Privacy Policy

 

 

Privacy and Confidentiality Policy and Procedure

 

POLICY STATEMENT

 

Inner West Paediatrics Ltd is committed to protect the privacy of the clients and community partners we work with. Inner West Paediatrics respects the privacy of others and is bound by Australian Privacy Principles outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth). The information we collect allows Inner West Paediatrics to provide the best service to our clients. With the permission of the client’s parent or guardian, Inner West Paediatrics only collects what we need in order to deliver programs and supports relevant to our clients.

 

DEFINITIONS

 

Personal Information - Information or an opinion about an identified individual, or an individual who is reasonably identifiable. For example: name, address, email and phone details.

 

Sensitive Information - is a subset of personal information that can include information or opinion about a person e.g. Religion, criminal record; health information, genetic information and biometric information.

 

Health Information - is defined as information on the person such as a disability, wishes about the future provision of health services or genetic information.

 

OBJECTIVES

 

The objectives of this policy are to:

 

  • Promote privacy and confidentiality as a priority for people accessing Inner West Paediatrics’ services.
  • Implement reasonable steps to safeguard the information Inner West Paediatrics holds about individuals.
  • Assist employees in understanding their obligations regarding privacy and

 

What Does Privacy and Confidentiality Mean for Clients?

 

An individual’s right to privacy and confidentiality underpins all practices at Inner West Paediatrics. Before accessing a program or support from Inner West Paediatrics a client’s legal guardian (if under 18 years) must agree to collecting and exchanging personal information for the purposes of providing a service to the person.

 

Please refer to:

  • Service Agreement and Privacy Statement
  • Case History Form
  • NDIS Service Agreement


 

A client’s legal guardian/s have a right to know what information Inner West Paediatrics keeps about them and can request access to this information at any time. It is appropriate that this is supervised and only provided to people with a legal right to access the information. For example, a parent cannot request to access information about a client unless they are their legal guardian. This information should only be provided in accordance with the Australian Privacy Principle 12: access to personal information and 13: correction of personal information. . Exchange of personal information must be in accordance with the Australian Privacy Principle 6: Use or Disclosure and Australian Privacy Principle 7: Direct marketing.

 

Employees must take appropriate steps to ensure information about a client is only discussed/relayed to support the provision of service and in an appropriate and secure environment.

 

Employees are to ensure that all personal information is treated in a way that respects the individual’s right to confidentiality and dignity. This includes ensuring that a person’s issues are not discussed:

  • With employees other than those who need to know in the team,
  • With employees of other agencies or service providers unless consent to share information has been provided,
  • In front of the person if they are not included in the conversation,
  • With others without the child or young person’s consent, and
  • In

 

Children and Young Persons

 

The legal framework for inter-agency information exchange established under the Children and Young Persons (Care and Protection) Act 1998 allows organisations to share information about children or young people without their clients’ consent. It takes precedence over the protection of confidentiality or of an individual’s privacy because the safe welfare and well-being of children and young people are paramount.

 

Please refer to:

  • Child Protection Policy and Procedure

 

Children and young persons in statutory out of home care are subject to additional requirements under the Children and Young Persons (Care and Protection) Act 1998 (refer to Sections 105 and 149).

Requirements are outlined under the NSW Child Safe Standards for Permanent Care (refer to standard 7: Confidentiality and Privacy).

 

What does Privacy and Confidentiality Mean for Employees?

 

Prior to commencing work all employees sign an employment contract. These documents specify requirements to ensure appropriate levels of confidentiality are maintained. Privacy at Inner West Paediatrics covers people’s personal information and sensitive information.

 

Please refer to:

  • Code of Conduct Policy and Procedure


PROCEDURE

 

Collection of Information

 

Inner West Paediatrics collects information about individuals who are supporters, volunteers, consultants, service providers, clients and their families. The kind of information collected includes:

  • Name, address, contact information (including telephone numbers and email address)
  • Identification
  • Forms submitted
  • Payment details
  • Information about people’s dealings with us or organisations we work with, including records of any telephone, email or correspondence.

 

In some circumstances such as where you use a particular program or support Inner West Paediatrics provides, we may collect health and disability information and assessments and other information the client’s family or carer may choose to provide to assist us in the delivery of our programs. Some of this personal information is collected via the Inner West Paediatrics website if you fill in an online form, for example from ‘contact us’ feature on the website and emails. Inner West Paediatrics also collects some personal information directly from third parties including public sources, organisation, representatives, information service providers, social media and the parties with whom we exchange information as described here. Sensitive information can only be collected with the consent of the individual or guardian. Inner West Paediatrics collects information from families in this occasion to support their child and ensure that there is a safe environment for them, for example, with respect to children’s allergies. Inner West Paediatrics follows the Australian Privacy Principles (APPs) which regulate the handling of personal information and collects information and maintains records about employees.

 

Examples include:

  • Learning and development records including plans and training
  • Information including personal contact details, employment dates, classifications, leave
  • Hard copy records, for example, completed leave forms and
  • Centralised HR
  • Records relating to injuries, incidents and workers compensation
  • Payroll
  • Supervision and performance review and appraisal
  • Site induction records. (e.g. locked office/storage room, filing cabinets, password protected electronic records, secure storage or locked cabinets and secure network drives) and is only accessible to people with authority to view these records.

