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Privacy & Confidentiality Policy

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1. Aim
Affordable Community Housing Alliance Tasmania Limited trading as “Centacare Evolve Housing (ABN 23 154 824 969)” (CEH) is committed to complying with its obligations under the Privacy Act 1998 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).

CEH is committed to respecting your privacy and protecting your rights with respect to your personal information.

2. Policy
This policy explains how CEH manages and secures your personal information. It also describes the kinds of personal information that CEH holds and for what purposes, and how that information is collected, held, used and disclosed.

This policy is available on CEH’s website at http://centacareevolve.com.au/. You may request a copy of the policy by contacting the Privacy Officer in accordance with paragraph 13 of this policy.

Please read this policy carefully before you provide CEH with any personal information.

3. Types of personal information that CEH collects and holds
Personal information
CEH may collect and hold the following types of personal information about you:
a) identification information, including your name, postal address, email address, date of birth, Medicare number, driver’s licence, Centrelink number, passport and contact details;
b) bank account details;
c) financial transactions relating to your CEH accounts;
d) balances of accounts held at CEH;
e) tax file number;
f) marital status; and
g) any other information that CEH considers to be reasonably necessary.

Sensitive information
CEH may need to collect sensitive information about you. CEH will only collect sensitive information about you if:
a) you consent to the collection of the information and the information is directly related to CEH’s functions; or
b) the information relates:
(i) to the activities of CEH; and
(ii) solely to the members of CEH, or to individuals who have regular contact with CEH in connection with its activities; or
c) the collection is otherwise permitted under the Privacy Act.

The types of sensitive information that CEH collects and holds about you may include:
a) information or an opinion about your race or ethnic origin, religious beliefs or affiliations, philosophical beliefs, membership of a profession or trade association, membership of a trade union, sexual orientation and/or practices;
b) criminal records; or
c) health information.

Information required by law
CEH may also collect personal information about you because the collection of the information is required or authorised by law or a court/tribunal order.

4. Collecting your personal information
CEH will, if it is reasonable and practical to do so, collect personal information directly from you.

CEH may collect your information when you:
a) give CEH information over the telephone;
b) interact with CEH electronically or in person;
c) access its website; and
d) complete application forms.

On occasion CEH may collect personal information about you from other sources where it is necessary to do so. Examples of other sources that CEH may collect personal information from include, but are not limited to:
a) schools;
b) your relatives;
c) CEH’s service providers; and
d) information that is publicly available on the electoral roll.

If you do not provide CEH with your personal information, it may not be able to:
a) provide you with the product or service you want; and
b) verify your identity.

Unsolicited personal information
If CEH inadvertently collects personal information about you that it did not ask for, CEH will check whether it could have collected that information itself. If CEH could have collected the information, CEH will handle it in the same way it handles other information it collects from you. If:
a) CEH could not have collected the personal information; and
b) the information is not contained in a Commonwealth record,

CEH will destroy the information or de-identify the information provided it is lawful and reasonable to do so.

5. Storing personal information
CEH stores your personal information in different ways, including paper and electronic form, via cloud and via Dropbox.

CEH treats all personal information as confidential. It will take reasonable steps to ensure personal information is protected from:
a) misuse, interference and loss; and
b) unauthorised access, modification and disclosure.

Some of the ways CEH does this are:
a) confidentiality requirements for employees;
b) document storage facilities;
c) security measures for access to systems;
d) only giving access to personal information to a person who is verified to be able to access that information;
e) control of access to buildings; and
f) electronic security systems, such as firewalls and data encryption, user identifiers, passwords or other access codes, antivirus, antispyware, backup and recovery of systems.

If CEH no longer needs your personal information for any purpose, it will take reasonable steps to destroy or permanently de-identify the information, unless:
a) the information is contained in a Commonwealth record; or
b) CEH is required by law, or a court/tribunal order, to retain the information.

