20 September 2023
2.1 In order to carry out its activities, the ANMF may collect personal information from, or on behalf of, members, and in some circumstances, former members, in order to provide professional and industrial services related to the professions of nursing and midwifery or the employment of nurses and midwives.
3.0 What is your personal information?
3.1 Personal information is defined under the Act as information or an opinion about an identified individual or an individual who is reasonably identifiable. Therefore, any information we collect from which your identity is apparent, or can be reasonably determined, will be considered your personal information.
3.2 Some personal information may be considered ‘sensitive information’ as defined by the Act. Sensitive information includes, but is not limited to:
- your union membership status (if any);
- whether you identify as being of Aboriginal and/or Torres Strait Islander descent;
- whether you identify as being from a culturally and/or linguistically diverse background;
- whether you identify as LGBTQIA+;
- your professional, social and political opinions;
- your political party membership (if any);
- your criminal record (if any); and
- other information relating to an industrial, professional, health and safety or workers’ compensation matter that the ANMF is handling on your behalf.
3.3 The Act allows the ANMF, with your consent, to collect sensitive information where it relates to the ANMF’s activities. We will only collect sensitive information where we have received your consent in accordance with this Policy.
4.0 What information do we collect and hold?
4.1 Information we may collect and hold that may be considered personal information may include your:
- age or date of birth;
- postal or residential address;
- email address, telephone number or other contact details;
- social media details;
- job title, classification, educational qualifications or any additional information relating to your employment, profession or elected representative position/s;
- inquiry or complaint details and any additional information necessary to deliver services to you;
- bank account details, financial institution and payment card managed in accordance with the Payment Card Industry Data Security Standards; and
- any other information you provide to us through the use of our websites, online community or other tools.
4.2 The ANMF may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
4.3 The ANMF website may collect anonymous information for statistical purposes. This may include:
- your server address;
- the top level domain name (e.g. .com, .gov, .net, .au, etc.);
- the date and time of the visit to the website;
- the pages accessed and documents downloaded;
- the previous website visited; and/or
- the type of browser used.
4.4 No attempt will be made to identify users or their browsing activities from aggregated website data except, in the unlikely event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider’s logs.
5.0 How do we collect your personal information?
5.1 The ANMF may collect personal information from you in ways including, but not limited to:
- via one of our websites;
- via our app;
- via social media;
- via telephone;
- via email;
- via fax;
- in person; and/or
- in writing.
5.2 The ANMF will collect your personal information from you directly unless it is unreasonable or impractical to do so, we are legally required to do otherwise, or you have consented to the ANMF’s collection of your personal information from third parties. This Policy also applies to personal information the ANMF collects from any other third party, about you.
5.3 Another way information may be collected is through the use of “cookies”. A cookie is a small text file that the ANMF website may place on your computer. Cookies may be used, among other things, to track the webpages you have visited, to remember your preferences and to store personal information about you. You can adjust your internet browser to disable cookies or to warn you when cookies are being used. However, if you disable cookies, you may not be able to access certain areas of our website or take advantage of the improved experience that cookies offer.
6.0 Why do we collect your personal information?
6.1 The ANMF may collect, hold, use and disclose your personal information for the following purposes:
- to assist you with industrial relations, professional, and employment queries;
- to inform you about industrial, social, professional and political issues and campaigns;
- to inform you about your rights at work;
- to inform you about changes to legislation;
- to refer you to a legal practitioner, insurance broker, accountant or other professional;
- to improve our service delivery;
- to manage our relationship with you;
- to conduct surveys and research;
- to provide educational services and professional development;
- to conduct union elections; and
- to comply with the law.
6.2 You may choose to interact with us anonymously or by using a pseudonym where it is lawful and practicable. However, your decision to interact with us anonymously or by using a pseudonym may affect the level of services we can offer you. For example, we may not be able to assist you with a specific industrial enquiry or investigate a privacy complaint on an anonymous or pseudonymous basis. We will inform you if this is the case and the options available to you.
7.0 What happens if we can’t collect your personal information?
7.1 If you do not provide us with the personal information described above, some or all of the following may occur:
- we may not be able to accept your application for membership;
- we may not be able to assist you with your industrial relations, professional and employment queries; and/or
- we may not be able to provide the requested services to you.
7.2 If you are an applicant for employment with the ANMF and you do not provide us with your personal information, we may not be able to consider your application or engage you as an employee.
8.0 To whom may we disclose your personal information?
8.1 The ANMF may disclose your personal information to:
- our employees, contractors or service providers for any of the purposes outlined in this Policy or a related purpose;
- elected union delegates, workplace representatives and other member activists for the purposes outlined in this Policy;
- third parties with who we have contractual relationships for the purposes outlined in this Policy;
- affiliated peak union bodies, trades and labour councils and any other Australian trade union to further the purposes outlined in this Policy; and/or
- any other organisation for any purpose with your express consent or as required under law.
