LifeTec Australia Privacy Policy

LifeTec respects the privacy of all people and is committed to safeguarding the personal information that is provided to us.

Purpose

The purpose of this privacy policy is to:

• clearly communicate the personal information handling practices of LifeTec
• enhance the transparency of LifeTec operations, and
• give individuals a better and more complete understanding of the sort of personal information that LifeTec holds, and the way we handle that information.

Scope

This policy and procedure applies to all people accessing LifeTec services.

The Privacy Act and this Privacy Policy do not apply to acts or practices which directly relate to employee records of LifeTec’s current and former employees.

Definitions

Personal information as defined by the Privacy Act 1988 (as amended) is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.

Sensitive information as defined by the Privacy Act 1988 (as amended) is information or opinion (that is also personal information) about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record or health, genetic, biometric information or biometric templates, that is also personal information.

Outline of this Policy

Our Information Handling Practices

This section explains our general information handling practices across LifeTec including information about how we collect, use, disclose and store your information.

Our obligations under the Privacy Act

This privacy policy sets out how we comply with our obligations under the Privacy Act 1988 (Privacy Act). We are bound by the Australian Privacy Principles (APPs) in the Privacy Act which regulate how organisations may collect, use, disclose and store personal information, and how individuals may access and correct personal information held about them.

Collection of Personal and Sensitive Information

If you would like to access any LifeTec Services on an anonymous basis or using a pseudonym, please tell us. If this is possible and lawful, we will take all reasonable steps to comply with your request. However, we may not be able to provide the services in question if we are not provided with the personal information requested.

The nature and extent of personal and sensitive information collected by LifeTec varies depending on your particular interaction with LifeTec.

Any person accessing LifeTec Services

The kinds of information that may be collected include:

• contact details (name, address, email, contact details, organisation)
• personal details including: date of birth, gender, cultural background
• information on personal issues and experiences, relationships
• family background, supports clients may have in the community
• areas of interest and needs
• health information and/or medical history
• credit card numbers or bank account details (if registering for a paid event)
• clinical assessments and progress notes
• profession/position

This information may be collected by a variety of methods including:

• Face to Face
• Telephone
• Teleconsultation services
• Enquiry and Registration forms (manual/electronic formats)
• Correspondence (email/fax/post/online)

LifeTec uses this information for the following purposes:

• Providing LifeTec Services
• to meet any requirements of government funding for programs
• to monitor and evaluate existing services and plan for future services
• to obtain feedback from individuals about their experiences and outcomes
• to produce annual reports and for research purposes
• to comply with legal obligations
• to provide information about LifeTec’s services
• to provide information about relevant industry events and activities

LifeTec Members

Type of information collected:

• contact details (name, address, telephone numbers, email)
• Profession
• Membership status

This information may be collected by a variety of methods including:

• Registration forms (manual/electronic formats)
• Correspondence (email/fax/post/online)

Purpose for which LifeTec uses the information:

• Distribution of Annual Report to members
• To comply with legal obligations
• Reporting memberships to the LifeTec Queensland Inc. Board of Management
• To process membership fees and provide accurate receipts
• to provide information about LifeTec’s services
• to receive invitations to upcoming events and activities
• to recognise your support of LifeTec

Additional Information

LifeTec’s website may from time to time contain links to other websites. LifeTec stresses that when an online user accesses a website that is not the LifeTec website, it may have a different privacy policy. To verify how that website collects and uses information, the user should check that particular website’s policy.

Email Disclaimer

The information contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. If you received this communication in error, please notify the sender immediately and delete it from your computer system network

How We Collect Information

Where possible, we collect your personal and sensitive information directly from you. We collect information through various manual and electronic means, including telephone, face to face, teleconsultation, email, fax and a range of forms and surveys. If you feel that the information that we are requesting, either on our forms or in our discussions with you, is not information that you wish to provide, please feel free to raise this with us.

