Web Based Privacy Policy
Introduction
Hobart City Council considers that an individual’s personal
information and privacy is a foundational expectation in our interactions with you
as a customer. This web based privacy policy
sets out how we collect, deal with and manage the personal information obtained
from your interactions with our web based IT solutions in accordance with the Personal
Information Protection Act 2004 (TAS) (“Act”).
Why have a Web Based Privacy Policy?
The Policy ensures that Council discloses the purpose and
use of information it collects about a person or their identity, where that
information is stored and/or used as part of its role as a public authority. The Council is defined in the Act as a public
authority and as a personal information custodian.
Personal Information Protection
Principles
Section 16 of the Act contains ten Personal Information
Protection Principles. Council uses
these principles to guide its decision making processes to ensure that it
complies with the Act and other legislation that impact upon our use, storage
and disclosure of personal information.
The Personal Information
Protection Principles are summarised as follows:
1. Collection
2. Use and disclosure
3. Data quality
4. Data security
5. Openness
6. Access and correction
7. Unique identifiers
8. Anonymity
9. Disclosure of information
outside Tasmania
10. Sensitive information
What does the Web Based Privacy
Policy Cover?
This Policy applies to all personal information about an
individual that is collected, stored, used or disclosed by Council through our
web based IT services or our website.
What personal information is
ordinarily collected through web based engagement?
When you use our web based services you are freely able to
browse our site without providing information about yourself, your demographic
or your views. However, if you wish to
engage further with our content, there are some distinct personal information attributes
that we identify and collect about you.
These include profile information, engagement information and usage
information.
Profile Information
This is
information we collect about you when you register to use our web site and engagement
tools and services. This includes your email address and additional demographic
information provided by you which may appear on the online registration form.
Engagement Information
This
relates to the content you create as part of your interactions with the website
or web based services. These can include responses to surveys, comments on
discussion forums, providing submissions, answering surveys or any of the other
engagement opportunities we may promote on the site.
By using the website and any other of our web based services you licence
the Council to use the Engagement Information you create for our own purposes. If we do use your information in a broader
context we will de-identify you wherever possible. Please see our Moderation Terms and
our Terms and Conditions tabs for more information.
Usage Information
Relates to
the information we collect about your specific usage of the website or our
engagement processes and may include information such as pages visited,
documents downloaded, surveys undertaken, forms completed, links selected or
could be metadata or cookies. We do this
principally to enhance the user experience and understand what information we
publish is of most use to our customer base.
Storage
Council will take all necessary steps to ensure that
personal information is stored safely and securely to protect it from misuse,
loss, and unauthorised modification and disclosure. This applies regardless of
the format in which the information is held.
Council stores information about its customers on our own IT systems and
servers, as well as in the Council document management system that we licence
from another provider. We may store
information in other locations based on our need or in compliance with other
software provider’s requirements. We use
external contractors to undertake other engagement processes for us including
the Hobart Your Say site.
From time to time, we may use survey or other information engagement sources
from third party organisations or on an adhoc basis. This may mean the data collected
online may be stored on servers located in another country which the Council
does not control. If you are clicking on
a link that is to another service provider, we encourage you to read their
privacy policy disclosure documents before proceeding. If you do not feel comfortable providing your
comments online or interacting with these providers, please reach out to our
staff and discuss your concerns with them and to find out if there are any
other options available for you to obtain the information you are seeking or engage
in the process or activity you wish to participate in.
How we use the information we
collect
We collect this information in order to:
- analyse and interpret it
to help meet our objectives and obligations;
- communicate information
to you about engagement opportunities, events and other initiatives
according to the topics and subjects you selected in the registration
process;
- to evaluate proposals
that the council is considering;
- to manage complaints and
information that help us with our regulatory roles and responsibilities
and our customer expectations; and
- to respond to enquiries
and effectively engage with our customers and stakeholders.
Anonymity
Where
it is lawful and practicable, Council will offer you the option of remaining
anonymous as part of a transaction, engagement or interaction with our services. Generally though, the use of our online
engagement tools requires you to complete the registration process which will
provide us with essential personal information to enable your account.
If anonymity is afforded to you, this may limit Council’s
ability to process a complaint or other matter. Council reserves the right to take no action
on any matter where you choose not to supply relevant personal information so
that it can perform its functions in accordance with legislation or the aims
and objectives of its engagement function.
Confidentiality
The City of
Hobart will treat your personal information in accordance with the Personal Information
Protection Act 2004 (Tas) and any other law that it is required to
comply with, including ones that require the maintaining and keeping of
registers, or the disclosure of information in the public interest. The Council is governed by the Right to
Information Act 2009 (Tas) (“RTI”).
That RTI legislation contains a number of tests to assess whether and in
what circumstances personal information should be disclosed. Prior to personal information being
disclosed, there are mechanisms that enable consultation with you and appeal
rights. The Council can however elect in
accordance with that RTI legislation to remove your personal information from
any submission, complaint or engagement and publish the remainder of the
information that you supply, without having to consult with you.
How we protect your personal
information
Council operates secure information technology networks and in
doing so, we take all reasonable measures using our best endeavours to prevent
unauthorised access to, or disclosure of, your personal information. While no online service can be guaranteed as
secure, the Council operates information technology platforms and firewalls and
conducts staff training and development to maximise our attempts to keep our
systems safe from phishing and other attempts to compromise or hack our
systems. Council uses a number of system security measures, virus protection
software systems and data storage systems within Australia, to protect your
personal and other identity information.
