1. About this policy

Lifeline Australia ABN 84 081 031 263 (Lifeline, we, us, our) is bound by laws governing its collection and use of personal information, including the Privacy Act 1988 (Cth) (Privacy Act) which includes the Australian Privacy Principles (APPs) and State and Territory health records laws, such as the Health Records Act 2001 (Vic) and the Health Records and Information Privacy Act 2002 (NSW) (HRIP Act) as applicable. This Privacy Policy outlines how Lifeline Australia use, share, protect and store personal information collected.

Lifeline is the company established to support the organisation, establishment, development and operation of Lifeline National Services and Lifeline Centres throughout Australia and is a Registered Training Organisation (RTO) (RTO No. 88036). Lifeline develops and conducts programs, projects and initiatives to enable people to overcome isolation and cope with problems and crisis affecting mental health, wellbeing, life and safety. 

Lifeline National Services include crisis support services delivered by phone (on 13 11 14, 13 YARN and 13 HELP), by text (on 0477 13 11 14) and online chat (at Lifeline Crisis Online Chat Service); counselling services through MensLine Australia, Regional Access, the Suicide Call Back Service, and SuicideLine Victoria; DV-Alert training; and any other Australia-wide services provided by Lifeline Australia and Lifeline Centres. 

Any services previously provided by Lifeline are covered under the applicable privacy policy at the time the service was offered. 

Lifeline Australia works collaboratively with Lifeline Members who are crucial partners in the delivery of Lifeline National Services from their Lifeline Centres located in every state and territory across Australia, forming the national Lifeline Member network. The Lifeline Members are separate legal entities to Lifeline Australia. 

This Privacy Policy applies to the activities (described in more detail below) undertaken by Lifeline Australia to carry out Lifeline Australia’s objectives. This Privacy Policy does not apply to Lifeline Members also involved in the delivery of Lifeline National Services. Lifeline Member organisations have their own privacy policies which you can locate on their websites.

Lifeline Australia will update this Privacy Policy when our information handling practices, our services or applicable laws change, or to explain our practices further. Updates will be published on the Lifeline Australia website and are effective from the date of publication.

Lifeline Australia also publishes collection statements to address specific contexts in which personal information may be collected, held, used, and disclosed. If any provision in a collection statement conflict with this Privacy Policy, the provision in the collection statement will take precedence to the extent of any conflict, but this Privacy Policy will apply in all other respects. The current collection statements are:

• Privacy Collection Statement for Crisis Support Services
• Privacy Collection Statement for Counselling Services
• Privacy Collection Statement for Beyond Now
• Privacy Collection Statement for Donors and Supporters

2. Scope of this policy

This policy applies to Lifeline Australia's handling of 'personal information' it collects and holds which is broadly defined in and has the same meaning as defined under section 6 of the Privacy Act:

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.

This policy also refers to 'sensitive information’, which is a subset of personal information. Sensitive information includes information or an opinion about racial or ethnic origin, political opinions, philosophical or religious beliefs and affiliations, sexual orientation, health or genetic information, and criminal record.

3. Confidentiality and anonymity

Lifeline Australia is a confidential service, however, records of interactions with our services are retained as health information in accordance with the HRIP Act. Depending on the Lifeline services you engage with and how you engage with them, you may be able to take steps to interact anonymously. 

Lifeline collects personal information where it is reasonably necessary for one or more of our functions or activities, including to provide crisis support and related services, respond to enquiries, ensure the safety and quality of our services, and meet our legal and regulatory obligations. 

When you contact us, we collect the personal information made available to us during your interaction, including technical information such as your phone number (unless you turn off your Caller ID before calling), approximate location, your IP address (for web-based services), information about your use of our services and donor/fundraising information. We will only collect sensitive information as permitted under the Privacy Act 1988 (Cth) or another applicable law.

Services and Anonymity: 

Crisis Support calls will be recorded and retained as health information in accordance with the HRIP Act. You can opt out of audio recording by pressing 1 when prompted or by advising your Crisis Supporter at any time during the call. Recordings can also be held anonymously if a caller turns off their Caller ID before calling and does not provide their name or identifying details during the call. 

Text and webchat interactions will be recorded and retained as health information in accordance with the HRIP Act; you cannot opt-out of this recording. These recordings will include your telephone number (Text) and/or your IP address (webchat) and information provided during your interaction. 

Counselling Services will be recorded and retained as health information in accordance with the HRIP Act. These recordings will include your telephone number and information you provide during your interaction. You cannot opt-out of these recordings. 

Donations and Fundraising personal and financial information will be collected, used and stored for the purpose of processing donations; facilitating participation in fundraising activities; communicating with you about donations, fundraising and updates on Lifeline’s activities; conducting market research and surveys; and engaging in promotional activities. This may involve sharing some of your personal information to third parties such as direct marketing, consulting and research organisations (who may use artificial intelligence (AI) tools), and obtaining personal information from third parties such as marketing list sellers, consultants and research organisations. In all cases, we will manage your personal information in accordance with the Privacy Act and any other relevant legislation.  