6. Purpose for collecting, holding, using and disclosing information
CEH collects, holds, uses and discloses your personal information for the following purposes:
a) to assess your account application;
b) to establish and administer your account;
c) to verify your identity;
d) to consider any other application made by you for products or services;
e) for customer relations purposes, including managing CEH’s relationship with you;
f) to comply with any applicable laws, regulations or codes of practice;
g) to comply with any payment systems requirements;
h) for information technology systems development and testing where CEH’s internal computer system is upgraded;
i) for CEH’s internal operations, including record keeping, risk management, auditing, training, file reviews and account analysis;
j) to investigate, resolve and prevent complaints;
k) to make arrangements with other organisations to provide services in relation to CEH’s products and services (for example, CEH may arrange for mailing houses to distribute account statements);
l) to conduct fraud assessments;
m) for reporting and data analytics purposes, including for regulatory, management, statistical or research purposes;
n) direct marketing purposes; and
o) for any other purpose for which you have given your consent.

7. Use and disclosure of information
Personal information CEH holds about you that was collected for a particular purpose will not be disclosed for another purpose, unless:
a) you have consented to the use or disclosure of the information for another purpose; or
b) the access, use or disclosure is otherwise permitted under the Privacy Act (e.g. you would reasonably expect CEH to use or disclose the information for another purpose or the use or disclosure of the information is required or authorised by law or a court/tribunal order).

CEH may disclose personal information about you to third parties. Examples of third parties that CEH may disclose your personal information to include, but are not limited to:
a) CEH’s service providers;
b) CEH’s agents, contractors and external advisors (for example, CEH lawyers, auditors and Catholic Development Fund Tasmania);
c) any person acting on your behalf, including your legal and financial advisers;
d) Government and other regulatory bodies, law enforcement bodies and courts as required or authorised by law;
e) external dispute resolution bodies;
f) other financial institutions; and
g) any other person where you have given your consent.

CEH is not likely to disclose your personal information to any overseas recipients.
Where your personal information is disclosed, CEH will seek to ensure that information is used, held and disclosed consistently with the Privacy Act and any other applicable laws.

8. Direct marketing
CEH may use or disclose your personal information (excluding sensitive information) for direct marketing purposes. CEH may conduct direct marketing via email, telephone, mail out or any other electronic means.
CEH will only use your sensitive information for the purposes of direct marketing if you have consented to the information being used or disclosed for the purposes of direct marketing.
If at any time you decide you do not want to receive any more marketing material from CEH, you may:
a) contact the Privacy Officer in accordance with paragraph 13 of this policy; or
b) opt-out of receiving any more marketing material via any opt-out mechanism contained in CEH’s marketing correspondence.

All CEH’s marketing correspondence will display a clearly visible and user-friendly opt-out mechanism. CEH may imply consent to receive direct marketing material if you do not use the opt-out mechanism.

If you request to no longer receive direct marketing material CEH will process your request within a reasonable period after the request is made.

9. Quality of personal information
CEH will take all reasonable steps to ensure that any personal information it collects, uses or discloses is accurate, complete, up-to-date and relevant to CEH’s functions or activities.
If you believe that your personal information is not accurate, complete or up to date, you should contact the Privacy Officer in accordance with paragraph 13 of this policy.

10. Access to personal information
You can access your personal information unless an exception in the Privacy Act applies.

You can request access to your personal information by contacting the Privacy Officer in accordance with paragraph 13 of this policy.

Depending on the nature of the request, CEH may charge you a small fee for granting you access.

CEH will respond to a request for access within a reasonable time (usually 30 days), and give access in the manner requested by you, if it is reasonable and practicable to do so.

Sometimes, it may not be possible for CEH to give you access. If CEH refuses to give you access, it will:
a) take reasonable steps to give you access in a manner that meets CEH’s needs as well as yours;
b) provide you with written reasons for the refusal provided it is reasonable to do so; and
c) provide you with the mechanisms available to complain about the refusal.

11. Correcting personal information
If you think that any personal information CEH holds about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request CEH to correct the information by contacting the Privacy Officer in accordance with paragraph 13 of this policy.

CEH will take all reasonable steps to correct that information to ensure that, having regard to the purposes for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

If CEH corrects personal information that has been disclosed to another entity and you ask CEH to tell the other entity about the correction, CEH will take all reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.

If CEH refuses to correct the personal information, then it will provide you with:
a) written reasons for the refusal provided it is reasonable to do so; and
b) the mechanism available to complain about the refusal.

CEH must respond to a correction request within a reasonable time (usually 30 days).

12. Anonymity
You have the option to remain anonymous, or to use a pseudonym when dealing with CEH where it is lawful and practical to do so.

