PRIVACY AND CONFIDENTIALITY POLICY
As a provider of services, sales and hire to the wider community, INDEPENDENCE WORLD requires access to a range of private and personal information that assists us to achieve our obligations according to relevant laws, as well as enabling us to meet the service needs of our Clients, customers and fulfill our role as an employer. In doing so, INDEPENDENCE WORLD will take precaution to only use information gathered as you choose or that is required so that we can continue to provide you with services, sales and hire.
CLIENT POLICY STATEMENT
To provide an effective and high-quality service and to maintain appropriate accountability, we must collect, store and sometimes share relevant personal information about our Clients. It is important that we are consistent and careful in the way we manage what is written and said about a client and how we decide who can see or hear this information.
Our Clients have legislated rights to privacy. It is essential that we protect and uphold these rights, and also that we act correctly in those circumstances where the right to privacy may be overridden by other considerations.
To uphold the rights of Clients to privacy, each staff member needs an appropriate level of understanding about how we meet our legal obligations.
All Employees are obliged to sign the confidentiality clause in their employment contracts at commencement with INDEPENDENCE WORLD. A code of conduct is included in the signed Employment Agreement for Employees regarding confidentiality.
In the context of this policy the following definitions apply:
Confidentiality: A principle which states that personal information about others should not be revealed to persons not authorised to receive such information. It is our Employee’s obligation to respect our Client’s privacy and to keep secure the information that is shared so that service users feel confident to discuss their private situation. Confidentiality applies to verbal information, written information and information stored on computers.
Privacy: Privacy is the right of an individual or group to exclude information about themselves and thereby reveal personal information about themselves selectively. The boundaries and content of what is considered private differs between cultures and individuals, but shares basic common themes. Privacy is facilitated for service users by the provision of suitable interview spaces and private areas to discuss personal information. These arrangements will be made with consideration for work place health and safety requirements and Employee safety at all times. INDEPENDENCE WORLD will only collect information that is necessary for its specific service activities, will only collect personal information in a lawful and un-intrusive way and only collect information about an individual from that individual wherever possible.
Personal information: In the Commonwealth Privacy Act (1988) this means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Informed consent: Infers that the Client has been provided with all the necessary information relating to how we manage their personal information. Informed Consent is required before we can collect personal information. For consent to be valid it must be given by a person with the capacity to give it. In certain situations this can be provided by an authorised representative of the Client. I.e.: Informal support; Advocate.
Limits to confidentiality – There may be limits to confidentiality based on business procedure and legal requirements in some circumstances. The best interests of the Client must always be taken into consideration when deciding whether to share information.
(a) A document
(b) A database (however kept)
(c) A photograph or other pictorial representation of a person
- At initial contact with INDEPENDENCE WORLD Care service the Client must be made aware of the context in which the service is provided, the purpose for collecting personal information and limits to confidentiality.
- Employees must gain written consent by Clients for the collection, sharing and storage of personal information by completing a Client Consent Form which is stored in their Client file in locked filing cabinets.
- Written consent covers the requirements contained within the Information Privacy Act 2009and includes circumstances that may require the sharing of Client information such as those with co-Employees, other agencies or government departments.
- In situations where Client information may need to be shared, staff should endeavour to let Clients know that this has happened and involve Clients in the decisions and the process.
- Employees are to make decisions on sharing information according to the above procedures and/or in the best interests of the Client in order to achieve identified outcomes.
Limits to Confidentiality
- The Employees will explain that the limited confidentiality conditions include:
- That information will be shared at internal staff meetings.
- That non-identifying information will be shared across agencies involved in their individual care plan.
- That the service has procedures regarding safety risks and that confidentiality will not be observed in the following circumstances.
- If an Employee is made aware that a serious crime has been committed or is about to be committed and the Employee knows the details to be accurate, they are obliged to report such information to the Office Manager, who will report to the police.
- Any issue which presents a serious or imminent threat that could endanger the life, health or safety of the Client, their dependents, other service users or Employees.
- If a Client informs you of an intention to harm themselves, another individual or presents a danger to the community in general, under common law guidelines you are obliged to respond by contacting the appropriate agency and authorities.
- If Employees have concerns about child abuse or neglect, it is an organisational policy to report these concerns to an authorised officer at Department of Child Safety. In this instance the Employee would not be departing from any ethical code of conduct in breaking confidentiality. The Office Manager will determine the most appropriate course of action in these cases.
