Privacy Policy

Privacy and Confidentiality Policy

Purpose: CoastalPlay OT is committed to protecting the privacy of personal information collected. CoastalPlay OT complies with the Australian Privacy Principles (APPs) under the Privacy Act 1988, other privacy laws that govern how private sector health service providers handle your personal information (including your health information), and Occupational Therapy Australia’s Code of Ethics. In order to provide clients with Occupational Therapy services, CoastalPlay OT will need to use and collect personal information. CoastalPlay OT relies on clients to provide accurate personal information. Should clients decide to withhold or provide inaccurate personal information to CoastalPlay OT they need to be aware that this could impact the ability of CoastalPlay OT to provide the service they request or require. Framed by the NPPs, the CoastalPlay OT Privacy Policy outlines the obligations which CoastalPlay OT has in managing the personal information it holds about its clients (parents, carers and children), potential clients, employees, suppliers, contractors and others. Any information provided, including identification of individuals, will be used only for the purpose/s intended and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.

Definitions: “Personal Information” includes a broad range of information, or an opinion, that could identify an individual. “What is personal information” will vary depending on whether a person can be identified or is reasonably identifiable in the circumstance. For example, personal information may include:

·  An individual’s name, signature, address, phone number or date of birth

·  Sensitive information

·  Credit information

·  Employee record information

·  Photographs

Sensitive information is also personal information, however special protection applies to this type of information. For example, sensitive information may include:

·  Racial or ethnic origin

·  Political opinions or associations

·  Religious or philosophical beliefs

·  Trade union membership or associations

·  Sexual orientation or practices

·  Criminal record

·  Health and genetic information

Policy: At CoastalPlay OT, we take the privacy and personal information of the parents, carers and children who visit us, our employees and our suppliers very seriously. We won’t discuss your child or give you or your child’s personal information to any individual, company or organisation outside of CoastalPlay OT unless you’ve provided us with your written consent or we are legally obliged to. Importantly, in the case of divorced or separated parents, we will only deal with the fee-paying party who engaged our services in the first instance. We will only share information relating to the assessment and treatment of the child with the other parent and/or carers if we have the consent of the initial party or are legally obliged to disclose specified information. We’ll never sell or trade your personal data to third party list brokers or direct marketing companies. We’ll do our very best to ensure that your personal data is kept safe and secure for as long as your details are in our care. Once our relationship has been concluded, CoastalPlay OT will destroy or de-identify personal information due to redundancy, after our legal obligations to retain the information have expired.

When will CoastalPlay OT collect personal information?
CoastalPlay OT will usually gather personal information about children and families:

·  When a parent or carer books a child in for an assessment/therapy

·  During the course of providing services

·  When a child, parent or family uses the CoastalPlay OT website (e.g. when they fill out a referral form or subscribe to an online newsletter).

Why does CoastalPlay OT collect personal information?
CoastalPlay OT collects personal information in order to conduct its business, to provide and market its services and to meet its legal obligations. We won’t use your personal data for any purpose that you have not agreed to, without first letting you know how and why we’d like to use your details. And, of course, we’ll make sure that we have your verbal and/or written permission first. Information is used for:

·  Setting up client profiles on our Practice Management Software

·  Billing either direct or through a third-party agency

·  When a handover is required between therapists within our clinic

·  Communicating with other Health Care Professionals or others involved in the child’s care (after third party consent has been received)

·  Audit purposes

·  To liaise with NDIA, NDIS, Health Funds and/or Medicare

About whom does CoastalPlay OT collect personal information?
The type of information CoastalPlay OT may collect and hold includes (but is not limited to) personal information about:

·  Clients (parents, carers and children) and potential clients

·  Employees, prospective employees and contractors

·  Business associates

·  Suppliers and their employees, and

·  Other people who come into contact with CoastalPlay OT

What kinds of personal information does CoastalPlay OT collect?

In general, the type of personal information CoastalPlay OT collects and holds includes (but is not limited to):

·  Parent’s/carer’s names, marital status, occupation(s), child’s/children’s names and dates of birth, parent and child’s home and postal address(es), parent’s email address(es), mobile number(s), home telephone number(s), work number(s) and facsimile number(s).