 

Inner West Paediatrics collects this information in order to fulfill its obligations as an employer and will not disclose to third parties without consent (unless the third party has a legal right to access the information).

 

Use and Disclosure

 

Inner West Paediatrics will:

  • Obtain consent from the person before disclosing any

 

  • Only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose.

 

Inner West Paediatrics will use and disclose your personal information for the purposes for which it was collected:

  • To manage the relationships with you or the organisation you
  • To provide you with information about events or other products or services that may interest you or the organisation you may represent.
  • To facilitate Inner West Paediatrics’ internal business operations, including fulfilling legal

 

Inner West Paediatrics may also collect, use, hold and disclose personal information to:

  • provide a receipt for sales,
  • confirm your identity and personal information,
  • maintain and update Inner West Paediatrics’s records,
  • train and manage Inner West Paediatrics’s people,
  • respond to your queries or complaints appropriately, and
  • provide you with efficient feedback

 

We may not be able to do these things without your personal information. For example, we may not be able to respond to your queries and/or provide receipts. Inner West Paediatrics will only provide personal information to third parties where authorised or required by law, or with your consent either expressed or implied. The parties we exchange personal information with include your and our representatives and our service providers that assist us with archival, accounting, stakeholder contact, legal, banking, payment, debt collection, delivery, data processing, data analysis, document management, information broking, research, investigation, insurance, website and technology services.

 

Quality and Right of Access

 

Inner West Paediatrics welcomes your assistance to help us keep personal information accurate and up to date. Please contact Inner West Paediatrics should any personal information be incorrect or incomplete. Inner West Paediatrics will provide access to your personal information in certain circumstances for which a fee may be charged. We may need to verify your identity. Access or updating may be denied in some circumstances as permitted by the Australian Privacy Principles or other applicable laws. We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information. Please contact Inner West Paediatrics if you would like to make a request.

 

Storage and Security

 

Inner West Paediatrics will:

  • Safeguard the information collected and stored against misuse, loss, unauthorised access and
  • Only destroy records in accordance with the organisation’s Information Management Policy and Australian Law.

 

  • Information about clients (when not in use) should be kept in a secure area at all times (for example, locked office/storage room, filing cabinets, password protected electronic records, secure storage or locked cabinets and secure network drives).
  • Only Inner West Paediatrics staff that can log into the system and the T contractor will have access to records.
  • Client records are destroyed and/or stored securely after their service has been
  • Systems and procedures are reviewed quarterly for misuse, interference, loss, modification, disclosure and unauthorised access.

 

Transparency

 

Inner West Paediatrics will ensure an open and transparent management system of personal information. It will:

  • Continually keep the Inner West Paediatrics Privacy Policy up to
  • Ensure stakeholders are aware of Inner West Paediatrics’s Privacy Policy and its purposes located in the Service Agreement and Privacy Statement and Welcome Pack.
  • Review practices, procedures and systems
  • Make this information freely available in print format and online through Inner West Paediatrics’ Practice Management Software (Cliniko).
  • Ensure the Executive team can answer feedback, privacy enquiries, and
  • Ensure that our Privacy Policy is available free of charge and in the form that an individual requests

 

Anonymity and Pseudonymity

 

It is your right to remain anonymous in your relationship with Inner West Paediatrics. Inner West Paediatrics will give stakeholders the option to remain anonymous when completing evaluation forms or opinion surveys, when there is no legal or contracted requirement to do so.

 

Making Information Available to Other Organisations

 

Inner West Paediatrics can only release personal information about an individual with that person’s express permission, via a signed release form. Inner West Paediatrics can release information to third parties where it is requested by the individual concerned.

 

Promotions, Direct Mail and Marketing

 

Inner West Paediatrics only sends promotions, direct mail and marketing to families and stakeholders when consent is obtained from the individual(s) concerned. Inner West Paediatrics will always provide a choice to ‘opt out’ from receiving promotions on any promotional material sent to stakeholders.

 

Please refer to:

  • Service Agreement and Privacy Statement

 

Images of Other Individuals

 

Photos of people are not published on the Inner West Paediatrics website unless that person or that person’s guardian has provided consent. Permission has been sought by parents to use the images of

 

their children on this website and should not be downloaded or used in any way by a third party without consent and against the wishes of carers and families.

 

Please refer to:

  • Case History Form
  • Service Agreement and Privacy Statement

 

We take your privacy concerns seriously. Where you express any concerns that we have interfered with your privacy, we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.

 

INTERNAL DOCUMENTATION

 

  • Case History Form
  • Service Agreement and Privacy Statement
  • NDIS Service Agreement
  • Child Protection Policy and Procedure
  • Information Management Policy and Procedure
  • Code of Conduct Policy and Procedure

 

 

Person Responsible

Head of Operations

Status (Draft/Released)

Released

Version

3

Date Last Reviewed/Updated

September 2023