- The Employee will follow the relevant policy e.g. Child Protection Policy
- If the Police produce a Search Warrant requesting Client information.
- If a valid search warrant is not produced the organisation is not obliged to provide personal information. This decision may be based on the best interest and safety of the Client or community.
- If the Employee or the Employee records are subpoenaed to court, the party seeking the records must be able to justify the need to have access to Client’s information.
- Employees will consider the physical arrangements of the Client’s premises to ensure maximum privacy for Clients at all times.
- Efforts to meet this policy are made by the appropriate arrangement of the office space, by keeping desk tops clear of personal information and by Employees ensuring respect for the privacy of Clients when in discussion on the phone and face to face with other Employees or external parties.
- Employees are responsible for ensuring that their own diary notes do not breach privacy principles. All diaries and files must be locked away when the Employee is absent from their desk and when the premises is unattended.
- To protect Client’s privacy, information recorded will be complete, relevant and factual. Opinions are not recorded as facts; any subjective opinions recorded will be acknowledged as such.
- All intake assessments will take place in a private space. Where possible Clients will be involved in the recording process.
MEDICAL SALES AND MOBILITY EQUIPMENT HIRE POLICY STATEMENT
At INDEPENDENCE WORLD we understand the absolute importance of security and privacy when purchasing or enquiring about products and services online or via E-mail, fax and phone. It is because of this that we have taken every precaution possible to ensure that when you do, your order or enquiry is processed safely and securely. However, data transmitted over the internet can never be completely secure and while we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We only collect the information that is necessary for us to have in order to provide you with exceptional sales, services, products or equipment hire. The only way we receive this information is from what you or your representative chooses to give us. This may be via phone, E-mail, fax, website surveys and forms or face to face.
HOW WE USE YOUR PERSONAL INFORMATION
- Identification of fraud or error.
- Regulatory reporting and compliance.
- Process sales and hire contracts.
- Internal accounting, marketing and administration.
- Servicing our relationship with you by, providing updates on promotions and services we think may interest you and gaining feedback on our relationship with you so we can improve it.
- We may provide generic information to third parties such as manufactures so that we can give you the correct equipment or medical products that suit your needs and requirements.
WHAT WE DO AND DON’T DO WITH YOUR PERSONAL INFORMATION
- We do not share your information with, or sell it to, other parties without your permission.
- Your personal information will not be disclosed to a third party without your prior consent, except as we may be required to do so by law.
- All confidential information will be archived or disposed of securely.
- We undertake to provide the person with access to their own information, and the right to correct it if necessary.
- The security of your personal information is important to us. When you enter sensitive information (such as credit card numbers) on our website, we encrypt that information using secure socket layer technology (SSL). When Credit Card details are collected, we simply pass them on in order to be processed as required. We never permanently store complete Credit Card details.
- When a Facebook button is used, the information is sent to Facebook.
INDEPENDENCE WORLD uses the eWAY Payment Gateway for its online credit card transactions.
eWAY processes online credit card transactions for thousands of Australian merchants,
providing a safe and secure means of collecting payments via the Internet.
All online credit card transactions performed on this site using the eWAY gateway are secured
- Payments are fully automated with an immediate response.
- Your complete credit card number cannot be viewed by INDEPENDENCE WORLD or any outside party.
- All transactions are performed under 128 Bit SSL Certificate.
- All transaction data is encrypted for storage within eWAY’s bank-grade data centre, further
protecting your credit card data.
- eWAY is an authorised third party processor for all the major Australian banks.
- eWAY at no time touches your funds; all monies are directly transferred from your credit card to the
merchant account held by INDEPENDENCE WORLD.
For more information about eWAY and online credit card payments, please visitwww.eWAY.com.au
CHANGES TO OUR POLICY
From time to time it may be necessary for us to review and revise this Policy. We reserve the right to change our Policy at any time. Should this occur the amendment would be posted on our website and or mailed to our customer base.
|Client Consent Form|
Code of Conduct Policy
Information Management Policy
Child Protection Policy
Information Privacy Act 2009
Privacy Act 1988 (cth)
Disability Services Act 2006
Service Standard 1: Service Access
Service Standard 4: Privacy, dignity and confidentiality
Service Standard 6: Valued Status
Service Standard 8: Service Management
Service Standard 10: Staff recruitment, employment and development
Date Made: May 2014
Date Last Reviewed: November 2018
Date Last Amended: May 2014
Date Next To Be Reviewed: May 2019