Living Without Boundaries is bound by the National Privacy Principles (NPPs) contained in the Privacy Act 1988 (Privacy Act). Living Without Boundaries is committed to protecting your privacy. Any personal information gathered, handled, stored, or disclosed about you will be managed in accordance with, and meet the requirements of the Victorian Government’s Code of Fair Information Practice.
In this Privacy Policy Living Without Boundaries outlines the obligations which Living Without Boundaries has in managing the personal information it holds about its clients (individuals, parents, and children), potential clients, employees, suppliers, contractors, and others. Any information provided, including identification of individuals, will be used only for the purpose/s intended and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.
In summary, ‘personal information’ is information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is known, or can reasonably be determined from the information or opinion. Sensitive information is also identified as personal information, however special protection applies to this type of information. For example, sensitive information could include details about health, racial background, religious beliefs, or any criminal record.
Living Without Boundaries takes the privacy and personal information of individuals, parents and children who visit us, our employees, and our suppliers very seriously. We will not discuss any individuals, parent/s personal information to any individual, company, or organisation outside of Living Without Boundaries unless you have provided us with your written consent, or we are legally obliged to under Court Order.
In the case of divorced or separated parents, we will only deal with the fee-paying party who engaged our services in the first instance. We will only share information relating to the assessment and treatment of the child with the other parent and/or carers if we have the consent of the initial party or are legally obliged to disclose specified information under Court Order.
Living Without Boundaries will never sell or trade your personal data to third party list brokers or direct marketing companies. We will do our very best to ensure that your personal data is kept safe and secure for as long as your details are in our care. Once our relationship has been concluded, Living Without Boundaries will destroy or de-identify personal information due to redundancy, after our legal obligations to retain the information have expired. Collection of personal information. Living Without Boundaries will gather personal information about individuals, children, and families:
· When an individual, parent or care person books either themselves or a child in for an assessment
· Information is collected during the course of providing services.
· Information is collected when an individual, child, parent or family engages the Living Without Boundaries website (e.g. when you book an appointment or subscribe to an online newsletter). Purpose behind the collection of personal information. Living Without Boundaries is required under legislation to collect personal information in order to conduct its business, to provide and market its services and to meet its legal obligations. Living Without Boundaries will not use your personal data for any purpose that you have not agreed to, without first letting you know how and why we would like to use your details. Living Without Boundaries will ask to obtain verbal and written consent prior to use or sharing of personal data.
Who’s information does Living Without Boundaries require? The type of information that Living without Boundaries may collect and hold includes (but is not limited to) personal information about:
· Individual clients, parents and children, including potential future clients
· Employees, prospective employees and contractors
· Business associates/relevant stakeholders
· Suppliers and their employees, and
Other people who are directly linked to a member within Living Without Boundaries as a business and/or staff.
What types of personal information does Living Without Boundaries collect?
In general, the type of personal information Living Without Boundaries collects and holds includes (but is not limited to) is:
· Names of all individuals using services, marital status, occupation(s), child’s/children’s names and dates of birth, individuals, parents and child’s home and postal address(es), email address(es), mobile number(s), home telephone number(s), work number(s) and facsimile number(s).
· General practitioner, Specialists and referring doctor
· Any information relating to Federal Government Healthcare Programs (i.e. Medicare Programs for Children, NDIS, HCWA, individual Care Plans
Transaction details associated with services we have provided to you
* Any additional information provided to us by you
* Any information you provided to us through client surveys
* Other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations.
How does Living Without Boundaries collect personal information?
Living Without Boundaries collects personal information with your agreement by way of telephone conversations, forms filled out either in hard copy or on-line, in face-to-face meetings, assessments, interviews, business cards and from third parties.
In some circumstances Living Without Boundaries may be provided with personal information about an individual from a third party – for example, a report provided by a medical professional or a referral from another professional.
Website collection of information Living Without Boundaries collects personal information from the web site www.livingwb.com.au through receiving subscription applications and emails. They also use third parties to analyze traffic at that web site, which may involve the use of cookies.
How might Living Without Boundaries use and disclose your personal information?
Living Without Boundaries may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.
In general, Living Without Boundaries uses and discloses your personal information for the following purposes:
*To conduct its business
* To provide and market its services
* To communicate with you
* To provide treatment and care to individuals, families and children
* To assist your treating health professionals to provide treatment and care to you
* To assist us in providing you with information about your care, if required
* To assist with our internal administrative requirements
* To process Medicare, HCWA, NDIS and private health fund claims
* To supply information to medical practitioners and other allied health professionals who provide necessary follow up treatment and ongoing care
* To conduct research and development
* To conduct service planning
* To communicate offers and special events
* For general marketing purposes
* To help us manage and enhance our services
* To comply with our legal obligations.
To whom might Living Without Boundaries disclose your personal information?
Living Without Boundaries may disclose your personal information to:
· Other members of the Living Without Boundaries Team
· Legal practitioners, courts, tribunals and regulatory authorities, and
· Anyone else to whom you authorise us to disclose it as per the Privacy Permission Form
Living Without Boundaries also collects personal information from these organisations and individual’s and will deal with that information in accordance with this Policy.
Living Without Boundaries works in partnership with a range of government departments and health services and is required by law to pass on certain information about clients. We must also adhere to the laws of Mandatory Notification, and therefore must notify relevant authorities about certain issues (e.g. child protection).
External and internal quality auditors may view a small amount of personal information to check that Living Without Boundaries is meeting its obligations for Quality Accreditation. Auditors are bound by their own and/or Living Without Boundaries confidentiality requirements. Volunteers and students on placement at Living Without Boundaries are also bound by Living Without Boundaries confidentiality requirements. In some cases, we share stories about Living Without Boundaries interventions and individual achievements through newsletters, publications, media stories and fundraising activities.
