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1.1 Play & Learn Occupational Therapy (“Play & Learn OT”) is committed to ensuring the privacy and confidentiality of all personal information affiliated with Play & Learn OT business undertakings.
1.2 Play & Learn OT follows the terms and conditions of privacy and confidentiality in accordance to the Australian Privacy Principles (APPs) as per schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth), forming part of the Privacy Act 1988 (‘the Act’).
1.3 The purpose of this Privacy Policy is to clearly communicate how Play & Learn OT collects and manages personal information.
1.4 The point of contact regarding any queries regarding this policy is Rachel van der Linden, Director, Play & Learn OT. Phone: 0414687836 Email: rachel@playot.com.au
2.1 As a private sector health service provider and under permitted health situations, Play & Learn OT is required to comply with the APPs as prescribed under the Act.
2.2 The APPs regulate how Play & Learn OT may collect, use, disclose and store personal information and how individuals, including Play & Learn OT’s clients may:
• address breaches of the APPs by Play & Learn OT
• access their own personal information; and, •correct their own personal information.
2.3 In order to provide clients with adequate health care services, Play & Learn OT will need to collect and use personal information. It is important to be aware that if the client provides incomplete or inaccurate information or the client withholds personal health information Play & Learn OT may not be able to provide the client with the services they are requesting.
2.4 In this Privacy Policy, common terms and definitions include:
a) "personal information" as defined by the Privacy Act 1988 (Cth). Meaning "information or an opinion including information or an opinion forming part of a database, whether true or not, and whether recorded in a material format or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion"; and,
b) "health information" as defined by the Privacy Act 1988 (Cth). This is a particular subset of "personal information" and means:
i. Information or opinion about the health or disability (at any time i.e. past, present or future) of an individual that can be classified as personal information;
ii. Information or opinion about an individual’s expressed wishes about the future provision of health services that can be classified as personal information;
iii. Information or opinion about health service provided, or to be provided, to an individual, that can be classified as personal information;
iv. Other personal information collected to provide, or in providing, a health service;
v. Other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances; or
vi. Genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual. c)Personal information also includes 'sensitive information' which is information including, but not limited to a client’s:
i. race;
ii. religion;
iii. political opinions;
iv. sexual preferences; and or,
v. health information.
Information deemed 'sensitive information' attracts a higher privacy standard under the Act and is subject to additional mechanisms for the client’s protection.
3.1 Play & Learn OT collects information from each individual client that is necessary to provide the client with adequate occupational therapy services. 3.2 This may include collecting information about a client’s health history, family history, ethnic background or current lifestyle to assist the occupational therapy team in diagnosing and treating a client’s condition.
4.1 This information will in most circumstances be collected directly from the client through, but not limited to, the following mediums:
• Play & Learn OT client consent form;
• medical treatment form; referrals and or,
• face to face consultation.
4.2 In other instances, Play & Learn OT may need to collect personal information about a client from a third party source. This may include:
• relatives; or,
•other health service providers.
4.3 This will only be conducted if the client has provided consent for Play & Learn OT to collect his/her information from a third party source; or, where it is not reasonable or practical for Play & Learn OT to collect this information directly from the client. This may include where:
• the client’s health is potentially at risk and his/her personal information is needed to provide them with emergency medical treatment.
4.4 Play & Learn OT endeavours to store and retain a client’s personal & health information in an electronic record system stored on our cloud-based client management system
5.1 Play & Learn OT only uses a client’s personal information for the purpose(s) they have provided the information for unless one of the following applies:
• the client has consented for Play & Learn OT to use his/her information for an alternative or additional purpose;
• the disclosure of the client’s information by Play & Learn OT is reasonably necessary for the enforcement of criminal law or a law imposing a penalty or sanction, or for the protection of public revenue;
• the disclosure of the client’s information by Play & Learn OT will prevent or lessen a serious and imminent threat to somebody's life or health; or,
• Play & Learn OT is required or authorised by law to disclose the client’s information for another purpose.