We do use your contact details in
a centralised system to enable the Council staff to interact with you and
respond to your requests, without the need for each inquiry requiring you to
register for a separate service.
For instance, you may request
Council to liaise with you about a matter that we are consulting about. Separately you may have a complaint about a
Council footpath, or a neighbour’s dog.
We create a centralised customer record, so that the staff can access
your contact details to respond to those matters. This also allows us a centralised point to
update your contact information without the need for you to write to each
relevant department of Council. However
there are some instances governed by law where you need to make a specific
written request to change specific details, for instance requesting a change to
property or companion animal ownership details. This means that there is less
duplication and more robust protections of your personal information.
Access to and correction of, your
personal information
Council will endeavour to maintain the personal information
it holds about you as accurate, complete and up to date.
Wherever possible, Council will append and/or update any new
personal information you provide to your existing customer record to assist in
keeping your customer record complete and up to date.
There are some circumstances where you must request in
writing for this to occur, such as amending details about your property and
rates ownership, permit details, leases, licences and tenancy information, companion
animal ownership, debtor account details or other specific matters that Council
interacts with you about, where we have a regulatory obligation to know who we
are dealing with.
You may request that Council amend
any personal information you have supplied to it, including:
- to access your personal
data to rectify any inaccuracies within that personal data; or
- to request for the
erasure of your personal data residing with us, subject to the Archives
Act 1983 (Tas) and the Right to Information Act 2009 (Tas);
There may be other circumstances
where you can request that we amend, alter, withhold or erase your personal
information which can be obtained through our Privacy Policy or by contacting
the Council on coh@hobartcity.com.au
If you wish to contact us to with
a request relating to personal information we hold about you, please email us
at coh@hobartcity.com.au including
your name and contact details. We may need to verify your identity before
providing you with your personal information.
In some cases, we may be unable to
provide you with access to all of your personal information and where this
occurs, we will explain why.
What information is disclosed
Hobart City Council will not use or disclose your personal
information other than for the primary purpose for which it was collected
unless one of the following apply:
(a)
we have your consent to disclose all or some of the
information;
(b)
we have a related secondary purpose that you have been
made aware of or you would reasonably expect would occur;
(c)
as required or permitted by the Act or any other
legislation;
(d)
to other departments within the Council to respond to
your inquiries or deal with you personally;
(e)
in accordance with the Right to Information Act 2009
(TAS) which overrides the Act and other protections afforded to you through
another assessment process contained within that law;
(f)
by adding your name and contact details to our
centralised customer record system so that we can respond to other matters or
dealings with you including waste inquiries, parking permits, pet
registrations, community services such as library, pool, gym, sports and
recreational programs, tourist information and kunanyi/Mt Wellington mountain information,
community based support programs, youth engagement, festivals and events, etc.
Written submissions to Council
and Committee meetings
Personal information provided by you as part of a public
submission (name, email address, property address, etc.) to a Council or
committee meeting may be included with the published agenda papers and minutes
of the meeting, which are displayed online and are available in hardcopy format
for an indefinite period. If we collect
responses to an engagement or survey, those responses may be published without
further notice to you.
If you are uncertain about how
your information will be dealt with, you should contact the Council at coh@hobartcity.com.au.
Council will not request sensitive
personal information about you including requesting you to provide your identity
information or health information in order to participate in a submission or
engagement process. We may require this
information if you want us to amend, delete or withhold information about you
that may otherwise be publicly available.
Contracted service providers
Council outsources some of its functions to third parties (“Contractors”)
who perform various services for and on behalf of the Council. Council may disclose personal information it
has collected about an individual to the Contractor, where it is necessary for
the Contractor to carry out a specific job or task. For example, personal
information is passed on to a Contractor by Council for the purposes of a waste
kerbside collection service. Information provided to these Contractors is
limited to the information required by them to provide the services to you on
behalf of Council (including responding to any complaint you have made).
Council has an expectation of our Contractors
(including consultants and service providers) to apply the same level or
personal information protection to customer information as the Council
implements. To assist with compliance
the Contractor is alerted to our expectations and our privacy policy.
Our staff are afforded specific
training relating to their dealings with personal information and there is an
expectation of confidentiality from our volunteers and work experience persons.
Elected Members are subject to an
Elected Members Code of Conduct which also regulates what they do with Council
held information.
When dealing with web based
services, particularly those that we use to survey or glean your comments on
programs and proposals, the Council sometimes engages Contractors to assemble,
assess, research, compile, collate, de-identify, document trends or other targeted
uses for the information gathered. By
using our web based services, you are taken to licence Council to deal with
your personal information and commentary through these means in order to
conduct our business.
External links
From time to time the City of Hobart website and our other
web based solutions may contain links to other third party websites. This may
be because those linked services are providing specific services to the Council
in relation to the matter you are engaging with, or because they have more
specific detail about a proposal or are conducting engagement work on our
behalf. There are also times where we
have other reasons why we want to share links with you. We do not hold out an endorsement for any
third party website, simply because we provide a link to it.
The links provided are for
convenience and may not remain current or be maintained. We are not responsible
for the privacy practices of linked websites and we suggest you review the
privacy policies of those websites before using them.
The Council is also not endorsing
any linked provider and if you prefer to engage with Council in a different
way, please email us on coh@hobartcity.com.au
Contact Us
For further information about our web based privacy policy,
to obtain further information about our Council wide privacy policy and related
information practices, or to access or correct your personal information, or to
make a complaint, please contact us on coh@hobartcity.com.au