13. Data Breach
A Data Breach is an incident where personal or confidential information, or non-personal information that could be sensitive or commercial is compromised, disclosed, copied, transmitted, accessed, removed, destroyed, stolen or used by unauthorised individuals, whether accidently or intentionally.

CEH is obligated under the Australian Privacy Amendment (Notifiable Data Breaches) Act 2017 to notify individuals whose personal information is involved in a data breach that could potentially result in serious harm.

14. Complaints or queries
If you:
a) have any issues about the way CEH handles your personal information after reading this policy;
b) become aware of a potential breach of privacy; or
c) wish to make a privacy complaint,

You are requested to contact the CEH Privacy Officer at:

CEH Privacy Officer
Email: privacyofficer@aohtas.org.au
Telephone: (03) 6208 6222
Post: Shop 2, 28 Green Point Rd, Bridgewater, TAS, 7030
Visit: 35 Tower Road, New Town, TAS, 7008

If CEH’s Privacy Officer is unable to resolve the matter, it will be escalated (internally or externally) as appropriate to facilitate resolution.

If you are not happy with the outcome of CEH’s Privacy Officer’s investigation, then you can raise your concern with the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner Telephone: 1300 363 992
Email: enquiries@oaic.com.au
Mail: GPO Box 5218 Sydney NSW 2001
Web: www.oaic.gov.au

Changes to this policy
CEH will review this policy from time to time. CEH encourages you to check its website regularly for any updates to this policy.

Housing Allocation Policy

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We select tenants based on an assessment process which considers individual and local housing needs. Our procedures for allocating housing ensure transparency and consistency.

Eligibility based on relative need

We have eligibility criteria for the different types of rental housing we manage, aligned to relevant legislation, funding guidelines and our organisation’s aims.

We will not discriminate unlawfully against people on the grounds of gender, race, age, marital status, disability or sexual preference. However, we do manage housing that is specifically allocated to support particular groups (such as women fleeing domestic violence) with the eligibility criteria reflecting government/public policy initiatives.

We will ensure that any information used to assess potential tenants is a fair and non-discriminatory.

Applying for housing

We allocate Social Housing using the Tasmanian government’s public housing register or, our own standard Affordable Housing application form. We will make this application form, and this policy, publicly available for potential tenants to access and apply for housing.

Our application form only collects enough information to inform our decision-making around eligibility and priority for allocation, and for us to fulfil data reporting requirements. We will support those applicants who may need assistance to complete the application form. We will offer applicants a copy of their completed application form.

If required, we will supplement the application form with a personal interview — either at the time of application or when a housing allocation is being considered. We will hold an interview at a time that suits the applicant and prefer face-to-face where possible but may interview by telephone. We will arrange an interpreter if needed.

We will provide applicants with information about:

• the assessment process;

• when they will get a decision;

• how long they can realistically expect to wait for housing.

We periodically review Affordable Housing applications and the applicants’ continuing eligibility. In addition to this review and at the time of allocation, we check that an applicant continues to meet the eligibility criteria for the housing type being offered. We encourage applicants to keep themselves on the eligibility list by providing an alternate contact person and number and/or regularly confirming their interest.

Allocating housing stock, including any priority categories

We allocate housing openly and fairly, based on eligibility criteria and a range of factors such as local community needs, property type, tenant mix, an individual’s current circumstances, financial considerations and household size relative to the available property size.

When we make an offer of housing (by phone, email or letter) we will allow the applicant adequate opportunity to make an informed choice about whether to accept it. In order to make an informed decision, we will provide the applicant with opportunity to:

• ask any questions;

• visit the property;

• refuse the offer;

• request modifications and repairs.

Our allocation procedure balances the rights of a tenant to refuse an offer of housing on reasonable grounds, with our need to manage properties efficiently and to assist other applicants. We consider an offer is reasonable if the property meets the following criteria:

• has the number of bedrooms the potential tenant’s household requires;

• is located in the allocation zone requested (the property may be in any suburb within the allocation zone);

• has any other features the tenant has been assessed as needing.

We monitor housing allocations to ensure that they are made efficiently, within documented timeframes and in accordance with procedures. We are required to report on:

• frequency and length of vacancy periods;

• numbers of allocations by household type;

• tenant satisfaction;

• allocation process.