8.2 The ANMF will take reasonable steps to ensure that each organisation that we disclose your personal information to is committed to protecting your privacy and complies with the APPs, or is subject to a law or scheme that is at least substantially similar to the way in which the APPs protect personal information.
8.3 By providing your personal information to the ANMF, you consent to the ANMF disclosing your personal information to such other organisations:
- for the purpose for which you provided it;
- as otherwise outlined in this Policy; and/or
- as otherwise permitted by the Act.
8.4 It is unlikely that the ANMF will disclose personal information to overseas recipients, although this may occur from time to time. It is not practicable to specify the countries in which such recipients are likely to be located in this Policy. If disclosure to an overseas entity is to occur, the ANMF will require the overseas recipient to agree to comply with the ANMF’s obligations under the Act and undertake to only use the information for the purpose it is provided and not to disclose to another entity or person.
8.5 Your personal information will not be shared or disclosed other than as described in this Policy.
9.0 How do we use and disclose your personal information for direct marketing?
9.1 By providing us with your personal information you consent to our use and disclosure of your personal information for the purposes of direct marketing which may including providing you with information about events, campaigns, products or other services which may be of interest to you.
9.2 If you do not want us to use your personal information for direct marketing purposes, you may elect not to receive direct marketing at the time of providing your personal information.
9.3 If you no longer wish to receive direct marketing or other communications, you may request at any time to cancel your sent to such communications as follows:
- Email: you may “unsubscribe” at any time by clicking the link in the email; or
- Contacting the ANMF in writing.
9.4 No personal information is disclosed to third parties for the purposes of direct marketing.
9.5 Personal information is used, from time to time, for the purpose of forwarding information in the form of journals, newsletters and circular letters, unless an individual requests that their personal information is not used for that purpose.
10.1 The ANMF will take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification, and disclosure.
10.2 Your personal information will only be accessed by authorised personnel, and may be stored electronically on data servers that are password protected and secured by user identifiers, or in hard copy form in secure access-controlled premises.
10.3 By providing your personal information to the ANMF, you consent to your information being stored and processed on a data server/s owned by a third party that may be located outside of Australia. The ANMF will take reasonable steps to ensure that third party providers comply with the APPs.
10.4 ANMF publications and communications may contain links to third party websites and social media platforms including Facebook, Instagram, Twitter, and LinkedIn. The ANMF is not responsible for the privacy policies of third party platforms and we recommend you review the privacy policies applicable to any other platform you visit.
11.0 Government identifiers
11.1 The ANMF will not adopt as our own identifier a government related identifier of an individual, such as a tax file number or Medicare card number, and will only use or disclose a government related identifier where the use or disclosure:
- is reasonably necessary for the ANMF to verify your identity for the purposes or our activities or functions;
- is reasonably necessary for the ANMF to fulfil its obligations to an agency or a State or Territory authority;
- is required or authorised by or under an Australian law; or
- is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
12.0 How can you access and correct your personal information?
12.1 You may request access to any personal information we hold about you at any time by contacting the ANMF in writing. If your personal information has changed and/or you believe that the personal information is incorrect, incomplete or inaccurate then you may request, in writing, that we amend it. Where the ANMF holds information that you are entitled to access, we will provide a suitable means of accessing it. The ANMF will require that you verify your identity in order to seek access and/or correct your personal information.
12.2 The ANMF will seek to provide you with access to your personal information within a reasonable period following receipt of a valid request. The ANMF may charge a reasonable fee where access is provided.
12.3 The ANMF may refuse to provide access if permitted or required to do so by law, including under the APPs. If, for any reason, access is refused, written reasoning for the refusal will be provided.
13.0 What is the process for complaining about a breach of privacy?
13.1 If you believe your privacy has been breached, please contact the ANMF in writing providing details of the incident so that we can investigate it.
13.2 The ANMF will seek to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. The ANMF will inform you whether we will conduct an investigation, and if so, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
13.3 Where an investigation is undertaken, the outcome will be provided to the complainant in writing. The ANMF will seek to respond within a reasonable period following the receipt of a valid complaint.
14.0 What happens if your personal information is subject to a data breach?
14.1 The ANMF will comply with the requirements of the Notifiable Data Breaches Scheme as set out under the Act.
14.2 An eligible data breach occurs when personal information held by an organisation is lost or subjected to unauthorised access or disclosure that is likely to result in serious harm to any of the individuals to whom the information relates. If the ANMF believes on reasonable grounds that an eligible data breach has occurred, the ANMF will notify the individuals whose personal information is involved in the breach in a timely manner.
15.0 Contacting the ANMF
15.1 If you have any questions about this Policy, any concerns or a complaint regarding the treatment of your personal information or a possible breach of your privacy, please contact the ANMF office using the details set out below. The ANMF will treat your requests or complaints confidentially and will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Privacy Officer Australian Nursing and Midwifery Federation ACT Branch PO Box 4 Woden ACT 2606
16.1 This Policy may be varied from time to time and an updated version will be available on the ANMF ACT Branch website. Please check our website regularly to ensure that you have the most recent version of the Policy.