Purpose - Why do we have this policy?

In this policy, you'll learn how we handle your and our service users' personal information and it sets out how we deal with confidentiality.

Scope
This policy applies to Australian Street Aid Project Ltd. directors, sub-committee members, staff members, volunteers, contractors, other stakeholders and people experiencing homelessness who use our service including:
● People experiencing homelessness seeking services and/or referral from Australian Street Aid Project
● Suppliers
● Contractors
● Industry partners
● Community partners
● Staff members
● Sub-committee members
● Volunteers
● Directors
● Australian Street Aid Project Ltd. as an entity.

We abide by the relevant legal requirements when making decisions about how to apply this policy.
This privacy policy encompasses all information related to our service users, volunteers and staff, sub-committee members and directors whether it is written, verbal or electronic.
Australian Street Aid Project Ltd. collects, stores and sometimes shares relevant personal information about service users to provide an effective and high-quality service. It's important that Australian Street Aid Project Ltd.'s Board and staff are consistent and careful in the way personal information is stored and shared.
Our service users, volunteers and staff have legislated rights to privacy. It is essential that we all protect and uphold these rights, and act correctly in circumstances where the right to privacy may be overridden by other considerations.

Policy

We are committed to protecting the privacy and confidentiality of the personal information that we collect, hold and administer. Personal information is information that directly or indirectly identifies a person.

To ensure privacy and confidentiality is maintained, we:

• Provide our service users, volunteers and staff with information about their rights regarding privacy and confidentiality, our process to protect these rights as well as any limits or expectations.
• Ensure privacy during interviews or discussions of a personal or sensitive nature.
• Meet legal and ethical obligations in relation to handling confidential information.
• Only when necessary, and with the person's written consent, share verbal and written information about our service users, volunteers and staff with external organisations or individuals. (Certain circumstances may limit confidentiality rights).

Take reasonable steps to protect the information that we hold from misuse, loss, unauthorised access, modification or disclosure.

What this means for you

Personal information should not be shared without that person’s permission. Everyone at Australian Street Aid Project Ltd. has a responsibility to protect personal information.
There are specific circumstances where personal information will be shared without permission and management must make this decision.
https://www.oaic.gov.au/privacy/guidance-and-advice/what-is-personal-information

 

Responsibilities

All team members are responsible for ensuring the privacy and confidentiality of the personal information that we collect and hold. 

 

Procedures

Collection and storage of information

Purpose of collecting and storing information
Australian Street Aid Project Ltd. collects and stores information solely for the following purposes:
● To provide effective and efficient service to people experiencing homelessness seeking services
● To appropriately refer a person experiencing homelessness to another service
● Any other purpose agreed to by the person experiencing homelessness and Australian Street Aid Project Ltd.
● To meet funding body or legislative requirements
● To identify opportunities for improving the service provided to people experiencing homelessness.
● To recruit, induct, manage, and exit staff and volunteers.
● To administer our human resource responsibilities.

Kinds of information to be collected and / or stored
Information that Australian Street Aid Project Ltd. may be required to collect includes:
● Contact details
● Education and employment status
● Age, gender, disability, medical history
● Family/household structure
● Next of kin/emergency contacts
● Criminal history
● Type and degree of access of other community services
● Complaints
● Specifically for volunteers and/or staff
- Proof if identify
- Employment history
- Qualifications and skills certification
- References and criminal history checks
- Tax, Superannuation and bank details.

How information is to be collected
Information may be collected via:
● Initial interviews with people experiencing homelessness
● Discussion with family members
● Completion of intake forms
● Records of complaints
● Referral information from other organisations
● Feedback processes
● Specifically for volunteers and staff
- Application documents
- Interviews
- Reference checks
- Screening checks
- Induction forms.

How information is to be stored
Australian Street Aid Project Ltd. will take all reasonable steps to meets its obligation to protect personal information it holds from:
● Misuse
● Interference
● Loss
● Unauthorised access
● Unauthorised modification
● Unauthorised disclosure.

Where necessary, Australian Street Aid Project Ltd. is to destroy or de-identify personal information so the privacy and confidentiality of people experiencing homelessness is upheld.

