VIPA collects personal information in order to conduct its business of professionally representing our pilots in the Virgin Australia Group of Companies and related entities and providing you with loss of licence protection. VIPA operates provides services in the political, legal, industrial and social spheres.
In this Policy, VIPA includes VIPA, its related entities and any entity associated with the provision of the VIPA Loss of Licence product.
How this Policy applies
This Policy applies to personal information VIPA collects from you:
• via one of our websites;
• via social media;
• via telephone;
• via email;
• via fax;
• in person; and/or
• in writing.
This Policy also applies to personal information VIPA collects from any other third party, about you.
VIPA websites collect two types of information. The first type is anonymous information. The web server makes a record of your visit and logs the following information for statistical purposes:
• the user’s server address;
• the user’s top level domain name (e.g. com, .gov, .net, .au, etc.);
• the date and time of the visit to the site;
• the pages accessed and documents downloaded;
• the previous site visited; and
• the type of browser used.
No attempt will be made to identify users or their browsing activities except, in the unlikely event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider’s logs.
Another way information may be collected is through the use of “cookies”. A cookie is a small text file that the website may place on your computer. Cookies may be used, among other things, to track the pages you have visited, to remember your preferences and to store personal information about you.
You can adjust your Internet browser to disable cookies or to warn you when cookies are being used. However, if you disable cookies, you may not be able to access certain areas of the Website or take advantage of the improved web site experience that cookies offer.
Our websites may contain links to other websites and social media pages including Facebook, Twitter and LinkedIn. We are not responsible for the privacy policies of the entities responsible for those websites and we recommend that you review the privacy policies applicable to any other websites you visit.
The kinds of information VIPA may collect
From time to time you may voluntarily supply your personal information to VIPA. VIPA will record your email address if you send us a message, subscribe to an email newsletter, or complete a form if this information is requested.
When you provide your personal information, it allows us, for example, to assist you with industrial relations and employment queries, inform you about industrial, social and political campaigns, and accept your application for membership. You may supply personal information to VIPA by, for example and not limited to, responding to a survey, filling in a meeting attendance sheet, taking part in a competition, completing a membership form, discussing your issues with a delegate, providing information relating to loss of licence protection or signing up to a campaign. VIPA only collects personal information that is necessary for VIPA to perform its functions and/or activities.
Depending upon the circumstances you may provide to VIPA, and VIPA may collect information such as, but not limited to:
• your name;
• your contact details;
• your social media details (e.g. blogs, twitter, Facebook, LinkedIn);
• your gender;
• your marital status;
• your employment details;
• your educational qualifications; and
• your inquiry or complaint details.
Some personal information is considered sensitive information and includes:
• your political opinions;
• your political party membership (if any);
• your union membership (if any);
• your racial or ethnic origin;
• your sexual orientation;
• any disabilities, illnesses or injuries you may have; and/or
• any other health information.
The Privacy Act allows VIPA to collect sensitive information which relates solely to association members or people who have regular contact with VIPA if the sensitive information relates to VIPA’s activities. We will only collect sensitive information where we have received your consent to your personal information being collected, used, disclosed and stored by VIPA in accordance with this Policy.
Where you provide information to VIPA in relation to a job application the personal information you provide will only be collected, held, used and disclosed for the purposes of considering your potential employment with VIPA. Where you provide the details of referees, you confirm that you have informed the referees that you are providing their contact information to VIPA and they have consented to VIPA contacting them and discussing the personal information you have provided in relation to the job application.
We will collect personal information directly from you unless:
• you have consented to VIPA’s collection of your personal information from third parties or
• when we are legally required to do so; or
• it is unreasonable or impractical to do so.
Where we have collected personal information about you either directly or by other means as set out above, we will notify you at the time, or as soon as practicable, to ensure that you are aware of such collection and its purpose.
You can choose to interact with us anonymously or by using a pseudonym where it is lawful and practicable. For example, you may wish to participate in a blog or enquire about a particular campaign or activity anonymously or under a pseudonym. Your decision to interact anonymously or by using a pseudonym may affect the level of services we can offer you. For example, we may not be able to assist you with a specific industrial enquiry or investigate a privacy complaint on an anonymous or pseudonymous basis. We will inform you if this is the case and let you know the options available to you.
If we receive unsolicited personal information about or relating to you and we determine that such information could have been collected in the same manner if we had solicited the information, then we will treat it in the same way as solicited personal information and in accordance with the APPs. Otherwise if we determine that such information could not have been collected in the same manner as solicited personal information, and that information is not contained in a Commonwealth record, we will, if it is lawful and reasonable to do so, destroy the information or de-identify the information.
The purposes for which personal information is collected, held, used and disclosed
VIPA collects, holds, uses and discloses your personal information to:
• assist you with industrial relations and employment queries;
• inform you about industrial, social and political campaigns;
• inform you about your rights at work;
• inform you about changes to legislation;
• refer you to a legal practitioner, accountant or other professional;
• improve our service delivery;
• manage our relationship with you;
• conduct surveys and research;
• provide educational services and professional development;
• conduct VIPA elections;
• manage financial or insurance services to you either directly through VIPA or by way of a third party.