In some situations we may be provided with your personal information from a third party source. For example, we may collect information about you from a health care provider or a friend or relative who is seeking services on your behalf. If we collect information about you in this way, we will take reasonable steps to inform you and ensure that you are aware of the purposes for which we are collecting your personal information and the organisations to which we may disclose your information, subject to any exceptions under the Act.

Health Information

As part of administering LifeTec services, we may collect health information. For example, LifeTec collects health information (such as medical history) from some clients to provide quality services to meet your needs/goals. When collecting health information from you, LifeTec will obtain your consent to such collection and explain how the information will be used and disclosed.

If health information is collected from a third party, LifeTec will inform you that this information has been collected and will explain how this information will be used and disclosed.

LifeTec will not use health information beyond the consent provided by you, unless your further consent is obtained or in accordance with one of the exceptions under the Privacy Act or in compliance with another law. If LifeTec uses your health information for research or statistical purposes, it will be de-identified if practicable to do so.

Use and Disclosure of Information

We only use information for the purposes for which it was given to us, or for purposes which are related to one of our functions or activities.

For the purposes referred to in this Privacy Policy (discussed above under ‘Collection of Personal and Sensitive Information’), we may also disclose your personal information to other external organisations including:

• Government departments/agencies which provide funding for LifeTec services (your information will be de-identified if practicable to do so).
• Doctors and health care professionals, who assist us to deliver our services;
• Our professional advisors, including our accountants, auditors and lawyers.
• Contractors who manage or deliver some of the services we offer to you.
• Steps are taken to ensure they comply with the APPs when they handle personal information and are authorised only to use personal information in order to provide the services or to perform the functions required by LifeTec;

Except as set out above, LifeTec will not disclose an individual’s information to a third party unless one of the following applies:

• the individual has consented
• the individual would reasonably expect us to use or give that information for another purpose related to the purpose for which it was collected (or in the case of sensitive information – directly related to the purpose for which it was collected)
• it is otherwise required or authorised by law
• it will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety
• it is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities
• it is reasonably necessary to assist in locating a missing person
• it is reasonably necessary to establish, exercise or defend a claim at law
• it is reasonably necessary for a confidential dispute resolution process
• it is necessary to provide a health service
• it is necessary for the management, funding or monitoring of a health service relevant to public health or public safety
• it is necessary for research or the compilation or analysis of statistics relevant to public health or public safety
• it is reasonably necessary for the enforcement of a law conducted by an enforcement body.

We will not send information out of Australia without additional specific consent or as required by law.  If we are required to send information overseas we will seek specific consent from the individual, and take measures to protect your information such as ensuring that the country of destination has similar protections in relation to privacy or that we enter into contractual arrangements with the recipient of your information that safeguards your privacy.

LifeTec may use cloud based service providers for the purpose of storing information or utilising specific applications for service delivery and reporting. LifeTec will take measures to protect your information such as ensuring that the country of destination has similar protections in relation to privacy or that we enter into contractual arrangements with the recipient of your information that safeguards your privacy.

Security of Personal and Sensitive Information

LifeTec takes reasonable steps to protect the personal, sensitive and health information we hold against misuse, interference, loss, unauthorised access, modification and disclosure.

These steps include password protection for accessing our electronic IT system, securing paper files in locked cabinets and physical access restrictions. Only authorized personnel are permitted to access these details.

When the personal information is no longer required, it is destroyed in a secure manner, or deleted according to our Records Control Procedure.

Correction of Information

If an individual requests that we change that information, the staff member receiving that request will make the changes unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make the changes.

Requests for correction should be made to the treating therapist or staff member or can be formally requested directly to the Privacy Officer (details of which are set out below). For security reasons, you may be required to put your request in writing and provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

Access to Information

Requests for access should be made directly to the Privacy Officer (details of which are set out below). For security reasons, you will be required to put your request in writing and provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

Access will be provided as outlined in this policy, unless we consider that there is a sound reason under the Privacy Act or other relevant law to withhold the information.

In the first instance, LifeTec will generally provide a summary of the information held about the individual. It will be assumed (unless told otherwise) that the request relates to current records. These current records will include personal information which is included in LifeTec databases, and which may be used on a day to day basis.

