Privacy, Dignity and Confidentiality Policy
Purpose
Happy Paws Happy Hearts Foundation privacy, copyright and disclaimer statements are designed to protect your rights and govern the use of information on this website.
Privacy Statement
HPHH privacy procedures have been developed with your rights and needs in mind. HPHH will take all reasonable and appropriate steps to protect the privacy of individuals in regards to the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles contained in the Privacy Act.
All employees, volunteers and other service partners of Happy Paws Happy Hearts (HPHH or we or us) are expected to uphold the rights of people to privacy, dignity and confidentiality.
HPHH values your privacy. We abide by the requirements of the Privacy Act in relation to the collection, use and disclosure of your personal information and comply with other applicable laws protecting privacy including State and Territory health information regulation.
By accessing our website, engaging our services or providing personal information to us, you consent to our collection, use and disclosure of that information on the terms of this privacy policy and any other contractual or other arrangements that we may agree on between us (if applicable).
Scope
This policy describes how your privacy is respected and protected in accordance with the Australian Privacy Principles. This applies to any information we collect about you through our services. This includes information collected in person, in forms completed by you or on your behalf, by telephone, through this website, via our services, via your other service providers and by other electronic communication channels which you use to access our services.
Implementation of this policy applies to all persons engaged by HPHH. Records and information obtained relating to employees and volunteers are to be kept in accordance with the Happy Paws Happy Hearts – Privacy, Dignity and Confidentiality Procedure.
Objectives
Participants have an ethical and legal right to privacy, dignity and confidentiality. Employees and volunteers will recognise and respect a participant’s right to privacy, dignity and confidentiality in all aspects of their lives.
Agreement and Acceptance
Your continued use of our website and/or other services indicates that you accept the conditions of our Privacy Policy, consent to the collection and use by us of any personal information you provide while using our services, website or HPHH’s apps.
What is personal information?
Personal information is defined under the Privacy Act as "any information or an opinion about an identified individual, or an individual who is reasonably identifiable: (i) whether the information or opinion is true or not; and (ii) whether the information or opinion is recorded in a material form or not." This may include your name, address, telephone number, email and profession or occupation. If the information received identifies you or your client, or you are reasonably identified through it, the information is considered personal information.
Collecting and using your personal information
HPHH collects and holds personal information in accordance with this privacy statement and we
will:
tell you when and for what purpose we will be collecting the information;
tell you what information is necessary to access our products and services, including
payments and transactions;
not ask for or collect any personal or sensitive information about you unless it is necessary to meet legal, public interest or statistical requirements to complete the requested transaction; and
take all reasonable steps to permanently remove personal identification from the information collected about you if it is no longer needed.
Why do we collect personal information?
HPHH collects your personal information for the purpose of assessing your eligibility to participate in HPHH programs, as well as to conduct the programs and contact you about other relevant programs and offers. Accordingly, we may use and disclose personal information we collect to:
both deliver and improve on our services to participants and their supports;
assess the satisfaction and progress participants make in our services;
verify the identity of who we are interacting with;
communicate and raise awareness of our services;
administer and manage our services including issuing invoices (as applicable);
check for any fraud;
update our records and keep contact details up to date;
maintain and develop our business systems and infrastructure; and
suit any other purpose which are with your consent and permitted by law.
For these reasons, we may disclose your information to third party organisations such as background check providers and third-party IT service providers some of which may be located in overseas locations.
Here are some examples of times we may collect personal information which includes but is not
limited to the following:
Processing expressions of interest to participate or volunteer in our services:
HPHH collects and stores personal information on our database which may include name, address, email address and contact phone numbers in order to contact you about our upcoming courses for either you or your participants. We will only use sensitive information (e.g. health information) for direct marketing purposes with express prior consent. You may opt-out of receiving materials from us by contacting our office (contact
details below).
Providing or developing services to you or your clients and marketing our services to you or your clients: HPHH collects personal information about individuals for our general operations to deliver our courses. From time to time, we may collect, use and disclose personal information for quality assurance, risk management, billing and admin purposes.
Research: If you agree to partake in our research and feedback processes, we may place your name and contact details in our internal systems. You can opt-out of participating in research activities or feedback processes at any time by contacting us or discussing this with our trainers.
