- About this Policy
- Scope of this Policy
- When you can interact anonymously
- The types of personal information collected
- How Lifeline Australia use personal information
- Consent to collect and use personal information
- Collection and use of your personal information
- Quality of personal information
- Storage and security of information
- Retention of records
- Access and correction
- How to make a complaint or contact Lifeline Australia
- Appendix 1: Information collected and uses
1. About this Policy
(Version 3.1, October 2022)
Lifeline Australia acknowledges that it may provide a health service to individuals who contact the crisis support services and Lifeline Australia may assess, maintain, improve, or otherwise help to manage the mental health of individuals. Lifeline Australia acknowledges that it may not provide a health service to all individuals who contact the crisis support services however, for the purposes of our privacy obligations, Lifeline Australia also complies with the Health Records and Information Privacy Act 2002 (NSW) (HRIP Act) which includes the privacy rules in the Health Privacy Principles (HPPs) in relation to all individuals who contact the crisis support services.
Lifeline Australia employees and prospective employees who have been offered a position should also refer to our Employment Conditions Policy.
This policy is written in simple language. The specific legal obligations Lifeline Australia has when collecting and handling personal information is outlined at a federal level in the Privacy Act, and in particular the Australian Privacy Principles (APPs) found in that Act, and at a State level in the HRIP Act and the HPPs.
2. Scope of this Policy
This policy applies to Lifeline Australia's handling of personal information 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. When you can interact anonymously
Where possible, Lifeline Australia will allow you to interact anonymously or using a pseudonym, unless it is impracticable, or an applicable Australian law requires Lifeline Australia to only deal with an identified individual. For example, for the voice and digital (text and chat) service or our general enquiries and feedback online form, your name and identifying information is not requested unless it is needed to adequately respond to your request or to assist you. Please see below how your information is collected via Lifeline Australia’s Information Technology (IT) systems when you contact Lifeline’s crisis support services. If you want to subscribe to a mailing list, donate, apply to become a volunteer, or apply for employment, certain personal information is required.
Lifeline Australia may record calls received on its crisis support services. You can choose what information you provide, however some information that makes you reasonably identifiable may be collected. If you provide identifiable information, it may be disclosed to protect you or others. For example, your phone number may be provided to emergency services if there is a risk of harm to you or another person. This is described in more detail in section 8.1.
4. The types of personal information collected
Lifeline Australia try to only collect personal information that is reasonably necessary for, or directly related to, an activity undertaken to carry out a Lifeline Australia Objective (as described below).
The main way Lifeline Australia collect personal information about you is when you provide it directly or through a Lifeline Australia Member (service delivery provider). The information collected will depend on who you are and the nature of your interaction – whether you use a Lifeline Australia services, subscribe to a mailing list, donate, apply to become a volunteer, apply for employment, wish to partner or undertake research. The choice of how much information you provide is yours and depends on the purpose(s) for which you interact with Lifeline Australia.
Lifeline may also collect health information about you if you contact a crisis support service. The choice of how much health information you provide is yours and, if you share health information with Lifeline, it will be protected in accordance with the HRIP Act and the HPPs.
The personal information, when and how it is collected is further described in Appendix 1: information collected and uses.
5. How Lifeline Australia use personal information
Lifeline Australia collect, hold, use, and disclose personal information for the purpose of carrying out the objectives of Lifeline Australia. The objectives of Lifeline Australia (Lifeline Australia Objectives) are to:
- encourage, support and undertake the organisation, establishment, maintenance, development, operation and improvement of the service quality of Lifeline Services and Lifeline Centres throughout Australia, where those services are provided by Members, other accredited bodies corporate or Lifeline Australia itself;
- grant accreditation to Lifeline Centres so as to provide to all communities an accessible caring and counselling service, primarily (though not exclusively) through telephone counselling services to enable people to overcome isolation and cope with problems and crisis affecting mental health, well-being, 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, well-being, 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 things incidental or conducive to the furtherance of these objectives.
Lifeline Australia is a member-centric organisation comprising the national office (Lifeline Australia) and a national network of Members and Lifeline Centres located in every state and territory across Australia. The list of Lifeline Members can be found at Our Members.