Registered Training Organisation records cannot be anonymous for this function as the purpose relates to learners, training and assessment activities. Personal information will be collected, used and retained in accordance with applicable legislation and regulatory requirements such as the National Vocational Education and Training Regulatory Act 2011 (Cth), Standards for Registered Training Organisations 2025 and the Privacy Act. 

Employee & Volunteer records are maintained as identifiable personal information in all cases. Lifeline collects, uses and stores this identifiable personal information for the purposes associated with recruitment, employment, engagement, remuneration, training, performance management, staff engagement and wellbeing research, workplace health and safety, monitoring of compliance with policies and codes of conduct, and investigations and disciplinary action. These records will be collected, used and retained in accordance with applicable legislation, regulatory requirements and Lifeline policies and procedures. Personal information may be shared with third parties for the purposes of recruitment and onboarding, investigations, monitoring of technology use, and measuring and analysing staff engagement and wellbeing, among other purposes. 

We may use or disclose personal information where reasonably necessary for the purposes described above, to service providers who assist us in delivering our services or conducting our organisation’s operations, and where required or authorised by law, such as emergency services. 

4. The types of personal information collected and how

Lifeline Australia’s practice is to only collect personal information that is reasonably necessary for an activity undertaken to carry out a Lifeline Australia function or activity in accordance with the Privacy Act and other relevant law.

The main way Lifeline Australia collects personal information about you is when you provide it directly and will depend on who you are and the nature of your interaction – whether you use a Lifeline National Service and how you access it (e.g., by voice call, text, or chat), join the Lifeline National Service delivery workforce, subscribe to a mailing list, fundraise on our behalf or donate, apply to become a volunteer, apply for employment, participate in training or enrol in a nationally recognised training course as a student, wish to partner, or undertake research. The type and amount of personal information collected depends on the purpose(s) for which you interact with Lifeline Australia.

Lifeline will collect health information (which is a type of sensitive information) about you if you contact a crisis support service and/or a counselling service. The choice of how much health information you provide is yours and, if you share health information with Lifeline, it will be protected and handled in accordance with the applicable laws.

Collecting information through Member Services

Lifeline Australia also collect personal information when you give it to a Lifeline Member or other counselling support service and that information is entered by that Member into IT systems that are provided and supported by Lifeline Australia.

Collecting information through Third Parties

Lifeline Australia may collect personal information from a third party or a publicly available source, but only if you have consented to such collection or would reasonably expect Lifeline Australia to collect their personal information in this way. For example, Lifeline Australia collects personal information from:

• referees provided by you in support of an application for a Lifeline Australia position (either as an employee or as a contractor);
• third parties such as contractors (including fundraising service providers) and list vendors;
• other organisations that you have donated to, where you have consented to receiving information from like-minded organisations such as Lifeline Australia; and
• academic and training organisations where required to verify a person's educational status.
• a referee for Lifeline to provide counselling services.

Collecting information of Minors

In the delivery of crisis support services, Lifeline Australia makes no active effort to collect personal information from minors (children under the age of 18). However, Lifeline Australia may collect personal information relating to children where a minor has contacted that service and provides the information directly including on phone calls, or where another individual contacts Lifeline Australia on behalf of the minor with child safety concerns.  Minors may contact the listed counselling services and personal information may be collected during triage and service provision. 

In relation to donations, minors who do wish to submit information to Lifeline (to process a donation) should secure permission from their parent or legal guardian prior to doing so.

Collecting information through websites

Lifeline Australia has its own public website (www.lifeline.org.au), which hosts some Lifeline Member websites, and also has dedicated websites for 13YARN, DV-alert, and the listed counselling services, that have several ways information is collected.

Analytics

These Lifeline Australia websites use Google Analytics and an internal tool to collect data about your interaction with that website. The internal tool is hosted by Lifeline Australia, while Google Analytics is hosted by a third party. The sole purpose of collecting your data in this way is to improve your experience when using the websites. As an example, the types of data collected with these tools can include:

• your device's IP address (collected and stored in an anonymised format);
• device screen size;
• device type, operating system and browser information;
• geographic location;
• referring domain and out link if applicable;
• search terms and pages visited; and
• date and time when website pages were accessed.

Cookies

Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the websites.

Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing Lifeline Australia’s websites.

The core functionality on these platforms will be largely unaffected if you disable cookies in your browser, but you may be unable to access some advanced functions.

Social Networking Services

Lifeline Australia use social networking services such as Facebook, Instagram, LinkedIn and X (previously known as Twitter) to communicate with the public about Lifeline services. When you communicate with Lifeline Australia using these social networking services your personal information may be collected, but it is only used to help Lifeline Australia to communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These social networking services have their own privacy policies and you can access their privacy policies on their websites and applications.

NB: Lifeline Australia does not provide crisis support, suicide prevention services or counselling via Lifeline Australia’s social media platforms.