Using your information for direct marketing
You consent to our use and disclosure of your personal information for the purposes of direct marketing which may include providing you with information about events, products or services which may be of interest to you.
If you do not want us to use your personal information for direct marketing purposes, you may elect not to receive direct marketing at the time of providing your personal information.
Unsubscribing and opting out
If you no longer wish to receive direct marketing or other communications, you may request at any time to cancel your consent to such communications as follows:
• If subscribing to an email newsletter you may “unsubscribe” at any time from the newsletter mailing list;
• VIPA may, from time to time, send you text messages about issues of importance such as events or campaigns. You may “opt out” by texting STOP in reply to a text message from VIPA; or
• You may contact us at any time by mail or email directed to our Privacy Officer.
Disclosure of your personal information
VIPA may disclose your personal information, in connection with or to further the purposes outlined above, to:
• Lloyd’s of London and any related entities
• the ACTU;
• other Australian trade unions;
• affiliated trades halls or labour councils;
• government bodies or agencies (including the Fair Work Commission, the Fair Work Ombudsman, the Australian Tax Office, an anti-discrimination body, a work/occupational health and safety regulator);
• organisations to whom we outsource functions (including information technology providers, print service providers, mail houses, insurance);
• otherwise as you have consented; and/or
• otherwise as required by law.
If any of these organisations are located outside Australia, you expressly consent to us disclosing your personal information to those organisations. These parties may be located in the following countries:
United States of America
We take reasonable steps to ensure that each organisation that we disclose your personal information to is committed to protecting your privacy and complies with the Australian Privacy Principles, or is subject to a law or scheme that is at least substantially similar to the way in which the Australian Privacy Principles protect information.
By providing your personal information to VIPA, you consent to us transferring your personal information to such other organisations.
How VIPA holds personal information
Wherever reasonably practicable VIPA holds electronic personal information on data servers that are owned and controlled by VIPA in Australia. The data servers are password protected and login secured. However, by providing personal information to VIPA you consent to your information being stored and processed on a data server or data servers (e.g. cloud services) owned by a third party or third parties that may be located outside of Australia. VIPA will take reasonable steps to ensure that any third party providers comply with the APPs. If personal information is only routed through servers located outside of Australia – this not regarded as a disclosure.
Wherever reasonably practicable VIPA holds physical personal information in access controlled premises.
When VIPA no longer requires your personal information for a specific purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to ensure that the information is de-identified.
We will not adopt as our own identifier a government related identifier of an individual, such as a tax file number or Medicare card number and will only use or disclose a government related identifier where the use or disclosure:
• is reasonably necessary for VIPA to verify your identity for the purposes of our activities or functions;
• is reasonably necessary for VIPA to fulfil its obligations to an agency or a State or Territory authority;
• is required or authorised by or under an Australian law; or
• is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
How you may seek access and/or correction to personal information held by VIPA
You have the right to request access to your personal information and request that it be updated or corrected. In most cases you can gain access to your personal information that VIPA holds. To request access to, correction of, or updating of any personal information held about you, please write to the Privacy Officer at the following address:
Privacy Officer – VIPA
PO Box 1871
Geelong VIC 3220
General enquiries can be made via telephone by calling 1800 116 460, option 2.
VIPA requires that you provide proof of identity in order to seek access to your personal information. VIPA may charge a reasonable fee where access is provided. VIPA may refuse to provide access if permitted to do so by law or under the APPs. VIPA will seek to provide you with access to your personal information within 30 days of receipt of a valid request and may charge you a reasonable fee for doing so.
You should contact VIPA when your personal information details change. It is important that we keep our membership details up to date. Please contact Membership to update any personal information. VIPA may also take steps to update your personal information by reference to publicly available sources such as telephone directories or electoral rolls.
Membership can be contacted at the following address:
secretary AT vipa.asn.au
How you may complain about a breach of the APPs
To make a complaint about an alleged breach of the APPs please write to or email the Privacy Officer at one of the following addresses:
Privacy Officer – VIPA
PO Box 1871
Geelong VIC 3220
All complaints must be written. Please provide all details about your complaint as well as any supporting documentation to the Privacy Officer.
How VIPA will deal with complaints
VIPA will seek to deal with privacy complaints as follows:
• complaints will be treated seriously;
• complaints will be dealt with promptly;
• complaints will be dealt with confidentially;
• complaints will be investigated by the Privacy Officer; and
the outcome of an investigation will be provided to the complainant where the complainant has provided proof of identity. VIPA will seek to respond within 30 days of receipt of a valid complaint.
Variations to the Policy
This Policy may be varied from time to time and an updated version will be posted on VIPA’s websites. Please check our websites regularly to ensure that you have the most recent version of the Policy.