Privacy Policy
Purpose
SHE HR Consulting (or “the Organisation”) is committed to protecting the privacy of the
information which the organisation collects, holds and administers.
Scope
This Policy applies to all SHE HR Consulting employees (including temporary, permanent
and contract), volunteers, contractors, consultants and visitors. This policy applies to any
location where duties are performed by individuals undertaking activities associated with the
SHE HR Consulting.
Policy
The SHE HR Consulting collects and administers a range of information to support the
growth and development of the Australian Foyer Movement. The Organisation is committed
to protecting the privacy of the individuals whose information it collects, holds and
administers.
The SHE HR Consulting recognises the essential right of individuals to have their
information administered in ways which they would reasonably expect – protected on one
hand, and made accessible to them on the other. The Privacy Act 1988 (Privacy Act)
regulates the handling, holding, use, access and collection of personal information (including
sensitive information) about individuals. The SHE HR Consulting takes its obligations under
the Privacy Act seriously when handling all personal information, including sensitive
information about employees.
1.Responsibilities
1.1 Executive Director Responsibilities
● SHE HR Consulting’s Executive is responsible for developing, adopting and
reviewing this policy, ensuring it aligns with overall strategic direction and the
Organisation’s vision and goals;
● overseeing the development, implementation and enforcement of this policy;
● ensuring compliance with legal and regulatory standards; and
● monitoring changes in privacy legislation, and for advising on the need to review or
revise this policy when the need arises.
1.2 Manager Responsibilities
● Implementing and enforcing this policy within their team;
● ensuring team members understand and adhere to this policy;
● provide guidance and clarification on this policy to team;
● monitor and manage compliance with this policy in daily operations;
● address any policy violations and where necessary, report up to the CEO; and
● contribute to the policy review and provide feedback based on team and operational
insights.
1.3 Employee Responsibilities
● Ensure an understanding of all company policies relevant to their role and as a
member of the organisation;
● seek clarification on this policy when needed;
● comply with the standards outlined in this policy;
● report any policy violations or concerns to their Direct Manager or the Executive
Director;
● participate in policy training and updates as required; and
● contribute to a safe and respectful work environment in line with all company policies,
including this policy.
2.Privacy Principles
SHE HR Consulting is bound by laws which impose specific obligations when it comes to
handling information. The Organisation has adopted the following principles contained as
minimum standards in relation to handling personal information.
● collect only information which the organisation requires for its primary function;
● ensure that individuals are informed as to why we collect the information and how
we administer the information gathered;
● use and disclose personal information only for our primary functions or a directly
related purpose, or for another purpose with the person’s consent;
● store personal information securely, protecting it from unauthorised access;
● provide individuals with access to their own information, and the right to seek its
correction; and
● take reasonable steps to ensure the information SHE HR Consulting collects is
accurate, complete, up to date, and relevant to the functions we perform.
3.Collection of Information
SHE HR Consulting will only collect information by lawful and fair means, directly from
interactions with the individual whom the personal, sensitive or health information relates
to. In some cases, where it is unreasonable or impracticable to obtain personal information
directly from an individual, SHE HR Consulting will seek to obtain it from a publicly
available source or a third party.
3.1 Unsolicited Information
When unsolicited information is received, SHE HR Consulting will determine whether the
personal information could have been collected in alignment with correct legislative
practice, and then if it could have, it will be treated normally. If it could not have been, it
must be destroyed, and the person whose personal information has been destroyed will be
notified about the receipt and destruction of their personal information.
3.2 Personal Information
In addition to only collecting information that is necessary for the needs of SHE HR
Consulting’s primary purpose, the organisation will also:
● notify individuals about why we collect the information and how it is administered;
● collect personal information from the person themselves wherever possible; and
● if collecting personal information from a third party, be able to advise the person
whom the information concerns, from whom their personal information has been
collected.
3.3 Sensitive Information
SHE HR Consulting will collect sensitive information only with the person’s consent or if
required by law.
SHE HR Consulting will also collect sensitive information about an individual if such
collection is necessary to prevent or lessen a serious and imminent threat to the life or
health of any individual, where the individual whom the information concerns:
● is physically or legally incapable of giving consent to the collection; or
● physically cannot communicate consent to the collection.
