Privacy policy

Audience

Department-wide including contractors, consultants and third parties working with the Queensland Reconstruction Authority (QRA) 

Purpose

To ensure that all QRA employees understand their responsibilities in managing personal information in accordance with the Queensland Privacy Principles (QPPs) in the Information Privacy Act 2009. 

This policy aims to protect the privacy of individuals by ensuring that personal information is collected, stored, used, and disclosed responsibly, transparently, and securely. It also seeks to promote accountability and consistency in the handling of personal information to maintain public trust and confidence. 

Policy statement

QRA is committed to safeguarding the personal information of individuals, including employees, government bodies and members of the public, in compliance with the Information Privacy Act 2009. Personal information must only be collected, used, stored, and disclosed for lawful purposes directly related to the department’s functions and activities.
All staff are required to:
•    collect personal information in a fair, lawful, and transparent manner
•    ensure that personal information is accurate, complete, and up to date before use
•    store personal information securely to prevent unauthorised access, loss, or misuse
•    use personal information only for the purpose for which it was collected, unless otherwise authorised by law
•    disclose personal information only when legally permitted or with the individual’s consent
•    respond promptly to requests for access to or correction of personal information in accordance with departmental procedures.

QRA will provide ongoing training and resources to ensure all staff understand their privacy obligations and will continue to develop and implement robust systems and processes to support compliance. 

Any breaches of this policy may result in disciplinary action and must be reported in accordance with the department’s procedures.

Principles

QRA’s approach is guided by the QPPs: 

QPPStatementImplementation
QPP 1: Open and transparent management of personal informationThe department must have a clearly expressed and up-to-date Privacy Policy about management of personal information, which is available free of charge.
  • This document serves as QRA’s Privacy Policy, outlining commitments and responsibilities for managing personal information.
  • Further information is available on QRA’s website, providing transparency for individuals whose personal information is collected or held by QRA.
QPP 2: Anonymity and pseudonymityThe department must provide individuals with the option to deal with it anonymously or pseudonymously, where lawful and practicable.
  • Individuals may interact with QRA anonymously or using a pseudonym when making general inquiries, providing feedback, or accessing services that do not require identity verification
  • Staff must respect this option unless QRA is required under law or authorised to deal with identified individuals or where it is impracticable to deal with individuals who have not identified themselves or use a pseudonym
  • Staff are to refer to internal procedures on handling anonymous or pseudonymous. 
QPP 3: Collection of solicited personal information The department must only collect personal information that is necessary for its functions or activities and must do so lawfully and fairly.
  • Personal information is collected directly from individuals wherever possible, using lawful and transparent methods.
  • Staff must ensure that only information relevant to QRA’s functions is collected and that individuals are not coerced into providing personal information.
     
QPP 4: Dealing with unsolicited personal information

The department must destroy or deidentify unsolicited personal information as soon as practicable if:

  • it would not have been permitted to collect the personal information under QPP3, and
  • it is not contained in a public record
  • if it is lawful and reasonable to do so.
  • Staff are to refer to internal procedures on assessing unsolicited personal information to determine if it could have been lawfully collected under QPP 3 and whether it is a public record.
  • Staff are trained on the appropriate steps to securely destroy or de-identify unsolicited personal information when it cannot be lawfully retained, and how to manage unsolicited public records in compliance with the Public Records Act 2002.
     
QPP 5: Notification of the collection of personal information

Departments must take reasonable steps to ensure individuals are aware of key matters when their personal information is collected, whether directly from the individual or from a third party. These matters include:

  • the department’s contact details
  • the fact and circumstances of the collection, particularly if the information is collected from someone other than the individual
  • the purpose of the collection and how the information will be used
  • any consequences for the individual if the information is not provided.
  • Staff are to refer to internal procedures on notifying individuals of the collection of personal information, including when and how to provide the required QPP 5 matters. 
QPP 6: Use or disclosure of personal informationDepartments must only use or disclose personal information for the purpose for which it was collected, unless a secondary purpose is permitted under QPP 6.
  • Staff are to refer to internal procedures on the primary and permitted secondary purposes for which information may be used or disclosed and assess whether the proposed use or disclosure falls within the permitted purposes.
  • If in doubt, staff must seek guidance from QRA’s Privacy Officer before proceeding
  • all uses or disclosures must be documented, including the purpose and justification for the action
  • Any breaches or unauthorised disclosures must be reported immediately and managed in accordance with QRA’s privacy breach management procedures and Data Breach Policy
QPP 10: Quality and accuracy of personal informationThe department must only use personal information for the purpose for which it was collected, unless an exception applies.
  • Staff must take reasonable steps to ensure personal information collected is accurate, up to date and complete.
  • Before using or disclosing personal information, staff must verify its accuracy and relevance to the intended purpose.
QPP 11: Security, deidentification and destruction of personal informationThe department must take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure
  • QRA has robust security measures to safeguard personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure.
  • Staff must adhere to QRA’s policies and procedures for securely handling personal information, including when accessing, sharing, retaining or disposing of it.
  • Any unauthorised disclosure must be reported as a potential privacy breach and managed in accordance with QRA’s privacy breach management procedures and Data Breach Policy.
     
