PRINCIPLES

Sundale Ltd (referred to in this document as we, us or our) is committed to protecting all personal and Sensitive Information collected by us. We use reasonable efforts to protect the privacy of your personal and Sensitive Information and comply with the Privacy Act 1988 (Cth), Australian Privacy Principles and registered privacy codes (Privacy Act).

We understand that when personal or Sensitive Information is provided to us, it imposes a responsibility upon us to protect this information and to maintain a high level of trust with those who provide this information to us in order to receive our services. This policy describes the information that may be collected by us, how we use personal and Sensitive Information collected by us and how we protect this information in accordance with the Privacy Act.

SCOPE

All Sundale team members, volunteers, contractors and visitors.

OBJECTIVES

The purpose of this policy is to ensure:

- That Personal Information is managed in an open and transparent way;

- That the privacy of personal and Sensitive Information including health information of elders, residents, clients, children, team members, volunteers and contractors is protected;

- We provide for the fair collection and handling of personal and Sensitive Information;

- That the information we collect is used and disclosed for our functions or activities;

- That we regulate the access to and correction of Personal Information; and

- The confidentiality of personal and Sensitive Information through appropriate storage and security.

DEFINITIONS

Personal Information: is information or an opinion, whether true or not and whether recorded in a material form of not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Sensitive Information: means information or an opinion about a person’s racial or ethnic origin; political opinions; membership or political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional trade or trade association; membership of a trade union; sexual orientation or practices; criminal record; health information about a person; genetic information about a person 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.

ASSOCIATED DOCUMENTATION

Privacy Amendment (Enhancing Privacy Protection) Act 2012 Sundale Privacy Collection Statement Document (QA-200-P-31) INFORMATION: This process may be varied, withdrawn or replaced at any time. Printed copies of this process or part thereof are regarded as uncontrolled and should not be relied upon as a current reference document. It is the responsibility of the Sundale team member printing the process to always refer to the Accreditation Portal for the latest version. Compliance to this process is mandatory and team members are to ensure that they read this process in conjunction with the latest version of relevant policies and procedures.

COLLECTION

What information will we collect?

We may collect and hold Personal Information about you, that is, information that can identify you, and is relevant to providing you with the services you are seeking. We may also collect and hold Sensitive Information about you, including information about you health.

We collect information of a personal or sensitive nature that is necessary for our functions and activities as a health care provider. We collect information by lawful and fair means, and not in an unreasonably intrusive way. Where it is reasonable and practicable, we will only collect information directly from you or your authorised representative.

When you deal with us, the information we collect about you may, among other things, include details of your name, date of birth, sex, marital status, current and previous addresses, telephone/mobile phone number, e-mail address, employment details, insurance details, credit card and/or bank details and complaint details (including details about any injuries or reactions and treatment) or other information relevant to providing you with the services you are, or someone else you know is, seeking . It may also include details of the services or products we provide to you, as well as the status of those services or products. You may also be able to transact with us anonymously where this is lawful and practicable to do so.

What method will we use to collect information?

Personal information will generally be collected directly from you through the use of any of our standard application forms, over the internet, via email, through a face to face meeting with you or through a telephone conversation with you. We may also collect Personal Information about you from third parties acting on your behalf (for instance, an authorised representative or legal advisor).

We may also collect Personal Information about you from third parties, including family members, any person or organisation that assesses health status or care requirements (for instance, an Aged Care Assessment Team), health practitioners or volunteers.

There may, however, be some instances where Personal Information about you will be collected indirectly because it is unreasonable or impractical to collect Personal Information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.

Except as otherwise permitted by law, we only collect Sensitive Information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out below.

PURPOSE OF COLLECTION

The Personal Information that we collect and hold about you depends on your interactions with us. Generally, we collect, use and hold your Personal Information for purposes which include:

- to assess an application in relation to residential aged care, accommodation, home care service provision, independent living accommodation and child care services;

- to provide relevant care, services and products to you, including services and products related to residential aged care, home care, child care and independent living;

- dealing with any enquiries or complaints;

 - to administer and manage those services and products, including charging, billing and collecting debts;

- enabling contact with a nominated person regarding your health status;

- lawfully liaise with a nominated representative and to contact family if requested or needed;

- to comply with the provisions of State or Commonwealth law;

- provide data to government agencies in compliance with State or Commonwealth law;

- determining eligibility to entitlements provided under any State or Commonwealth law;

- maintaining our relationship with you;

- facilitating our internal business and administrative operations, including the fulfillment of any legal requirements; Failure to provide information You may not wish to provide information to us, however the information we collect is relevant to providing you with the care, services and products you seek or require. If you choose not to provide us with some or all of the information we request, we may not be able to provide you with the care, services and products you seek or require.

- conducting consumer surveys; and

- to promote and market to you other services or products which we consider may be of interest to you. We will generally only do this with your consent and we will always give you a choice to ‘opt out’ of receiving such marketing information in future.

