments
• Limited access to Personal Information (e.g. only relevant employees who require an individual’s Personal Information to carry out his / her normal line of duties are allowed access)
• Management of access privileges, and regular review of the privileges
• Destroying or de-identifying Personal Information pursuant to the law and record retention policies

2.7 Sensitive Information

‘Sensitive information’ is a subset of Personal Information. Sensitive Information is defined in the Act as information or an opinion about an individual’s: 

• racial or ethnic origin
• political opinions or membership of a political association
• religious beliefs or affiliations, or philosophical beliefs
• membership of a professional or trade association or trade union
• sexual orientation or practices, or
• criminal record

It also includes Personal Information, or information about an individual’s health, genetics or biometrics. 

The Company recognises that Sensitive Information is generally afforded a higher level of privacy protection under the APPs than other Personal Information. The Company recognises that inappropriate handling of sensitive information can have adverse consequences for an individual or those associated with the individual, including discrimination, mistreatment, humiliation, embarrassment or the undermining of an individual’s dignity.

The Company may collect Sensitive Information about an individual, but only where the individual has provided consent and where the information is relevant to the services provided by the Company.

2.8 Access and Correction of Information

Individuals have the right to request access to the Personal Information the Company holds about them, and request correction of any inaccurate, out-of-date, incomplete, irrelevant or misleading Personal Information. 

Individuals who would like to request access to, or correction of, their Personal Information held by the Comapny, must contact the Comapny using the details provided in Section 2.10 below. The Company will respond to the request for access within a reasonable period and give access in the manner requested by the individual, if it is reasonable and practicable to do so. The Company may charge for its reasonable costs in providing the Personal Information and any such costs will be notified to the individual at the time it seeks that information. Costs will not be charged to the individual to consider a request, or correct information. Information will not be provided to individuals if they are unable to provide identification documentation to confirm their identity. 

The Company may refuse a request to access Personal Information if it falls under a category outlined in Australian Privacy Principle 12 of the APPs. On these occasions the Company will inform the individual in writing of the reason for the refusal and any avenues to make a complaint about that decision. 

It is the individual’s responsibility to inform the Company of any corrections or changes to Personal Information. Individuals may lodge a request to correct Personal Information held by the Company, following which the Company will take such steps (if any) as are reasonable in the circumstances to correct the information to ensure that it is accurate, up-to-date, complete, relevant and not misleading. 

If the Company believes that the Personal Information should not be corrected or changed, the Company will provide the individual with a written notice explaining the reasons for its decision and how to raise a complaint if they’re unhappy with the Company’s decision. 

If the Company refuses a request to correct or change Personal Information, the individual may ask the Company to attach a statement to the information stating that the information is inaccurate, out-of-date, incomplete, irrelevant, or misleading. 

2.9 Complaints

If an individual is concerned that the Company has not complied with applicable privacy laws or this Policy, the individual may raise a complaint through the Company’s complaints process. The process is as follows: 

Step 1: Let the Company know

The individual should contact our Privacy Officer using the details provided in Section 2.10 below. We will acknowledge the complaint within 2 working days.

Step 2: Investigation of Complaint

The complaint will be investigated by our Privacy Officer. A response to the complaint will be provided in accordance with the Company’s Complaints Management Policy. 

Step 3: It is expected that the Company’s procedures will deal fairly and promptly with a complaint. However, if the individual remains dissatisfied, they can also contact the Office of the Australian Information Commissioner as follows:

Office of the Australian Information Commissioner (OAIC)
GPO Box 5288
Sydney NSW 2001
www.oaic.gov.au

Note: The OAIC requires:

• an individual to first complain to the Company, with the complaint to be escalated to the OAIC only where a response is not received within 30 days or the individual is unhappy with the Company’s response; and 
• complaints to be made in writing 

• 2.10 Contacting the Company about Privacy

Individuals may contact the Company with regards to the following matters:

Matter	Contact Details and Options
To access, update or correctPersonal Information  To opt out of receiving newsletters or Company related direct marketing material	Telephone: 1800 MY EVOLVE (1800 693 865)  Email: myevolve@evolvehousing.com.au  Address: Henry Dodd House, 9-13 Argyle Street Parramatta NSW 2150
To seek more information about anything contained in this Policy  To make a privacy related complaint or feedback	Telephone: 1800 MY EVOLVE (1800 693 865)  Email: privacy@evolvehousing.com.au  Address: Privacy Officer, Henry Dodd House, 9-13 Argyle Street Parramatta NSW 2150

3. APPLICABILITY

This Policy applies to Company; Evolve Housing VIC Limited, EchoRealty Vic Limited, Evolve Playford Limited, Evolve Rosanna Limited, Evolve Sunshine Limited.

4. DEFINITIONS

• Client(s) – for the purpose of this Policy, a person who uses or applies to use goods or services provided by the Company 
• Director – a person who is a Director of the Company
• Employee – any person employed by, or engaged to represent Evolve Housing including contractors, volunteers and students
•  Employment Candidate – a person who makes an application for employment with Company
• Personal Information – has meaning give to it in this Policy
• Sensitive Information – has the meaning given to that term in section 2.7 of this Policy 

5. RELATED RESOURCES

• Australian Privacy Principles 2014
• Privacy Act 1988 (Cth)
  • Privacy Amendment (Enhancing Privacy Protection) Act 2012
  •  Office of the Australian Information Commissioner – www.oaic.gov.au

This Policy is subject to change from time to time at the discretion of the Company. Any approvals required under this Policy will be granted in accordance with the Company Delegations of Authority Policy. Further information on this Policy and other topics, is available on the Evolve Housing VIC website www.evolvehousing.com.au/vic If you have any specific questions regarding this Policy, please contact Evolve Housing VIC. 

Document No: VGRC002 | Approved: October 2024