3.4 Health Information
SHE HR Consulting will collect health information about an individual if:
● the information is necessary to provide a health service to the individual; and
● the information is collected as required or authorised by or under law and in
accordance with rules established by competent health or medical bodies that deal
with obligations of professional confidentiality which bind the organisation.
4.Use and Disclosure
SHE HR Consulting will only use or disclose information for the primary purpose for which
it was collected or a directly related secondary purpose. For other uses, SHE HR
Consulting will obtain consent from the affected person.
4.1 Secondary Purpose
In relation to a secondary purpose, use or disclosure of the personal information will occur
only where:
● there is a direct relation to the primary purpose and the individual would reasonably
have expected us to use it for purposes;
● the person has consented; or
● certain other legal reasons exist, or disclosure is required to prevent serious and
imminent threat to life, health or safety.
4.2 Direct Marketing
In relation to personal information which has been collected from a person, SHE HR
Consulting will use the personal information for direct marketing, where the reasonable
person would expect it to be used for this purpose, and SHE HR Consulting has provided
an opt out and the opt out has not been taken up.
If personal information has been collected other than from the person themselves, SHE
HR Consulting will only use the personal information for direct marketing if the person
whose personal information has been collected has consented (and they have not taken
up the opt-out).
If the disclosure of sensitive information is necessary for research or the compilation or
analysis of statistics relevant to public health or public safety and it is impracticable for
SHE HR Consulting to seek the individual’s consent before the use or disclosure and the
use or disclosure is conducted in accordance with guidelines approved by the
Commissioner under section 95A, the organisation may make such a disclosure.
4.3 Unlawful Activity
If SHE HR Consulting has sufficient reasons to believe that an unlawful activity has been,
is being or may be engaged in, and the disclosure of personal information becomes a
necessary part of its investigation of the matter or in reporting its concerns to relevant
persons or authorities, the organisation may make such disclosures.
SHE HR Consulting may further disclose personal information if its disclosure is mandated
by an enforcement body or is required for the following:
● the prevention, detection, investigation, prosecution or punishment of criminal
offences, breaches of a law imposing a penalty or sanction or breaches of a
prescribed law;
● the enforcement of laws relating to the confiscation of the proceeds of crime;
● the protection of the public revenue;
● the prevention, detection, investigation or remedying of seriously improper conduct
or prescribed conduct; or
● the preparation for, or conduct of, proceedings before any court or tribunal, or
implementation of the orders of a court or tribunal.
4.4 Storage of Information
SHE HR Consulting takes reasonable steps to protect information from misuse and loss,
and from unauthorised access, modification and disclosure. These steps include but are
not limited to:
● undertaking training and providing direction to all SHE HR Consulting employees
who handle this information;
● entering information into a customised, secure database, which is accessed on a
‘need-only basis’ and is handled in a sensitive and secure way;
● destroying or de-identifying personal, sensitive or health information when SHE HR
Consulting no longer requires the information for business purposes; or
● archiving financial information in a secure location in accordance with the
requirements of the Australian Taxation Office.
5. Access and Correction
SHE HR Consulting takes reasonable steps to ensure that the personal information it
collects, holds and uses is accurate, up-to-date and complete. SHE HR Consulting
understands individuals have a right to seek access to information held about them and to correct it if inaccurate, incomplete, misleading or not up to date.
Therefore if an individual and SHE HR Consulting disagree about whether the information
is accurate, complete and up to date, and the individual asks SHE HR Consulting to
associate with the information a statement claiming that the information is not accurate,
complete or up to date, SHE HR Consulting will take reasonable steps to do so.
5.1 Withhold Access of Information
SHE HR Consulting can withhold the access of an individual to their information if:
● providing access would pose a serious and imminent threat to the life or health of
any individual; or
● providing access would have an unreasonable impact upon the privacy of other
individuals; or
● the request for access is frivolous or vexatious; or
● the information relates to existing or anticipated legal proceedings between the
organisation and the individual, and the information would not be accessible by the
process of discovery in those proceedings; or
● providing access would reveal the intentions of the organisation in relation to
negotiations with the individual in such a way as to prejudice those negotiations; or
● providing access would be unlawful; or
● providing access would be likely to prejudice an investigation of possible unlawful
activity; or
● an enforcement body performing a lawful security function asks SHE HR
Consulting not to provide access to the information on the basis that providing
access would be likely to cause damage to the security of Australia.