Pixel Tracking 

Lifeline Australia may use pixel tracking technologies, such as tracking pixels or web beacons on websites or emails to understand whether communications are opened or accessed and how users interact with our content. Pixel tracking may collect information such as IP address, device or browser information and engagement data. Where required, Lifeline will obtain consent for the use of pixel tracking and will manage any personal information collected in accordance with this Privacy Policy and applicable privacy laws. 

Crisis Support and Counselling Services

Lifeline Australia collects information you provide to the Lifeline voice and digital (text and online chat) crisis support services and counselling voice and digital (online or video chat) through its role in providing:

• services directly to you and delivered through Lifeline Members;
• administration, IT support and infrastructure to Lifeline Members; and/or
• service quality and research activities.

In the delivery of crisis support, personal information, such as your name and contact details, will not be recorded unless you provide this information to Lifeline Australia, or if this information is otherwise captured by its systems or call recordings. Your name, date of birth, postcode, and other information as required by the service funder, will be requested when accessing counselling services. 

The following personal information which may include sensitive information, such as health information, may be collected depending on your interaction with Lifeline:

The personal information we collect, when and how it is collected is further described in Appendix 1: Privacy Statement Crisis Support, and Appendix 2: information collected and uses.

5. How Lifeline Australia uses personal information

Lifeline Australia collects, holds, uses, and discloses personal information for the purpose of carrying out the Lifeline Australia Objectives:

• encourage, support and undertake the organisation, establishment, maintenance, development, operation and improvement of the Lifeline National Services quality and Lifeline Centres throughout Australia, where those services are provided by the Lifeline Member network, other accredited bodies corporate or Lifeline Australia itself;
• grant accreditation of Lifeline Members and their Lifeline Centres to provide identified accessible support services within their respective communities whilst primarily (though not exclusively) providing crisis support and the listed counselling services to enable people to overcome isolation and cope with problems and crisis affecting mental health, wellbeing, life and safety;
• develop and conduct programs, projects and initiatives to enable people to overcome isolation and cope with problems and crisis affecting mental health, wellbeing, life and safety;
• assist third parties, such as emergency services, where there is a risk of harm to you or another person; and
• do any other activities incidental or conducive to the furtherance of these objectives.

Lifeline Australia uses personal information to perform activities necessary to carry out the Lifeline Australia Objectives. These activities include:

• providing crisis support and suicide prevention services through Lifeline Members;
• providing those counselling services listed above;
• providing administration and IT support to Lifeline Members to enable them to provide crisis support and suicide prevention services, and those counselling services listed above, in voice or digital (text and chat) modalities;
• conducting education and training in suicide prevention to external individuals and organisations;
• conducting research and evaluation and quality assurance activities and achieve continuous improvement in the provision of Lifeline National Services and other services;
• administering and providing nationally recognised training of Crisis Supporters (a crisis supporter is a person who interacts directly with the help seeker when providing Lifeline Crisis Support services), of front-line workers to support women and children impacted by domestic violence, and Lifeline employees and contractors in other supporting programs. This includes trainers who are employed or contracted by, and students enrolled with, Lifeline Members;
• conducting fundraising activities to raise funds to support the implementation of the Lifeline Australia Objectives;
• assessing suitable candidates for career opportunities within Lifeline Australia and managing employees;
• assessing suitable candidates for volunteering opportunities within Lifeline Australia and may share relevant information with Lifeline Members where opportunities are available;
• communicating with the public and the media, including through websites and social media, to raise public awareness of Lifeline National Services and other services;
• supporting research and analysis relevant to the Lifeline Australia Objectives;
• conducting investigations, and managing responses, in relation to internal incidents and complaints concerning Lifeline National Services and other services, and the operations of Lifeline Australia and Lifeline Members;
• complying with our legal and contractual obligations; and
• assisting investigations and information requests from third parties, such as the police or the coroner, in accordance with the law.

Use for primary purpose and certain secondary purposes

Lifeline Australia must only use individuals’ personal information for the primary purpose for which it was collected, a secondary purpose to which the individual has consented, or for a purpose related to (or if sensitive information directly related to) the primary purpose of collection and the individual would reasonably expect the personal information to be used for such purpose.

Where the purposes of collection and/or disclosure is not already set out in this policy, the primary purposes (and secondary purposes for which consent is required and is sought) should be set out in collection statements, and may include:

6. Consent to collect and use personal information

Lifeline Australia uses collection statements tailored to the different services and activities we provide, including crisis support, counselling, text and web chat services, Beyond Now application, volunteering, donations and fundraising. These statements explain what personal information we collect, how it is collected and how it will be used for the relevant purpose. 

When you contact or use our services, your consent to the collection and use of personal information will be implied by your decision to proceed with the service. We will collect and use information reasonably necessary to provide and manage the service for its primary purpose, in accordance with applicable privacy legislation and this Privacy Policy.

Consent for recording of interactions

Lifeline Australia operates various telephone services, each of which will include Interactive Voice Response prompts (IVR) that provides information about recording and available options Counselling services and Text and online chat interactions will always be recorded and retained in accordance with the HRIP Act The IVR for our Crisis Support Call service provides an opt-out option. If you do not consent to the recording when the option is stated in the IVR to press 1 to opt out of the recording you may do so or advise the crisis supporter at any time during the call. 

