We will use all reasonable efforts to protect the privacy of individuals’ personal information and to comply with the obligations imposed by the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs), the Aged Care Act and the Aged Care Principles.
We will only collect personal information by lawful and fair means and will only collect personal information that is necessary for one or more of our organisation’s functions or activities.
If it is reasonable and practicable to do so, we will collect personal information about an individual only from that individual.
In meeting our obligations with respect to the privacy of our clients we acknowledge that people with vision or hearing impairments and those of culturally and linguistically diverse people may require special consideration.
Purpose of policy
The purpose of this policy and procedure is to:
- ensure personal information is managed in an open and transparent way;
- protect the privacy of personal information including Health Information of clients, residents and Workers;
- provide for the fair collection and handling of personal information;
- ensure that personal information we collect is used and disclosed for relevant purposes only;
- regulate the access to and correction of personal information; and
- ensure the confidentiality of personal information through appropriate storage and security.
This policy applies to employees, contractors or subcontractors, employees of a labour hire company assigned to work in our business, outworkers, apprentices or trainees, work experience students and volunteers (Workers).
Collection of your personal information
At all times we try to only collect the information we need for the particular function or activity we are carrying out.
The main ways in which we collect personal information are set out as follows in relation to residents and prospective residents:
- From the Commonwealth Government’s Department of Health Aged Care Assessment Team.
- From you, your representative or family member when you or they make initial enquiries with us in respect of our services.
- From you, your representative or family member when you or they attend on us personally for the purpose of making further enquiries and/or applying for a place within one of our residential aged care services.
- From you, your representative or family member in order to enable you to enter into a Residential Care Agreement with us.
- From your General Practitioner, Specialist or any other medical practitioner involved in your previous or ongoing medical treatment.
- From other allied health professionals who have treated you and from other Residential Aged Care Services where you have resided and hospitals where you have been treated.
In relation to employees and prospective employees:
- From you, when you supply your resume and personal details.
- From your referees when we contact them.
- With your consent, from the Federal Police in the form of a National Police Record Check.
- From previous employers when we request information from them.
Collecting sensitive information
Sometimes we may need to collect sensitive information about you, for example, to handle a complaint or make a report to a Government Department such as Social Services or the police. This might include information about your health, racial or ethnic origin, political opinions, association memberships, religious beliefs, sexual orientation, criminal history, genetic or biometric information.
In the course of handling and resolving a complaint, review or an investigation, we may collect personal information (including sensitive information) about you indirectly from publicly available sources or from third parties such as:
- Your authorised representative, such as the person you have appointed as your Attorney under an Enduring Power of Attorney document.
- Applicants, complainants, respondents to a complaint or application or witnesses.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact our enquiries email with a general question we will not ask for your name unless we need it to adequately handle your question.
However, for most of our functions and activities we usually need your name and contact information and enough information about the particular matter to enable us to fairly and efficiently handle your inquiry, request, complaint or application, or to act on your report.
Collecting through our website
Hill View Aged Care Pty Ltd has its own public website — www.hillviewcare.com.au.
Where our website allows you to make comments or give feedback we collect your email address and sometimes other contact details. We may use your email address to respond to your feedback. We store this personal information on servers located in Australia.
Analytic, session and cookies tools
The information collected by these tools may include the IP address of the device you are using and information about sites that IP address has come from, the pages accessed on our site and the next site visited. We use the information to maintain, secure and improve our websites and to enhance your experience when using them. In relation to Google Analytics you can opt out of the collection of this information using the Google Analytics Opt-out Browser Add-on.
Social Networking Services
We use social networking services such as Twitter, Facebook and YouTube to communicate with the public about our work. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These sites have their own privacy policies.
We use and or disclose the personal information that we hold in the following ways:
- To provide appropriate levels of residential care to our residents.
- To comply with the provisions of the Aged Care Act 1997 and associated legislative instruments.
- To determine residents’ eligibility to entitlements provided by the Aged Care Act
- To enable the Commonwealth Government, specifically the Department of Health and the Department of Social Services, to correctly calculate and pay the correct subsidies in respect of each of our Residents.
- To enable us to contact appropriate persons and organise proper treatment in respect of resident health and medical issues.
- To assist a hospital or other medical professional to provide appropriate treatment where a resident requires medical attention outside our facilities.
- To enable us to effectively communicate and work with residents’ legally appointed representatives and to contact family members if required or requested to do so.
- In relation to residential respite care, to Commonwealth Respite and Carelink Centres and their agents, to enable them to calculate eligibility and the correct level of funding to be provided.