5.2 Health Professionals to provide treatment Play & Learn OT staff may, following consent from the client/family, refer the client to other health service providers for further treatment and/or support. These services include, but are not limited to:
* Physiotherapy;
* Speech therapy;
* Medical staff, such as Paediatrician or Psychiatrist; or,
* Outpatient or community health services.
These health professionals will be designated health service providers appointed to use the client’s health information as part of the process of providing treatment. Please note that this process will be conducted whilst maintaining the confidentiality and privacy of the client’s personal information.
5.3 Alternative Health Services At any point a client wishes to be treated by an alternative medical practitioner or health care service that requires access to his/her personal/health information Play & Learn OT requires written authorisation. This written authorisation is to state that the client will be utilising alternative health services and that these health services have consented for a transfer of personal/health information.
5.4 Other Third Parties Play & Learn OT may provide the client’s personal information regarding a client’s treatment or condition to additional third parties. These third parties may include:
* parent(s) or guardian(s);
* other relatives;
* close personal friends;
* other carers (eg teacher, support worker); or,
* a person exercising a client’s power of attorney under an enduring power of attorney.
Where information is relevant or reasonable to be provided to third parties, written consent from the client is required.
Additionally, the client may at any time wish to disclose that no third parties as stated are to access or be informed about his/her personal information or circumstances.
5.5 Other Uses of Personal Information
In order to provide the best possible environment to treat clients, Play & Learn OT may also use personal/health information where necessary for: * activities such as quality assurance processes, accreditation, audits, risk and claims management, client satisfaction surveys and staff education and training;
* invoicing, billing and account management;
* to liaise with a client’s health fund, Medicare, NDIA, as necessary; and,
* the purpose of complying with any applicable laws – i.e. in response to a subpoena or compulsory reporting to State or Federal authorities.
5.6 If at any point or for any of the aforementioned reasons Play & Learn OT uses or discloses personal/ health information in accordance with the APPs, Play & Learn OT will provide written notice for the client’s consent for the use and/or disclosure.
6.1 If an individual client reasonably requests access to their personal information for the purposes of changing the information he/she must engage with the relevant practice manager.
6.2 The point of contact for client access to personal information is: Rachel van der Linden Director – Play & Learn Occupational Therapy 0414687836 rachel@playot.com.au
6.3 Once an individual client requests access to his/her personal information Play & Learn OT will respond within a reasonable period of time to provide the information.
6.4 All personal information will be updated in accordance to any changes to a client’s personal circumstances brought to Play & Learn OT’s attention. All changes to personal information will be subject to client’s consent and acknowledgement.
6.5 If an individual requests access to his/her personal information Play & Learn OT will charge $50. Please note that this fee is associated with administrative costs only.
7.1 Clients who would like to make a complaint about a perceived breach of the Australian Privacy Principles through Play & Learn OT, can do so by contacting the Director at Play & Learn OT (see 6.2 above).
7.2 Play & Learn OT is dedicated to ensuring your information is secure. In the event that a breach of your information is identified, affected clients will be notified by Play & Learn OT and informed of our processes for handling any breaches. If at any stage a client identifies a breach of their privacy, they are requested to speak to the Director about lodging their concerns formally
8.1 Use of Overseas Parties:
Play & Learn OT does not currently engage with overseas entities, with which personal or health information would be transferred, appointed or disclosed.
9.1 If Play & Learn OT receives any unsolicited personal information that is not deemed appropriate for the permitted health situation, Play & Learn OT will reasonably de-identify and dispose of the information accordingly.
9.2 If Play & Learn OT holds any personal or health information that is no longer deemed relevant or appropriate for the permitted health situation, Play & Learn OT will reasonably de-identify and dispose of the information accordingly.
10.1Play & Learn OT provides free copies of this Privacy Policy for clients and staff to access, which can be provided. Hard Copies provided upon request.
Last updated: 10/05/2024
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