Privacy & Dignity Policy
DLS Allied Health
ABN 20 650 721 850
Privacy and Dignity Policy
Approved By: The Director of DLS Allied Health Pty Ltd
Version: 2
Approval Date: April 2023
1. Introduction
1.1 Purpose
This policy and the Policies and Procedures and related documentation set out in section 1.5 below (Related Documentation) supports DLS Allied Health to apply the Privacy and Dignity principles in compliance with the NDIS Practice Standards.
1.2 Policy Aims
DLS Allied Health is committed to ensuring each participant is treated with dignity and respect, can maintain their identity, make informed choices about their care and services, and live the life they choose.
In this regard, DLS Allied Health is committed to ensuring it:
(a) has a culture of inclusion and respect for participants; and
(b) supports participants to exercise choice and independence; and
(c) respects participant’s privacy.
1.3 NDIS Quality Indicators
DLS Allied Health aims to demonstrate each of the following quality indicators through the application of this policy and the relevant systems, procedures, workflows and other strategies referred to in this policy and the related documentation:
Privacy and Dignity
(a) Consistent processes and practices are in place that respect and protect the personal privacy and dignity of each participant.
(b) Management of each participant’s information ensures that it is identifiable, accurately recorded, current and confidential. Each participant’s information is easily accessible to the participant and appropriately utilised by relevant employees.
(c) Each participant understands and agrees to what personal information will be collected and why, including recorded material in audio and/or visual format.
Information Management
(a) Each participant’s consent is obtained to collect, use and retain their information or to disclose their information (including assessments) to other parties, including details of the purpose of collection, use and disclosure. Each participant is informed in what circumstances the information could be disclosed, including that the information could be provided without their consent if required or authorised by law.
(b) Each participant is informed of how their information is stored and used, and when and how each participant can access or correct their information, and withdraw or amend their prior consent.
(c) An information management system is maintained that is relevant and proportionate to the size and scale of the organisation and records each participant’s information in an accurate and timely manner.
(d) Documents are stored with appropriate use, access, transfer, storage, security, retrieval, retention, destruction and disposal processes relevant and proportionate to the scope and complexity of support delivered.
1.4 Scope
(a) This policy applies to the provision of all services and supports at DLS Allied Health.
(b) All permanent, fixed term and casual staff, contractors and volunteers are required to take full responsibility for ensuring full understanding of the commitments outlined in this policy.
1.5 Related Documentation
The application of the above NDIS Practice Standard by DLS Allied Health is supported in part by and should be read alongside the Policies and Procedures and related documentation corresponding to this policy in the Policy Register.
2. Definitions
DLS Allied Health means DLS Allied Health Pty Ltd ABN 20 650 721 850.
Participant means a participant of DLS Allied Health.
Key Management Personnel means Daniel Sharman and other key management personnel involved in DLS Allied Health from time to time.
Legislation Register means the register of legislation, regulations, rules and guidelines maintained by DLS Allied Health.
Personal information means information or an opinion (whether true or not and whether recorded in a material form or not) about an individual who is identified or reasonably identifiable from the information.
Policy Register means the register of policies of DLS Allied Health.
Director means Daniel Sharman.
Related Documentation has the meaning given to that term in section
1.1.
Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection. Sensitive information includes health and genetic information and information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record and some types of biometric information.
Employee means a permanent, fixed term or casual member of staff, a contractor or volunteer employed or otherwise engaged by DLS Allied Health and includes the Director.
3. Policy Statement
(Continued in next message due to length...)
(Continuation of the Privacy and Dignity Policy V2 for webpage use)
3.1 Communication of Privacy and Dignity Policy
To ensure participants understand the subject matter of policy in a manner which is responsive to their needs and in the language, mode of communication and terms that the participant is most likely to understand, DLS Allied Health will:
(a) use respectful, open, clear, and honest communication in all professional interactions (e.g., spoken, written, social media).
(b) consistently respect the participant’s privacy and confidentiality in how they communicate and interact with them.