- In relation to persons who are not residents, to enable us to contact them.
- In relation to employees and prospective employees, to enable us to properly assess applications for employment and to properly manage the ongoing employment relationship.
Disclosure to other agencies and departments
We may disclose personal information to an organisation if a complainant, applicant or respondent seeks to investigate a complaint made against us by an employee, resident or other affected person or where the agency or organisation has a legal right to attend or investigate the service or an incident occurring at the service. We will only disclose identifiable personal information where we are legally obliged to do so or only after first obtaining your consent in any other case. We may disclose this information to the following organisations:
- QCOMP/WorkCover authority
- The Queensland Police Service
- The Queensland Ambulance Service
- Queensland Fire and Rescue Service
- The Aged Care Quality Agency (formerly the Aged Care Standards and Accreditation Agency)
- The Aged Care Commissioner
- The Department of Social Services
- The Health Department.
Disclosure to the media
We only provide the media with personal information relating to a complaint if you have consented, or where the issue is already publically available.
Disclosure to service providers
Hill View Aged Care Pty Ltd uses a number of service providers to whom we disclose personal information. These include providers that host our website servers, manage our IT and manage our human resources information.
To protect the personal information we disclose we:
- enter into a contract or service agreement which requires the service provider to only use or disclose the information for the purposes of the contract or service agreement.
- include special privacy requirements in the contract or service agreement as required.
Disclosure of sensitive information
We only disclose your sensitive information for the purposes for which you gave it to us or for directly related purposes you would reasonably expect or if you agree.
Disclosure of personal information overseas
Generally we only disclose personal information overseas so that we can properly handle an application for residential care or if the residents’ representative is overseas or if the resident receives income from overseas (eg. expatriate service pension). For example, if;
- the residents’ legally appointed representative is overseas
- a resident’s medical practitioner or medical records are overseas
- a resident receives income from a foreign source
Web traffic information is disclosed to Google Analytics when you visit our websites. Google stores information across multiple countries. For further information see Google Data Centers and Google Locations.
When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.
Quality of personal information
To ensure that the personal information we collect is accurate, up-to-date and complete we:
- record information in a consistent format
- where necessary, confirm the accuracy of information we collect from a third party or a public source
- promptly add updated or new personal information to existing records
- regularly audit our contact lists to check their accuracy. We also review the quality of personal information before we use or disclose it.
Storage and security of personal information
We take steps to protect the security of the personal information we hold from both internal and external threats by:
- regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information
- taking measures to address those risks, for example, we keep a record (audit trail) of when someone has added, changed or deleted personal information held in our electronic databases and regularly check that staff only access those records when they need to
- conducting regular internal and external audits to assess whether we have adequately complied with or implemented these measures.
We destroy personal information in a secure manner when we no longer need it.
We store personal information in the following ways;
- electronically in our computer databases and servers
- in locked rooms and locked filing cabinets on our premises
- in our safe
- with an external records management provider
Accessing and correcting your personal information
Under the Privacy Act (Australian Privacy Principles 12 and 13) you have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information. You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.
We will ask you to verify your identity before we give you access to your information or correct it and we will try to make the process as simple as possible. We may charge you a fee for the service of providing access. The fee will be reasonable and be no more than necessary to cover our administration and printing costs associated with providing the information. If we refuse to give you access to, or correct, your personal information we must notify you in writing setting out the reasons.
If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.
If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why.
How to make a complaint
If you wish to complain to us about how we have handled your personal information you should complain in writing. If you need help lodging a complaint, you can contact us.
If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.
If we decide that a complaint should be investigated further, the complaint will usually be handled by a more senior person than the person whose actions you are complaining about.
We will tell you promptly that we have received your complaint and then respond to the complaint within 30 days.
If you are not satisfied with our response you may ask for a review by a more senior staff member within the organisation (if that has not already happened) or you can complain to the Aged Care Quality Agency.
How to contact us
You can contact us by:
Telephone: +61 7 5559 3222
National Relay Service:
- TTY users phone 133 677 then ask for 07 5559 3222
- Speak and Listen users phone 1300 555 727 then ask for 07 5559 3222.
- Internet relay users connect to the NRS then ask for 07 5559 3222.
Translating and Interpreting Service: 131 450 then ask for 07 5559 3222. Apart from the local or national call cost these are free services for you.
Post: P O Box 4185
Ashmore Qld 4214
Facsimile: +61 7 5522 9794