Ingenia Communities Group (Ingenia or Group) is committed to protecting its customers’ and employees’ privacy and personal information irrespective of how that information has been provided. Ingenia is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other privacy laws which govern the way in which organisations (such as Ingenia) hold, collect, use and disclose personal information.
In the unfortunate event a breach does occur Ingenia Communities will respond to reduce the risk of damage in accordance with the OAIC mandatory data breach reporting requirements.
This policy applies to all Ingenia employees, directors, board members, temporary workers and independent contractors (collectively referred to in this policy as ’employee/s’) and covers all information collected and/or disseminated by Ingenia Communities Group, including information obtained via electronic devices used to access our services.
Ingenia Communities Group comprises Ingenia Communities Holdings Limited, Ingenia Communities Management Trust and Ingenia Communities Fund. Together they are a triple stapled entity of which Ingenia Communities RE Limited is the responsible entity.
Listed on the ASX as INA, Ingenia is a leading owner, operator and developer of a diversified portfolio of seniors housing accommodation. Ingenia Communities has a number of assets across Australia branded as Ingenia Lifestyle, Ingenia Garden Villages, Ingenia Holidays and Ingenia Settlers. Residents may also from time to time receive assistance to access care services.
What Do We Collect?
Information collected by Ingenia is used for the purpose for which it was primarily collected. Information collected from our customers is used for the purpose of managing our relationship with our customers, while information we collect from employees and individuals applying for employment is used to assist Ingenia Communities operate and manage its business.
The personal information that we collect, hold and use about you may include (but is not limited to):
- Personal identification and contact details;
- 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 our residents receiving assistance to access care); and
- Next of kin and power of attorney details.
Additional privacy measures are employed to protect sensitive information (such as health information).
Why Do We Collect?
Personal information is collected from investors to allow Ingenia (or an external service provider*) to process applications and to administer and report on investments.
*If you are an investor and would like to find out how the registry handles your information please contact them at:
Link Market Services
Level 12, 680 George Street
Sydney NSW 2000
Telephone: 1300 554 474
Collection of personal information from a tenant in an Ingenia village allows us to make leasing arrangements, collect rent, communicate with you as well as complete other associated documents.
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 our relationship with our recipients of care. It also allows us to assist in facilitating the services required, to communicate with you and notify you 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.
Ingenia collects information necessary to undertake its employment processes, comply with industrial legislation and taxation requirements, promptly pay salaries and wages, properly manage its business, and in the event of an accident or emergency contact your next of kin.
Ingenia maintains a personnel file for each employee to assist in the management of employees and the operation of its business. This file contains a copy of the employee’s employment application, employment contract, most recent performance appraisals and any formal counseling and disciplinary documents. Other records associated with the administration of payroll and other employment matters may also be included in the file.
Short Term Holiday
Ingenia 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 us in managing our holiday bookings, communicating with you and collecting payments.
Ingenia may use your details to manage our business operations (including insurances and legal obligations), help run our organisation and to market other products that we offer from time to time or to update you on developments within the existing business. If you would rather not have your personal information used for this purpose you should let us know via email or by contacting us on the details at the bottom of this document.
How Do We Collect?
Personal information may be collected from you via face to face interviews, application forms, correspondence (written and verbal) and care assistance documentation.
In most cases, and where possible, we collect your personal information directly from you. If this is not practical, the information may be obtained from another person or entity.
Ingenia will only collect personal information which is reasonably necessary to appropriately facilitate the provision of its services to you and appropriately operate and manage its business.
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 Ingenia may outsource functions, for example unit registry, custodial services, as well as care services provided to our residents as these third parties need to have access to personal information;
- to anyone authorised by you to receive your personal information (your consent may be express or implied);
- to organisations with whom Ingenia has contracted to assist in providing services, such as professional advisers;
- to anyone Ingenia is required or permitted by law to disclose your personal information to;
- to any third parties involved in your ongoing healthcare (such as general practitioner, specialist or carer).
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.
We will at all times take reasonable steps to ensure that the personal information collected and held by us 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 are controlled via access management procedures;
- Ingenia Communities Information Security policies and procedures regarding keeping information secure, which all employees are bound by;
- requiring all employees to complete training on information security and privacy as required;
- Ingenia Communities regularly reviewing and monitoring compliance with policies and best practice.
Unfortunately there are inherent risks in transmitting information across the internet and Ingenia Communities does not have the ability to control security of information collected and stored on third party platforms. In relation to our own servers, Ingenia Communities take all reasonable steps to manage data stored on our servers to ensure data security.
As mentioned previously additional privacy measures are employed to protect sensitive information (such as health information).
Access & Correction
You have the right to seek access to and/or correct the personal information Ingenia Communities holds about you if you believe it to be inaccurate or out of date.
If you are a customer, you can arrange this by calling the Privacy Officer of Ingenia Communities (on the contact details listed below). Your request should include a detailed description of the information required. To ensure information is only disclosed to relevant people you may be asked to provide identification or in the case of a telephone call asked to verify your identity via a number of questions.
Employees can update their personal information by completing the Employee Detail form located in the payroll folder on the intranet and forward the completed form to firstname.lastname@example.org for any changes to personal details such as bank accounts, email addresses and pay variations. Employees may also use the Employee Service Portal to change some of their personal information.
Employees who need verification of their employment and salary details must submit a written request to Human Resources with at least one week’s notice. If you require such information to be released to a third party, your request must indicate that you authorise Ingenia Communities to release the required details.
Personal information records are held for a period considered appropriate by Ingenia Communities. Should you cease to be a customer/investor/resident/employee of Ingenia Communities, any personal information which we hold about you will be held for the relevant retention periods required by law.
Enquiries and complaints
Customers who have a question or wish to complain about the treatment of their personal information should contact Ingenia Communities as set out below:
Level 9, 115 Pitt Street
Sydney NSW 2000
Telephone: 1300 132 946
Ingenia Communities will consider the question or complaint and acknowledge receipt within 48 hours, and provide a response within 30 days. Whilst we will do our best to answer your question or resolve your complaint, if you feel it remains unresolved or you wish for further investigation to take place you should contact:
Australian Information Commissioner
Please contact Link Market Services if you are an investor and would like to understand how the registry handle your information at:
Review of Policy
Ingenia Communities may change the way we handle personal information from time to time. If we do this we will update the policy to reflect the changes. The most recent version will always be available on the Ingenia Communities website.