Learn more about our mental health services
Get started
Learn more about our youth and family services
Get started
Learn more about our domestic violence services
Get started

Privacy Policy

Last updated: 29 March 2022

Lutheran Church of Australia Queensland District (Lutheran Community Care) trading as Lutheran Services ABN 47 291 464 804 (Lutheran Services, we, us, our) respects your privacy and is committed to protecting it.  We comply with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way private sector organisations collect, use, keep secure and disclose personal information.

If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, please contact us using contact details set out in this policy and will respond to your concern or answer your question.

We recommend that you keep this information for future reference.

Unless otherwise defined, terms that appear in bolded text (on their first use in this document) have the meaning given in the Definitions section further below.

Managing personal information

Collection

At or around the time Lutheran Services collects your personal information, we will endeavour to provide a notice which details how Lutheran Services will use and disclose that specific information.

As much as possible or unless provided otherwise in this policy or a notification statement, Lutheran Services will collect personal information directly from you or your authorised person.

Personal information may be collected from a third party if:

When you engage in certain activities, such as filling out a survey or sending us feedback, we may ask you to provide certain information.  It is completely optional for you to engage in these activities.

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary.  If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.

Unsolicited personal information

In the event Lutheran Services collects personal information from you, or a third party, in circumstances where it has not requested or solicited that information (known as unsolicited information), and it is determined by Lutheran Services that the personal information is not required, Lutheran Services will destroy or de-identify that information as soon as possible.

In the event that the unsolicited personal information collected is in relation to potential future employment with Lutheran Services, such as your CV, resume or candidacy related information, and it is determined by Lutheran Services that it may consider you for potential future employment, that information may be kept on Lutheran Services’ human resource records.

Use and disclosure

Lutheran Services will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you. The primary purpose for collection will be notified at or around the time of collecting that personal information from you or your authorised person (i.e. through a collection notification statement).

We set out some of the most common collection, use and disclosure instances in the table below.

PurposeTypes of personal informationUsesDisclosures
EnquiriesContact information: such as your name, email address, phone numbers, and any other personal information you voluntarily provide to us in the content of your enquiry.The types of uses we will make of personal information collected for this type of purpose include:

Identity verification: if required, the verification of your identity.

Services: the provision of our services to you including: Using your personal information in order for you to use the services offered. To provide customer service functions, including handling customer enquiries and complaints.

Marketing: using your personal information for the purposes set out in “Marketing Services” section below.

General administrative and security use: To protect Lutheran Service’ websites from security threats, fraud or other criminal activities. Use for the administration and management of Lutheran Services. Maintenance and development of our services, business systems and infrastructure. In connection with the sale of any part of Lutheran Services’ business or a company owned by a Lutheran Services entity. To provide customer services to clients and for quality assurance purposes.
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation, to:

a) Related bodies corporate of Lutheran Services (including related entities).

b) Service providers (including IT service providers and consultants) who assist Lutheran Services in providing our services.

c) Third parties in connection with the sale of any part of Lutheran Services’ business or a company owned by a Lutheran Services’ entity.

d) As required or authorised by law.
Marketing ServicesContact information: such as your name, email address, current postal and residential addresses, phone numbers, country of residence (and, if applicable, age); credit or debit card details.

Online blogs/Lutheran Services website forums: information such as:

a) User account information such as username and password and other contact information.

b) Any other information provided to Lutheran Services or posted on the Lutheran Services website forum and blogs.

c) Social media activity: including “likes”, comments posted, any of your oppositions or feedback, photos posted or uploaded and other information pertaining to your social media activities which concern, or relate, to Lutheran Services.
General marketing and consumer analytics: using your personal information: To aggregate with other information and to then use it for marketing and consumer analytics. To offer you updates on events or information that may be of interest to you. For marketing and promotional activities by us (including by direct mail, telemarketing and email) such as our email alerts, awareness information and newsletters. For the Uses detailed above in “Enquiries”.

Events and symposiums: using your personal information to provide you with information regarding conferences, fundraising and donation opportunities which Lutheran Services organises.

