1.1. Therapy For Life Allied Health Services is committed to ensuring the privacy and confidentiality of all personal information affiliated with Therapy For Life Allied Health Services business undertakings.

1.2. Therapy For Life Allied Health Services follows the terms and conditions of privacy and confidentiality in accordance with the Australian Privacy Principles (APPs) as per schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth), forming part of the Privacy Act 1988 (‘the Act’).

1.3. This policy ensure we protect and handle personal information in accordance with the NDIS and relevant privacy legislation. We acknowledge and individuals right to privacy while recognising that personal information is required to be collected, maintained and administered in order to provide a safe working environment and a high standard of quality.

1.4. The information we collect is used to provide services to participants in a safe and healthy environment with individual requirements to meet duty of care obligations, to initiate appropriate referrals, and to conduct business activities to support those activities.

1.5. The purpose of this Privacy Policy is to clearly communicate how Therapy For Life Allied Health Services collects and manages personal information.

1.6. The point of contact regarding any queries regarding this policy is Alice Ayliffe, Senior Occupational Therapist/Director, Therapy For Life Allied Health Services, phone: 0479 184 126 Email: [email protected]

2.1. When

● Applies to all personal information and sensitive personal information including the personal information of employees and participants

● Applies to all company confidential information- this is any information not publicly available

2.2. When

● Applies to all representatives including key management personnel, directors, full time workers, part time workers, casual workers, contractors and volunteers.

2.1. When

● Applies to all personal information and sensitive personal information including the personal information of employees and participants

● Applies to all company confidential information- this is any information not publicly available

2.2. When

● Applies to all representatives including key management personnel, directors, full time workers, part time workers, casual workers, contractors and volunteers.

3.1. We are committed to complying with the privacy requirements of the Privacy Act, the Australian Privacy Principles and for Privacy Amendment (Notifiable Data Breaches) as required by organisations providing disability services.

3.2. We are fully committed to complying with the consent requirements of the NDIS Quality and Safeguarding Framework and relevant state or territory requirements.

3.3. We provide all individuals with access to information about the privacy of their personal information.

3.4. Each individual has the right to opt out of consenting to and providing their personal details if they wish.

3.5. Individuals have the right to request access to their personal records by requesting this with their contact person.

3.6. Where we are required to report to government funding bodies, information provided is non-identifiable and related to services and support hours provided, age, disability, language, and nationality.

3.7. Personal information will only be used by us and will not be shared outside the organisation without your permission unless required by law (e.g. reporting assault, abuse, neglect, or where a court order is issued).

3.8. Images or video footage of participants will not be used without their consent.

3.9. participants have the option of being involved in external NDIS audits if they wish.

4.1. As a private sector health service provider and under permitted health situations, Therapy For Life Allied Health Services is required to comply with the APPs as prescribed under the Act.

4.2. The APPs regulate how Therapy For Life Allied Health Services may collect, use, disclose and store personal information and how individuals, including Therapy For Life Allied Health Services ‘s patients may:

● address breaches of the APPs by Therapy For Life Allied Health Services

● access their own personal information; and,

● correct their own personal information.

4.3. In order to provide patients with adequate health care services, Therapy For Life Allied Health Services will need to collect and use personal information. It is important to be aware that if the patient provides incomplete or inaccurate information or the patient withholds personal health information Therapy For Life Allied Health Services may not be able to provide the patient with the services they are requesting.

4.4. In this Privacy Policy, common terms and definitions include:

a) "personal information" as defined by the Privacy Act 1988 (Cth). Meaning "information or an opinion including information or an opinion forming

part of a database, whether true or not, and whether recorded in a material format or not, about an individual whose identity is apparent, or can

reasonably be ascertained, from the information or opinion"; and,

b) "health information" as defined by the Privacy Act 1988 (Cth). This is a particular subset of "personal information" and means:

i. Information or opinion about the health or disability (at any time i.e. past, present or future) of an

i individual that can be classified as personal information;

ii. Information or opinion about an individual’s expressed wishes about the future provision of health

services that can be classified as personal information;

iii. Information or opinion about health service provided, or to be provided, to an individual, that can be

classified as personal information;

iv. Other personal information collected to provide, or in providing, a health service;

v. Other personal information about an individual collected in connection with the donation, or intended

donation, by the individual of his or her body parts, organs or body substances; or

vi. Genetic information about an individual in a form that is, or could be, predictive of the health of the

individual or a genetic relative of the individual.

c) Personal information also includes 'sensitive information' which is information including, but not limited to a patient’s:

a. race;

b. religion;

c. political opinions;

d. sexual preferences; and/or,

e. health information.