Lifeline Australia use 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 Australia’s wholly owned subsidiary;
- providing administration and IT support to Lifeline Members to enable them to provide crisis support and suicide prevention voice and digital (text and chat) services;
- conducting education and training in suicide prevention to external individuals and organisations;
- conducting research and evaluation and assurance activities to ensure the delivery of quality services and achieve continuous improvement in service delivery;
- training of Crisis Supporters and Lifeline employees;
- 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;
- communicating with the public and the media, including through websites and social media, to raise public awareness of Lifeline services;
- supporting research relevant to the Lifeline Australia objectives;
- conducting investigations, and managing responses, in relation to complaints concerning Lifeline services and the operations of Lifeline Australia and its Members; 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.
Primary purposes (and secondary purposes for which consent is required and is sought) should be set out in collection notices, and may include:
Crisis support services
providing crisis support and suicide prevention services to all Australians suffering emotional distress.
recording interactions between Crisis Supporters or other Lifeline staff and the individual for the purpose of service quality, training, and improvement purposes in relation to Lifeline Australia’s services.
supporting Lifeline Australia’s requirements in relation to investigating and facilitating the complaints process, in addition to assisting information requests from third parties, such as the police or the coroner, to undertake investigations.
to communicate with individuals about donations, products, services, campaigns, causes, and events.
to conduct and/or fund research into Lifeline Australia’s programs and services or research into supporter attitudes and understanding how to improve crisis support services.
Volunteering and other support
to enable individuals to assist with volunteering, community fundraising, advocacy, or other activities where community’s assistance is sought.
communicating with individuals in relation to Lifeline Australia operations, activities, and objectives, to verify their identity, to improve and evaluate programs and services and comply with relevant laws.
6. Consent to collect and use personal information
Consent for call recording
Lifeline Australia may record calls received on its crisis support telephone lines for the primary purposes described above. Lifeline may use the call recording for the primary purposes, but only where the individual has been clearly informed that the call will be recorded, and the relevant individual has consented to the call recording.
How consent for call recording will be obtained
If you use Lifeline Australia’s telephone service:
At the beginning of the call
Individuals are taken to consent to the call recording for Lifeline’s primary purpose unless once connected, they ask the Crisis Supporter to stop recording at the beginning of the call.
During the call
If individuals wish to terminate the call recording during their call with the Crisis Supporter, they may request the Crisis Supporter to terminate the recording.
In relation to employees and volunteers of Lifeline using Lifeline Australia’s call service:
- Employees and volunteers conducting a call that is recorded must be provided with a written notice that the calls they answer on the service line will be recorded and of the primary purposes of the call recording.
- Employees and volunteers will be given reasonable opportunity to give their consent to the call recording.
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 the individual may opt out of receiving that type of communication, and
- The relevant individual has not made such a request.
How Lifeline Australia will obtain your consent for direct marketing
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 contact (02) 6215 9400 or firstname.lastname@example.org to opt out 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. Collection and use of your personal information
What information is collected
The kinds of personal information collected and its uses, are described in Appendix 1: information collected and uses.
When is personal information collected
Lifeline Australia usually collect personal information from you when you:
- have contact Lifeline Australia over the telephone or by text message;
- have contact with Lifeline Australia in person;
- interact online including via the Lifeline Australia website, Online Crisis Support Chat Service, Facebook, and Twitter; and
- communicate with Lifeline Australia in writing including via post.
Lifeline Australia also collect personal information when you give it to a Lifeline Member and that information is entered by that Member into IT systems that are provided and supported by Lifeline Australia.
Sometimes Lifeline Australia collect personal information from a third party or a publicly available source, but only if the individual has consented to such collection or would reasonably expect Lifeline Australia to collect their personal information in this way. For example, Lifeline Australia collect 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);
- from third parties such as contractors (including fundraising service providers) and list vendors;
- from other organisations that you have donated to, where you have consented to receiving information from like-minded organisations such as Lifeline Australia; and
- from academic and training organisations where required to verify a person's educational status.
Lifeline Australia may also collect personal information about you from a third party in the course of a person contacting a Lifeline service. Personal information, such as name and contact details, will not be recorded unless you provide this information to us, or if this information is otherwise captured by IT systems or call recordings, and together may create a reasonably identifiable record with Lifeline Australia.
