When you share information with the Summer Foundation, it’s important that you know how we may use it.

This Privacy Policy talks about what types of information we collect and the ways we may use that information.

If you have any questions about how we will use your information, ask the Summer Foundation team member you are working with to explain it to you. If you have any questions about the Privacy Policy below, please give us a call on 1300 626 560 or email privacy@summerfoundation.org.au.

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/, https://www.housinghub.org.au/,https://www.buildingbetterhomes.org.au/ and https://www.downto10days.org.au/ (Sites).  The types of information we collect when you engage with us across our various platforms is outlined below:

The Housing Hub

We will collect information about your gender and living arrangements via this website. With your consent, we may collect sensitive information including health information such as disability and accessibility needs information where it is relevant to providing you with the most suitable housing options. We will also collect information on your housing needs and preferences.

Tenancy Matching Service

Through this service, with your consent, we may collect sensitive information including health reports, hospital discharge summaries, NDIS plans and numbers, and information about individual support, health needs, family situation, current living situation and health plans, and information on criminal history, where required and lawful.

If you engage with the Tenancy Matching Service we collect this information for these reasons:

• to determine whether you are, or will be, eligible for SDA housing;
• to form an accurate and comprehensive understanding of your health and life needs and to determine whether the SDA housing you have applied for meets your needs;
• to assess your compatibility with residents already residing in, or applying to reside in, the housing you have applied for;
• to provide the sensitive information to Housing Providers where this is reasonably necessary for them to process your application; and
• to provide the sensitive information, either directly or through Housing Providers, Support Providers or other Professionals you tell us about where this is reasonably necessary for them to assess your health and life needs.

Support Coordination Service

Through this service, with your consent, we may collect sensitive information including health reports, hospital discharge summaries, NDIS plans and numbers, and information about individual support, health needs, family situation, current living situation and health plans and information on criminal history, where required and lawful.

If you engage with the Support Coordination Service we collect this information for these reasons:

• to determine whether you are, or will be, eligible for NDIS home and living support funding;
• to develop plans and reports to support your application for funding from the NDIS;
• to submit requests for funding on your behalf to the NDIA for inclusion in your NDIS Plan;
• to assess your compatibility with residents already residing in, or applying to reside in, the housing you have applied for;
• to provide the sensitive information to Housing Providers where this is reasonably necessary for them to process your application; and
• to provide the sensitive information, either directly or through Housing Providers, Support Providers or other Professionals you tell us about where this is reasonably necessary for them to assess your health and life needs.

UpSkill

Through this program, the UpSkill Community of Practice, the UpSkill Directory and UpSkill training, we will collect your name, organisation name, role type, contact information including address, email address and telephone number and demographic information such as your gender and nationality. We will collect other personal information that you submit to us on the UpSkill Directory including a description of your skills and experience. 

Summer Foundation Research

Through our research program, 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.

Housing Brokerage Service

Through this service,  with your consent, we may collect sensitive information, including information relating to health, disability and functional abilities where this information is relevant to the services we are providing.

Lived Experience team

Through this 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.

Policy team

We may collect direct quotes, photographs and videos of you when you engage with this team. 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.

Building Better Homes campaign

Through this campaign we will collect your name and contact details.  With your consent we may collect direct quotes, photographs and videos of you. 

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

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

Down to 10 Days campaign

Through this 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.

Applying for a position with us

We collect information from you when you complete the online application form, as well as at other stages during the selection process. We require this information to consider your application within our organisation and to assist in advising you of your progress with your application

If your application is successful, we will retain your information as part of your employment records. If your application is unsuccessful, we may retain your information on file and may contact you if a suitable employment opportunity arises or if there are other positions available that may be of interest to you.

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 an allied health professional;
• 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
• 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.

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.

3. 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:

• Assist you conveniently and easily accessing the services that we offer and provide, including the services listed above
• Contact you for research purposes and to organise events or services
• Conduct research
• Form and maintain research partnerships and housing partner relationships;
• Internal record keeping
• Periodically send communications about information which we consider that you may find interesting
• Make policy submissions
• Allocate resources
• Develop and roll out programs
• Consider your application for an employment opportunity within our organisation

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

• Assist you conveniently and easily access 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

If you engage with the Tenancy Matching Service:

• to determine whether you are, or will be, eligible for SDA housing;
• to form an accurate and comprehensive understanding of your health and life needs and to determine whether the SDA housing you have applied for meets your needs;
• to assess your compatibility with residents already residing in, or applying to reside in, the housing you have applied for;
• to provide the sensitive information to Housing Providers where this is reasonably necessary for them to process your application; and
• to provide the sensitive information, either directly or through Housing Providers, to Third-Party Support Organisations and Professionals you tell us about where this is reasonably necessary for them to assess your health and life needs; and 

If you engage the Support Coordination Service:

• to determine whether you are, or will be, eligible for NDIS home and living support funding;
• To prepare and submit plans and reports on your behalf to apply for home and living funding from the NDIS.

4. 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 Hosting Network, Microsoft 365, Google Workspace, Marketcircle, Mailchimp, Salesforce, Facebook, DigitalOcean, Monday.com, Formstack, Amazon Web Services, Sync.com, LearnWorlds, Slack, Trello, Smartsheet, Adobe, TryBooking, ELMO and Zoom
• 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 we will provide your sensitive information to Housing Providers where this is reasonably necessary for them to process your application and we will provide your sensitive information, either directly or through Housing Providers, to Support Providers and other professionals you tell us about where this is reasonably necessary for them to assess your health and life needs.
• If you engage with the Support Coordination Service, to the NDIA and professionals who can help support your applications for home and living funding;
• 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
• Entities established to help identify illegal activities and prevent fraud where authorised by law
• If you are applying for a position with the organisation we may disclose the information you provide to referees, related companies, recruitment agencies, and other organisations who perform services on our behalf.

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.

5. 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 the user’s needs. We only use this information for statistical analysis purposes. There is a Facebook tracking pixel on the Summer Foundation website which may be used for marketing purposes however, personal details are not shared with Facebook or any other third parties, unless users are explicitly notified.

Overall, cookies help us provide you with better experience when using our websites 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.

6. 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.

7. 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.

8. 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.

9. 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.

10. Disclosure to overseas recipients

We may disclose personal information to third parties like technical support writers and communication distributors located in Singapore, Canada, 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.

11. 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.

12. 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: privacy@summerfoundation.org.au Address: PO Box 208, Blackburn Victoria 3130

• First published on 18 March 2019
• Revised 20 November 2020
• Revised 21 June 2021
• Revised 19 July 2021
• Revised 30 September 2021
• Revised 15 March 2022
• Updated 01 April 2022