Nomination agreements with third parties

For those properties we manage on behalf of others, we have formal agreements that are regularly reviewed. Irrespective of housing type and related eligibility criteria, our commitment to fairness, consistency and transparency applies to all allocations across all the properties we manage.

Establishing & Maintaining Tenancies Policy

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We are tenant-focused and actively work with tenants to establish and maintain successful tenancies. To this end, we have documented tenancy management procedures that are consistent with relevant legislation and our organisational aims.

Establishing tenancies

We provide clear information to ensure tenants understand their rights and responsibilities. This includes expectations under both the Residential Tenancy Act and our own policies and procedures. We provide this advice before a lease agreement is signed.

When establishing a tenancy, we take the tenant through our lease agreement and explain the major clauses to them. These include the length and type of tenancy agreement and the processes around eviction. We provide information about:

• bonds (if they are collected);

• rent payment, rent methods and rent arrears;

• our approach to property improvements and repairs;

• procedures for reporting repairs;

• maintenance the tenant is responsible for;

• how to manage neighbourhood disputes and conflict.

At this time, we will also provide tenants with information about:

• our services and procedures for housing management;

• how to contact the organisation;

• how to engage with us through meetings and surveys;;

• how to access advice and advocacy services.

We will make all of this information accessible for tenants and facilitate translation if required.

We ensure that condition reports are completed prior to occupancy and we provide the tenant with a completed and signed copy of the report. We document any repairs that are needed and advise timeframes for completion of these works.

Managing security deposit/bonds

Where bonds are collected, we will advise tenants how much bond will need to be paid at the start of the tenancy and how it needs to be lodged.

Rent management

We have affordable rent benchmarks, a rent setting policy for each type of social and affordable housing we manage, and documented methods for calculating the rent payable. We provide Tenants with an explanation of how their rent is calculated. We offer a range of rent payment methods, described in the lease agreement, on our website and in our Tenant Handbook.

We have a procedure for managing rental arrears. We establish realistic repayment arrangements with each tenant if required. We encourage tenants to give early notice of financial difficulties and we make referrals (with the tenant’s permission) to organisations who can assist with budgeting or financial counselling.

We have a procedure for conducting rental and income reviews. We conduct rent reviews annually, or upon advice that the tenant’s circumstances have changed. We inform tenants what they need to provide and give adequate notice of a change in rent, consistent with the Residential Tenancy Act.

Addressing disputes between tenants and neighbours

We are committed to working with tenants to achieve successful and long-term tenancies and more broadly, building positive and sustainable neighbourhoods and communities. We support tenants to respect that every tenant has the right to live peacefully in their home.

We expect and will support tenants to follow the conditions outlined in their lease agreement. This includes being responsible for their own behaviour and the behaviour of visitors and occupants at their property so that neighbours are not unreasonably disturbed.

We encourage tenants to try to solve issues with neighbours by talking with them directly or through a mediator. We will not get involved in this process as an advocate or third party.

As outlined in the lease agreement, our properties cannot be used for any illegal purposes and if we believe this is the case, we will refer the matter to Tasmania Police.

The changing needs of tenants

We will respond to the changing housing needs of tenants fairly and flexibly, within our capacity and in a manner that is consistent with legislation, eligibility criteria and our allocation procedures.

We will work with tenants who are experiencing domestic violence, or whose relationships have broken down, to find appropriate housing solutions. For existing tenants who want to transfer homes within our property portfolio, we will consider changes in a tenant’s housing need, (including those that are identified and raised by external support agencies working with the tenant), relative to the availability of alternate housing and our waiting lists.

For those tenants whose circumstances change through illness or injury, we will endeavour to provide support to assist them to maintain their tenancy and so remain in their home. This may include arranging adaptations to the property itself or assisting the tenant to access home modification services and funding or, facilitating access to support services that provide in-home care. Where maintaining the tenancy is not an option, we will work with other support services and agencies to try and find alternative accommodation.

Our aim is to ensure the most effective use of each property, aligned to the changing needs of tenants. We will seek to limit under occupancy issues where they occur.

Access to services

We offer applicants and tenants, as far as possible, opportunities to access a range of services appropriate to their needs, including access to relevant support to help manage and maintain their tenancy. Our written and online sources of information will be current, accessible, and user-friendly and reflect our commitment to ensuring equitable access to our activities and services.

