Privacy Policy

Privacy Policy – National Nursing Archives of Australia Limited

1. INTRODUCTION

1.1 Purpose

The National Nursing Archives of Australia (NNAA) has this NNAA Privacy Policy for the management of ‘personal information’ and ‘sensitive information’ in accordance with the NNAA obligations as an APP entity under the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act).

The 13 APPs are summarised in Appendix A of this policy and are available in full in Schedule 1 of the Privacy Act.

Some terms defined in legislation are identified using inverted commas (‘ ‘).

1.2 Scope

This NNAA Privacy Policy applies to ‘personal information’ and ‘sensitive information’ in records created, collected or held by the NNAA to fulfill its charitable purpose being to preserve and promote nursing history and associated research.

The NNAA collects personal information to perform its functions of:

  1. collecting, securing and preserving information, publications, books and other literary material, memorabilia and artefacts related to the profession of nursing;
  2. establishing an archive of information, publications, books and other literary material, memorabilia and artefacts related to the profession of nursing;
  3. establishing and operating a museum to make information, publications, books and other literary material, memorabilia and artefacts related to the nursing profession available to interested persons;
  4. maintaining an online searchable record of nursing archives across Australia; and
  5. accept gifts, devises, bequests and assignments;
  6. act as trustee of money, programs or other property vested in the NNAA on trust;
  7. doing anything ancillary to the functions referred to in 1 to 6 above.

This NNAA Privacy Policy has limited application to the archival collection of the NNAA – for example, where the ‘personal information’:

Is not collected by the NNAA for inclusion in a ‘record’ or a ‘generally available publication’;

Is in an item kept by the NNAA for the purposes of reference, study or exhibition and therefore is not a ‘record’ under the Privacy Act; or

1.3 Personal information and sensitive information

The Privacy Act defines terms including ‘personal information’ and ‘sensitive information’.

‘Personal information’ means 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.

‘Sensitive information’ includes ‘personal information’ that is 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;
  • health or genetic 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; and
  • biometric templates.

1.4 Overview of this NNAA Privacy Policy

In compliance with APP 1, the NNAA takes steps as are reasonable in the circumstances to implement practices, procedures and systems that ensure compliance with the APPs and any relevant APP code, including for dealing with any related enquiries or complaints.

This NNAA Privacy Policy explains how the NNAA manages personal information, including:

  • the kinds of personal information that the NNAA collects and holds;
  • how the NNAA collects and holds personal information;
  • the purposes for which the NNAA collects, holds, uses and discloses personal information;
  • how an individual may access personal information about the individual that is held by the NNAA and seek the correction of such information;
  • how an individual may complain about an alleged breach of the APPs, or any relevant APP code, and how the NNAA will deal with any complaints;
  • whether the NNAA is likely to disclose personal information to overseas recipients and, if so, the countries where recipients are likely to be located.

2. PERSONAL INFORMATION HANDLING PRACTICES

2.1 The kinds of personal information the NNAA collects and holds

The NNAA may collect personal information from an individual, or from a third party. The NNAA uses forms, online systems and other electronic or paper correspondence, as well as telephone and face-to-face interactions, to collect personal information.

The NNAA collects and holds over 19 classes of personal information which may include:

  • contact details – staff and clients;
  • employment history and educational qualifications of staff;
  • complaint details;
  • reference and user enquiries;
  • stakeholder mailing lists;
  • financial information and accounting system;
  • mailing and membership list of Friends of the NNAA;
  • sponsorship and fundraising information;
  • volunteers of the NNAA;
  • user feedback database;
  • registration and information provided to NNAA websites;
  • subscriptions to NNAA newsletters (online and print);
  • entries to social media competitions;
  • online event ticketing;
  • details of donors, lenders and rights owners of items in the NNAA Collection;
  • biographical information, including career history information;
  • published and broadcast commentary and opinion;
  • unpublished recordings and manuscripts; and
  • oral histories.