Where providing access would reveal evaluative information generated within the
organisation in connection with a commercially sensitive decision making process, SHE
HR Consulting may give the individual an explanation for the commercially sensitive
decision rather than direct access to the information. SHE HR Consulting will provide to
the individual its reasons for denial of access or a refusal to correct personal information.
6. Summary
All stakeholders associated with the SHE HR Consulting must take their obligations under
the Privacy Act seriously. This means handling any and all personal information in
accordance with the Privacy Act and this policy. Breaches of this policy are taken seriously
and disciplinary action, including but not limited to termination, may be taken for such
breaches.
If you are an employee and have any questions about this policy or would like further
information, please contact the Executive Director.
If you are external to the organisation and have any questions or concerns about the way
in which we have handled your personal information, or if you believe that we have not
complied with our obligations under the Privacy Act, please contact
7. Review
Our Privacy Policy is subject to review every two years. This review assesses the policy's
effectiveness, relevance, and compliance with current employment laws and employee
feedback. Any necessary changes will be promptly communicated to all staff.
Definitions
Health Information
Includes all personal information relating to an individual’s physical or
mental health, disability or services provided to them to support them in
managing their health.
Personal Information
Includes 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 information or opinion about an individual's racial or ethnic origin,
political opinion, religious beliefs, sexual orientation or criminal record,
provided the information or opinion otherwise meets the definition of
personal information.
Unsolicited Information
Includes information that has been received by the organisation where the
organisation has taken no active steps to collect the information.
Privacy Policy
Purpose
SHE HR Consulting (or “the Organisation”) is committed to protecting the privacy of the
information which the organisation collects, holds and administers.
Scope
This Policy applies to all SHE HR Consulting employees (including temporary, permanent
and contract), volunteers, contractors, consultants and visitors. This policy applies to any
location where duties are performed by individuals undertaking activities associated with the SHE HR Consulting.
Policy
The SHE HR Consulting collects and administers a range of information to support the growth and development of the Australian Foyer Movement. The Organisation is committed to protecting the privacy of the individuals whose information it collects, holds and
administers.
The SHE HR Consulting recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – protected on one hand, and made accessible to them on the other. The Privacy Act 1988 (Privacy Act) regulates the handling, holding, use, access and collection of personal information (including sensitive information) about individuals. The SHE HR Consulting takes its obligations under the Privacy Act seriously when handling all personal information, including sensitive information about employees.
1.Responsibilities
1.1 Executive Director Responsibilities
● SHE HR Consulting’s Executive is responsible for developing, adopting and
reviewing this policy, ensuring it aligns with overall strategic direction and the
Organisation’s vision and goals;
● overseeing the development, implementation and enforcement of this policy;
● ensuring compliance with legal and regulatory standards; and
● monitoring changes in privacy legislation, and for advising on the need to review or
revise this policy when the need arises.
1.2 Manager Responsibilities
● Implementing and enforcing this policy within their team;
● ensuring team members understand and adhere to this policy;
● provide guidance and clarification on this policy to team;
● monitor and manage compliance with this policy in daily operations;
● address any policy violations and where necessary, report up to the CEO; and
● contribute to the policy review and provide feedback based on team and operational
insights.
1.3 Employee Responsibilities
● Ensure an understanding of all company policies relevant to their role and as a
member of the organisation;
● seek clarification on this policy when needed;
● comply with the standards outlined in this policy;
● report any policy violations or concerns to their Direct Manager or the Executive
Director;
● participate in policy training and updates as required; and
● contribute to a safe and respectful work environment in line with all company policies,
including this policy.
2.Privacy Principles
SHE HR Consulting is bound by laws which impose specific obligations when it comes to
handling information. The Organisation has adopted the following principles contained as
minimum standards in relation to handling personal information:
● collect only information which the organisation requires for its primary function;
● ensure that individuals are informed as to why we collect the information and how
we administer the information gathered;
● use and disclose personal information only for our primary functions or a directly
related purpose, or for another purpose with the person’s consent;
● store personal information securely, protecting it from unauthorised access;
● provide individuals with access to their own information, and the right to seek its
correction; and
● take reasonable steps to ensure the information SHE HR Consulting collects is
accurate, complete, up to date, and relevant to the functions we perform.