QPP 12, QPP13: Access to/correction of personal informationThe department must give access to and correct personal information they hold, subject to limitations.
  • Staff must follow internal procedures for responding to access and correction requests, including:
    • assessing whether access or correction is required under the Information Privacy Act 2009
    • providing access administratively where appropriate and lawful
    • documenting decisions to refuse access or correction, including reasons and any advice provided to the individual.
  • Contentious or complex requests must be escalated to the Privacy Officer for review.
  • Staff must ensure appropriate safeguards are in place when transferring personal information in response to access requests.
  • Where QRA has control of a document containing personal information, it must give the subject of the information access if they ask for it.
  • Generally, where the circumstances surrounding the information are not contentious, releasing it would not breach legislative or confidentiality obligations, and access would not be refused under the RTI Act, staff should consider providing access administratively.
  • To correct personal information, staff must take reasonable steps if: it is satisfied, independent of any request, that personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, having regards to the purpose for which it is held; or the individual asks QRA to correct the information.

Roles, responsibilities

All staff are responsible for ensuring they adhere to the above principles in the receipt, handling and disclosure of personal information. Internal procedures provide detailed guidance to support staff in adhering to the principles. In addition to all-staff responsibilities, the below officers have discrete responsibilities related to this policy:

RoleResponsibilities
Director, Information Management and Security•    undertake Privacy Breach Assessments
•    notify the Office of the Information Commissioner
•    manage policy and register for Mandatory Notification of Data Breach (MNDB)
 
Privacy Officer•    liaise with the Office of the Information Commissioner as required to seek guidance and support 
•    develop and review privacy related policies and procedures
•    monitor QRA’s privacy practices to ensure ongoing compliance
•    develop, approve and oversee privacy training and awareness programs across QRA
•    provide advice to QRA staff 
•    manage privacy complaints 
•    review and approve Privacy Impact Assessments for new projects, systems, or processes that involve personal information

Delegations/authorisations

Delegations/authorisationsDetailsDelegated to
Delegation for Right to Information (RTI) and Information Privacy (IP) ApplicationsDelegation to process and decide on applications made under the Information Privacy Act 2009 for access to or amendment of personal information.Privacy Officer 
Authorisation to Access or Disclose Personal InformationDelegation to approve the access to or disclosure of personal information, ensuring it complies with the Information Privacy Principles (IPPs) or other legislative requirements.Privacy Officer

Definition

TermDefinition
Anonymity Means that the individual dealing with QRA cannot be reasonably identified, and QRA does not ask them for personal information or information that might identify them. QRA should not be able to identify the individual at the time of the dealing or subsequently. Anonymous dealings could include an unidentified individual phoning QRA to make a general enquiry, seek general advice or lodge a complaint. 
Mandatory Notification of Data Breach (MNDB)

Mandatory Notification of Data Breach scheme created in Chapter 3A of the IP Act.

It imposes obligations on agencies to prepare, respond and communicate in the event of suspected eligible data breaches or confirmed eligible data breaches.

The anticipated commencement date for the MNDB scheme is 1 July 2025 for agencies

Personal Information Section 12 of the IP Act provides that personal information means information or an opinion about an identified living individual or a living individual who is reasonably identifiable, whether it is true or recorded in a material form. 
The individual does not need to be directly identified in the information for it to be personal information. It is sufficient if they can reasonably be identified reference to other information. Information does not have to be true in order to be personal information and it does not need to be written down or recorded in a material form, such as a photograph or audio recording. 
PseudonymMeans that an individual gives QRA a name, term or descriptor instead of their actual name. The use of a pseudonym does not mean that an individual cannot be identified, the object of QPP2 is to give individuals the opportunity to deal with QRA without revealing their identity. 
Queensland Privacy Principles (QPP)The Queensland Privacy Principles in the Information Privacy Act 2009 set the rules for how departments deal with personal information. 
Sensitive Information Sensitive information is:
•    information or an opinion, that is also personal information, about the individual's - racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of professional or trade association, membership of a trade union, sexual orientation or practices and criminal record.
•    health information about the individual
•    genetic information about the individual that is not otherwise health information
•    biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
Unsolicited personal InformationUnsolicited personal information is personal information received by an agency that the agency took no active steps to collect. It is information that someone gives or sends to an agency at their own instigation, for example a petition from a community member that includes their personal information and the personal information of the signers.

Compliance

QRA will conduct periodic reviews to ensure compliance with this policy.

Communication

This policy is to be made available to QRA staff via the intranet and the public via QRA primary website.

Legislation, References and Authorities

•    Public Records Act 2023
•    Information Privacy Act 2009
•    Right to Information Act 2009
•    Queensland Reconstruction Authority Act 2011
•    Information Privacy and Other Legislation Amendment Act 2023

Related documents

•    Information Privacy Complaints Procedure
•    Complaints Management Policy
•    Delegations Register
•    Data Breach Policy

Review

The Chief Executive Officer will review this policy within twelve months of the initial approval date, then at least once every three years, and as required to take into account changes to relevant legislation, government policy and practices, changing trends, and feedback.

Document control 

Version: 0.2
Date: 19 June 2025
Approved by: Major General Jake Ellwood (Retd), CEO
Next scheduled review date: 1 July 2026.

 

Last updated: 1 July 2025. QRA Reference QRATF/25/5242 and DOC/25/36637.