Our Privacy Policy
Introduction
Ashgrove Meals on Wheels is committed to protecting the privacy of personal information which the organisation collects, holds and administers. Personal information is information which directly or indirectly identifies a person.
Purpose
The purpose of this document is to provide a framework for Ashgrove Meals on Wheels in dealing with privacy considerations.
Policy
Ashgrove Meals on Wheels collects and administers a range of personal information for the purposes of administration of the organisation.
Ashgrove Meals on Wheels recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – protected on one hand and made accessible to them on the other. These privacy values are reflected in and supported by our core values and philosophies and also reflected in our Privacy Policy, which is compliant with the Privacy Act 1988 (Cth).
Ashgrove Meals on Wheels is bound by laws which impose specific obligations when it comes to handling information. The organisation has adopted the following principles contained as minimum standards in relation to handling personal information.
Ashgrove Meals on Wheels will:
The Committee of Ashgrove Meals on Wheels is responsible for developing, adopting and reviewing this policy.
Ashgrove Meals on Wheels’ Service Manager is responsible for the implementation of this policy, for monitoring changes in Privacy legislation, and for advising on the need to review or revise this policy as and when the need arises.
Processes
Collection
Ashgrove Meals on Wheels will:
In all instances Ashgrove Meals on Wheels will require and ask for a client’s written consent for collection, use or disclosure of certain client information. This consent can be withdrawn by the client in writing at any time.
For evidentiary purposes, a standard form of consent on the Client Induction form is used to validate that a client has consented to information being made available to a meal service that they agree to be referred to.
If a client needs to be referred to another service, Ashgrove Meals on Wheels will require clients to give their written consent to this at the time of referral.
For the input of relevant Government reporting information, the Client Consent form is used. The consent form will provide the “proof” that a valid consent was obtained, when it was obtained and by whom. This consent is to be obtained without duress.
In the event of an emergency, the release of client information may occur to next-of-kin or an authorised delegate (Enduring Power of Attorney) identified by the client in their client file. The client is contacted to ensure they are aware of the request and to give permission.
In the event a client is unable to sign, an authorised delegate (EPA) may sign on the client’s behalf. For example, in the event that a client does not have the mental capacity to understand the contents of a Client Consent form, the authorised delegate (who has been expressly authorised by the client to do so) may provide consent on behalf of the client.
Use and Disclosure
Ashgrove Meals on Wheels will:
Implement and maintain steps to ensure that personal information is protected from misuse and loss, unauthorised access, interference, unauthorised modification or disclosure:
Ashgrove Meals on Wheels will:
Ashgrove Meals on Wheels will:
Ashgrove Meals on Wheels will:
Ashgrove Meals on Wheels will:
Ashgrove Meals on Wheels can:
If any person has a question or complaint in relation to this policy or about the way in which privacy issues are dealt with, they can write to or contact the Service Manager of Ashgrove Meals on Wheels.
Related Documents
Ashgrove Meals on Wheels is committed to protecting the privacy of personal information which the organisation collects, holds and administers. Personal information is information which directly or indirectly identifies a person.
Purpose
The purpose of this document is to provide a framework for Ashgrove Meals on Wheels in dealing with privacy considerations.
Policy
Ashgrove Meals on Wheels collects and administers a range of personal information for the purposes of administration of the organisation.
Ashgrove Meals on Wheels recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – protected on one hand and made accessible to them on the other. These privacy values are reflected in and supported by our core values and philosophies and also reflected in our Privacy Policy, which is compliant with the Privacy Act 1988 (Cth).
Ashgrove Meals on Wheels is bound by laws which impose specific obligations when it comes to handling information. The organisation has adopted the following principles contained as minimum standards in relation to handling personal information.
Ashgrove Meals on Wheels will:
- Collect only information which the organisation requires for its primary function;
- Ensure that stakeholders are informed as to why we collect the information and how we administer the information gathered;
- Use and disclose personal information only for our primary functions or a directly related purpose, or for another purpose with the person’s consent;
- Store personal information securely, protecting it from unauthorised access; and
- Provide stakeholders with access to their own information, and the right to seek its correction.
The Committee of Ashgrove Meals on Wheels is responsible for developing, adopting and reviewing this policy.
Ashgrove Meals on Wheels’ Service Manager is responsible for the implementation of this policy, for monitoring changes in Privacy legislation, and for advising on the need to review or revise this policy as and when the need arises.
Processes
Collection
Ashgrove Meals on Wheels will:
- Only collect information that is necessary for the performance and primary function of Ashgrove Meals on Wheels
- Notify stakeholders about why we collect the information and how it is administered
- Notify stakeholders that this information is accessible to them
- Collect personal information from the person themselves wherever possible
- If collecting personal information from a third party, be able to advise the person whom the information concerns, from whom their personal information has been collected
- Collect sensitive information only with the person’s consent. (Sensitive information includes health information and information about religious beliefs, race, gender and others)
- Determine, where unsolicited information is received, whether the personal information could have collected it in the usual way, and then if it could have, it will be treated normally. (If it could not have been, it must be destroyed, and the person whose personal information has been destroyed will be notified about the receipt and destruction of their personal information).