Our primary office located at Bridgewater is open business hours Monday-Friday and is wheel chair accessible. An emergency maintenance phone response operates after-hours including weekends.

We aim to provide services that are culturally appropriate to our potential and current service users by accessing resources from, and consulting with, other relevant organisations and agencies. Our positive working relationships with other agencies can help tenants access a full range of support options. With the tenant’s agreement, we will make a referral to another agency where the tenant would benefit from additional support in order to remain housed.

This policy aligns with Standards 1.2, 1.3, 3.4 and 4.1 of the National Community Housing Standards

Ending Tenancies Policy

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We will respond immediately to advice or indication that a tenant will be moving out of their property (or has moved out) and we will work proactively to support a planned and stable exit.

We will support the tenant to understand and meet their lease obligations. We require the tenant to pay, either in full or by instalments, any outstanding debt.

We have procedures to manage voluntary and forced termination of tenancies that are consistent with legislation. Our procedure outlines who in the organisation is empowered to make decisions regarding terminations and how records of communication are documented and maintained.

We will not evict without a just cause and we take reasonable steps to ensure tenants are not evicted into homelessness.

Forced terminations

We will take all reasonable steps to support a tenant to uphold their lease obligations, such as:

• attempt to hold a personal interview with the tenant outlining the situation

• provide information and facilitate access to support agencies

• encourage the tenant to attend any Court or legal hearings

When these efforts fail and we initiate a tenancy termination, we will proactively attempt to engage with the tenant and continue to treat the tenant fairly and with respect. We will ensure that due legal process is followed and relevant legislation is adhered to.

We will facilitate access to our complaints policy for those tenants whose tenancy is terminated and who wish to raise issues about the termination with us.

Voluntary terminations

When a tenant gives notice of ending a tenancy, we will:

• attempt to organise a joint inspection of the property. We will use the condition report prepared at the beginning of the tenancy as a baseline for identifying damages that the tenant is responsible for. A joint inspection also provides the opportunity for the parties to make an agreement about any outstanding issues or actions that need to be taken;

• calculate rental payment and assess bond conditions (if applicable).

Abandonment of tenancy

We have a procedure that is consistent with relevant legislation, to recover possession of an abandoned property and deal with any of the tenant’s goods. We keep records and document all action taken in line with legislation to:

• contact the tenant and inform them how long their goods will be stored

• take an inventory of the goods

• store the goods for a reasonable period

• dispose of the goods

• recover any costs in relation to the disposal of goods and/or cleaning/repairing the property

This policy aligns with Standard 1.4 of the National Community Housing Standards

Responsive Maintenance & Repairs Policy

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We are committed to effectively repairing and maintaining the properties we manage for the benefit of both our organisation and our tenants.

We have procedures for initiating, monitoring and completing responsive maintenance and repairs. These procedures:

• enable us to deliver good customer service in a timely manner that is consistent between tenants and across properties;

• take into account funding guidelines and arrangements as well as the types, ages and current condition of properties;

• are consistent with the Residential Tenancy Act 1997.

We provide easy-to use information on repairs and maintenance to ensure tenants understand the process for having repair requests approved and acted upon so they have realistic expectations. This information, available on our website and in the Tenant Handbook, includes:

• how to request repairs;

• time frames for different categories of repairs;

• ways to comment on the repairs.

We welcome feedback from tenants about repairs and maintenance via phone, email, in person at our office or by completing a feedback form or tenant survey.

We measure our performance in the area of repairs and maintenance, using indicators such as tenant satisfaction, timeliness, quality and price.

Tenant Repair Costs

We advise tenants about their responsibility for the cost of repairs due to intentional damage, neglect caused by the tenant or a member of the tenant's household (including pets), or a visitor. When damage occurs, the tenant can expect:

• that we will collect and record information about the type and extent of damage to the property and the circumstances under which the damage has occurred;

• to be provided with written notice when we consider that they are responsible for repair costs;

• the opportunity to dispute liability and that we will review our decision to charge the repair costs and either:

• to cancel or amend the Tenant Repair Costs and advise the tenant in writing; or

• to take cost recovery action;

We require tenants to tell us as soon as possible if the property has been damaged and to report to Tasmania Police any damage that is suspected to have resulted from criminal activity, such as break and enter, vandalism or domestic violence.