Lifeline Australia makes no active effort to collect personal information from Children under the age of 18. However, Lifeline Australia may collect personal information relating to Children where the Child has contacted the support services and provides the information directly, or where another individual contacts Lifeline Australia on behalf of the Child with child safety concerns.
In relation to donations, Children 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 and there are several ways in which information is collected though the website.
The Lifeline Australia website uses Google Analytics and an internal tool to collect data about your interaction with the 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 website. 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 are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the website.
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 the Lifeline Australia website.
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 and 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 it 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 services have their own privacy policies. You can access the privacy policies for Twitter and Facebook on their websites.
NB: Lifeline Australia does not provide crisis support or suicide prevention services via Lifeline Australia’s social media platform (Twitter, Facebook or Instagram).
General Disclosure Practices
Lifeline Australia do not disclose personal information to another person or organisation (including police, emergency services and other government agencies) unless one of the following applies:
- the individual has consented (whether expressly or impliedly) to the disclosure of their personal information;
- the individual would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies 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 information between such types of charitable or like-minded organisations;
- the disclosure is otherwise required or authorised by law, including to comply with 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 somebody's life, health or safety (including your own) or serious threat to public health, property or public safety;
- the individual has made threats to harm third parties;
- the individual has made threats against Lifeline personnel;
- 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. These include providers that:
- translate interactions with you, if required, into the language you speak; and
- host Lifeline Australia website servers and Customer Relationship Management (CRM) system.
To protect the personal information Lifeline Australia:
- enters into a contract which requires the service provider to only use or disclose the information for the purposes of the contract;
- includes special privacy requirements in contracts, where necessary.
Disclosure of personal information overseas
Web traffic information is disclosed to Google Analytics when you visit Lifeline Australia websites. Google stores information across multiple countries.
When you communicate through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.
Lifeline Australia’s databases are hosted on secure servers and reasonable steps have been taken to ensure:
- the recipient of 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.
9. Quality of personal information
To ensure that the personal information collected is accurate, up-to-date, and complete Lifeline Australia apply the following data quality procedures:
- information is recorded in a consistent format;
- where necessary, confirm the accuracy of information collected from a third party or a public source;
- promptly add updated or new personal information to existing records;
- review the quality of personal information before use or disclosure.
10. Storage and security of information
Lifeline Australia take steps to protect the personal information held against loss, unauthorised access, use, modification or disclosure, and against other misuse. These steps include:
- only allowing personnel with a 'need to know' to access IT systems and records, including recordings and transcripts;
- (where relevant) undertaking background checks on personnel who require access to IT systems and records;
- password protection for accessing electronic IT systems; and
- securing paper files in locked cabinets and 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 in compliance with the Payment Card Industry standards, which governs Lifeline Australia’s handling of payment card information.
11. Retention of records
In relation to crisis support services, Lifeline Australia will store information for the relevant statutory period required.
In relation to children contacting the crisis support service, Lifeline Australia will store the personal information for 7 years after the date which the child turns 18, where their age and identity is disclosed. Where it is unknown whether a child has contacted the service, Lifeline Australia will retain the record for the relevant statutory period.
Lifeline Australia otherwise will only retain information for the time necessary to provide the requested service.
12. Access and correction
APPs 12 and 13 give you the right to ask for and receive access to personal information held about you and to ask for corrections to that personal information.
Lifeline Australia will endeavour to respond within 30 days if you ask for access or correction of your personal information. You will be given access to your personal 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, health 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 or correction is undertaken:
A written request for access and/or correct addressed to the Privacy Officer and sent either via email to email@example.com or via post to PO Box R1084, ROYAL EXCHANGE NSW 1225.
To conduct a record search of the crisis support and suicide prevention service data bases the following information is required:
- the date, time and number used to contact Lifeline’s voice and digital (text and chat) services; or
- the date, time and IP address used to access Lifeline’s online crisis support chat service
Proof of identity (this may be achieved by the 100-point identification system and proof of contact number, certified statutory declaration).
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 some cases, additional proof of identity information may be required, or access may be denied because ownership of a record cannot be proven.
If an access request relates to an individual who is deceased, the personal information will be released to the requester, in accordance with the Privacy Act, 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 access to, or correction of, your personal information is denied, you will be notified in writing setting out the reasons.
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 not to.