·  Child’s diagnosis and reason for referral

·  General practitioner or referring doctor/practitioner 

·  Other health professionals and agencies involved 

·  School or kindergarten details 

·  Any information relating to Federal Government Healthcare Programs (i.e. Medicare or NDIS)

·  Transaction details associated with services we have provided to you

·  Any additional information provided to us by you

·  Any information you provided to us through client surveys

·  Other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations.

How does CoastalPlay OT collect personal information?
CoastalPlay OT will generally collect personal information with your agreement by way of telephone conversations, forms filled out either in hard copy or on-line, in face-to-face meetings, assessments, interviews, business cards and from third parties. In some circumstances CoastalPlay OT may be provided with personal information about an individual from a third party – for example, a report provided by a medical professional or a referral from another professional.

Website collection
CoastalPlay OT collects personal information from our website through referral forms, emails or newsletter subscription. They also use third parties to analyse traffic at that web site, which may involve the use of cookies. CoastalPlay OT may create links to third party websites and is not responsible for the content or privacy practices employed by websites that are linked from CoastalPlay OT website. 

How might CoastalPlay OT use and disclose your personal information?
CoastalPlay OT may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.

In general, CoastalPlay OT uses and discloses your personal information for the following purposes:

·  To conduct its business

·  To provide and market its services

·  To communicate with you

·  To provide treatment and care to your child

·  To assist your treating health professionals to provide treatment and care to you – e.g. speech pathologists, psychologist, counsellors 

·  To assist us to provide you with information about your care, if required

·  To assist with our internal administrative requirements

·  To process Medicare, NDIS and private health fund claims

·  To supply information to medical practitioners and other allied health professionals who provide necessary follow up treatment and ongoing care

·  To conduct research and development

·  To conduct service planning

·  To communicate offers and special events

·  For general marketing purposes

·  To help us manage and enhance our services

·  To comply with our legal obligations.

To whom might CoastalPlay OT disclose your personal information?
CoastalPlay OT may disclose your personal information to:

·  Other members of the CoastalPlay OT Team

·  Legal practitioners, courts, tribunals and regulatory authorities, and

·  Anyone else to whom you authorise us to disclose it to

CoastalPlay OT also collects personal information from these organisations and individuals, and will deal with that information in accordance with this Policy.

How does CoastalPlay OT keep personal information accurate and up-to-date?              
CoastalPlay OT endeavours to ensure that the personal information we hold is accurate, complete and up-to-date. We encourage you to contact our admin team to update any personal information we hold about you. CoastalPlay OT works in partnership with a range of government departments and health services and is required by law to pass on certain information about clients. We must also adhere to the laws of Mandatory Reporting, and therefore must notify relevant authorities about certain issues (e.g. child protection). External and internal quality auditors may view a small amount of personal information to check that CoastalPlay OT is meeting its obligations for accreditation. Auditors are bound by their own and/or CoastalPlay OT’s confidentiality requirements. Volunteers and students on placement at CoastalPlay OT are also bound by CoastalPlay OT’s confidentiality requirements. In some cases, we share stories about CoastalPlay OT families through newsletters, publications, or media stories. We will always seek your permission to do this and will tell you exactly where and when your story will appear.

Sending information overseas

CoastalPlay OT will not send your personal information to recipients outside of Australia without:

·  Obtaining your consent (in some cases this consent will be implied), or

·  Otherwise complying with the NPPs.

Access to information

Clients may request access to their personal information held by CoastalPlay OT by writing to the Director via email. CoastalPlay OT will require you to verify your identity and to specify what information you require. In some instances, a fee may be charged for providing access. We will advise you of the likely cost in advance. Where we hold information that clients are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you may collect (e.g. post or in-person collection). If you believe that personal information that we hold about you is incorrect, incomplete or inaccurate, then you may request amendments. We will consider if the information requires amendment and if we do not agree, we will add a note to the personal information stating your disagreement with the information.

Management of personal information

The NPPs require CoastalPlay OT to take reasonable steps to protect the security of personal information. CoastalPlay OT personnel are required to respect the confidentiality of personal information and the privacy of individuals. As such, all staff sign a confidentiality agreement upon employment at CoastalPlay OT. CoastalPlay OT takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Where CoastalPlay OT no longer require your personal information for a permitted purpose under the NPPs, they will take reasonable steps to destroy it. If a breach occurs CoastalPlay OT will follow our ‘Breach of Personal Information Policy and Procedure’.