Privacy Policy
PRIVACY AND DIGNITY POLICY AND PROCEDURE
Flow Healthcare Pty Ltd will manage and ensure that the organisation provides participants access to services and supports that respect and protect their dignity and right to privacy.
This policy applies to all staff and contractors.
POLICY:
Flow Healthcare Pty Ltd is committed to protecting and upholding all stakeholders’ right to privacy and dignity, including participants, staff, management and representatives of agencies Flow Healthcare Pty Ltd deals with.
Flow Healthcare Pty Ltd is committed to protecting and upholding the participant's right to privacy and dignity as the organisation collects, stores and handles information about participants, their needs and services.
Flow Healthcare Pty Ltd is subject to NDIS (Quality and Safeguards) Commission rules and regulations. Flow Healthcare Pty Ltd will follow the guidelines of the Australian Privacy Principles in its information management practices.
Flow Healthcare Pty Ltd will ensure that each participant understands and agrees to what personal information will be collected and is informed of the reason for the collection. The participant will be notified and agree that this information is being recorded material in an audio and/or visual format.Flow Healthcare Pty Ltd will advise each participant of privacy policies using the language, mode of communication and terms that the participant is most likely to understand. (Easy Read documents are made available to all participants).
Flow Healthcare Pty Ltd will ensure that:
It meets its legal and ethical obligations as an employer and service provider about protecting the privacy of participants and organisational personnel.
The participants are provided with information about their rights regarding privacy and confidentiality.
The participants and organisational personnel are provided with privacy, and confidentiality is assured when they are being interviewed or discussing matters of a personal or sensitive nature.
All staff, management, and volunteers understand what is required to meet these obligations.
Participants are advised of Flow Healthcare Pty Ltd's confidentiality policies using the language, mode of communication and terms most likely to be understood.
Flow Healthcare Pty Ltd will attempt to locate interpreters and use accessible materials.
This policy conforms to the Federal Privacy Act (1988) and the Australian Privacy Principles, which govern the collection, use, and storage of personal information.
This policy will apply to all records, whether hard copy or electronic, containing personal information about individuals and to interviews or discussions of a sensitive personal nature.
PROCEDURES
Dealing with personal information
In dealing with personal information, Flow Healthcare Pty Ltd staff will:
- Ensure privacy for the participants, staff, or management when they are being interviewed or discussing matters of a personal or sensitive nature.
- Only collect and store personal information necessary for the organisation's functioning and activities.
- Use fair and lawful ways to collect personal information.
- Collect personal information only with consent from the individual.
- Ensure that people know the type of personal information being held, the purpose of keeping the data, the method by which it is collected, used, and disclosed, and who will have access to it.
- Ensure that personal information collected or disclosed is accurate, complete, and up-to-date, and provide access to the individual to review or correct incorrect information about themselves.
- Take reasonable steps to protect all personal information from misuse and loss from unauthorised access, modification, or disclosure.
- Destroy or permanently de-identify personal information no longer needed and/or after legal requirements for retaining documents have expired.
- Ensure that participants understand and agree with what personal information will be collected and why.
- Ensure participants are informed when any recordings occur in either audio and/or visual format. The participant's involvement in any recording must be agreed to in writing.
Participant Records
Participant records will be kept confidential and only handled by staff directly delivering services to the participant. Information about participants may only be made available to other parties with the participant's consent, their advocate, guardian or legal representative. A written agreement permitting the recording must be maintained in the participant's file.
All hard copy files of participant records will be kept securely in a locked filing cabinet in the office space.
All digital files of participant records will be password protected.
Responsibilities for Managing Privacy
All staff are responsible for managing personal information to which they have access. The Director is responsible for the content in Flow Healthcare Pty Ltd publications, communications and on the website and must ensure the following:
- Appropriate consent is obtained to include personal information about any individual, including Flow Healthcare Pty Ltd personnel (Consent Policy and Procedure).
- Information provided by other agencies or external individuals conforms to privacy principles.
- The website contains a Privacy Statement that clarifies the conditions of any collection of personal information from the public through their visit to the website.
The Director is responsible for safeguarding personal information about Flow Healthcare Pty Ltd's staff, management and contractors. The Director will be responsible for:
- Ensuring all staff are familiar with the Privacy Policy and administrative procedures for handling personal information.
- Ensuring that participants and other relevant individuals are provided with information about their rights regarding privacy and dignity.
- Handling any queries or complaints about a privacy issue.
Privacy Information for Participants
At the first interview, participants will be notified of the type of information being collected about them, how their privacy will be protected, and their rights regarding this data. Information sharing is part of Flow Healthcare Pty Ltd’s legislative requirements. Participants must consent to any information sharing between the organisation and government bodies. The participant can opt out of any NDIS information sharing during audits via their consent form.
Privacy for Interviews and Personal Discussions
To ensure privacy for participants or staff when discussing sensitive or personal matters, Flow Healthcare Pty Ltd will only collect personal information which is necessary for the provision of support and services and which:
- Is given voluntarily; and
- Will be stored securely on the Flow Healthcare Pty Ltd database.
When in possession or control of a record containing personal information, Flow Healthcare Pty Ltd will protect the record against loss, unauthorised access, modification or disclosure by reasonable steps. Suppose the record must be given to a person in connection with providing a service to Flow Healthcare Pty Ltd. In that case, everything reasonable will be done to prevent unauthorised use or disclosure of that record Flow Healthcare Pty Ltd will not disclose any personal information to a third party without the individual’s consent unless that disclosure is required or authorised by or under law.
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