1. Purpose
Support Services Queensland provides an effective and high-quality service. In order to do this, and to maintain appropriate accountability, we must collect, store and sometimes share, relevant personal information about our clients, staff, committee and volunteers. The purpose of this policy is to help us be consistent and careful in the way we manage what is recorded about anyone, and how we decide who can see or hear this information. Our clients have legislated rights to privacy. It is essential that we protect and uphold these rights, and also that we act correctly in those circumstances where the right to privacy may be overridden by other considerations.
To uphold the rights of clients to privacy, each staff and management member, and every contractor or volunteer working for Support Services Queensland, needs an appropriate level of understanding about how we meet our legal obligations.
2. Scope
This policy will apply to all clients, staff, managers, contractors and volunteers working for Support
Services Queensland. All information, whether written, verbal or electronic, is covered by this policy.
Support Services Queensland may be legally required to disclose information about a client:
• At the client’s request, for example as part of hand-over to another service provider
• In accordance with a client’s recorded directions, for example an instruction to inform a family member
• In a medical emergency in order to ensure correct treatment where the client is unable to communicate their needs or wishes
• If required to do so by law
3. Policy statement: Our commitment
Support Services Queensland is committed to protecting and upholding the rights of our clients to privacy in the way we collect, store and use information about them, their needs and the services we provide to them. We want our clients to have confidence that we take these responsibilities seriously.
Specifically, we will:
• Explain this policy to clients and the measures we put in place to protect their privacy,
• Explain to clients the circumstances and legal obligations that may require us to share their information,
• Explain this policy and our behavior expectations to staff, managers, contractors and volunteers working for Support Services Queensland,
• Require that staff, managers, contractors and volunteers confirm their commitment to upholding this policy in writing,
• Ensure that when clients are interviewed or discussing matters of a personal or sensitive nature with staff or volunteers that this is done in a private area in order to avoid being overheard,
• Require that Support Services Queensland staff, managers and volunteers record information about clients and others carefully, accurately and sensitively- using professional language and capturing the details necessary to ensure high-quality services can be delivered,
• Use technology such as password protection and secure storage to protect private information.
4. Procedures
4.1 Privacy
Support Services Queensland manages our obligations in relation to protecting the privacy of our
clients by making sure that we meet the Australian Privacy Principles specified in the Federal Privacy
Act of 1988 which requires that:
1. Personal Information is managed in accordance with the Privacy Act and in an open and transparent way, and that the organization has an up to date Privacy Policy detailing;
• The kinds of personal information Support Services Queensland collects and holds,
• How it collects and holds personal information,
• The reasons for collection, use and disclosure of information,
• How an individual may access and/or correct personal information about them,
• How an individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint,
• Whether the entity is likely to disclose personal information to overseas recipients, and if so, the likely recipients and their location(s).
2. Support Services Queensland provides individuals with the option of not identifying themselves, or of using a pseudonym, unless there is a legal requirement that individuals identify themselves.
3. Support Services Queensland refrains from collecting personal information (other than sensitive information) unless the information is reasonably necessary for, or directly related to, one or more of the entity’s functions or activities. The collection of sensitive information about individuals must be carried out by legal means, with consent, and be reasonably necessary for, or
directly related to, one or more of Support Services Queensland’s functions or activities; or be required by law.
4. Support Services Queensland decides whether unsolicited personal information it receives could legally have been collected, and if not, then this information must be appropriately destroyed.
5. At the time of collecting information, Support Services Queensland notify the individual that they are collecting information about them, why, how it will be stored, the circumstances under which it may need to be shared, how the individual may access or correct the information and how they may make a complaint.
6. Support Services Queensland avoids collecting information for one purpose and then use or disclose it for another purpose without the consent of the individual, unless required by law.
7. Support Services Queensland must avoid disclosing information for the purpose of direct marketing without the consent of the individual.
8. If Support Services Queensland needed to disclose information to an overseas recipient, that reasonable steps be taken to ensure the overseas recipient does not breach the Australian Privacy Principles.
9. Support Services Queensland avoids disclosing or adopting a government related identifier of an individual as its own identifier of the individual, unless required or authorized to do so by law, or unless disclosure is essential to carrying out its functions.
10. Support Services Queensland takes steps to ensure that the personal information that the entity collects is accurate, up-to-date, complete and relevant.
11. Support Services Queensland takes steps to protect personal information from misuse, interference and loss; and from unauthorised access, modification or disclosure.
12. Support Services Queensland give individuals access, on request, to their own information and any charge imposed for doing so must not be unreasonable.
13. Support Services Queensland allow individuals to correct personal information that is held about them, and if requested to do so by the individual, must notify third parties of the correction.
Support Services Queensland also operates in accordance with Queensland Privacy law.
The Queensland Information Privacy Act 2009 (the IP Act) replaces the administrative privacy scheme.
The IP Act:
• Gives you a right to apply to access and amend your own personal information
• Details the privacy principles public sector agencies must comply with
• Establishes the Privacy Commissioner as a deputy to the Information Commissioner with particular responsibility for Information Privacy in Queensland
• Provides a complaint mechanism for formal complaints about breaches of the privacy principles or other requirements of the IP Act. In protecting the privacy of our clients, we ensure they are well informed about their rights and that we take our responsibilities seriously:
• Every client signing up with Support Services Queensland receives both a face to face and written explanation of their privacy rights, the information about them that is collected, stored and the circumstances under which it could be shared. Clients are also informed of the process for correcting information and making complaints,
• Everyone who works or volunteers for Support Services Queensland must read and be trained in applying this policy. They must also be trained in the Support Services Queensland Information Management Policy to ensure that client information is recorded properly and stored securely,
• Employers, volunteers and managers are required to take calls and conduct client meetings in the meeting rooms provided in the office, or in places where they cannot be overheard if they are not working off-site.
The offices of Support Services Queensland provide:
• A private room for interviewing clients or talking with them about matters of a sensitive or personal nature,
• Workstations that are not overlooked by people entering at reception,
• Lockable cupboards to hold client files and employee files
• A lockable archive room for files.
Support Services Queensland clients may also request a home visit and may send an email or leave a message out of hours to book an appointment.
Appendix A: Privacy Statement
Privacy Statement
Support Services Queensland provides high quality services to clients. Part of our work requires that we collect private information about clients, staff, managers and volunteers.
Support Services Queensland undertakes that we will:
• Only collect personal information necessary to perform our services,
• Collect and store personal information carefully and so as ensure it is accurate and to avoid accidental disclosure or theft,
• Allow people whose personal information has been collected to access it and to provide corrections if necessary,
• Only disclose personal information to other people or agencies with permission or as required by law,
• Operate in accordance with State and Commonwealth law,
• Maintain an up to date privacy policy, and act on it in the way we run our organisation,
• Educate staff and volunteers on the Privacy Policy and make it available to clients.
If clients believe Support Services Queensland has fallen short of these standards, they may complain to Support Services Queensland and we will do our best to fix the problem. If clients are still unsatisfied with a resolution, they may also complain to the Queensland Office of the Information Commissioner at www.oic.qld.gov.au
Policy Context
This policy relates to:
Human Service Quality Framework Standard 1 Governance and Management
Indicator 7: The organisation has effective information
management systems that maintain appropriate controls
of privacy and confidentiality for stakeholders
Legislation or other requirements The Privacy Act
1988 (Cth) http://www.privacy.gov.au/act/index.html
The Information Privacy Act 2009
(Qld) http://www.rti.qld.gov.au
Personally Controlled Electronic Health Records Act
2012 (PCEHR Act)
Do Not Call Register Act 2006;
The Spam Act 2003;