Employee and Volunteer Consent to Recording

Employees and Volunteers who participate in recorded service interactions are notified that their interactions will be recorded and consent to the collection, use and storage of these recordings as a part of their employment or engagement with Lifeline. Consent is provided through their employment or engagement agreement and their acknowledgement and acceptance of applicable Lifeline Policies, procedures and requirements. Recordings are managed in accordance with applicable privacy legislation and this Privacy Policy. 

Consent for direct marketing

Lifeline Australia may use some personal information for direct marketing purposes, but only where:

• the direct marketing communication contains a prominent statement that you may opt out of receiving that type of communication, and
• you have not made such a request.

How Lifeline Australia will obtain your consent for direct marketing

Individuals whose personal information is collected using a collection notice that references this Privacy Policy are taken to consent to the use of their personal information for direct marketing purposes unless they have specifically opted out.

Opting out of direct marketing

Email direct marketing communications should contain an ‘unsubscribe’ link that provides individuals with the opportunity to opt out of direct marketing communications. In other circumstances, individuals who do not wish to receive direct marketing communications from Lifeline Australia may request this in writing to fundraising@lifeline.org.au or use the opt out provided on the direct marketing material.

Lifeline Australia must take all necessary steps to opt such individuals out of direct marketing communications. Requests to opt out of direct marketing communications should be treated in the first instance as a request to opt out of the particular campaign or event to which the communication relates. However, individuals must be given the opportunity to contact Lifeline Australia (for example, by phone) to opt out of all direct marketing communications, across all programs, events, and channels.

Individuals who have opted out of direct marketing may still receive administrative emails or phone calls, such as reminders to bank funds raised.

Removal of opt-outs

Individuals who register for events, donate or otherwise provide their personal information for marketing-related purposes after they have previously opted out of direct marketing communications should be taken to have ‘opted in’ once again and may receive direct marketing communications. However, all such direct marketing communications must give the individual the opportunity to opt out as described above.

7. Disclosure of personal information

General Disclosure Practices

Lifeline Australia will only disclose personal information for the primary purposes for which it was collected unless permitted by law. Personal information may also be disclosed for secondary purposes where:

• the individual has provided consent (express or implied) to the disclosure of their personal information; or
• the individual would reasonably expect, or has been told, about the disclosure and the disclosure:
  • in the case of personal information (that is not sensitive information) relates to the primary purpose for which it was collected; or
  • in the case of sensitive information, including health information, is directly related to the primary purpose for which it was collected; or
  • relates to collection from a third party, that being a charitable or other likeminded organisation, including third party service providers who facilitate the sharing of such information;
• the disclosure is otherwise required or authorised by law, including mandatory reporting requirements in relation to suspected cases of child abuse and neglect or disclosure to police in relation to offshore detention issues;
• Lifeline Australia reasonably believe that the disclosure will prevent or lessen a serious and imminent threat to an individual’s life, wellbeing or safety (including your own) or serious threat to public health, property or public safety;
• the individual has made threats harm third parties or against a Lifeline Australia employee or volunteer, or the workforce who deliver Lifeline National Services;
• the individual repeatedly makes nuisance or unwelcome contact; or
• the disclosure is to a Lifeline Australia service provider as described below.

Disclosure to service providers

Lifeline Australia uses service providers that have access to personal information it collects and holds. These include providers that:

• translate interactions with you, if required, into the language you speak; 
• host servers for Lifeline Australia’s websites, systems used to deliver Lifeline National Services and other services, and Customer Relationship Management (CRM) system;
• other mental health or social services providers under referral arrangements, with your consent;
• engage with donors on behalf of Lifeline Australia to facilitate future giving; 
• provide analytical and business intelligence services (including by automated algorithms) to improve service quality and optimise marketing and fundraising campaigns; and
• provide research or evaluation services for improving our programs and services or to discover insights into mental health and wellbeing generally.

To protect the personal information they access or receive, Lifeline Australia:

• enters into a contract which requires the service provider to only use or disclose the information for the purposes of the contract; 
• imposes contractual obligations on the service provider to comply with the Privacy Act, or if the service provider is located overseas, protect personal information to a level comparable to (or exceeding) the Privacy Act and to comply with their local privacy laws; and
• includes special privacy requirements in contracts, where necessary (such as if the personal information includes sensitive information).

Disclosure to Related Entities and Service Funders

Lifeline Australia discloses information to service funders according to the contractual obligations of our service agreement with each of those affiliated organisations. Where practicable, this information will be de-identified and/or in aggregate form.

Disclosure of personal information overseas

Web traffic information is disclosed to Google Analytics when you visit Lifeline Australia’s websites. Google stores information across multiple countries.

When you communicate through a social network service such as Facebook or X, the social network provider and its partners may collect and hold your personal information overseas.

