Governors Hill Cara Park is committed to protecting its employees, prospective employees, investors and customers’ privacy and personal information irrespective of how that information has been provided. Governors Hill Cara Park is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other privacy laws which govern the way in which organisations hold, collect, use and disclose personal information. In the event a breach does occur Governors Hill Cara Park will respond to reduce the risk of damage in accordance with the Office of the Australian Information Commissioner (“OAIC”) mandatory data breach reporting requirements.

2.0 Scope This policy applies to all Governors Hill Cara Park employees, directors, board members, temporary workers and independent contractors (collectively referred to in this policy as employee/s). It covers all information collected and/or disseminated by Governors Hill Cara Park, including information obtained via electronic devices used to access our services. This policy also applies to prospective employees who may provide Governors Hill Cara Park with personal information in relation to potential employment.

3.0 What does Governors Hill Cara Park Collect? Information collected is used for the purpose for which it was primarily collected. Information collected from customers is used for the purpose of managing customer relationships, while information collected from employees and individuals applying for employment is used to assist Governors Hill Cara Park to operate and manage its business. The personal information that is collected, held and used may include (but is not limited to):

• Personal identification and contact details;

• Previous employment history;

• Financial information, including pension and payment details;

• Tax file and Medicare numbers;

• Bank account details;

• Health information such as private health care provider details (from residents receiving assistance to access care);

• Next of kin and power of attorney details.

• Additional privacy measures are employed to protect sensitive information (such as health information).

4.0 Purpose of Collection

4.1 Tenants Collection of personal information from a tenant in Governors Hill community allows us to make leasing arrangements, collect rent, communicate with tenants as well as complete other associated documents.

4.3 Residents Receiving Assistance to Access Care Services Collection of personal or sensitive information including information about the health and wellbeing of a resident receiving assistance to access care services is necessary to manage relationships with our care recipients. It also allows Governors Hill Cara Park to assist in facilitating the services required, to communicate with residents, notify them about additional services and to comply with applicable laws. The type of information collected will be dependent on the services that the recipient requests or requires.

4.4 Short Term Holiday Guests Governors Hill Cara Park collects information such as contact details, credit card information and direct debit details from individuals renting cabins (or other accommodation) for short term holidays. This information assists Governors Hill Cara Park in managing holiday bookings, communicating with guests and collecting payments.

5.6 Other Governors Hill Cara Park may use personal details to manage its business operations (including insurances and legal obligations), help run the organisation, to market other products that it may offer or to provide updates on developments within the business. If an individual would rather not have their personal information used for this purpose they should let Governors Hill Cara Park know via the contact details located below.

6.0 How is Information Collected? Personal information may be collected via face to face interviews, application forms, correspondence (written and verbal) and care assistance documentation. In most cases, and where possible, personal information is collected directly from the source. If this is not practical, the information may be obtained from another person or entity. Governors Hill Cara Park will only collect personal information which is reasonably necessary to appropriately facilitate the provision of its services and appropriately operate and manage its business.

7.0 ‘Cookies’ A ‘cookie’ is a small data file placed on a computer or device which lets Governors Hill Cara Park identify and interact more effectively with the individual. Cookies do not identify the individual, they simply allow Governors Hill Cara Park to track usage patterns including date and time of day the individual accesses Governors Hill Cara Park's website, browser type, browser language, the internet protocol (IP) address, number of hits, pages visited and length of user session. Apart from the IP address of the computer an individual may be using, Governors Hill Cara Park does not use cookies to collect any personal data such as name and email address, except when specifically, and knowingly provide such information.

8.0 Use and Disclosure of Personal Information Personal information is not disclosed to any other person except in the following circumstances:

• In the course of general business practice Governors Hill Cara Park may outsource functions, for example unit registry, custodial services, as well as care services provided to residents as these third parties need to have access to personal information;

• During the recruitment process to contact referees and undertake background checks as well as any third- party service providers as may be necessary to progress an application;

• To anyone involved in providing services to employees’ of Governors Hill Cara Park including superannuation companies, relevant workers compensation organisations and government agencies including the Australian Tax Office and Department of Human Services;

• To anyone authorised by the individual to receive their personal information (consent may be express or implied);

• To organisations with whom Governors Hill Cara Park has contracted to assist in providing services, such as professional advisers;

• To anyone Governors Hill Cara Park is required or permitted by law to disclose personal information to;To any third parties involved in a resident’s ongoing healthcare (such as general practitioner, specialist or carer).

9.0 Exemptions Any exemptions to the clauses outlined in this policy will be considered on an individual basis. They are to be documented and discussed with the General Manager IT for consideration. The General Manager IT will provide permission in writing for any such exemption.

10.0 Security At all times Governors Hill Cara Park will take reasonable steps to ensure that the personal information collected and held is protected from misuse, loss, unauthorised access and disclosure. Much of this information is stored electronically in a secure environment. Any information that needs to be kept in hard copy is also protected via a range of measures including but not limited to:

• Access to information systems is controlled via access management procedures;

• Company policies and procedures regarding keeping information secure which all employees are bound by;

• All employees are required to complete training on information security and privacy as required;

• Governors Hill Cara Park regularly reviews and monitors compliance with policies and best practice.

There are however inherent risks in transmitting information across the internet and Governors Hill Cara Park does not have the ability to control security of information collected and stored on third party platforms.