Failure to provide information

You may not wish to provide information to us, however the information we collect is relevant to providing you with the care, services and products you seek or require. If you choose not to provide us with some or all of the information we request, we may not be able to provide you with the care, services and products you seek or require. 

Internet users

If you access our website, we may collect additional Personal Information about you in the form of your IP address and domain name.

Our website uses cookies. The main purpose of cookies is to identify users and to prepare customised web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve you more effectively.

Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.

Use and disclosure

Generally, we only use and disclose Personal and/or Sensitive Information about you for the purposes for which it was collected (as set out above). We may disclose Personal Information about you to:

- our related entities to facilitate our and their internal business operations;

- third party service providers, who assist us in operating our business (including technology service providers, contractors and health practitioners), and these service providers may not be required to comply with our privacy policy;

- our related entities and other organisations with whom we have affiliations so that those organisations may provide you with information about services, products and various promotions.

In some circumstances, the law may permit or require us to use or disclose Personal Information for other purposes (for instance where you would reasonably expect us to and the purpose is related to the purpose of collection).

Overseas disclosure

We do not disclose Personal or Sensitive Information to countries outside Australia for the purposes of providing services or products to you.

Access and correction

You may request access to Personal Information we hold about you, by making a request either verbally or in writing using the details below. We will respond to your request with a reasonable

At admission, you or your authorised representative should identify any parties from whom they do not wish personal or Sensitive Information to be collected, or to whom they do not wish personal or Sensitive Information to be provided. This is to be recorded in the file of an elder, resident, client and child and complied with to the extent permitted by law.

period and we may ask that you verify your identity before we assess your request for access. We may charge you a reasonable fee for processing your request (but not for making a request for access).

We may decline a request for access to Personal Information in circumstances prescribed by the Privacy Act, and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).

We aim to ensure that the Personal Information we hold is accurate, complete and up to date. Please contact us if any of the Personal Information you have provided to us has changed. Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.

If, upon receiving access to your Personal Information, or at any other time, you believe the Personal Information was hold about you is inaccurate, incomplete, out of date, or misleading, please notify us immediately. We take reasonable steps to correct the information so that it is accurate, complete and up to date.

If we refuse to correct your Personal Information, we will give you a written notice that sets out:

- the reasons for the refusal, except to the extent that it would be unreasonable to refuse;

- the mechanisms available to complain about the refusal; and

- any other matter prescribed by the regulations.

It is important that the information we hold about you is up to date and current. You must let us know when the information you have provided changes.

Security

We store your Personal and Sensitive information in different ways, including in paper and electronic form. We are committed to keeping secure the Personal and Sensitive information we collect from you. We will take all reasonable steps to ensure the Personal and Sensitive information we hold is protected from misuse, interference, loss, from unauthorised access, modification or disclosure. Our electronic and physical security measures include secure and locked storage areas and limited or authorised access to Personal and Sensitive information.

Complaints and feedback

If you wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us, please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you in writing. If you are not happy with our response, you may complain directly to the Australian Information Commissioner.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. To contact us with feedback, whether a compliment or complaint, or if you have a question relating to privacy, you can:

- write to us at: Sundale Ltd. Attention: Privacy Officer. PO Box 5202, SCMC NAMBOUR QLD 4560

- call any Service Manager (please check our website for current contact details for individual Sundale service locations); or

- call our Privacy Officer on 07 5441 0788 between 8.30am and 4.30pm Monday to Friday

Alternatively, complaints may also be referred to a number of services as set out below:

(a) Australian Information Commissioner

The Australian Information Commissioner receives complaints under the Act. Complaints can be made:

- Online: www.oaic.gov.au/privacy/making-a-privacy-complaint

- By phoning the Privacy Hotline: on 1300 363 992

- By fax: on 02 9284 9666

- In writing by addressing your letter to the: Australian Information Commissioner at the Office of the Australian Information Commissioner. GPO Box 5218, Sydney NSW 1042

(b) Aged Care Complaints Scheme

The Aged Care Complaints Scheme operates within the Department of Social Services receives complaints under the Act. Complaints can be made:

- Online: At http://www.agedcarecomplaints.govspace.gov.au/concern.

- By phone: on 1800 550 552.

- Or if you need an interpreter you can phone the Translating and Interpretation Service on 131 450 and ask them to put you through to the Aged Care Complaints Scheme on 1800 500 552.

-  For hearing or speech impaired TTY users phone 1800 555 677 then ask for 1800 550 552

-  For Speak and Listen users phone 1800 555 727 then ask for 1800 550 552

-  For Internet relay users connect to https://www.iprelay.com.au/call/index.aspx and enter 1800 550 552

- In writing by addressing your letter to the Aged Care Complaints Scheme at the: Australian Department of Social Services. GPO Box 9848, BRISBANE QLD 4001