Lifeline Australia’s databases are hosted on secure servers in Australia (where possible), but we may also use the services of third parties which are hosted on overseas servers. We have measures in place to protect the personal information processed and take reasonable steps to ensure:

• the recipient of the information is subject to a law, or binding scheme, that is substantially like the way in which the Australian Privacy Principles protect the information; and
• there are mechanisms to access and enforce that protection of the law or binding scheme.

8. Quality of personal information

Lifeline takes reasonable steps to ensure that the personal information it collects and holds is accurate, complete, up to date and relevant for the purpose for which it was used or disclosed. 

Individuals may contact Lifeline to request correction of their personal information where they believe it is inaccurate, incomplete or out of date.  

8. Automatic decision making

Automatic decision making (ADM) involves using technology or automated systems to make or assist with decisions about an individual, which significantly affects the individual’s rights or interests. Lifeline Australia may use this in ways to process aggregate information, run algorithms, use artificial intelligence for redaction or other automated tools.

Uses of ADM include the following:

Where we use automated decision making, we will do so in accordance with the Privacy Act and other relevant legislation and take reasonable steps to have safeguards in place such as applying human review where practicable. 

If your rights are adversely affected by Lifeline’s use of ADM, you may request a review with the relevant contact person or team is disclosed in Lifeline’s communications about the use case, or where no such contacts are provided, Lifeline Australia’s complaints and feedback form at this site: https://www.lifeline.org.au/about/contact-us

10. Storage and security of personal information

Lifeline Australia takes reasonable steps to protect the personal information held against loss, unauthorised access, use, modification or disclosure, and against other misuse.

These steps include:

• role based access whereby only ‘need to know’ personnel have access to IT systems and records, including recordings and transcripts;
• undertaking background checks on personnel who require access to IT systems and records;
• strong password protection and multifactor authentication when accessing IT systems;
• performance of privacy, information and cyber security training to all staff who access IT systems; and
• securing paper files in locked cabinets and other physical access restrictions.

Lifeline Australia regularly engage independent information security experts to review and test relevant systems and processes. When no longer required, personal information is destroyed or deleted in a secure manner. We do not store payment card information.

11. Retention of records

Lifeline Australia will store information for the relevant statutory period depending on the purpose. All records held by Lifeline Australia which may be considered health information, are retained in accordance with the HRIP Act.

Lifeline Australia crisis support services do not solicit information which could identify a person’s age such as date of birth. As it is unknown whether a minor has contacted the service, Lifeline Australia will retain all records which may be considered health information for a period of 16 years to meet the retention requirement of the HRIP Act.  

Records upon cessation of service

If Lifeline Australia ceases to operate, any personal information held by Lifeline will be dealt with in accordance with applicable privacy laws and regulatory requirements. Lifeline Australia’s assets, including records and information where applicable, will be dealt with in accordance with Lifeline’s Constitution and any applicable legal requirements, including transfer to another charity and deductible gift recipient (DGR) endorsed entity with the same or similar charitable objectives where required. 

Records of Deceased Individuals

Where an individual whose personal information is held by Lifeline passes away, Lifeline may retain and manage information relating to that individual for legitimate organisational, legal, regulatory, historical, or archival purposes. Lifeline will continue to protect and retain such information in accordance with relevant laws and regulations.

12. Request for information access, correction and deletion

APPs 12 and 13 give you the right to ask for and receive access to personal information Lifeline Australia holds about you and to ask for corrections to that personal information. You may also ask us to delete the personal information we hold about you and such requests will be processed subject to any legislative and contractual records-retention obligations and technological limitations. 

Lifeline Australia will endeavour to respond within 30 days if you request access, correction, or deletion of your personal information. Where the information you have requested is located/confirmed as held by Lifeline, you will be given access to this information and reasonable steps taken to correct it if Lifeline Australia consider it is incorrect unless there is an exception in APP 12 or another law that allows or requires that to be denied. For example, access to your personal information will be denied if it is reasonably believed that:

• giving access would have an unreasonable impact on the privacy of other individuals;
• giving access would pose a serious threat to the life, wellbeing or safety of any individual, or to public health or public safety; or
• the request for access is frivolous or vexatious.

Individuals will be required to provide the following information before access, correction or deletion is undertaken:

• A written request for access and/or correction addressed to the Privacy Officer in the form of a statutory declaration and sent either via email to privacy@lifeline.org.au or via post to PO Box R1084, ROYAL EXCHANGE NSW 1225 and proof of identity in accordance with the NSW government health 100-point identification check.
• To conduct a record search of the crisis support and counselling service databases the following information is required:
• the phone number used to contact Lifeline’s voice and digital (text) crisis support or counselling services and the date and time of contact (if known); or
• the IP address used to access Lifeline’s online crisis support or counselling chat services and the first name and surname (or if only one name, the name combined with address, phone number or email) of the individual accessing the chat service. Where this information is not collected prior to the chat, the information needs to be included in the chat to reasonably identify the record
• Proof of identity achieved by the 100-point identification system, with proof of contact number and the purpose of the record search, clearly stated in a statutory declaration. All proof of identity documentation and the statutory declaration must be certified by an authorised person in your jurisdiction. 