(c) communicate effectively with participants to promote their understanding of this policy (e.g., active listening, use of plain language, encouraging questions).
(d) identify potential barriers to effective communication and make a reasonable effort to address these barriers including by providing information and materials on how to access interpreter services, legal and advocacy services.
(e) work with bilingual assessment staff, interpreters (linguistic and/or sign), communication specialists and relevant advocacy agencies/services that can also assist participant participation, inclusion, informed choice and control.
(f) encourage participants to engage with their family, friends and chosen community if DLS Allied Health has been directed to do so.
3.2 The personal information that DLS Allied Health collects
The personal information that DLS Allied Health collects from a participant includes their:
(a) name, address, telephone and email contact details;
(b) gender, date of birth and marital status, information about their disability and support needs;
(c) health and medical information;
(d) numbers and other identifiers used by Government Agencies or other organisations to identify individuals;
(e) financial information and billing details including information about the services individuals are funded to receive, whether under the NDIS or otherwise;
(f) records of interactions with individuals such as system notes and records of conversations individuals have had with DLS Allied Health’s employees; and
(g) information about the services DLS Allied Health provides to individuals and the way in which DLS Allied Health will deliver those to individuals.
Typically, DLS Allied Health does not collect personal information in the form of recorded material in audio and/or visual format.
3.3 Sensitive information and protection of dignity
DLS Allied Health only collects sensitive information where it is reasonably necessary for DLS Allied Health’s functions or activities and either:
(a) the individual has consented; or
(b) DLS Allied Health is required or authorised by or under law (including applicable privacy legislation) to do so.
DLS Allied Health will treat participants with dignity and respect and as far as reasonably practicable protect the privacy and dignity of each participant and, in particular, their sensitive information.
3.4 How DLS Allied Health collects personal information
DLS Allied Health collects personal information in a number of ways, including:
(a) when individuals correspond with DLS Allied Health (for example, by letter, email or telephone);
(b) on hard copy forms;
(c) in person;
(d) from referring third parties (for example, the National Disability Insurance Scheme or a support coordinator);
(e) at events and forums; and
(f) from third party funding and Government Agencies.
3.5 Why does DLS Allied Health collect personal information?
The main purposes for which DLS Allied Health collects, holds, uses and discloses personal information are:
(a) providing individuals with information about DLS Allied Health’s services and supports.
(b) answering their inquiries and delivering service to participants.
(c) administering DLS Allied Health’s services and supports and processes payments.
(d) conducting quality assurance activities including conducting surveys, research and analysis and resolving complaints.
(e) complying with laws and regulations and to report to funding and Government Agencies.
(f) promoting DLS Allied Health and its activities, including through events and forums.
(g) conducting research and statistical analysis relevant to DLS Allied Health's activities (including inviting individuals to participate in research projects and activities).
(h) reporting to funding providers.
(i) recruiting employees and contractors.
(j) processing payments.
(k) answering queries and resolving complaints.
(l) evaluating DLS Allied Health’s work and reporting externally.
(m) carrying out internal functions including administration, training, accounting, audit and information technology.
(n) other purposes which are explained at the time of collection or which are required or authorised by or under law (including, without limitation, privacy legislation).
(o) purposes for which an individual has provided their consent.
(p) for research, evaluation of services, quality assurance activities, and education in a manner which does not identify individuals. If individuals do not wish for their de-identified data to be used this way, they should contact DLS Allied Health.
(q) to keep individuals informed and up to date about DLS Allied Health’s work, for example, changes to the National Disability Insurance Scheme or information about disability supports, either where DLS Allied Health has their express or implied consent, or where DLS Allied Health is otherwise permitted by law to do so. DLS Allied Health may send this information in a variety of ways, including by mail, email, SMS, telephone, or social media.
(r)
where an individual has consented to receiving marketing communications from DLS Allied Health, that consent will remain current until they advise DLS Allied Health otherwise. However, individuals can opt out at any time.