Raffles and competitions: for donations and fundraising, and provision of prizes to winners.

Online accounts or social media: if you create an account with Lutheran Services or participate in our social media platforms (such as Facebook, Twitter and LinkedIn) and you provide us your personal information, we will use it for:
a) Adding account holders to the marketing database.
b) Customer service related contact.
c) Responding to social media messages.
d)Fulfilling social media platform rules.
We may disclose your personal information to: Third parties connected with the marketing process who assist us in providing our services to you.The parties listed in the Disclosure column for “Enquiries”.  
Careers, Employment and ContractingContact information: such as your name, e-mail address, current postal and residential address, phone numbers, country of residence, next of kin contact details.

Employee record information.

Identifying information: such as your photo, passport and residency details, date of birth.

CV, resume or application related information: such as the details provided in your resume or CV, your eligibility to work in Australia, your education, previous employment details, professional memberships or trade qualifications.

Tax, superannuation and payroll information: such as your Tax File Number and ATO Declaration, Superannuation details and financial institution details.Background check information: information obtained from you or third parties to perform background checks.

Medical or health information which you voluntarily provide to us as part of pre-employment medicals, random drug and alcohol testing or such other information which may be related to an incident which has occurred during the course of your employment or engagement with Lutheran Services.

Performance related information: pre-employment testing and other information collected by Lutheran Services’ systems in the course of your employment or engagement with Lutheran Services.

Information collected from referees.

Security information: such as CCTV footage and photographs taken on our premises.
Background checks: utilising the information collected for the purpose of assessing candidate suitability for role, including by obtaining:
a) Verification of your identity and age.
b) Criminal history background checks including publicly available information including Facebook, Twitter, Instagram, YouTube.
c) Confirmation of eligibility to work in Australia.
d) Confirmation of education and qualifications.
e) Confirmation of previous employment.
f) Medical history and general fitness assessment to ensure you are able to perform your job safely and effectively.
g) Consideration regarding medical leave.

Administration and performance monitoring use: utilising the information collected for the purpose of:
a) Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be).
b) Use of such information whether or not the employment or contractor relationship is prospective, current or past.
c) Use of such information to monitor systems, performance and time usage and internet usage.
d) The use of your personal information collected in the administration and management of Lutheran Services.  
We may disclose your personal information to: Related bodies corporate of Lutheran Services (including related entities).Relevant superannuation companies.Government agencies, including but not limited to the Australian Taxation Office, Centrelink and Department of Human Services.Relevant Worker’s Compensation organisation (e.g. WorkCover Queensland etc).Recruitment agents used in connection with your application with us.Third party referees nominated by you in connection with an application made to Lutheran Services.Third party parties in connection with obtaining any background checks, pre-employment screening.Service providers (including IT service providers and payroll providers), if any.Third parties in connection with the sale of any part of Lutheran Services’ business or a company owned by a Lutheran Services’ entity.Financial institutions for payroll purposes.As required or authorised by law.
Care and Service DeliveryContact information: such as your name, email address, current postal and residential addresses, phone numbers (and, if applicable, age), next of kin contact details.Identifying information: such as your photo, passport and residency details, date of birth.Health information: such as:Height and weight.Medical conditions and medications.Scans and other medical imaging information.Medicare details.Individual Healthcare Identifier (IHI).Private healthcare information.Hospital details and contact information.Medical practitioner’s name and contact information.Legal information: including the identity and contact details of your attorney appointed under Enduring Power of Attorney (EPOA).Information shared with Lutheran Services by your friends, family and other visitors.Information you elect to provide as a part of your participation in our services.Security information: such as CCTV footage and photographs taken on our premises.Identity verification: if required, the verification of your identity.

Services: the provision of our services to you including:

a) Using your personal information in order for you to use the services offered.

b) Conferring with your attorney.

c) Assisting you (and, if applicable, your attorney) to make decisions relating to your care and health.

d) Processing Medicare and National Disability Insurance Scheme (NDIS) claims on your behalf and submitting necessary funding claims.

e) Providing customer service functions, including handling customer enquiries and complaints.

