Confidentiality – Ensures that information is accessible only to those authorised to have access, and is protected throughout its lifecycle.
Consent – Refers to consent that is clearly and unmistakably stated and can be obtained either in writing, orally or in other forms where the consent is clearly communicated.
Personal information – Any information that can be used to personally identify a person. This may include their name, address, telephone number, email address and profession or occupation. Personal information also includes sensitive information about a person, such as health information.
Sensitive information – Information on race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health information or sexual activities is classified as sensitive information under legislation.
Collection of Information
Synergy Vision Pty Ltd collects personal information (name, contact details as well as other information including health information) in order to carry out its functions. The information is used to:
- Assess what services are required.
- Assess eligibility for our services.
- Evaluating services.
- Assessing applications to become volunteer, contractor or employee.
- Research and analysis.
- Complaint handling.
The function will determine the type and amount of information required in each situation. See Human Resources Policies, Information Management Policies, Feedback and Complaint Policy for more detailed information about information handling in these contexts.
De-identification of individuals
Where it is not necessary to identify who information relates to, such as surveys, personal information should be collected in a way so that an individual cannot be identified from the information.
Source of personal information collected
Personal information is only collected from the individual it relates to unless collection from another party is authorised through expressed consent from the individual concerned. If the individual is under 16 years of age, information can be collected from a parent or legal guardian.
Synergy Vision Pty Ltd provides information to service users at the time they first make enquiries of the legal, practical or other contractual limits of personal information collection and confidentiality. This information is provided in the privacy statement available on our website, in the Information Pack that is provided to prospective service users and in an open conversation at the point of first contact with service.
The information provided includes:
- Purpose of collecting information.
- How information will be used.
- Who (if anyone) information may be transferred to and under what circumstances information will be transferred.
- Limits to the privacy of personal information.
- How a client can access or amend their health information.
- How a client can make a complaint about the use of their personal information.
This information and more is available on the Client Rights and Responsibilities Charter provided by Synergy Vision.
Use and Disclose
Synergy Vision Pty Ltd only uses personal information for the purpose for which it was given. It may be provided to government agencies, other organisations and individuals if:
- The individual has consented via a Consent Form provided by Synergy Vision.
- It is required or authorised by law.
- It will prevent or lessen an imminent threat to somebody’s life or health.
Synergy Vision Pty Ltd may use the information for internal reviews and analysis and may also use certain consolidated statistics about services. However, Synergy Vision Pty Ltd will not disclose individual information, nor sell, trade or rent information under any circumstances.
Where Synergy Vision Pty Ltd submits copies of client records, files and other documents for accreditation or quality assurance checks, consent will be obtained from the client before doing so. Further assurances will be sought from the reviewers in relation to confidentiality and privacy and no personal and sensitive information may be taken, used to identify an individual as part of this process.
If Synergy Vision Pty Ltd needs to disclose any information to conform with any laws or legal processes, staff will advise the individuals impacted what information has been disclosed and to whom (unless informing them is precluded by legislation). The Manager’s approval is also required before the information can be released.
Some government departments that Synergy Vision Pty Ltd receives funding from requiring regular reports about the types of services provided and to whom they are provided. They may also need information to conduct program evaluations. The information provided is aggregated data from our records and no individual can be identified. Synergy Vision Pty Ltd sends this information under secure conditions.
Synergy Vision Pty Ltd takes steps to ensure that the personal information collected is accurate, up-to-date and complete. These steps include maintaining and updating personal information when we are advised by individuals that it has changed (and at other times as necessary) and checking that information provided about an individual by another is correct.
Synergy Vision Pty Ltd takes steps to protect the personal information held against loss, unauthorised access, use, modification or disclosure and against other misuses. These steps include reasonable physical, technical and administrative security safeguards for electronic and hard copy of paper records as identified below.
Reasonable physical safeguards include:
- Locking filing cabinets and unattended storage areas.
- Physically securing the areas in which personal information is stored.
- Not storing personal information in public areas.
- Positioning computer terminals and fax machines so that they cannot be seen or accessed by unauthorised people or members of the public.
Reasonable technical safeguards include:
- Using passwords to restrict computer access, and requiring regular changes to passwords.
- Establishing different access levels so that not all staff can view all information.
- Ensuring information is transferred securely (for example, not transmitting health information via non-secure email).
- Using electronic audit trails.
- Installing virus protections and firewalls.
Reasonable administration safeguards include not only the existence of policies and processes for guidance but also training to ensure staff, Board members, students and volunteers are competent in this area.
Information is not kept any longer than is necessary and is disposed of and archived appropriately in line with the Records Management Policy provided by Synergy Vision.
Access and Correction
Individuals may request access to personal information held about them. Access will be provided unless there is a sound reason under the Privacy Act or other relevant law. Other situations in which access to information may be withheld include:
- There is a threat to the life or health of an individual
- Access to information creates an unreasonable impact on the privacy of others
- There are existing or anticipated legal dispute resolution proceedings
- Denial of access is required by legislation or law enforcement agencies
Synergy Vision Pty Ltd is required to respond to a request to access or amend the information within 30 days of receiving the request.
Amendments may be made to personal information to ensure it is accurate, relevant, up-to-date, complete and not misleading, taking into account the purpose for which the information is collected and used. If the request to amend information does not meet these criteria, Synergy Vision Pty Ltd may refuse the request.
If the requested changes to personal information is not granted, the individual may make a statement about the requested change, which will be attached to the record.
Supervisors are responsible for responding to queries and requests for access/amendment to personal information.
Anonymity and Identifiers
Individuals are entitled to receive services anonymously where it is lawful and practicable, for example Synergy Vision Pty Ltd will accept anonymous donations but is unable to issue tax-deductible receipt to the donor.
It may not be possible to provide a full service if consent to collect personal information and/or create a record (or part thereof) is declined. The reason for this would be explained in full to the individual at the time.
The ‘Publications Consent Form’ is to be explained to all service users, staff and volunteers at their commencement with Synergy Vision Pty Ltd. The agreement section is to be completed for all instances where photographs, film footage, audio material, electronic images, correspondence and/or quotations are used, in material using the Synergy Vision Pty Ltd’ name or logo or collected/taken in the name of the organisation, or in services or activities organised by Synergy Vision Pty Ltd.
Material would always seek to display the individual and Synergy Vision Pty Ltd in the most positive and appropriate manner.
The permission contained in the Publications Consent Form may be withdrawn, at any time by notifying Synergy Vision Pty Ltd in writing. The notification will be attached to the form by the relevant supervisor.
Additionally, those taking part in one-off events will be required to give their consent through the ‘Event Registration’ process.
Other Organisational information
The Human Resources Management policies detail how the organisation handles staff records to manage privacy and confidentiality responsibilities, including the storage of and access to staff personnel files and the storage of unsuccessful position applicants’ information.
Synergy Vision Pty Ltd works with a variety of stakeholders including private consultants. The organisation may collect confidential or sensitive information about its stakeholders as part of a working relationship. Staff at Synergy Vision Pty Ltd will not disclose information about its stakeholders that is not already in the public domain without stakeholder consent.
The manner in which staff members manage stakeholder information will be clearly articulated in any contractual agreements that the organisation enters into with a third party.
Breaches of Privacy and Confidentiality
If a service user or stakeholder is dissatisfied with the conduct of Synergy Vision Pty Ltd’s staff or Board member, a complaint should be raised as per the Feedback and Complaints Policy. Information on making a complaint will be made available to service users and stakeholders or obtained by contacting the Synergy Vision Pty Ltd office directly.