Information may be stored via:
● Electronic files, including use of portable hard drives, backup services and Cloud technology
● Individual hardcopy files, which may be stored in desk drawers and locked filing cabinets
● Lockable archives
● Databases managed by Australian Street Aid Project Ltd., government agencies or other organisations.

Quality of information
Australian Street Aid Project Ltd. directors and staff are committed to maintaining correct personal information it holds about individuals. Reasonable steps are taken to ensure the personal information it uses or discloses is:
● Accurate
● Up to date
● Complete
● Relevant, regarding the purpose of the use or disclosure.

If errors are identified in the personal information held about people experiencing homelessness, reasonable steps are to be taken to make necessary corrections as soon as possible.

Disclosure of confidential information
Avoiding disclosure of confidential information
To avoid inappropriate verbal and written disclosure of information, within and outside the organisation, staff members are to:
● Keep information about people experiencing homelessness in drawers or filing cabinets when not in use.
● Lock files in filing cabinets at the end of each working day.
● Maintain confidentiality of passwords on computers and software applications which house data about people experiencing homelessness.
● Ensure that volunteers and staff members not authorised to have access to the information, visitors or others cannot overhear private conversations, whether over the telephone or in person, in Australian Street Aid Project Ltd. building or in another public place (unless verbal consent is given).
● Ensure private or confidential information is not left in the public domain (such as documents left on the photocopier or in a car, etc.)
● Avoid discussing private information with anyone not authorised to have access to the information, including other staff members, directors, volunteers, other service providers, family or friends.
● Dispose of information in an appropriate manner when it is no longer needed (such as archiving or shredding).

Maintaining private conversations
Australian Street Aid Project Ltd. understands the importance of ensuring people experiencing homelessness can have private discussions with appropriately qualified team members. Australian Street Aid Project Ltd. pays attention to the physical layout of our premises regarding privacy. The following provisions for private interview space when interviewing people experiencing homelessness or talking with them about matters of a sensitive or personal nature are:
● Conducting private discussions with people experiencing homelessness in a private space:
● If a person experiencing homelessness discloses personal information while in a public area, or within earshot of other people, encouraging them to move to a private space before continuing the conversation.

Person experiencing homelessness’s informal disclosure of information
The structure of Australian Street Aid Project Ltd.’s building can create situations where people experiencing homelessness may disclose personal information they did not initially intend to share. The building is and open plan, informal layout and the people experiencing homelessness may be vulnerable and/or have limited social skills to be able to identify boundaries or appropriate disclosure of personal information.
To avoid unintentionally breaching the confidentiality of people experiencing homelessness, directors, staff and volunteers who are not assigned to work with our service users, contractors or visitors are to:
● Avoid initiating or maintaining personal conversations with people experiencing homelessness.
● Avoid conversations about topics that people experiencing homelessness may have a personal connection to, such as drug use or mental health issues.
● If such conversations arise, refer the person experiencing homelessness immediately to the Case Manager or CEO.
● Avoid asking questions or being within earshot of discussions about personal details of people experiencing homelessness.
● Request that such conversations are held in locations where privacy can be maintained.
Sharing information
If it can be shared in a way that doesn't identify an individual, or if the individual consents, staff members may discuss circumstances of people experiencing homelessness to provide effective service.
Australian Street Aid Project Ltd. directors and staff members are not to share information without consent when:
● It has been identified as confidential by Australian Street Aid Project Ltd.
● The person experiencing homelessness has identified the information as confidential.
● The information relates to personal details of a person experiencing homelessness (family history, work and/or financial history, tenancy history, medical history, etc.)
● It can be reasonably assumed that the information would be confidential.

Information sharing agreements with other organisations
We may have agreements, memoranda of understandings, or protocols for sharing information about people experiencing homelessness with other agencies. In these situations, individuals will be notified about these agreements and their consent obtained for sharing information where necessary.
The CEO may from time to time ask a service user for permission to share information for marketing purposes. Even if permission is given the CEO must consider how the sharing of information will impact the service user now and into the future.
Australian Street Aid Project Ltd. is unlikely to have occasion to disclose personal information to overseas recipients.