Access to personal information will not be provided unless the person seeking access is the person to whom the information relates, or the law otherwise supports such access. 

In the event that the Privacy Officer is not reasonably satisfied as to the identity of the requestor, or the authority to make the request, access to the information may be refused, delayed or further information may be requested, until the Privacy officer confirms it is satisfactorily verified. Any information requested will be limited to what is reasonably necessary to verify identity, in order to protect personal or sensitive information from unauthorised disclosure. 

If access to, correction of, or deletion of your personal information is denied, you will be notified in writing, setting out the reason/s, including where we are required by law or a lawful purpose to retain it or we do not hold the information ourselves.

If an access request relates to an individual who is deceased, the Privacy Officer may require evidence sufficient to establish: 

• the identity and relationship of the applicant to the deceased,
• confirmation of the death of the individual concerned; and 
• the applicants legal authority to access the information or act on behalf of the deceased’s estate.

Such evidence may include a death certificate, grant of probate, enduring power of attorney (where relevant prior to death) or other documentation reasonably requested by Lifeline Australia. 

The personal information will be released to the requester, in accordance with the Privacy Act and applicable health records laws, unless the information contains the personal information or sensitive information, including health information, of another living person who is reasonably identifiable from the information available.

If you are seeking a copy or correction of a Statement of Attainment issued by the Lifeline Australia RTO, this proof of identity process also applies. 

If a correction is made and the incorrect information was disclosed to others, you can request they be notified about the correction unless there is a valid reason for Lifeline Australia not to.

If a correction to your personal information is denied, you can ask for us to attach a statement from you about why you believe the information is incorrect, and it will be attached to the record of that information.

13. Data breaches and notification

Lifeline Australia takes reasonable steps to protect personal and sensitive information from misuse, interference, loss, unauthorised access and unauthorised disclosure. 

Despite these measures, no method of transmitting or storing information is completely secure. If Lifeline Australia becomes aware of a suspected data breach involving personal information, we will assess the incident in accordance with our data breach response procedures and applicable legal obligations. 

Notifiable Data Breaches 

Where Lifeline Australia determines that a data breach is likely to result in serious harm to one or more individuals, and the requirements of the Notifiable Data Breaches scheme under the Privacy Act are met, we will: 

• activate our Data Breach response Plan;
• take reasonable steps to contain and assess the breach;
• notify the affected individuals as required by law, unless an exception applies;
• provide information about the nature of the breach, the information affected, and recommended steps individuals can take to reduce potential harm; and 
• notify the Office of the Australian Information Commissioner (OAIC) as required by the Privacy Act. 

Our Response to Data Breaches 

In responding to a data breach, Lifeline Australia may take steps including:

• securing systems and information;
• investigating the cause and extent of the breach;
• mitigating the risk of harm to affected individuals;
• reviewing and improving security controls and practices; and
• cooperating with regulators, law enforcement agencies or other authorities where appropriate.

Lifeline Australia aims to notify affected individuals as soon as practicable after becoming aware of an eligible data breach and completing the required assessment under the Privacy Act and Notifiable Data Breaches Scheme. Further information about Notifiable Data Breaches is available from the OAIC. 

14. How to make a privacy complaint with Lifeline Australia

If you wish to contact Lifeline Australia about a privacy matter, or believe that Lifeline Australia has breached your privacy, the Privacy Act, you can lodge a  request or complaint with the Privacy Officer.

How to make your complaint

Privacy complaints should be submitted in writing to the Privacy officer using the contact details set out below.  

Postal Address: PO Box R1084, ROYAL EXCHANGE NSW 1225
Email Address: privacy@lifeline.org.au

Information to include to assist investigation of your complaint: 

• your full name and contact details
• details of your privacy concern/ the alleged privacy breach
• all relevant dates, documents or services accessed for review
• the outcome you are seeking
• any other information to aid investigation

How we deal with your complaint

Upon receipt of a privacy complaint Lifeline Australia will:

1. acknowledge receipt of the complaint with a reasonable period (5 business days);
2. assess the complaint and, where appropriate conduct inquiries and obtain relevant information;
3. provide the complainant with an opportunity to provide additional information if required;
4. make reasonable efforts to resolve the complaint promptly and fairly; and
5. provide a written response setting out the outcome of the investigation and any actions taken or proposed. 

Lifeline Australia aims to respond to privacy complaints within thirty (30) calendar days of receipt. If additional time is required due to complexity of the complaint, we will inform the complainant and provide an estimated timeframe for completion. 

If you are not satisfied

If you are dissatisfied with Lifeline Australia’s response to your privacy complaint,, you can lodge a complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au/privacy/privacy-complaints/ who is independent of Lifeline Australia.

15. Updates to this privacy policy

Lifeline Australia will update this Privacy Policy when our information handling practices or services or applicable laws change, or to explain our practices further. 