Property inspections

We have a program for regularly inspecting properties that includes:

• an annual inspection of each property (minimum);

• an inspection at the time a tenant is vacating a property, using the Property Condition Report;

• inspections before and after complex repairs;

• periodic stock condition surveys undertaken by a qualified professional.

We conduct inspections in accordance with the Residential Tenancy Act 1997. If we determine that more frequent inspections are necessary to maintain a tenancy, we will manage these to ensure that the tenants’ right to privacy and quiet enjoyment is not violated.

Vacated properties

As described in the lease, tenants are required to provide a minimum of 14 days written notice of their intention to vacate the property. We have a procedure for managing vacating tenants.

We provide the tenant with a simple checklist of things to do so they have every opportunity to receive their bond back (where applicable) and understand that the property is to be restored to the condition it was in at the start of the tenancy, allowing for fair wear and tear. This includes cleaning, rubbish removal and not leaving goods at the property such as furniture and vehicles.

We will carry out a final inspection with the tenant (where possible) and complete the Property Condition Report. It is the tenant’s responsibility to return keys to us. Once the tenant has returned the keys to us and vacated the property, the tenant is not responsible for any subsequent damage.

If the tenant abandons the premises or fails to return the keys, we will obtain possession of the property and assess its condition. If there is evidence that the tenant is responsible for damage that goes beyond fair wear and tear, we will attend to the repairs and invoice the tenant for related costs.

We have procedures for the maintenance of properties after they have been vacated to:

• identify what maintenance work is to be undertaken;

• prioritise health and safety issues;

• bring forward planned maintenance or major upgrades if applicable;

• identify and manage insurance implications, and

• mitigate potential damage and vandalism to the property.

Agreements with contractors

We select and work with contractors to ensure that the interests of our organisation are protected and, in particular, that contractors:

• respect our tenants and their home and property;

• deliver good quality work in a timely fashion;

• are competitively priced and represent value for money.

We have guidelines for selecting contractors and agreements that describe our expectations and what each contractor can expect from us. We review contractors’ reliability, timeliness and quality of work for price and provide them with feedback.

Responding to afterhours emergencies

We provide an afterhours service for emergency repairs. When responding to an emergency repair, our contractors will conduct a phone assessment to determine whether the issue needs to be attended to immediately. If the property is deemed uninhabitable, the General Manager, Housing Operations will source emergency accommodation. Examples of emergency repairs are described in our Tenant Handbook.

This policy aligns with Standard 2.2 of the National Community Housing Standards

Complaints & Appeals Policy

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We welcome complaints and appeals as an opportunity to improve what we do. We will respond promptly and fairly and have a documented procedure for receiving and responding to complaints and appeals within nominated time-frames.

Information about lodging a complaint or appeal is provided to tenants at lease sign-up, available on our website and is included in the Tenant Handbook. Tenants can also seek information and forms in person by visiting or phoning our office. We also provide information on how to access advocacy organisations or individual advocates who can help to lodge a complaint or appeal. We will provide an interpreter service if necessary.

How we respond to complaints and appeals

We commit to:

  • responding to your complaint courteously and respectfully;
  • keeping you informed of the progress of your complaint;
  • addressing each complaint in an equitable, objective manner;
  • protecting personally identifiable information about the complainant, other than for the purposes of addressing the complaint within our organisation.

Where tenants complain to us about a range of issues that fall outside our jurisdiction we will respond constructively and refer tenants to the relevant body or advocacy services as appropriate.
Our feedback and complaints mechanisms form part of a regular, external auditing process.

Complaints relate to dissatisfaction with an area of our service delivery, over which we have direct control. Generally, complaints relate to the manner in which we provided the service to you, by a staff member, contractor or third party working on our behalf. Our complaints process allows a tenant or third party to formally express their dissatisfaction, have their point of view heard and obtain some form of resolution.

Appeals relate to a tenant or service user’s dissatisfaction about the outcome of a complaint made to us. Our appeal process gives the tenant opportunity to dispute our decision and possibly have it changed.

Disputes relate to wider neighbourhood issues such as difficulties with neighbours or accusations of antisocial behaviour. Mostly, these are areas that we do not have direct control over, which is why disputes are covered in our separate policy, Establishing and maintaining tenancies.