3.Collection of Information
SHE HR Consulting will only collect information by lawful and fair means, directly from
interactions with the individual whom the personal, sensitive or health information relates
to. In some cases, where it is unreasonable or impracticable to obtain personal information
directly from an individual, SHE HR Consulting will seek to obtain it from a publicly
available source or a third party.
3.1 Unsolicited Information
When unsolicited information is received, SHE HR Consulting will determine whether the
personal information could have been collected in alignment with correct legislative practice, and then if it could have, it will be treated normally. If it could not have been, it must be destroyed, and the person whose personal information has been destroyed will be notified about the receipt and destruction of their personal information.
3.2 Personal Information
In addition to only collecting information that is necessary for the needs of SHE HR
Consulting’s primary purpose, the organisation will also:
● notify individuals about why we collect the information and how it is administered;
● collect personal information from the person themselves wherever possible; and
● if collecting personal information from a third party, be able to advise the person
whom the information concerns, from whom their personal information has been
collected.
3.3 Sensitive Information
SHE HR Consulting will collect sensitive information only with the person’s consent or if
required by law.
SHE HR Consulting will also collect sensitive information about an individual if such
collection is necessary to prevent or lessen a serious and imminent threat to the life or
health of any individual, where the individual whom the information concerns:
● is physically or legally incapable of giving consent to the collection; or
● physically cannot communicate consent to the collection.
3.4 Health Information
SHE HR Consulting will collect health information about an individual if:
● the information is necessary to provide a health service to the individual; and
● the information is collected as required or authorised by or under law and in
accordance with rules established by competent health or medical bodies that deal
with obligations of professional confidentiality which bind the organisation.
4.Use and Disclosure
SHE HR Consulting will only use or disclose information for the primary purpose for which
it was collected or a directly related secondary purpose. For other uses, SHE HR Consulting will obtain consent from the affected person.
4.1 Secondary Purpose
In relation to a secondary purpose, use or disclosure of the personal information will occur
only where:
● there is a direct relation to the primary purpose and the individual would reasonably
have expected us to use it for purposes;
● the person has consented; or
● certain other legal reasons exist, or disclosure is required to prevent serious and
imminent threat to life, health or safety.
4.2 Direct Marketing
In relation to personal information which has been collected from a person, SHE HR
Consulting will use the personal information for direct marketing, where the reasonable person would expect it to be used for this purpose, and SHE HR Consulting has provided an opt out and the opt out has not been taken up.
If personal information has been collected other than from the person themselves, SHE HR Consulting will only use the personal information for direct marketing if the person whose personal information has been collected has consented (and they have not taken up the opt-out).
If the disclosure of sensitive information is necessary for research or the compilation or
analysis of statistics relevant to public health or public safety and it is impracticable for SHE HR Consulting to seek the individual’s consent before the use or disclosure and the use or disclosure is conducted in accordance with guidelines approved by the Commissioner under section 95A, the organisation may make such a disclosure.
4.3 Unlawful Activity
If SHE HR Consulting has sufficient reasons to believe that an unlawful activity has been, is being or may be engaged in, and the disclosure of personal information becomes a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities, the organisation may make such disclosures.
SHE HR Consulting may further disclose personal information if its disclosure is mandated
by an enforcement body or is required for the following:
● the prevention, detection, investigation, prosecution or punishment of criminal
offences, breaches of a law imposing a penalty or sanction or breaches of a
prescribed law;
● the enforcement of laws relating to the confiscation of the proceeds of crime;
● the protection of the public revenue;
● the prevention, detection, investigation or remedying of seriously improper conduct
or prescribed conduct; or
● the preparation for, or conduct of, proceedings before any court or tribunal, or
implementation of the orders of a court or tribunal.
4.4 Storage of Information
SHE HR Consulting takes reasonable steps to protect information from misuse and loss,
and from unauthorised access, modification and disclosure. These steps include but are
not limited to:
● undertaking training and providing direction to all SHE HR Consulting employees
who handle this information;
● entering information into a customised, secure database, which is accessed on a
‘need-only basis’ and is handled in a sensitive and secure way;
● destroying or de-identifying personal, sensitive or health information when SHE HR
Consulting no longer requires the information for business purposes; or
● archiving financial information in a secure location in accordance with the
requirements of the Australian Taxation Office.