Sensitive information: As part of our business, we may collect sensitive information if it is relevant to the provision of our services. That information will be treated in accordance with the requirements of the Privacy Act and any state and territory health information legislation.
How is personal information collected?
In addition to the above, we may also collect personal information that is:
provided to us through our website;
provided to us from third-parties such as plan managers, rehab providers, etc.; and/or
obtained by us from publicly available sources of information.
We may use cookies, Google Analytics and other technology services to track visits to our website, smartphone, and web apps so that we can monitor the effectiveness of, and continuously improve, our services. Types of data collected include:
date and time of visits to our sites/apps;
server addresses of users;
top level domain names;
the identity of the pages accessed and services used;
any previous website visited before you landed on our website;
if the individual has visited the site before; and
the browser used.
Statistics collated for the above will not identify you as an individual.
Marketing and remarketing
HPHH uses Google, Facebook and Instagram analytics to track the effectiveness of our website and products. For more information on third party policies, please refer to:
HPHH uses third-party vendor remarketing tracking, including the Google Adwords tracking cookie and various social media remarketing cookies. This means we will continue to show ads to you across the internet such as social media platforms or the Google Content Network. As always we respect your privacy and are not collecting any identifiable information through the use of Google, or any other third party remarketing system.
Principles
The terms privacy, confidentiality and dignity relate to:
Privacy – the right to keep information and activities secret and being kept out of the presence or view of others (this includes but not limited to - storage of records, progress notes, support plans, videos, photos and with who can have access to information).
Dignity – the quality of being worthy of esteem and respect (this means that participants should: feel they are a valued member of the community; be supported and cared for in a respectful manner by closing doors of bathrooms or toilets if supporting a person with toileting; not talk on behalf of or over participants, listen to participants’ comments, views, ideas, feedback and/or complaints and take relevant action).
Confidentiality – respecting the confidence of another person or showing discretion in keeping information private from the knowledge of others (this means that meetings with participants and/or stakeholders should be conducted in a private room; matters concerning the personal information of a participant are only discussed with persons that require that information as part of the service delivery; and participant matters are not discussed in hallways, lunchrooms or outside the work environment).
Information about a participant is not to be shared with any stakeholders without the participant’s permission or the permission of their decision-maker. The only time information will be shared against the participant’s wishes with other agencies or persons, is in situations that pose a serious threat to life or health to the participant, employee, volunteer or members of the community, or for some other legal or legislative matter.
Information about the participant is recorded, maintained, stored and made available in ways that respect the participant’s right to privacy, dignity and confidentiality. HPHH will only collect information about a participant so as to ensure that participants can get the most benefit from attending the program.
Information we request from participants will help us ensure their safety, wellbeing, effectiveness and value for money. Personal information we may require includes:
name;
age or date of birth;
goals and aspirations;
emergency contact details;
decision-maker contact details (if applicable);
positive behavior support plan (if applicable);
support needs;
medical emergency contact details;
specific health or dietary requirements; and
signature.
HPHH has access to tools and resources to assist participants to understand their rights when sharing information, these include but are not limited to the NDIS Code of Conduct.
When will we disclose information?
We will not disclose your personal information to any third party unless one of the following reasons apply:
you have given us your consent to do so;
the information is needed to conduct a transaction relevant to HPHH's training programs between you and the third party;
there are grounds to believe disclosure will prevent or lessen a serious and imminent threat to somebody’s life or health;
if we are required by law or we believe in good faith that the action is necessary in order to comply with law, cooperate with law enforcement or other government agencies, or comply with legal process served on the company (including insurers) or court order;
our contractors only to the extent necessary for us to perform our duties or fulfill our services to you;
to our related companies, for the purpose of performing our services or fulfilling our duties to you;
to our professional advisers, including our accountant, auditors and lawyers to assist us in performing our services;
to any government or semi-government organisation who requests it (including but not limited to as part of an application for funding or other benefits);
if you are not able to provide us with consent, we may use and disclose your personal information with the consent of a guardian or other responsible person (if applicable)responsible person (as defined under the Privacy Act); or
as otherwise permitted by law.
If we retain any sensitive information, that information will not be used, shared or disclosed without the express consent or implied consent that is current, voluntarily given and obtained in accordance with the Australian Privacy Principles. If the individual is unable to give consent then we may use and disclose personal and sensitive information with the consent of a guardian or other responsible person (as defined under the Privacy Act).