We will provide access by allowing you to inspect, take notes or print outs of information that we hold about you. If information (for example, your name and address details) is duplicated across different databases, LifeTec will generally provide one printout of this information, rather than multiple printouts.

We will take all reasonable steps to provide access or the information requested within 14 days of your request. In situations where the request is complicated or requires access to a large volume of information, we will take all reasonable steps to provide access to the information requested within 30 days.

If an individual is able to establish that information LifeTec holds about her/him is not accurate, complete or up to date, LifeTec will take reasonable steps to correct our records.

Access will be denied if:

• the request does not relate to the information of the person making the request;
• providing access would pose a serious threat to the life, health or  safety of a person or to public health or public safety;
• providing access would create an unreasonable impact on the privacy of others;
• the request is frivolous and vexatious;
• the request relates to existing or anticipated legal proceedings;
• providing access would prejudice negotiations with the individual making the request;
• access would be unlawful;
• denial of access is authorised or required by law;
• access would prejudice law enforcement activities;
• access would prejudice an action in relation to suspected unlawful activity, or misconduct of a serious nature relating to the functions or activities of LifeTec
• access discloses a ‘commercially sensitive’ decision making process or information or;
• any other reason that is provided for in the APP’s or in the Privacy Act.

If we deny access to information we will set our reasons for denying access. Where there is a dispute about your right of access to information or forms of access, this will be dealt with in accordance with the complaints procedure set out below.

Complaints Procedure

If you have provided us with personal and sensitive information, or we have collected and hold your personal and sensitive information, you have a right to make a complaint and have it investigated and dealt with under this complaints procedure.

If you have a complaint about LifeTec privacy practices or our handling of your personal and sensitive information please contact our Privacy Officer (details of which are set out below).

A privacy complaint relates to any concern that you may have regarding LifeTec privacy practices or our handling of your information. This could include matters such as how your information is collected or stored, how your information is used or disclosed or how access is provided to your information.

The goal of this policy is to achieve an effective resolution of your complaint within a reasonable timeframe, usually 30 days or as soon as practicable.

However, in some cases, particularly if the matter is complex, the resolution may take longer.

Once the complaint has been made, we will try to resolve the matter in a number of ways such as:

• Request for further information: We may request further information from you. You should be prepared to provide us with as much information as possible, including details of any relevant dates and documentation. This will enable us to investigate the complaint and determine an appropriate solution. All details provided will be kept confidential.
• Discuss options: We will discuss options for resolution with you and if you have suggestions about how the matter might be resolved you should raise these with our Privacy Officer.
• Investigation: Where necessary, the complaint will be investigated. We will try to do so within a reasonable time frame. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.
• Conduct of our employees: If your complaint involves the conduct of our employees we will raise the matter with the employee concerned and seek their comment and input in the resolution of the complaint.
• The complaint is substantiated: If your complaint is found to be substantiated, you will be informed of this finding. We will then take appropriate agreed steps to resolve the complaint, address your concerns and prevent the problem from recurring.
• If the complaint is not substantiated, or cannot be resolved to your satisfaction, but this Privacy Policy has been followed, LifeTec may decide to refer the issue to an appropriate intermediary. For example, this may mean an appropriately qualified lawyer or an agreed third party, to act as a mediator.
• At the conclusion of the complaint, if you are still not satisfied with the outcome you are free to take your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au

We will keep a record of your complaint and the outcome.

We are unable to deal with anonymous complaints. This is because we are unable to investigate and follow-up such complaints.

Changes to this Privacy Policy

LifeTec reserves the right to review, amend and/or update this policy from time to time.

We aim to comply with the APPs and other privacy requirements required to be observed under State or Commonwealth Government contracts.

How to Contact Us

Individuals can obtain further information in relation to this privacy policy, or provide any comments, by contacting our privacy officer:

Jenny Velkovic
Finance and Administration Manager
Phone: 07 3552 9000
Email: jennyvelkovic@lifetec.org.au