2.2 About personal information the NNAA collects

The personal information collected in connection with the operations of the NNAA may be in relation to:

  • Requests for access to the NNAA Collection;
  • Details of volunteers;
  • Processing of financial transactions;
  • Establishing ownership of intellectual property rights;
  • Archival research and interpretation;
  • Applications for grants, fellowships and scholarships (including internships and ‘in-residence’ programs);
  • Compliance with Government regulations and legislation;
  • Donor liaison, sponsorship and fundraising activities;
  • Recording user feedback on services and activities including surveys and evaluations;
  • Electronic mailing lists relating to the activities of the NNAA;
  • Affiliate and Corporate mailing lists;
  • Registration details for the NNAA’s website;
  • Access to digital content;
  • Subscription information;
  • Online event ticketing;
  • Oral histories;
  • Employee records;
  • Membership records of Friends of the NNAA; and
  • Footage from closed circuit cameras.

2.3 How the NNAA collects personal information

In collecting information to perform its functions, the NNAA will not collect personal information (other than sensitive information) unless the information is reasonably necessary for, or directly related, to one or more of the NNAA’s functions or powers.  Any personal information that the NNAA collects will be relevant for the purpose to which it is collected.  The NNAA will only collect personal information by lawful and fair means and will generally collect the information about an individual from the individual personally, unless the individual consents otherwise, or it is unreasonable or impractical to do so.

Unsolicited personal information will be collected if the NNAA determines that it could have otherwise collected the information, or de-identify or destroy the information if the NNAA could not have collected the information.

Where it is reasonable in the circumstances, the NNAA will notify individuals about the collection of their information by reference to this NNAA Privacy Policy or will otherwise ensure that the individual is aware of relevant matters as required by the APPs.

2.4 How the NNAA holds personal information

The NNAA holds personal information in the following ways:

  • The records for the corporate mailing list are held in electronic and paper files;
  • The records for donors are held on the NNAA collection management database and in electronic and paper files;
  • The records for requests for access to the collection are held in electronic and paper files;
  • The records for financial transactions are held on the Finance database;
  • The records for membership of the Friends of the NNAA are held in electronic and paper files;
  • The records of relating to sponsorship and fund raising are held in electronic and paper files;
  • The records for volunteers are held in electronic and paper files;
  • The records for user feedback is held in electronic and paper files;
  • The records of online event ticketing are held in both electronic and paper files;
  • Oral histories are held in electronic and paper files; and
  • Employee records are held in electronic and paper files.

2.5 Access to and correction of personal information

An individual may apply to access or correct their personal information by application to the Privacy Contact Officer.

Access to personal information (APP 12)

Individuals have a right to access the personal information that the NNAA holds about that individual. The right of access is subject to the relevant exemptions in the FOI Act and any Act of the Commonwealth.  The NNAA will respond to the individual’s request within 30 days after the receipt of a request from the individual, to grant access or to give written reasons for any refusal to grant access to the information.

Amendment of personal information (APP 13)

The NNAA will take reasonable steps to correct personal information that it holds to ensure that it is accurate, up-to-date, complete, relevant and not misleading.

Individuals can request information that the NNAA holds about them to be corrected.  The NNAA will notify the individual of a decision within 30 days after the receipt of a request from the individual and will provide written reasons if the request to amend personal information is refused.

3. USE AND DISCLOSURE OF PERSONAL INFORMATION (APP 6)

3.1 General use and disclosure

The NNAA holds personal information that is collected for a primary purpose and will not use or disclose it for another purpose, except where an individual provides consent or in compliance with APP6, including where:

  • the individual would reasonably expect the sensitive information to be used for a purpose directly related to the primary purpose records;
  • the individual would reasonably expect the personal information (not sensitive information) to be used for a purpose related to the primary purpose;
  • it is required or authorised by law or a court/tribunal order;
  • a ‘permitted general situation’ exists; or
  • the NNAA believes it is reasonably necessary for the activities conducted by or on behalf of an enforcement body.

