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GOV 004-1

Privacy Policy

About this policy

Stream Services is committed to protecting and upholding the right to privacy and dignity of clients, staff, volunteers, stakeholders and representatives of agencies we deal with. In particular Stream Services is committed to protecting and upholding the rights of our clients to privacy in the way we collect, store and use information about them, including audio and video recorded information, their needs and the services we provide to them.

Stream Services requires staff, volunteers and other stakeholders to be consistent and careful in the way they manage what is written and said about individuals or legal entities and how they decide to whom this information can be disclosed.

Stream Services is subject to Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (Privacy Act). The organisation will follow the guidelines of the Australian Privacy Principles in its information management practices.

NDIS Practice Standards & Quality Indicators

All staff are to ensure that their conduct relating to this policy is compliant with these Outcomes and Quality Indicators from the NDIS Practice Standards. Where there is a conflict between the Quality Indicators and Stream Services’ policies, practices or cultural norms, all staff must strictly abide by the Outcomes and Quality Indicators to the best of their ability and provide details to quality@streamservices.com.au for continuous improvement.

Practice Standards Outcome

1.3 Privacy and Dignity

Each participant accesses supports that respect and protect their dignity and right to privacy.

Quality Indicators

1.3.1 Consistent processes and practices are in place that respect and protect the personal privacy and dignity of each participant.

1.3.2 Each participant is advised of confidentiality policies using the language, mode of communication and terms that the participant is most likely to understand.

1.3.3 Each participant understands and agrees to what personal information will be collected and why, including recorded material in audio and/or visual format

Record of policy development​

Version

Date approved

Date for review

1.5

12 September 2022

Sept 2023

1.4

23 November 2021

December 2022

1.3

October 2020

November 2021

1.2

13 May 2019

May 2020 (delayed)

1.1

25 February 2019

May 2019

Responsibilities and delegations

This policy applies to

all staff, clients, client’s families, volunteers and other stakeholders. “Stream Services” is the current trading name and trademark registrant (application number 2076944) of Clermont Country Care Pty. Ltd, the organisation has traded previously under the name Clermont Country Care. The entity’s legal name will be changed by 31 December 2022.

Specific responsibilities

The director/s will ensure that adequate training and materials are available for all staff to be trained in Privacy standards and expectations.

The director/s will have the responsibility for the day-to-day implementation of privacy procedures and for ensuring that all staff and volunteers are aware of this policy and subsequent procedures.

Policy approval

The director/s will be responsible for approving this policy.

Policy context – this policy relates to:

Standards

  • National Disability Standards.

  • Australian Privacy Principles

  • The NDIS Rules 2018.

  • NDIS Code of Conduct

  • NDIS Practice Standards (November 2021)

Organisation policies

Quality Management and Continuous Quality Improvement Policy

Forms, record keeping, other documents

  • Service Agreement Templates.

  • Client Intake Form

  • Client Consent From

Policy

Stream Services will ensure that:

  • It meets its legal and ethical obligations as an employer and service provider in relation to protecting the privacy of clients and organisational personnel.
  • Clients are provided with information about their rights regarding privacy and dignity using the language, mode of communication and terms that the participant is most likely to understand.
  • Clients and organisational personnel are provided with privacy when they are being interviewed or discussing matters of a personal or sensitive nature.
  • All staff and Director/s understand what is required in meeting these obligations.

This policy is designed to conform to the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (Privacy Act) and the Australian Privacy Principles which govern the collection, use and storage of personal information.

This policy will apply to all records, whether hard copy or electronic, containing personal information about individuals, and to interviews or discussions of a sensitive personal nature.

Pricacy Procedure

Procedures

Dealing with personal information
In dealing with personal information, Stream Services staff will:

• Ensure privacy for clients, staff, volunteers and other stakeholders when they are being interviewed or discussing matters of a personal or sensitive nature.
• Only collect and store personal information that is necessary for the functioning of the organisation
and its activities.
• Use fair and lawful ways to collect personal information.
• Collect personal information only by consent from an individual.
• Ensure that people know what sort of personal information is held, what purposes it is held it for and
how it is collected, used, disclosed and who will have access to this information.
• Ensure that personal information collected or disclosed is accurate, complete and up-to-date, and
provide access to any individual to review information or correct wrong information about themselves.
• Take reasonable steps to protect all personal information from misuse and loss and from
unauthorised access, modification or disclosure.
• Destroy personal information no longer needed and/or after legal requirements for retaining
documents have expired.

Responsibilities for managing privacy
• All staff and Director/s are responsible for the management of personal information to which they have
access, and in the conduct of research, consultation or advocacy work.
• Director/s are responsible for content in Stream Services publications, communications, social media
platforms and web site and must ensure the following:
− Appropriate consent is obtained for the inclusion of any personal information about any individual
including Stream Services staff.
− Information being provided by other agencies or external individuals conforms to privacy
principles.
− Stream Services’ website contains a Privacy statement that makes clear the conditions of any
collection of personal information from the public through their visit to the website.
• The Director/s are responsible for safeguarding personal information relating to Stream Services,
staff, volunteers, contractors and stakeholders.

The Privacy Contact Officer: The Privacy Contact Officer will be the Managing Director. The Managing
Director will be responsible for:
− Ensuring that all staff are familiar with the Privacy Policy and administrative procedures for
handling personal information.
− Ensuring that clients and other relevant individuals are provided with information about their rights
regarding privacy.
− Handling any queries or complaint about a privacy issue.

Privacy information for clients
At the first meeting with the client, the appropriate staff will inform clients what information is being collected,
how their privacy will be protected and their rights in relation to this information. If using a PER005 Client
Intake Form this conversation applies to the last section of the form.
 
If a Client is onboarded through the www.streamservices.com.au web platform they will be provided with the opportunity to select if they accept our privacy policy and procedures they will then be provided this
information for ongoing reference through:

1. continued access to their service agreement which incorporates an addendum of the privacy policy
and procedure at any time through their secure log in.
2. An email will be automatically sent to the participant which includes the content of their Service
Agreement including the privacy addendum.
 
If the Client is onboarded without a Client Intake Form and not through the www.streamservices.com.au web
platform, then they complete a PER007 Client Consent From.

Access to your Personal Information
Clients may access their personal information held by Stream Services.
 
Clients may wish to update and/or correct it, subject to certain exceptions. If a client wishes to access their
personal information, they must put the request in writing to the Privacy Contact Officer.
 
Stream Services will not charge any fee for a request, but may charge an administrative fee for providing a copy of personal information.
 
In order to protect a client’s personal information, Stream Services will require identification before releasing the requested information.