5. Access and Correction
SHE HR Consulting takes reasonable steps to ensure that the personal information it
collects, holds and uses is accurate, up-to-date and complete. SHE HR Consulting understands individuals have a right to seek access to information held about them and to correct it if inaccurate, incomplete, misleading or not up to date.
Therefore if an individual and SHE HR Consulting disagree about whether the information
is accurate, complete and up to date, and the individual asks SHE HR Consulting to associate with the information a statement claiming that the information is not accurate, complete or up to date, SHE HR Consulting will take reasonable steps to do so.
5.1 Withhold Access of Information
SHE HR Consulting can withhold the access of an individual to their information if:
● providing access would pose a serious and imminent threat to the life or health of
any individual; or
● providing access would have an unreasonable impact upon the privacy of other
individuals; or
● the request for access is frivolous or vexatious; or
● the information relates to existing or anticipated legal proceedings between the
organisation and the individual, and the information would not be accessible by the
process of discovery in those proceedings; or
● providing access would reveal the intentions of the organisation in relation to
negotiations with the individual in such a way as to prejudice those negotiations; or
● providing access would be unlawful; or
● providing access would be likely to prejudice an investigation of possible unlawful
activity; or
● an enforcement body performing a lawful security function asks SHE HR
Consulting not to provide access to the information on the basis that providing
access would be likely to cause damage to the security of Australia.
Where providing access would reveal evaluative information generated within the
organisation in connection with a commercially sensitive decision making process, SHE
HR Consulting may give the individual an explanation for the commercially sensitive
decision rather than direct access to the information. SHE HR Consulting will provide to
the individual its reasons for denial of access or a refusal to correct personal information.
6. Summary
All stakeholders associated with the SHE HR Consulting must take their obligations under
the Privacy Act seriously. This means handling any and all personal information in
accordance with the Privacy Act and this policy. Breaches of this policy are taken seriously
and disciplinary action, including but not limited to termination, may be taken for such
breaches.
If you are an employee and have any questions about this policy or would like further
information, please contact the Executive Director.
If you are external to the organisation and have any questions or concerns about the way
in which we have handled your personal information, or if you believe that we have not
complied with our obligations under the Privacy Act, please contact
7. Review
Our Privacy Policy is subject to review every two years. This review assesses the policy's
effectiveness, relevance, and compliance with current employment laws and employee
feedback. Any necessary changes will be promptly communicated to all staff.
Definitions
Health Information
Includes all personal information relating to an individual’s physical or
mental health, disability or services provided to them to support them in
managing their health.
Personal Information
Includes 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 information or opinion about an individual's racial or ethnic origin,
political opinion, religious beliefs, sexual orientation or criminal record,
provided the information or opinion otherwise meets the definition of
personal information.
Unsolicited Information
Includes information that has been received by the organisation where the
organisation has taken no active steps to collect the information.
SHE HR Consulting is an independent consultancy based in Naarm (Melbourne), Australia. We help our clients feel supported, informed, and protected by our services, adding value to their business or individual circumstances. SHE HR Consulting acknowledges the Wurundjeri Woi Wurrung people as the Traditional Owners of the lands on which our business is based. We acknowledge all First Nations groups on the sovereign and unceded lands of Australia and pay our respects to their Elders past and present. We recognise all First Nations peoples around the world, whose continuing connection to land, water, and culture we all benefit from.
© Copyright 2025. SHE HR Consulting. All Rights Reserved.
SHE HR Consulting is a safe space
for all LGBTQIA+ people.
SHE HR Consulting is an independent consultancy based in Naarm (Melbourne), Australia. We help our clients feel supported, informed, and protected by our services, adding value to their business or individual circumstances. SHE HR Consulting acknowledges the Wurundjeri Woi Wurrung people as the Traditional Owners of the lands on which our business is based. We acknowledge all First Nations groups on the sovereign and unceded lands of Australia and pay our respects to their Elders past and present. We recognise all First Nations peoples around the world, whose continuing connection to land, water, and culture we all benefit from.
Privacy Policy | © Copyright 2025 SHE HR Consulting All Rights Reserved