3.2 Disclosure of personal information to overseas recipients (APP 8)

The NNAA is not likely to disclose information to overseas recipients. 

APP 8 places obligations on the NNAA for disclosure of personal information to overseas entities, when the recipient is not in Australia or an external entity Territory, and is not the entity or the individual.  Before any personal information is disclosed overseas, the NNAA will take reasonable steps to ensure that the overseas recipient does not breach the APPs (other than APP 1) in relation to the information.

3.3 Accidental or unauthorised disclosure of personal information

The NNAA protects personal information the NNAA holds and will take seriously and deal promptly with any accidental or unauthorised disclosure of personal information.

External service providers who handle personal information about the NNAA’s staff, users or other individuals are ordinarily bound contractually to comply with the Privacy Act and may themselves have statutory obligations as APP entities.

If employees disclose official information without authority they may face disciplinary sanctions including, in the most serious cases, termination of employment.

4. DATA QUALITY

Collection systems aid in the automated correction of identified errors within NNAA Collection dataset when required – identification and resolution method are determined by NNAA staff and volunteers. Additionally, NNAA staff and volunteers upgrades data as part of their regular work.

In terms of securing personal data collected via acquisition work processes, this is achieved by limiting access to the NNAA collection management database to staff and endorsed researchers. This information is also withheld from the NNAA collection management database online interface.

5. STORAGE AND DATA SECURITY (APP 11)

The NNA takes reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

6. RECORDS MANAGEMENT

Storage of information (and the disposal of information when no longer required) is managed in accordance with NNAA management regulations, guidelines and authorities, including Records Authorities and General Disposal Authorities.

7. EMAIL COMMUNICATION

There are inherent risks associated with the transmission of information over the internet, including via email. Individuals should be aware of this when sending personal information to the NNAA via email. If this is of concern to any individual, they should use other methods of communication with the NNAA, such as post, fax, or phone.

8. NNAA WEBSITE – NNAAWEBSITE PRIVACY STATEMENT

The NNAA publishes a privacy statement on its website explaining the privacy aspects of visiting the website, web analytics, cookies and email.

View the NNAA Website Privacy Statement.

9. COMPLAINTS

9.1 How to make a complaint

In accordance with APP 1, an individual may complain about an alleged breach of the APPs by contacting the Privacy Contact Officer using the details at the end of this NNAA Privacy Policy.

9.2 NNAA complaint-handling commitment

In accordance with APP 1, the NNAA will take reasonable steps in the circumstances to deal with enquiries or complaints about compliance with the APPs. The NNAA will send a considered response to a complaint or suggestion within 30 days if contact details are provided. The NNAA is committed to quick and fair resolution of any complaints and will ensure the complaint is taken seriously.

10. NNAA PRIVACY POLICY UPDATES

In accordance with APP 1 this NNAA Privacy Policy will be reviewed every 12 months to ensure that it is up-to-date.

11. HOW TO CONTACT THE NNAA PRIVACY CONTACT OFFICER

In accordance with APP1, an individual may contact the Privacy Contact Officer to:

  • obtain access to their personal information;
  • make a complaint about a breach of their privacy;
  • query how their personal information is collected, used or disclosed;
  • request a free copy of this NNAA Privacy Policy, or
  • ask questions about this NNAA Privacy Policy.

The NNAA’s Privacy Contact Officer may be contacted by any of these contact points:

Post:    Privacy Officer c/o Company Secretary

National Nursing Archives of Australia

PO Box 219

DEAKIN WEST ACT 2601

Fax:      02 6282 3565

Email:   company.secretary@acn.edu.au

NNAA WEBSITE PRIVACY STATEMENT

USE OF INFORMATION COLLECTED ONLINE

The purpose of this statement is to let users of the National Nursing Archives of Australia (NNAA) website know what information is collected about them when they visit our website, how this information is used and if it is disclosed anywhere.

This statement has been prepared in accordance with the Office of the Australian Information Commissioner Guidelines for Organisations and Australian Government Agencies.