Information deemed 'sensitive information' attracts a higher privacy standard under the Act and is subject to additional mechanisms for the patient’s protection.

5.1. Therapy For Life Allied Health Services collects information from each individual patient that is necessary to provide the patient with adequate Occupational Therapy services.

5.2. This may include collecting information about a patient’s health history, family history, ethnic background or current lifestyle to assist the Occupational Therapy team in diagnosing and treating a patient’s condition.

6.1. This information will in most circumstances be collected directly from the patient through but not limited to the following mediums:

● Therapy For Life Allied Health Services patient consent form;

● medical treatment form; referrals and or,

● face to face consultation.

6.2. In other instances, Therapy For Life Allied Health Services may need to collect personal information about a patient from a third-party source. This may include:

● relatives; or,

● other health service providers.

6.3. This will only be conducted if the patient has provided consent for Therapy For Life Allied Health Services to collect his/her information from a third-party source; or, where it is not reasonable or practical for Therapy For Life Allied Health Services to collect this information directly from the patient. This may include where:

● the patient’s health is potentially at risk and his/her personal information is needed to provide them with emergency medical

treatment.

6.4. Therapy For Life Allied Health Services endeavours to store and retain a patient’s personal & health information in an electronic record system stored on our practice server Therapy For Life Allied Health Services.

7.1. Therapy For Life Allied Health Services only uses a patient’s personal information for the purpose(s) they have provided the information for unless one of the following applies:

● the patient has consented Therapy For Life Allied Health Services to use his/her information for an alternative or additional purpose;

● the disclosure of the patient’s information by Therapy For Life Allied Health Services is reasonably necessary for the enforcement of

criminal law or a law imposing a penalty or sanction, or for the protection of public revenue;

● the disclosure of the patient’s information by Therapy For Life Allied Health Services will prevent or lessen a serious and imminent

threat to somebody's life or health; or,

● Therapy For Life Allied Health Services is required or authorised by law to disclose the patient’s information for another purpose.

7.2. Health Professionals to provide treatment

During the patient’s treatment at Therapy For Life Allied Health Services he/she may be referred to alternative medical treatment/services (i.e. pathology or radiology) where Therapy For Life Allied Health Services’s staff may consult with senior medical experts when determining a patient’s diagnosis or treatment.

Therapy For Life Allied Health Services staff may also refer the patient to other health service providers for further treatment during and following the patient’s admission. These services include, but are not limited to Therapy For Life Allied Health Services;

a) Physiotherapy;

b) Occupational therapy;

c) Speech therapy;

d) Doctors; or,

e) Outpatient or community health services.

These health professionals will be designated health service providers appointed to use the patient’s health information as part of the process of providing treatment. Please note that this process will be conducted whilst maintaining the confidentiality and privacy of the patient’s personal information.

7.3. Alternative Health Services

At any point a patient wishes to be treated by an alternative medical practitioner or health care service that requires access to his/her personal/health information Therapy For Life Allied Health Services requires written authorisation. This written authorisation is to state that the patient will be utilising alternative health services and that these health services have consented for a transfer of personal/health information.

7.4. Other Third Parties

Therapy For Life Allied Health Services may provide the patient’s personal information regarding a patient’s treatment or condition to additional third parties. These third parties may include:

● parent(s);

● child/ren;

● other relatives;

● close personal friends;

● guardians; or,

● a person exercising a patient’s power of attorney under an enduring power of attorney.

Where information is relevant or reasonable to be provided to third parties, written consent from the patient is required.

Additionally, the patient may at any time wish to disclose that no third parties as stated are to access or be informed about his/her personal information or circumstances.

7.5. Other Uses of Personal Information

In order to provide the best possible environment to treat patients, Therapy For Life Allied Health Services may also use personal/health information where necessary for:

● activities such as quality assurance processes, accreditation, audits, risk and claims management, patient satisfaction surveys and staff

education and training;

● invoicing, billing and account management;

● to liaise with a patient’s health fund, Medicare or the Department of Veteran's Affairs, as necessary; and,

● the purpose of complying with any applicable laws – i.e. in response to a subpoena or compulsory reporting to State or Federal authorities.