General administrative and security use as detailed in the Uses column for “Enquiries”, and for administering programs for Lutheran Services initiatives for legacy and in memoriam.

Marketing: using your personal information for the purposes set out in “Marketing Services” section below.Providing customer services to clients and for quality assurance purposes.

Compliance with legal and regulatory obligations, including provision of information to government assessment agencies as required by legislation.
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation, to: Physicians, specialists, medical practitioners, hospitals, pharmacies and clinical partners who assist Lutheran Services in providing our services.Related bodies corporate of Lutheran Services (including related entities). Service providers (including IT service providers and consultants) who assist Lutheran Services in providing our services.Third parties in connection with the sale of any part of Lutheran Services’ business or a company owned by a Lutheran Services’ entity.

As required or authorised by law.

Lutheran Services does not provide personal information to government agencies, other organisations or anyone else unless one of the following applies:

Cross-border disclosures

Lutheran Services may store, use, disclose or transfer personal information, other than sensitive information (including health information), outside of Australia.

By submitting your personal information to Lutheran Services, you expressly agree and consent to the disclosure, transfer, storage or processing of your personal information outside of Australia, including in the United States.  In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information.  However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this policy.

The Privacy Act requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act.  By providing your consent, under the Privacy Act, we are not required to take such steps as may be reasonable in the circumstances.  However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this policy.

If you do not agree to the disclosure of your personal information outside Australia by Lutheran Services, you should tell Lutheran Services that you do not consent. To do this, either elect not to submit the personal information to Lutheran Services after being reasonably informed in a privacy collection statement or please contact us using the contact details set out in this policy.

Quality

Lutheran Services will take action to ensure that the personal information it collects is accurate, up-to-date and complete. This includes updating personal information as advised by you and carrying out periodic verification of information held by Lutheran Services.

Collection and use of sensitive information

In general, Lutheran Services attempts to limit the collection of sensitive information collected from you, but this may not always be possible and it may be necessary to collect sensitive information in order for Lutheran Services to deliver care to you and for quality compliance purposes.  We set out some types of sensitive information we may collect about you in the “Careers, Employment and Contracting” and “Care and Service Delivery” sections of the table above.  Sensitive information will not be:

Direct Marketing

Express informed consent

You give your express and informed consent to us using your personal information set out in the “Enquiries” and “Marketing Services” sections of the table above to provide you with information about Lutheran Services’ products, services or events or any other direct marketing activity (including third party products, services, and events), whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).

Inferred consent and reasonable expectations of direct marketing

Without limiting the above paragraph, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided) or if it is within your reasonable expectation that Lutheran Services will send Direct Marketing Communications given the transaction or communication you have had with Lutheran Services, then that personal information may be used for the purpose of sending you Direct Marketing Communications which Lutheran Services consider may be of interest to you.

Opt-out

All of our Direct Marketing Communications include an “unsubscribe” facility, which you may use at any time if you do not wish to receive any further Direct Marketing Communications from us.  You may also contact Lutheran Services directly to “opt out” from receiving Direct Marketing Communications, using the contact details set out in this policy.  Upon receipt of your “unsubscribe” or “opt out” request, Lutheran Services will immediately cease sending any Direct Marketing Communications to you.

Anonymity and pseudo-anonymity

Due to the nature of the services Lutheran Services provides, it is usually impractical (and in some cases, impossible) to deal with you on an anonymous basis or through use of a pseudonym.

However, complaints and whistleblower communications may be received and dealt with anonymously.

Security

Lutheran Services undertakes a range of actions to protect the personal information it holds against loss, unauthorised access, use, modification or disclosure, and against other misuse.

These actions include password protection for all IT systems and mobile electronic devices, securing paper files in locked cabinets and sachets and physical access restrictions (e.g. locked doors, secure access to offices).