Find out more in our Privacy Policy.

RECORDING YOUR VISIT

When you visit NNAA websites, we make a record of your visit and log the following information for statistical purposes:

  • your server address;
  • your top-level domain name (for example .com, .gov, .au);
  • the date and time of your visit to the site;
  • pages you accessed and documents you downloaded;
  • the previous site you visited;
  • the type of browser you used; and
  • how you interacted with our website.

The NNAA will not attempt to identify users or their browsing activities except in accordance with the Privacy Act 1988 (Cth). In the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect the NNAA’s or our service provider’s logs.

WHAT IS A COOKIE?

A cookie is a small data file stored on your device’s browser. Its purpose is to help a website keep track of your visits and activity. You will usually find information on cookies and how to manage them under options or settings on your browser. You can choose to see cookies before deleting them and to keep cookies from some websites. Setting your browser to block all cookies may make some websites take longer to load and stop you saving customised settings such as text sizes, location or sign-in information.

DIGITAL MARKETING

Third-party vendors whose services we use, such as Google and Meta, will place cookies on web browsers in order to serve ads based on past visits to our website. This allows us to continue to promote our services to those who have shown interest in our services in the past.

The NNAA utilises Meta Advertising and Google Ads. We do this to understand your preferences, deliver ads and make them more relevant to you. Cookies also enable us to learn whether someone who saw an ad on Facebook or Google later visited our website. The ultimate control of the dissemination of information gathered through Meta Advertising and Google Ads resides entirely with these organisations. You can opt out through settings on your social and Google accounts.

WEBSITE ANALYTICS

To improve your experience on our site, we may use cookies.

The NNAA website also uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage – to help us improve your interactions with us.

Google uses third-party cookies to track viewing behaviour when you watch YouTube videos embedded on NNAA websites. Google’s Privacy Policy contains more information about how they collect and use cookies.

By using NNAA websites, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

NNAA websites may also contain links to other websites. Please be aware that we are not responsible for the content or privacy practices of other sites. When you go to other websites from NNAA websites, we advise you to be aware and read that website’s privacy policies.

RECORDING YOUR EMAIL ADDRESS

We will only record your email address if you communicate with us. It will only be used for the purpose for which you have provided it (for example, in relation to signing up to one of our e-newsletters). Your email address will only be used or disclosed for another purpose with your consent, if authorised or required by law, or otherwise in accordance with the Privacy Act 1988 (Cth).

COLLECTING PERSONAL INFORMATION

From time to time, we will use electronic forms on NNAA websites to gather personal information for purposes directly related to a function or activity of the NNAA.

When we do so we will let you know the purpose for which the information is being collected (including if the information is to be published), and the legal authority for the collection if it is authorised or required by or under law.

We will also provide you with other options for providing the information (for example, a paper form and mailing address, or a telephone contact).

We will not collect or solicit personal information via NNAA websites which would be unlawful, unnecessary or unrelated to the functions or activities of the NNAA, or unfair or unreasonably intrusive.

Credit card details collected via electronic forms on this site are encrypted for transmission using secure server technologies and are only made accessible to staff members authorised to complete the transaction.

PUBLISHING PERSONAL INFORMATION

We will only publish personal information on NNAA websites if it has been collected for this purpose with your knowledge or if you have consented to the disclosure. When giving consent you should be aware that information published on this site is accessible to millions of users from all over the world, that it will be indexed by search engines and that it may be copied and used by any web user. This means that, once the information is published on this site, we will have no control over its subsequent use and disclosure.

TRANSMISSION OF INFORMATION ACROSS THE INTERNET

Our sites do not provide facilities for the secure transmission of information across the internet. Users should be aware that there are inherent risks transmitting information across the internet.

Because there are risks associated with using the internet as a transmission medium, when we use electronic forms to collect information, where practicable we will also give you other options for providing the information – for example, a paper form and mailing address and a telephone contact.

For further information, please email company.secretary@acn.edu.au.