Privacy Policy

Privacy Policy

Summer Foundation Ltd (ACN 117 719 516) (Foundation, us, we, our) maintain a policy of confidence concerning the personal information we collect from and about individuals (you, your) (Privacy Policy).

This Privacy Policy details how we deal with your personal information and has been developed in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

By providing your personal information to us directly or indirectly you accept the terms of this Privacy Policy. 

1. What kinds of information do we collect?

The type of information that we collect from you will depend on how you engage with us.

In order to provide you with our services, we will collect your name, contact information including address, email address and telephone number, demographic information such as age, guardian details, and any other personal information that you submit to us, via our website or otherwise, including https://www.summerfoundation.org.au/ and https://www.housinghub.org.au/ (Sites). Additionally: 

● If you engage with us through our research team, with your consent, we may collect sensitive information, including health information, personal experience and your opinions on disability and health policy and this information will be relevant to the research being conducted and explained to you further at the time of collection.

● If you engage with us through the Lived Experience team, with your consent, we may collect sensitive information, including information about your disability, health, behaviour, mental health, housing, care needs, travel needs, equipment needs and ethnicity. With your consent, we may also collect personal information such as your image.

● If you engage with us through the Policy team, we may collect direct quotes, photographs and videos of you. With your consent, we may collect sensitive information, including information about your disability, levels of ability, health needs and experiences in aged care, hospitals or group homes.

● If you engage with us as a supplier, housing provider or company customer, we will collect your organisation name and role. We may also collect your mobile phone number or social media pages in order to verify your identity.

● If you engage with us through the Building Better Homes Campaign we will collect your name and contact details. With your consent we may collect direct quotes, photographs and videos of you.

We will only collect sensitive information if you consent and it is relevant to providing our services. 

2. How do we collect your personal information?

We collect your personal information directly from you or where a person using our services provides us with your information (for example, if you are the carer of a person with a disability who uses our services and they provide your information as their contact person or advocate). The main ways we collect personal information about you are when you:

● request to receive the services offered and provided by us, including the services listed above;

● register to be on our mailing list;

● sign up as a housing seeker;

● sign up as a support coordinator;

● sign up as a housing provider;

● complete an online form on one of our Sites;

● participate in our web-based forums or on social media platforms such as Facebook, Twitter, Instagram, Youtube and LinkedIn;

● participate in an interview with us;

● apply for a position with us; and

● otherwise submit personal information about yourself, or someone else, to us, or any of our Sites.

We will only collect your personal information from third parties if you give the third party your consent to provide the information to us or it would be reasonably expected.

We will only collect sensitive information with your consent.

If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information. 

3. If you are under 18 years of age

If you are under 18 years of age you must ask your parent or legal guardian to approve your provision of personal information before you submit your personal details to us. 

4. Use of personal information

This Privacy Policy deals with personal information of the Sites’ users, service providers and other third parties.

We will only use your personal information for the purposes for which it was given to us, or for purposes which are directly related to the provision of our services.

Your personal information may be used by us in a number of ways, including:

● to assist you conveniently and easily accessing the services that we offer and provide, including the services listed above;

● to contact you for research purposes and to organise events or services;

● to conduct research;

● to form and maintain research partnerships and housing partner relationships;

● for internal record keeping;

● to periodically send communications about information which we consider that you may find interesting;

● to make policy submissions;

● to allocate resources; and

● develop and roll out programs; and

with your consent, we may also use sensitive information collected to: 

● to assist you conveniently and easily accessing the services that we offer and provide;

● conduct research;

● provide advice and guidance;

● inform training resources and policy development;

● train participants;

● make policy submissions;

● present at conferences and meetings;

● create case studies and video content; and

● if you engage with the Tenancy Matching Service, to establish your disability and support needs, likely success as a tenant and confirm Specialist Disability Accommodation potential eligibility.