We will always seek your permission to do this, and will tell you exactly where and when the story will appear. – Sending information overseas | Living Without Boundaries will not send your personal information to recipients outside of Australia without: Obtaining your consent (in some cases this consent will be implied), or Otherwise complying with the NPPs.
Living Without Boundaries may disclose your personal information to other members of the Living Without Boundaries Group, including offices potentially located outside Australia, when consented to by you or otherwise authorised under the Privacy Act.
Accessing personal information: Clients may request access to their personal information held by Living Without Boundaries by writing to the Director of Operations (i.e. specifically fee-paying parents of children to whom we are providing/have provided service) and are not required to provide a reason for requesting access. Where we hold information that clients are entitled to access, we will endeavor to provide you with a suitable range of choices as to how you may collect (e.g. post or collection).
If you believe that personal information that we hold about you is incorrect, incomplete or inaccurate, then you may request amendments. We will consider if the information requires amendment and if we do not agree, we will add a note to the personal information stating your disagreement with the information.
Sensitive information | Some personal information that Living Without Boundaries collects is ‘sensitive information’.
Sensitive information includes: information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, is also personal information; and health information about an individual.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (e.g., where required by law).
Management of personal information | The NPPs require Living Without Boundaries to take reasonable steps to protect the security of personal information. Living Without Boundaries personnel are required to respect the confidentiality of personal information and the privacy of individuals. As such, all staff are required to sign a confidentiality agreement upon employment. Living Without Boundaries takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records.
Where Living Without Boundaries no longer require your personal information for a permitted purpose under the NPPs, they will take reasonable steps to destroy it.
How does Living Without Boundaries keep personal information accurate and up-to-date?
Living Without Boundaries endeavors to ensure that the personal information we hold is accurate, complete and up-to-date. We encourage you to contact our admin team in order to, update any personal information we hold about you.
Contact details are: adminsupport@livingwb.com.au
You have the ability to seek access to your personal information. Subject to the exceptions set out in the Privacy Act, you may seek access to the personal information which Living Without Boundaries holds about you by contacting the Managing Director, Carly Treloar, carly@livingwb.com.au
Living Without Boundaries will require you to verify your identity and to specify what information you require. In some instances, a fee may be charged for providing access. We will advise you of the likely cost in advance.
Updates to this Policy This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.
Enquiries If you have any questions about privacy-related issues please contact Administration Supports on 03 8418 3618 or via email on adminsupport@livingwb.com.au
Feedback and complaints
Living Without Boundaries is committed to providing outstanding service and value the health and well-being of our clients by providing up to date, evidence based therapeutic interventions within an innovative and supportive environment.
Feedback about our clients’ experiences provides valuable information about what we are doing well, and where we can do things better. Living Without Boundaries values your opinion, working towards providing optimal healthcare.
We encourage clients to provide us with constructive feedback, whether it be positive or negative. Provision of this information will assist us in building a better service to the public, so if you are unhappy or have any concerns about your care or the care of a loved one, it is your right to do so.
Please feel free to discuss this in person with the Director of Living Without Boundaries, Carly Treloar, or if you prefer, you may put it in writing and send to:
Living Without Boundaries
Director of Operations
3/127 Bolton Street
ELTHAM, Vic, 3095
Who do I speak to if I have a concern about Privacy?
If you have a concern or complaint about the privacy of personal information being held by Living Without Boundaries, you should contact us directly on 03 8418 3618.
Your inquiry will be acted on immediately once received and you will be contacted within five working days to:
· discuss your complaint with you
· discuss the resolution you require and the available remedies
· where appropriate, put in place an agreed solution that meets the requirements of National Privacy Principles
· provide written notice to you of the outcome.
What if I do not feel that my complaint has been resolved?
If you feel that your complaint has not been resolved you may wish to contact the Health Complaints Commissioner for further assistance.
HEALTH COMPLAINTS COMMISSIONER 570 Bourke Street Melbourne, VIC 3000
Telephone: 1300 582 113
https://hcc.vic.gov.au/ You can read details of the Privacy Act on the Australian Government Office of the Privacy Commissioner’s website https://www.oaic.gov.au/ . You can also contact the Occupational Therapy Board of Australia on 1300 419 495 or https://www.occupationaltherapyboard.gov.au/ for assistance with matters relating to complaints.
FURTHER INFORMATION For more information about Living Without Boundaries commitment to protecting your privacy, contact us directly at Living Without Boundaries on 03 8418 3618
Consent to share information
Is located within the Living Without Boundaries ‘Service Agreement’
Example:
Consent. Please strike out option you wish so that it reads as you intend.
I do / do not provide consent for * Therapists name* to work with my child and store relevant information.
I do / not provide consent for * Therapists name* to communicate electronically, verbally and in writing with all members of my child therapy and education team.
I do / not provide consent for * Therapists name* to take photos or video during therapy sessions that assist in the teaching of my child. This material will be messaged to a parent and always deleted by the therapist at the end of the session.
Cancellation – Located within the Living Without Boundaries ‘Service Agreement’
I am aware of the cancellation policy and the need to notify the therapist by 8.00 am on the day of any scheduled session in order to avoid the full fee being charged.
Policy 1.1 Cancellations – Please email or leave voicemail by 8.00 am on the day of your child’s consult to cancel a session. This is the parent’s responsibility. Failure to do so will result in the full session fee being billed to the family. Cancellation fees are not billable to Medicare such as the Enhanced Primary Care Program. If the therapists are unable to conduct a scheduled session parents will be notified as soon as possible and an alternative time discussed. Leniency is provided in the event of an emergency where notification of cancellation has not been made.