Cookies, IP Addresses and Social Media

To improve the experience on Lutheran Services website, we may use ‘cookies’. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences, monitor traffic patterns, and help increase efficiency if you revisit Lutheran Services’ website. Browser settings can be used to refuse the use of cookies, however some site functionality will be lost. In some cases, cookies may enable Lutheran Services to aggregate certain information with other personal information it collects and holds about you. We will apply the same privacy protection to all personal information, whether gathered via cookies or from other sources, as detailed in this policy.

Lutheran Services’ website may contain links to other websites (e.g. Government webpages and social media sites such as Facebook and LinkedIn) and in this instance you are advised to be aware and read that site’s privacy policy.

Lutheran Services may use your information from IP addresses or social media sites to analyse trends, administer Lutheran Services’ website, gather broad demographic information and action requests for information, feedback and complaints where the website link to provide this data has been used.

Resolving Privacy Concerns and Complaints

Lutheran Services has put in place an effective mechanism and procedure to resolve privacy complaints.  Concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information can be submitted to the contact details set out below:

Telephone:           07 3858 3000

Email:                    privacy@lutheranservices.org.au

Address:               PO Box 1535, Milton 4064, Queensland, Australia

Please mark your correspondence to the attention of the Privacy Officer.

Lutheran Services will ensure that all complaints are dealt within a reasonably appropriate timeframe so that any decision (if a decision is required) is made in a timely manner that does not compromise the integrity or quality the decision.

In order to resolve a complaint, Lutheran Services:

We will keep a record of the complaint and any action taken in a Register of Complaints.

Access and correction

L You are entitled to access or update/change the personal information we hold about you upon request unless there is a sound reason under the Privacy Act, or other relevant law, to withhold the information, or not make the requested changes.  You are also entitled to edit and correct personal information held by Lutheran Services if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

Requests for access to personal information held by Lutheran Services, please contact us using the contact details set out in this policy.

If Lutheran Services does not agree to provide access to personal information or to amend or annotate the information Lutheran Services holds about you, you may make a statement about the requested changes to be attached to the record.

You may seek a review of the decision using Lutheran Services’ complaints management processes.

Retention of information

Lutheran Services will retain personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless required by law.  When no longer required, personal information is deleted, de-identified or destroyed in a secure manner.

Consent, modifications and updates

Interaction of this policy with contracts

This policy is a compliance document prescribed by law rather than a legal contract between two or more persons.  However, certain contracts may incorporate all, or part, of this policy into the terms of that contract.  In such instances, Lutheran Services may incorporate the terms of this policy such that:

Acknowledgement

By using our website, making an enquiry or purchasing services from Lutheran Services, where you have been provided with a copy of this policy or had a copy of this policy reasonably available to you, you are acknowledging and agreeing:

Modifications and updates

Lutheran Services reserves the right to modify this policy as our business needs require.  We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website).   If you do not agree to our continued use of your personal information due to the changes in our policy, please cease providing us with your personal information and contact us using the contact details set out in this policy.

Definitions

Personal information: information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about you whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

This represents anything that might identify you, including but not limited to names, contact details, photos, and copies of identification documents such as driving license.

Australian Privacy Principles or APPs means the Australian Privacy Principles in Schedule 1 to the Privacy Act.

Authorised persons: each of the following is you:

  1. The individual the information relates to;
  2. Parent or legal guardian of you who is a minor or otherwise lacks legal capacity to make your own privacy decisions ;
  1. a person acting as the Executor of the individual’s Deceased Estate.

Agency: An entity contracted by or in agreement with Lutheran Services to provide services for the purposes of performance of one or more of Lutheran Services functions.

Cookies: small text files that a website creates on the user’s computer. These cookies usually contain information about the individual’s activities on the website including preferences and pages visited. Every time that individual visits, the website instructs the browser to read the file and implement the preferences.

Sensitive information:

  1. information or an opinion about an individual’s:
  2. racial or ethnic origin; or
  3. political opinions; or
  1. religious beliefs or affiliations; or
  2. philosophical beliefs; or
  3. membership of a professional or trade association; or
  1. health information about an individual; or
  2. genetic information about an individual that is not otherwise health information.

[1] Section 6 of the Privacy Act 1988 (Cth).