If a correction to your personal information is denied, you can ask for a statement which indicates that you believe the information is incorrect, and will be attached to the information.
13. How to make a complaint or contact Lifeline Australia
If you wish to contact Lifeline Australia about a privacy matter or are concerned about the way your personal information has been handled, you can lodge a written request or complaint with the Privacy Officer at either of the following addresses:
Postal Address: PO Box R1084, ROYAL EXCHANGE NSW 1225 or
Email Address: firstname.lastname@example.org
If you are dissatisfied with the investigation of your concerns, 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.
14. Appendix 1: Information collected and uses
14.1 What information is collected when Lifeline provides crisis support services?
Lifeline Australia collects information you provide to the Lifeline voice and digital (text and chat) crisis support services through its role in providing:
- services directly to you through Lifeline Direct; or
- administration, IT support and infrastructure to Lifeline Australia Members.
Personal information, such as your name and contact details, will not be recorded unless you provide this information to Lifeline, or if this information is otherwise captured by its systems or call recordings. The following personal information may be collected depending on your interaction with Lifeline:
Your name or the names of people you tell Lifeline about
such as friends or family you are concerned about.
Your telephone number
if you use Lifeline’s text-based service then this will be used to communicate with you. Lifeline’s telephone system might also display the number you call us from, or you might give your number to Lifeline for Lifeline Australia to contact you again.
Your address or location
if Lifeline need to make sure you are in a safe space, or if Lifeline need to support you by asking authorities to visit your location.
Details about you and others which are relevant to the call
for example, if you tell Lifeline about your health, about the loss of a loved one, about a drug or alcohol problem affecting you or someone you know, or if you are thinking about suicide or are worried that someone you know might attempt suicide. Lifeline take notes about the things you say to us so that we can figure out the best way to help you.
If Lifeline make a care plan for you
then Lifeline might make notes about the actions recommended for you to take or the information given to you.
If you use Lifeline’s telephone service then the system will record and store any information
noises or other sounds captured by the call recording, in addition to call time and duration, originating area of the call, and telephone number (if unblocked). This information is stored separately to other information Lifeline collect when individuals access its services.
If you use Lifeline’s online chat, then our system will also take details
14.2 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 or other initiatives (but only if this information is needed to respond);
- make a complaint about the way a Lifeline 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; and
- apply for a job vacancy at Lifeline Australia.
14.3 What information is collected for fundraising?
Fundraising refers to the activities undertaken by Lifeline Australia to raise funds to support its Crisis 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 direct, 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 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.
14.4 What information collected when you purchase from Lifeline?
When you order resources from the Lifeline Shop, Lifeline Australia collects your name and contact details, and items purchased.
14.5 What information is collected when I volunteer to deliver Lifeline services?
Lifeline Australia collects personal information necessary to enable to the assessment of your application to register as a volunteer.
Depending on the role this may include your employment and volunteer history, education, criminal history and/or a working with children background check. Volunteers for Board member positions may also have to provide information relevant to assessing conflict of interest risks.
14.6 What information is collected when I apply for a job with Lifeline Australia?
When you apply to work with Lifeline Australia, personal information collected is necessary to enable an assessment of your application for employment with the organisation.
This may include:
- your résumé, statement addressing the criteria and referee reports;
- written tasks undertaken by you during the selection process;
- details of financial and other personal interests supplied by you for the purpose of managing potential conflicts of interest;
proof of Australian citizenship or residency; and
- copies of academic qualifications.
14.7 What information is collected about Lifeline Australia employees?
Lifeline Australia collects personal information necessary to manage its employees.
This may include:
- the employee's employment contract;
- 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;
- copies of academic qualifications;
- records relating to the employee's salary, benefits and leave;
- health related information supplied by an employee or their medical practitioner;
- taxation details;
- superannuation contributions; and
- information relating to the employee's training and development.
14.8 What information is collected in the Workforce Management System?
Lifeline Australia facilitates the use of a Workforce Management System (WFMS) by the Lifeline Members for the purpose of forecasting call demand and the allocation of resources across the Lifeline Member network (to support voice and digital (text and 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).
14.9 What information is collected for delivery of training and education 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 to deliver training and education.
Lifeline Australia collects personal information such as student contact details, enrolment forms and academic records.