Updates will be published on the Lifeline Australia website and are effective from the date of publication.

Notification at the time of any update will be listed as a banner on the website.

Appendix 1: Privacy Statement Crisis Support

Lifeline Australia is committed to protecting your privacy. This Privacy statement explains how we collect and handle your personal information when you use our crisis support services. 

Lifeline collects personal information where it is reasonably necessary for one or more of our functions or activities, including to provide crisis support and related services, respond to enquiries, ensure the safety and quality of our services, and meet our legal and regulatory obligations. 

When you contact us, we collect personal information that you provide during your interaction, as well as technical information such as your phone number (unless you turn off your Caller ID before calling), approximate location, your IP address (for web-based services), and information about your use of our services. Where required by law, we will only collect sensitive information as permitted under the Privacy Act 1988 (Cth) or another applicable law.

Crisis Support calls are audio recorded. You can opt out of audio recording by pressing 1 when prompted or by advising your Crisis Supporter at any time during the call. 

Text and webchat interactions will be recorded and retained as part of our service records; you cannot opt-out of this recording. These recordings will include your telephone number (Text) and/or your IP address (webchat) and information provided during your interaction. 

We may use or disclose personal information where reasonably necessary for the purposes described above, to service providers who assist us in delivering our services and where required or authorised by law, such as emergency services. 

Our Privacy Policy provides further information about how Lifeline collects, uses, stores and discloses personal information, how we protect it, whether information may be disclosed overseas, and how you can access or correct your information or make a privacy complaint. 

By using our services, you acknowledge that your personal information will be handled in accordance with our Privacy Policy. A copy of our Privacy Policy is available on our website: Lifeline/privacy-policy or can be sent to you on request.

Appendix 2: Information collected and uses

What information is collected from a general enquiry?

The information Lifeline Australia collects depends on your query. For example, your name and contact details are collected, as is the nature of your enquiry if you contact Lifeline Australia to:

• receive information from the organisation or to become involved in its campaigns, fundraising, training, merchandise, or other initiatives (but only if this information is needed to respond);
• make a complaint about the way a Lifeline National Service has been delivered to you;
• ask for access to information that Lifeline Australia holds about you;
• notify Lifeline Australia about a data breach;
• report a matter for investigation; 
• apply for a job vacancy or to volunteer with Lifeline Australia.

What information is collected for fundraising?

Fundraising refers to the activities undertaken by Lifeline Australia to raise funds to support its service including crisis support or listed counselling services. This includes but is not limited to, facilitating donations, workplace giving, and fundraising campaigns.

When you donate, Lifeline Australia may collect your name, contact details (including phone, email, address), credit card details, bank details, and the amount donated.

Where possible, Lifeline Australia will collect personal information directly from the individual. However, it is permissible to obtain personal information from third parties such as contractors (including fundraising service providers and list vendors). Lifeline Australia will ensure that any contractual arrangements with a list owner or broker will meet all requirements outlined in the Australian Privacy Principles. Until its first use, the broker or, in the case of the data being supplied directly, the list owner is responsible for the accuracy and the agreement of those people on the list for their details to be used by third parties.

If personal information about an individual is collected from a third party and it is unclear that the individual has consented to the disclosure of their personal information to Lifeline Australia, reasonable steps should be taken to contact the individual and ensure they are aware of the collection. In most cases, this can take place simultaneously with the first use of the information by Lifeline Australia.

Donors also have the availability to ‘opt in’ to providing other information such as donor information including gifts and wills with likely length of realisation, date of birth, employment information, including but not limited to job title, opinions via surveys and questionnaires. This information can be provided to Lifeline Australia in an ‘opt in’ basis, and donors may opt out of this at any time

Lifeline Australia may analyse the personal information a donor or fundraiser has provided and collect further information (including by creating or generating new information, or by providing and receiving personal information from third party sources, including commercial lists, data analytics and business intelligence providers, data brokers or publicly available sources, including social media). We may use this information to create a profile of a donor’s or fundraiser’s interests, preferences and ability to support Lifeline Australia, including the potential donations they may be able to give. 

What information is collected when I volunteer at Lifeline Australia?

Lifeline Australia collects and hold personal information about volunteers to assess and process applications, establish and maintain volunteer registrations, communicate with volunteers, and support their training, supervision and ongoing engagement with us.

Information collected may include contact details, employment and education history, emergency contact details, Working with Children Check (WWCC) and criminal history information, and information about accessibility requirements. We may also maintain records relating to a volunteer’s training, performance, assessment and ongoing participation.

As part of providing our services, volunteer interactions with service users may be recorded and monitored, including calls that may be listened to or reviewed for quality assurance, training, supervision and service improvement purposes. The collection and use of this information is managed in accordance with our privacy obligations and applicable laws.

Volunteers for Board member positions may also have to provide information relevant to  assessing conflict of interest risks.

What information is collected when I apply for a job with Lifeline Australia?

When you apply for a position with Lifeline Australia, we collect personal information that is reasonably necessary to assess your suitability for the position and to manage the recruitment and selection process.