If at any point or for any of the aforementioned reasons Therapy For Life Allied Health Services uses or discloses personal/ health information in accordance with the APPs, Therapy For Life Allied Health Services will provide written notice for the patient’s consent for the use and/or disclosure.

8.1. If an individual patient reasonably requests access to their personal information for the purposes of changing the information he/she must engage with the relevant practice manager.

8.2. The point of contact for patient access to personal information is:

Alice Ayliffe

Senior Occupational Therapist/Director

0479 184 126

[email protected]

Monday to Friday

8.3. Once an individual patient requests access to his/her personal information Therapy For Life Allied Health Services will respond within a reasonable period of time to provide the information.

8.4. All personal information will be updated in accordance to any changes to a patient’s personal circumstances brought to Therapy For Life Allied Health Serivces's attention. All changes to personal information will be subject to patient’s consent and acknowledgement.

8.5. If an individual requests access to his/her personal information Therapy For Life Allied Health Services will charge in certain circumstances at a rate of $215 per hour. Please note that this fee is associated with administrative costs only.

9.1. To keep information secure:

● We take reasonable steps to protect the personal information we hold against misuse, interference, loss, unauthorised access,

modification and disclosure.

● We ensure personal information is accessible to the participant and is able for use only by relevant workers.

● We ensure security for personal information includes password protection for IT systems, locked filing cabinets and physical

access restrictions with only authorised personnel permitted access.

● We ensure personal information no longer required is securely destroyed or de-identified.

10.1. As part of information security responsibilities:

● we will take reasonable steps to reduce the likelihood of a data breach occurring including storing personal information

securely and accessible only by relevant workers

● if we know or suspect your personal information has been accessed by unauthorised parties, and we think this could cause you

harm, we will take reasonable steps to reduce the chance of harm and advise you of the breach, and if necessary the Office of

the Australian Information Commissioner.

11. Complaints Handling

11.1. Patients who would like to make a complaint about a perceived breach of the Australian Privacy Principles through Therapy For Life Allied Health Services, can do so by contacting the Director at Therapy For Life Allied Health Services (see 6.1 above).

11.2. Therapy For Life Allied Health Services is dedicated to ensuring your information is secure. In the event that a breach of your information is identified, affected clients will be notified by Therapy For Life Allied Health Services and informed of our processes for handling any breaches. If at any stage a client identifies a breach of their privacy, they are requested to speak to the practice manager about lodging their concerns formally.

12. Disposal of Personal/Health Information

12.1. If Therapy For Life Allied Health Services receives any unsolicited personal information that is not deemed appropriate for the permitted health situation, Therapy For Life Allied Health Services will reasonably de-identify and dispose of the information accordingly.

12.2. If Therapy For Life Allied Health Services holds any personal or health information that is no longer deemed relevant or appropriate for the permitted health situation, Therapy For Life Allied Health Services will reasonably de-identify and dispose of the information accordingly.

13. Access to Policy

13.1. Therapy For Life Allied Health Services provides free copies of this Privacy Policy for patients and staff to access, which can be/will be located/provided:

● Web Link to Document

● Policy and Procedure Manual

● Hard Copies provided upon request

14. Review of Policy

14.1. Therapy For Life Allied Health Services in accordance with any legislative change will review the terms and conditions of this policy to ensure all content is both accurate and up to date.

14.2. Notification of any additional review(s) or alteration(s) to this policy will be provided to patients and staff within 2 weeks’ notice. If a change occurs patients are required by Therapy For Life Allied Health Services to review this Privacy policy. Staff are required to sign once they have reviewed the Privacy policy.

14.3. The policy will be displayed on the website and any changes made will be emailed out to patients of Therapy For Life.

Variations

Therapy For Life Allied Health Services reserves the right to vary, replace or terminate this policy from time to time.

Policy version and revision information

Policy Authorised by: Alice Ayliffe Original issue: 20.9.2023

Policy Maintained by: Alice Ayliffe Current version: 2

Review date: 20/9/2025

Privacy Policy

1. Purpose and context

2. Applicability

3. Privacy and Confidentiality Guidelines

4. Australian Privacy Principles

5. Types of Personal Information

6. Collection & Retention

7. Purpose of Collection, Use, and Disclosure

8. Access and Changes to Personal Information

9. Security of Information

10. Data Breaches