Security of your personal information
We regard the security of personal information as a key priority and implement a number of physical and electronic measures to protect it. Staff who have access to personal information may be required to sign a confidentiality agreement as well as follow our security protocol and if other service providers are used, they will be bound by our Privacy Policy and Data Sharing Agreement, which ensures they must comply with the Privacy Act in handling any personal information that we disclose to them.
Any printed personal records will be kept in a locked area and will only be made available to employees who need to access the information.
All HPHH personnel are to respect the privacy and confidentiality of relationships between participants, their families, guardians, advocates and friends.
Accessing, correcting and updating your information
Participants have the right to view their information and amend or alter any information.
Requests from participants who ask to see what information HPHH maintains about them will be dealt with in a prompt and transparent manner.
Accessing large amounts of information or information from various sources may take time before we can respond.
If you wish to view the information we hold of you, please contact the organisation (contact details provided below).
If we refuse to give you access to your personal information or correct your personal information, we will give you a reason for the decision. Generally, if requested, we can amend any personal information which you demonstrate is inaccurate, incomplete or not current and will remove any irrelevant information.
Online transactions
Our website or electronically issued invoices may be enabled to process online transactions using a certified secure payment gateway. You should still be aware that there are inherent risks in transferring information across the internet and we cannot accept liability for any breaches. When an internet payment is made, your credit card number is used only by the third-party service provider and it is not retained by us.
Security measures for online payments
Payments made online on our website or invoices are processed in real-time using a secure payment gateway. Payments are processed in Australia in Australian dollars. Our website has security measures designed to protect against the loss, misuse and/or alteration to your personal information to the extent that it is under our control.
Links to other websites
Our websites may contain links to third-party websites, and the third-party website may also have links to our websites. We do not endorse any of those websites or links. This Privacy Policy only applies to our organisation. We encourage you to read the privacy policies or any website you link to from this website.
Policy Review
This Privacy Policy is current. We may vary this Privacy Policy by publishing a new version on the website. You accept that by using the website or continuing to use our services, you agree to the terms of this current Privacy Policy, including as updated from time to time.
We reserve the right, as it may be necessary, to review, revise or make changes to this policy and will notify you of those changes by posting the latest version on our website.
Roles and Responsibilities
HPHH Employees and Volunteers must:
Familiarise themselves with this policy.
Understand what it means to respect and uphold a person’s right to privacy, dignity and confidentiality.
Not share any information about the participant without their consent and knowledge.
Assist participants in ways which help them to maintain their dignity.
Not discuss or pass any personal information/matters relating to any participant outside HPHH.
Not take and store photos, videos or information about the participant using their personal devices. HPHH will provide devices for this specific purpose during the sessions.
Chief Executive Officer is accountable for:
Ensuring all persons engaged in HPHH understand and comply with this policy.
Ensure all new participants are aware of their rights and provide approval to share their information (where applicable).
Ensure that the information is accurate, complete and up to date.
Guide and support employees and volunteers to ensure they understand and uphold, in all aspects, the participant’s right to privacy, dignity and confidentiality.
Take the necessary measures to safeguard participants’ records and other stored information.
Ensure that the information collected from the participant is used within the intentions as discussed and consented by the participant.
Complaints
If you wish to make a complaint about a possible breach of privacy, please provide full details in writing and set it to our organisation (contact details below).
If your complaint relates to our failure to provide access to or to correct personal information that we hold about you, you may lodge a complaint directly with the Office of the Australian Information Commissioner (/).
If your complaint does not relate to these matters, you must first lodge a complaint to us in writing and provide us with details so we can investigate. We treat any complaint with confidentiality, investigate your complaint and aim to ensure that we contact you and resolve your complaint in a reasonable time (any, in any event, the time required by the relevant privacy legislation, if applicable).
If you need more information on your rights and remedies for breaches of privacy, you can access detailed information through the Office of the Australian Information Commissioner - https://www.oaic.gov.au
Contact Details
If you would like any further information about our Privacy Policy or the way we manage your
personal information, you can contact us:
Email: hello@hphhfoundation.org
Mail: PO Box 458, Kenmore Queensland 4069
Phone: 1300 077 984
POL-010 Privacy, Dignity and Confidentiality Policy
Version: 2.0 Date Approved: 16/11/2021
Approved by: CEO