Introduction

Volaby is a 'Software as a Service' (SaaS) product owned by Volaby Australia Pty Ltd (ABN 21 676 942 840) and used by 'Customer Organisations'.

Volaby recognises that the confidentiality of personal information is vitally important and is committed to ensuring that information entrusted to Volaby is protected against misuse.

The Australian Privacy Principles (APPs), as set out in the Privacy Act 1988 (the 'Act') are applicable to Volaby.

This policy applies to all employees of Volaby Australia, as well as all organisations and users of Volaby, regardless of their status as paying customers or not.

Members of customer organisations should read this policy in conjunction with the privacy policy of their organisation.

Policy

The following policy has been developed to outline the maintenance of privacy within Volaby Australia and customer organisations of Volaby.

To ensure compliance with its obligations under the Act, Volaby Australia will take all reasonable steps in order to comply with the Act. The Volaby Privacy Policy deals with individual rights pursuant to privacy obligations and is independent of any contractual and ethical obligations.

Personal information

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• a) Whether the information or opinion is true or not; and
• b) Whether the information or opinion is recorded in a material form or not.

There are some obvious examples of personal information, such as your name or address. Personal information can also include medical records, bank account details, photos and videos.

Privacy process

Collection

Volaby will only collect information that is necessary to enable customer organisations to perform their services. This includes, but is not limited to, information such as:

• Name
• Date of birth
• Contact details such as email, address, phone numbers
• Next of kin details
• Relevant medical issues
• Drivers licence details
• Working with children check / working with vulnerable people check details

Volaby will advise when personal information is being collected, for what purpose it has been collected, and how such information will be used.

Use and Disclosure

Volaby will not use or disclose personal information for a purpose other than the primary purpose of collection unless the individual has consented to the use or disclosure.

Data Quality

Volaby will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up to date. Volaby will take reasonable steps to correct information that is not accurate.

Storage

Volaby will take reasonable steps to protect the security of the personal information held in order to avoid the misuse, loss, unauthorised access, modification or disclosure of this. Volaby will take reasonable steps to destroy personal information if it is no longer needed for any purpose where it may be used or disclosed relating to the primary purpose of collection.

Access

In appropriate circumstances, Volaby will provide access to the personal information that is held on employees and volunteers. If a person requires access to personal information held on them, that information is available to them on the Volaby platform.

To obtain access to personal information held on you by Volaby, you will be asked to provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct person/s and that the privacy of others is not undermined.

Upon request by an employee or volunteer, Volaby will give the volunteer access to their personal information except where an exemption to access under the Act applies.

Employees and volunteers are able to update personal information on the Volaby platform.

At all times, conduct under this Policy will be governed by the following principles:

• All requests for access will be treated seriously;
• All requests will be dealt with promptly and in a confidential manner.

Compliance with the Australian Privacy Principles

Anyone may make an inquiry or complaint about Volaby's compliance with the APPs by forwarding an email to info@volaby.org or letter to the registered office of Volaby Australia.

If an inquiry or complaint is made about Volaby's compliance with the APPs, Volaby will investigate the inquiry or complaint according to the Volaby procedure.

Employee and Volunteer records

The Act does not apply to Volaby when it handles current and past employee records for something that is directly related to the employment relationship. Volaby will take reasonable steps to ensure that employee records are maintained in accordance with the APPs.

Accountabilities

Role	Accountability
Volaby Board Members	Communicate commitment to the Privacy policy Ensure the policy is amended when required Model appropriate behaviours Address potential breaches of this Policy
Volaby leaders Customer organisation leaders	Ensure that there is consistent interpretation of this policy Monitor the work environment to ensure that acceptable standards of conduct are observed at all times Ensure that decisions regarding employees or volunteers and the work environment are in compliance with this policy Model appropriate behaviours Treat all complaints seriously and take immediate action to refer complaints or report conduct in breach of the policy Act as a first point of contact for employees and volunteers wishing to raise issues that have occurred that are contained within this policy Refer a complaint to another leader if they do not feel that they are the best person to deal with the case (e.g. if there is a conflict of interest or if the complaint is complex or serious)
Employees and volunteers	Understand their obligations and rights in dealing with personal information Comply with their responsibilities under this policy Follow the established procedure should they be involved in collecting personal information for the organisation

Amendments

This policy may be reviewed annually. Should the review find that there is a need to change the policy, anyone who may be impacted by this proposed change, will be advised prior to the change taking place.