INTRODUCTION

VHCC is committed to providing quality services, respecting the rights of the participants we work with and the privacy of VHCC staff and participants. Your right to privacy and confidentiality will be recognized, respected, and protected in all aspects of your contact with VHCC. This statement outlines our ongoing obligations to you in respect to how we manage your Personal Information.

VHCC complies with the requirements of the NDIS Practice Standards, NDIS Code of Conduct, Notifiable Data Breaches (NDB) Scheme and the Privacy Act (1988).

SCOPE

This policy and procedure apply to all employees, volunteers and participants engaged with VHCC. Employees include permanent staff, casual staff, and contractors.

WHAT IS PERSONAL INFORMATION AND WHY DO WE COLLECT IT?

Personal Information is information or an opinion that identifies an individual. Personal Information includes Health Information, which is information about the physical or mental health or disability of an individual.

Examples of Personal Information we collect includes (but not limited to): your identification (such as title, name, alias), your contact details, your residence, information of your supports and networks, medication information, care plans and information about next of kin.

We collect your Personal Information in many ways including: face to face meetings, phone call interactions, note taking during engagements and meetings, engagement with third parties, photos taken, video and audio recordings, and social media.

VHCC will only request and retain personal information that is necessary to:

• Assess your eligibility for support.
• Provide safe and responsive support.
• Monitor the supports provided; and
• Fulfil contractual and other requirements to provide non-identifying data and statistical information to government agencies.

When we collect Personal Information, we will explain to you why we are collecting the information and how we plan to use it.

THIRD PARTIES

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties (such as other disability services or allied health professionals). In such cases we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

CIRCUMSTANCES WHEN YOUR PERSONAL INFORMATION WILL BE SHARED

Your personal information will only be disclosed:

• to prevent or lessen a serious and imminent threat to the life or health of you or another person.
• to outside agencies with your or your representative’s permission.
• with written consent from a person with lawful authority; or
• when required by law, or to fulfil legislative obligations such as mandatory reporting.

SECURITY AND STORAGE OF PERSONAL INFORMATION

Your personal and health Information will be stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification, or disclosure. When your personal and health Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to permanently de-identify it.

VHCC stores all participant and staff information by the following:

• Secure and online electronic platform (SharePoint) which has access security permissions ensuring that access is limited to people who have authority to view the information.
• Utilizing the customer relationship management software that VHCC is using (Visual Care).
• Archive hard copy information is stored securely within filing cabinets within our main head office.

ACCESS TO YOUR PERSONAL INFORMATION

You may access the personal or health Information we hold about you, including to update or correct it, subject to certain exceptions. If you wish to access your personal or health information, please speak to a VHCC staff member.

To protect your personal or health Information we may require identification from you before releasing the requested information.

You have the right to:

• request access to personal information we hold about you.
• access this information; and
• make corrections if you consider the information is not accurate, complete, or up to date.

However, access may be denied in part or in total where:

• the request is frivolous or vexatious.
• providing access would have an unreasonable impact on the privacy of other individuals.
• providing access would be likely to prejudice an investigation of possible unlawful activity.
• providing access would pose a serious and imminent threat to the life or health of any individual; and
• denying access is required or authorised by or under law.

We aim to address all requests to access or correct information upon request and will negotiate with you in relation to turn around on when you would like to acquire the requested information. We will not charge any fee for your access request but may charge an administrative fee for providing a copy of your information.

MAINTAINING THE QUALITY OF YOUR PERSONAL INFORMATION

It is important to us that your information is up to date. We will take all reasonable steps to make sure that your personal information is accurate and complete. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

COMPLAINTS AND ENQUIRIES

If you have any queries or complaints about this Privacy Statement or how VHCC manages privacy matters, please contact our Compliance Manager:

• by email: hr@vhcc.au
• by phone: 1300 048 422, or
• in writing: Suite 1/486 Station Street, Box Hill VIC 3128