This policy aligns with Standard 3.6 of the National Community Housing Standards

Complaints & Appeals Procedure

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Centacare Evolve Housing employees are required to respond to feedback, suggestions and complaints according to the principles and guidelines outlined in this procedure.

We will:

• make sure that people know how to contact us to tell us what they think;

• listen to what they have to say;

• do our best to understand stated concerns or issues;

• investigate any concerns raised in a fair and impartial manner;

• do our best to resolve the issue or fix the problem, although this may not always be possible;

• acknowledge any mistakes or errors we have made;

• provide clear explanation for all our decisions, unless limited by law;

• provide a pathway to appeal any decisions we have made.

The following will guide our response, handling and management of all complaint to Centacare Evolve Housing:

• All feedback will be received respectfully;

• All feedback will be acknowledged and managed to specific, agreed and published timelines;

• All decisions will be explained clearly.

How people can provide feedback

People can provide feedback in person at reception, by phone, website, mail, email or to Centacare Evolve Housing employee.

What people can expect from us when lodging a complaint

We will:

• listen to the complaint and attempt to resolve the matter immediately if possible;

• investigate all complaints in a timely manner;

• provide a response to the complainant at the conclusion of our investigation of the complaint.

We expect:

• you talk to our staff respectfully;

• you provide us with as much information about the complaint as possible;

• you let us know of any special needs or if extra help is needed in understanding or accessing our complaints service.


Timeframes for acknowledging complaints:

Phone - 1 business day

Email or letter - 1 business day

Letter (no phone number provided) - 5 business days

Where possible complaints will be rectified immediately. If not, we discuss a suitable timeframe with you depending on the nature of your complaint. However we would expect all complaints to be resolved within two weeks.

In the unlikely event that we are not in a position to fully resolve your complaint within this timeframe, we will contact you to discuss this further.

Record Keeping

All feedback is recorded in our tenant management system.

Responses and Remedies

Possible responses and remedies include:

• an explanation;

• an acknowledgement of each parties perspective and agreement on ways to manage differences;

• an apology or expression of regret;

• an admission of fault;

• a change of decision;

• a change of policy, procedure or practice;

• agreement on what constitutes acceptable behaviour;

• an undertaking that unacceptable behaviour will change.


There maybe occasions where you wish to appeal the decision that was made in relation to your complaint. Appeals can be lodged with the General Manager of Centacare Evolve Housing by email or in writing. In order to be valid, appeals need to be lodged within 2 weeks from the date that the original decision was communicated to you.

Appeals will be handled internally by our senior management team. A new determination can be made when it is found that one or more of the following apply:

• the initial decision was based on an error;

• the initial decision was based on incomplete information;

• the initial decision was based on an incorrect interpretation of the information;

• the initial decision was contrary to higher principles, i.e. human rights, welfare of the child etc.;

• there were highly unusual circumstances;

• that new information is now available that was not available at the time the initial decision was made;

• there is provision for discretion, which had not been exercised.

Results of the appeal will be communicated within one week unless otherwise agreed.

External appeals process

If the internal processes have been exhausted and you wish to make a further appeal you can contact the ombudsman. The ombudsman will review appeals and determine the final outcome.

We can assist with contacting the ombudsman if needed.

Tenants Rights and Participation Policy

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We are committed to upholding tenant rights and to receiving feedback

We inform tenants of their rights and responsibilities through providing accessible information in plain English – at the time of application, in the tenancy/lease agreement, in the Tenant Handbook, on our website and when interacting with us by phone or in person.

We will utilise interpreters and other support agencies if required.

How we seek feedback

A fundamental right of all tenants is to provide us with feedback about the services we provide. Feedback from tenants provides us with an measure of how we are doing.

Where a significant issue arises that may be of interest to our tenants, we will seek their views through the Tenants Advisory Group (TAG) and may convene local meetings and events or conduct telephone surveys.

To ensure feedback and input is as widely accessed as possible, we use different methods for gathering feedback, including verbal, written, via electronic media, in groups or via our annual tenant satisfaction survey.

Where practical, we will involve tenants in the design of our service.

We monitor tenant participation in our organisation through the levels of feedback from consultations (attendance at meetings, returned surveys).

We monitor complaints and appeals as valuable sources of feedback.

This policy aligns with Standard 3.1 and 3.2 of the National Community Housing Standards