In all instances Ashgrove Meals on Wheels will require and ask for a client’s written consent for collection, use or disclosure of certain client information. This consent can be withdrawn by the client in writing at any time.
For evidentiary purposes, a standard form of consent on the Client Induction form is used to validate that a client has consented to information being made available to a meal service that they agree to be referred to.
If a client needs to be referred to another service, Ashgrove Meals on Wheels will require clients to give their written consent to this at the time of referral.
For the input of relevant Government reporting information, the Client Consent form is used. The consent form will provide the “proof” that a valid consent was obtained, when it was obtained and by whom. This consent is to be obtained without duress.
In the event of an emergency, the release of client information may occur to next-of-kin or an authorised delegate (Enduring Power of Attorney) identified by the client in their client file. The client is contacted to ensure they are aware of the request and to give permission.
In the event a client is unable to sign, an authorised delegate (EPA) may sign on the client’s behalf. For example, in the event that a client does not have the mental capacity to understand the contents of a Client Consent form, the authorised delegate (who has been expressly authorised by the client to do so) may provide consent on behalf of the client.
Use and Disclosure
Ashgrove Meals on Wheels will:
- Only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose;
- For other uses, Ashgrove Meals on Wheels will obtain consent from the affected person;
- In relation to a secondary purpose, use or disclose the personal information only where:
- a secondary purpose is related to the primary purpose and the individual would reasonably have expected us to use it for purposes; or
- the person has consented; or
- certain other legal reasons exist, or disclosure is required to prevent serious and imminent threat to life, health or safety
- In relation to personal information which has been collected from a person, use the personal information for direct marketing, where that person would reasonably expect it to be used for this purpose, and Ashgrove Meals on Wheels has provided an opt out and the opt out has not been taken up;
- In relation to personal information which has been collected other than from the person themselves, only use the personal information for direct marketing if the person whose personal information has been collected has consented (and they have not taken up the opt-out);
- State in Ashgrove Meals on Wheels’ Privacy Policy whether the information is sent overseas and further will ensure that any overseas providers of services are as compliant with privacy as Ashgrove Meals on Wheels is required to be;
- Provide all individuals’ access to personal information except where it is a threat to life or health or it is authorised by law to refuse and, if a person is able to establish that the personal information is not accurate, then Ashgrove Meals on Wheels must take steps to correct it;
- Ashgrove Meals on Wheels may allow a person to attach a statement to their information if Ashgrove Meals on Wheels disagrees it is inaccurate;
- Where for a legal or other reason we are not required to provide a person with access to the information, consider whether a mutually agreed intermediary would allow sufficient access to meet the needs of both parties; and
- Make no charge for making a request for personal information, correcting the information or associating a statement regarding accuracy with the personal information.
Implement and maintain steps to ensure that personal information is protected from misuse and loss, unauthorised access, interference, unauthorised modification or disclosure:
- Before Ashgrove Meals on Wheels discloses any personal information to an overseas recipient including a provider of IT services such as servers or cloud services, establish that they are privacy compliant. Ashgrove Meals on Wheels will have systems which provide sufficient security
- Ensure that Ashgrove Meals on Wheels data is up to date, accurate and complete
- Destroy personal information once is not required to be kept for the purpose for which it was collected, including from decommissioned laptops and mobile phones
- Change information to a pseudonym or treat it anonymously if required by the person whose information Ashgrove Meals on Wheels holds and will not use any government related identifiers unless they are reasonably necessary for our functions
Ashgrove Meals on Wheels will:
- Take reasonable steps to ensure the information Ashgrove Meals on Wheels collects is accurate, complete, up to date, and relevant to the functions we perform
Ashgrove Meals on Wheels will:
- Ensure stakeholders are aware of Ashgrove Meals on Wheels Privacy Policy and its purposes
- Make this information freely available in relevant publications and on the organisation’s website
Ashgrove Meals on Wheels will:
- Ensure individuals have a right to seek access to information held about them and to correct it if it is inaccurate, incomplete, misleading or not up to date.
Ashgrove Meals on Wheels will:
- Allow people from whom the personal information is being collected to not identify themselves or use a pseudonym unless it is impracticable to deal with them on this basis.
Ashgrove Meals on Wheels can:
- Release information to third parties where it is requested by the person concerned.
If any person has a question or complaint in relation to this policy or about the way in which privacy issues are dealt with, they can write to or contact the Service Manager of Ashgrove Meals on Wheels.
Related Documents
- Confidentiality Policy HR/CP/POL - 004
- Employment References Policy HR/ER/POL - 005
- Privacy Act 1988 (Cth)
- Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth)
- Privacy Regulation 2013 (Cth)