5. Disclosure of personal information

In certain circumstances, it may be necessary for us to disclose your personal information to third parties in order to assist us in providing our services, or where disclosure is required by us to meet our legal and regulatory obligations. Third parties may include: 

● digital marketing and other service providers such as P2P Networks, Office 365, Google, Marketcircle, Mailchimp, Salesforce, Facebook, Typeform, DigitalOcean, and Kinsta;

● technology support service providers where applicable to the service provided to you;

● government, government agencies and departments, NDIS, peak bodies, research bodies, universities and service planners;

● if you engage with the Tenancy Matching Service, Specialist Disability Accommodation and Supported Independent Living providers (and your family members and health professionals, with consent);

● if you engage with the Housing Hub or Tenancy Matching, housing providers and owners;

● your personal story may feature on the Sites or other materials if you provide further consent;

● if you consent and participate in research, your next of kin or appropriate support person will be contacted if you experience distress during an interview;

● government and law enforcement agencies and regulators; and

● entities established to help identify illegal activities and prevent fraud where authorised by law.

We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies (as defined in Section 16A of the Privacy Act).

If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its or their assets, your personal information may be among the assets transferred.

We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy. 

6. Cookies

A cookie is a small file which your web browser saves on your computer or device. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies, for specific websites if you wish. This may prevent you from taking full advantage of our Sites. Cookies help website owners analyse traffic to their website, and can also help web applications provide functionality and content tailored to you as an individual, by gathering and remembering information about your preferences, needs, likes and dislikes. We may use cookies for traffic logging purposes to identify which pages are being used. This helps us analyse data about webpage traffic and improve our Sites in order to tailor them to user’s needs. We only use this information for statistical analysis purposes. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

7. Direct marketing

We use personal information about you for the primary purpose of providing you with our services. We may also use it for other purposes for which you might reasonably expect us to use that information. You authorise us to use any email address or other contact information you provide to use at any time for such above purposes.

You can opt out of receiving electronic communications at any time. You agree and acknowledge that even if you opt out of receiving information about future events or other services offered by us, we will still send you essential information that we are required to send you relating to the services we provide. 

8. Storage and security

The security of your personal information is paramount to us and we use all reasonable endeavours to keep your information in a secure environment and to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us using the details below.

We keep records of the personal information we gather from you and we either password protect these, or store these on a secure server or in locked facilities. You warrant that you will not act in a manner that results in us collecting, using or storing information that is in breach of our obligations at law.

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy, securely delete, or de-identify your personal information as appropriate. 

9. Accuracy of your information

We take reasonable steps to ensure that the personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us using the below details and we will take reasonable steps to correct it. 

10.Variation and consent to variation

We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy.

11.Disclosure to overseas recipients

We may disclose personal information to third parties like technical support writers and communication distributors located in Singapore, USA and Spain, to the extent we use your personal information for these purposes. To the extent that the laws and rights of these countries are not equivalent to the laws of Australia, you agree to be bound by the laws and rights of the relevant extraterritorial jurisdiction. Such countries have data protection laws that are not equivalent to the laws of Australia and you may not have equivalent rights of enforcement. 

12.Access to your information and making a complaint

You may request access to the personal information we hold about you. If you do so we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions provided under the Privacy Act. You may request this information by writing to our Privacy Officer.

Where it is practical to do so, when contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

If you wish to make a complaint about a breach of the Privacy Act by us, you may do so by providing your complaint in writing to the contact details listed below. You may also make a complaint verbally. We will seek to respond to any complaint within a reasonable period of time. We may seek further information from you in order to provide a comprehensive and complete response.

You may also make a complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the Australian Information Commissioner via telephone on 1300 363 992, by submitting a complaint or inquiry online at www.oaic.gov.au or by writing to the OAIC at GPO Box 5218 Sydney NSW 2001. 

13.Contact us

If you have any questions, or if you wish to contact us for any of the reasons described above, including to correct or access the information we hold about you or to make a complaint, please contact our Privacy Officer:

The Privacy Officer

Email: [email protected] Address: PO Box 208, Blackburn Victoria 3130

Version 2, November 2020. 

First published on 18 March 2019. 

Revised 20 November 2020.