Depending on the position and stage of the recruitment process, this may include:

• your name and contact details;
• your résumé, application, cover letter and responses to selection criteria;
• information about your employment history, qualifications, skills and experience;
• references and information provided by referees;
• information provided during interviews, assessments or written tasks;
• emergency contact information;
• information relating to your eligibility to work in Australia;
• academic qualifications and other information required to verify your suitability for the position;
• information relevant to managing actual or potential conflicts of interest;
• information required to undertake employment screening or background checks, including criminal history or Working with Children Checks where relevant to the position; and
• health or accessibility information where relevant to the recruitment process or where you choose to provide it to enable reasonable adjustments.

We may collect personal information directly from you and, where reasonably necessary for the recruitment process, from referees, recruitment providers, screening providers, educational institutions or other relevant third parties. Where we collect personal information about you from a third party, we will take reasonable steps to ensure you are aware of the collection where required by law.

We use and disclose applicant information for purposes including assessing applications, conducting recruitment and selection, verifying information, undertaking required screening and checks, managing conflicts of interest, communicating with applicants, and complying with our legal and regulatory obligations.

If you do not provide information reasonably necessary for the recruitment process, Lifeline Australia may be unable to assess or progress your application.

Personal information collected during the recruitment process will be managed and retained in accordance with this Privacy Policy, our records management requirements and applicable laws.

What information is collected about Lifeline Australia employees?

Lifeline Australia collects personal information necessary to recruit, employ, manage, support, train and develop its employees, and to meet its legal, regulatory and operational obligations.

This may include:

• the employee's employment contract and employment history;
• details of financial and other personal interests which may be relevant for the purpose of managing conflicts of interest;
• proof of Australian citizenship or residency, residency or right to work;
• certified copies of academic and professional qualifications;
• records relating to the employee's salary, benefitsand leave;
• health or accessibility information supplied by an employee or their medical practitioner;
• taxation  and payroll details;
• superannuation information; 
• information relating to the employee's performance, trainingand professional development; and
• information generated through the employees use of Lifeline systems and in the course of their role

What information is collected in the Lifeline Australia Services Workforce Management System?

Lifeline Australia facilitates the use of a Workforce Management System (WFMS) by the Lifeline Members for the purpose of managing the prospective crisis support workforce (including volunteers), forecasting call demand and the allocation of resources across the Lifeline Member network (to support voice and digital (text and online chat) services).

The WFMS holds details of each Crisis Supporter’s name and contact details; skills and training, rostered shifts, and employment status (employee or volunteer).

What information is collected for providing nationally accredited training services?

As a Registered Training Organisation (RTO), Lifeline Australia is required by law to collect information from trainers and assessors to verify they possess the requisite qualifications and other competency informed obligations, to provide nationally recognised training and support.

Lifeline Australia also collects personal information from prospective and enrolled students such as student contact details, you Unique Student Identifier (USI), enrolment forms and accreditation and competency records for use as an RTO and for applicable government funding reporting requirements. 

Fitness Device & Activity Data Integration for Fundraising: What data is collected and how is it used?

If you choose to connect a third-party fitness device or application (such as Garmin, Strava, Apple Health, or similar) to your fundraising page, we may collect activity data from that device or application. This may include, but is not limited to:

• Distance travelled (steps, kilometres, miles)
• Activity type (walking, running, cycling, swimming)
• Duration and frequency of activity

• Unit-based measurements relevant to your fundraising campaign

   

This data is collected only with your explicit consent at the point of connection and may be withdrawn at any time by disconnecting your device or application.

Fitness activity data collected through your fundraising page is used to:

• Display your progress on your personal fundraising page
• Update fundraising milestones and campaign goals
• Provide you and your supporters with a meaningful and engaging fundraising experience

• Analyse activity patterns and engagement signals — including through automated or AI-assisted tools — to personalise your fundraising experience, optimise campaign performance, and improve the products and services we offer

   

Where automated analysis or artificial intelligence is used to process activity data, it is applied solely to enhance your fundraising experience. This may include personalised insights, prompts, or suggestions designed to support your fundraising activity and improve supporter engagement.

Important: Any artificial intelligence or automated processing applied to fitness activity data operates exclusively on anonymised, aggregated data. No personally identifiable information — including your name, contact details, or any data that could be used to identify you as an individual — is shared with or processed by AI systems. Automated processing will not be used to make decisions that have a legal or similarly significant effect on you without your knowledge.

Third-party fitness platforms

When you connect a third-party fitness application, data is transmitted to us via that platform’s authorised API. Your use of any third-party application is governed by that platform’s own terms of service and privacy policy. We are not responsible for the data practices of third-party platforms.

Fitness Activity Data retention

Fitness activity data is retained for as long as your fundraising page is active and for a reasonable period thereafter in accordance with our standard data retention practices, or until you request deletion.

Your rights with fitness application connection

You may disconnect your fitness device or application at any time. You may also request access to, correction of, or deletion of your activity data by contacting us.