Privacy and Information Management Policy
Policy statement
Transforming Therapy Services is bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988. The APPs are designed to protect the confidentiality of information and privacy of individuals by regulating the way personal information is collected, used, disclosed and managed.
Transforming Kids is committed to ensuring the privacy and dignity of our clients and employees and has created the Privacy and Information Management Policy to ensure we manage and safeguard company, employee and client information whilst meeting the requirements of:
The Privacy Act 1988
National Disability Insurance Scheme Act 2013
NSW Health Records and Information Privacy Act 2002 (HRIP Act)
Transforming Kids Therapy Services is committed to ensuring the privacy and confidentiality of company, employee, and client information, ensuring that information is stored with appropriate use, access, transfer, storage, security, retrieval, retention, destruction, and disposal processes relevant to the scope and complexity of supports delivered.
Transforming Kids is committed to enforcing The APP along with the National Disability Insurance Scheme Act 2013, ensuring the privacy and confidentiality of our clients and employees.
Transforming Kids is committed to reporting any data breech to OAIC and appropriate parties.
Our Privacy and Information Management Policy is split into 4 procedures:
Client Information Management Procedure
Workplace Health and Safety Information Management Procedure
Information Security Procedure
Data Breech Procedure
Transforming Kids employees receive training to enable adherence to Transforming Kids procedures which ultimately enable adherence to:
Privacy Laws
Human Rights Laws
Child Protection
Quality Management
Workplace Health and Safety
Clients / families / advocates can engage with the information management system through providing feedback and ideas as outlined in the:
Inclusion and Collaboration Policy and Procedure
Feedback and Ideas Policy and Procedure
This policy applies to all team members Transforming Kids Therapy Services including Directors and Managers and all customers, their families, and advocates.
All Procedures are available in clinic via speaking with the practice manager.
Client Information Management Procedure
1.0 Purpose
This procedure outlines how we manage client:
Information Collection and handling
Information Use and Disclosure
Information Quality
Information Security
Information Openness
Information Access
Information Identifiers
Information Anonymity
Specific procedures for the above regarding specific service procedures, are outlined within the service procedure i.e. Assessment or support planning.
2.0 Definition
Confidential Record or Report - A confidential record or report is one that may contain personal and/or financial information about a worker, such as medical certificates or reports.
3.0 Procedure
Information collection and handling
Transforming Kids Therapy Services aims to collect information in a useful, fair, lawful, and non-intrusive manner. Collection and handling procedures for specific procedural purposes i.e., assessment, support planning or collaboration are outlined within those policy and procedures.
In general, we:
Ask for permission to collect information at referral, on assessment and throughout therapy to identify and facilitate appropriate services.
During assessment we ask for consent to collect information through observation, client information such as reports from other professionals, questionaries’ and through discussion.
We request information on preferred language and any cultural considerations.
Information held may also include clinical session notes, emails, transcripts of telephone conversations and work samples.
CCTV footage is also held for 30 days before being automatically deleted. Some client videos may be held for teaching or professional development purposes. Clients are asked through the service provision agreement to ‘OPT OUT’ if they do not wish for any video footage to be used or stored for teaching purposes.
By law client information is held for 7 years after finalizing services or until the child is 25 years old, whichever is longer.
We request consent from clients to share any information with external providers. This consent can be withdrawn at any time through verbal or written communication with any Transforming Kids employee.
All client information is saved under the client’s name, file name and year and arranged into client folders.
Information Use and Disclosure
All information gathered is used or disclosed solely for the original purpose of collection, to facilitate best practice service provision for clients.
Video footage is used for best practice service provision, ensuring quality service provision through professional reviews and training. Clients can seek to opt out of video recordings.
When children are using Medicare Plans or Access to Allied Psychological Services (ATAPS) it is mandatory that initial and follow-up written reports are forwarded to the family doctor or to Medicare Local.
By law, we are required to disclose information without parent permission in exceptional circumstances. These may include evidence of child abuse, issue of a court order, location of a missing person, prevention of serious and imminent threat to a person’s health or welfare or during a National Disability Insurance Scheme audit through a registered auditor.
We are also required by the National Disability Insurance Scheme to report to the NDIS via submitting reports upon your review process. This is required and not optional.
No personal information is disclosed to overseas persons or agencies. There is no secondary use of information for advertising or research purposes, unless otherwise negotiated.
Information Quality
Transforming Kids takes all reasonable care to ensure that the personal information we collect or disclose is accurate, complete and current. We request parents advise us if personal information we are holding is inaccurate, out of date, incomplete, irrelevant or misleading. Parents have a responsibility to provide us with updated d.
All documentation produced by Transforming Kids Therapy Services must process through our quality management procedures which are outlined with the Quality Management Policy and Procedures.
Information SECURITY
All files are confidential with access limited to employees and where necessary clerical staff for administrative purposes. Transforming Kids Therapy Services employees have been instructed on the principles of the Privacy Legislation and are committed to protecting privacy rights.
All client information is stored on a secure cloud storage system which has end to end encryption ensuring privacy and confidentiality. Our cloud storage is held within Australia as per requirements by the Privacy Acts.
Any client information is held within locked offices and filing cases throughout the day and overnight. All Computers are password protected and locked when unattended and overnight.
Client sensitive information is held within red boxes and are not allowed to be in accessible and unsupervised areas at any time.
Employee offices are always closed and protected by number locks to limit access.
Information OPENNESS
Transforming Kids seeks to provide parents, carers and all parties involved with our client’s information regarding skill development, the brain and any other therapeutic information. We seek to provide this information transparently and free, allowing unrestricted access to knowledge and information to assist our client’s progression. We seek to collaboratively and cooperatively manage and make decisions with families and all parties involved.
All clients are informed of how their information is managed through:
Transforming Kids Welcome Pack which details privacy and information management.
Service Provision Agreement and Privacy Consent Forms
Service agreement Forms
Information ACCESS:
Parents or legal guardians can request a copy of information about their child generated by Transforming Kids Therapy Services. From the age of 18 years, young people can request a copy of information about themselves. Requests to access information should be made to the Director, Bridie Travers. Information about children who are ‘Under the Care of The Minister’ can only be provided with permission from the child’s caseworker. Information cannot be provided in the case of Medico Legal assessments.
Information IDENTIFIERS:
Transforming Kids Therapy Services does not use or disclose an identifier that has been assigned by a Commonwealth government ‘agency’ i.e. Tax File Number, Medicare Number.
Information ANONYMITY:
Parents may choose to withhold information about their child, or for themselves and their child to attend anonymously or with pseudonyms, with the understanding that this will probably jeopardize the quality of provided service.