Obtaining consent
Where it is necessary to share or access private or confidential information about a person experiencing homelessness, their written consent must first be obtained. Consent may be requested from people experiencing homelessness for:
● Discussing their circumstances with other service providers
● The effective support or referral
● Including their photograph in Australian Street Aid Project Ltd. publications, such as newsletter or annual report.
Staff members will obtain consent by:
● Contacting the person experiencing homelessness and requesting their consent
● Requesting that the person experiencing homelessness provide the consent in writing
● Where relevant, written consent is to be provided using Australian Street Aid Project’s designated consent form.

Duty to disclose
There are situations where it may be necessary or even required that staff disclose information that would otherwise be confidential. These instances include:
● Where information is required to be disclosed by law.
● Where lack of disclosure of information could reasonably cause harm to the individual or others.
In these instances, the relevant staff member will:
● Discuss the situation with the CEO, or Board Chair, where CEO is not available.
● Decide on the necessary course of action, and why this action is necessary.
● Where possible, advise the individual of the necessity to disclose information prior to disclosure.
● Disclose the information.
● Document all actions.
● Inform the CEO of action taken and discuss strategies to manage potential consequences.
● Action the strategies.

Restrictions
Australian Street Aid Project Ltd. collects and administers a range of information for a variety of purposes. For commercial, privacy or ethical reasons, some information may be restricted in its circulation.
Australian Street Aid Project Ltd. will place the minimum of restrictions on the information it holds and will ensure that necessary restrictions are observed by Board and staff members.
Australian Street Aid Project Ltd. will place restrictions on the information it holds when the information:
● Is commercial in confidence.
● Concerns the privacy of a person experiencing homelessness, Board member, staff member, volunteer, industry or community partner.
● Requires protection to safeguard the intellectual property of the organisation.

Team members who handle restricted material will be trained on how to identify it and how to handle it. These include:
● Storing this information in locked filing cabinets
● Maintaining firewalls on selected electronic data.
● Restricting access to Board or other meetings.
● Preparing general meeting minutes for availability in the public domain, subject to an assessment of confidentiality.

Rights of service users and staff
Notification of rights
We notify and remind people experiencing homelessness, volunteers and staff about their rights via:
● Intake interview and documentation.
● Team meetings.
● Informal discussion as needed.
● Induction.
● Website, social media and other online platforms.
Here's what we tell people experiencing homelessness, volunteers and staff about their privacy and confidentiality right:
● Impact of legislation, government policy and/or funding body changes relevant to people experiencing homelessness and staff.
● Summaries of Australian Street Aid Project Ltd. policies and/or procedures on how information about service users, volunteers and staff is collected, stored and used
● Verbal updates and discussions.

Anonymity and pseudonymity
Our service users have the option of not identifying themselves, or of using a pseudonym (with some limited exceptions).

Accessing personal information
All service users, volunteers and staff have access to and can update their personal information.
Here's how:
1. The service user, volunteer or staff member will give a written request to the CEO.
2. The CEO will review copies of the requested documents and decides whether to approve access to the information. In accordance with the Privacy Act (1988), access is to be provided to the individual, unless a specific exemption applies.
3. If the request is approved, the CEO will provide the documents to the service user, volunteer or staff member within 7 days.
4. If the request is not approved, the CEO will provide the service user, volunteer or staff member with a written notice that explains:
 The reasons for the refusal, except where it would be unreasonable to do so.
 How to complain about the refusal.

Appeals and complaints
the service user, volunteer and staff member have the right to:
● Appeal a decision made about access to their personal documents.
● Make a complaint about a breach of the Australian Privacy Principles by Australian Street Aid Project Ltd.

Here’s how:
1. Lodge a written appeal to Australian Street Aid Project Ltd. Board.
2. If you are not satisfied with the Board’s decision, lodge a complaint with the Office of the Australian Information Commissioner (OAIC). Refer to http://www.oaic.gov.au/privacy/privacy-complaints for further information.


Informing Volunteers and Staff Members
Volunteers and Staff members are informed and updated about Australian Street Aid Project Ltd.’s Privacy and Confidentiality policy and procedures, and any changes or updates to these, through:
● Code of Conduct
● Employment Contract
● Induction meetings
● Specifically designed training sessions
● Staff meetings
● Emails
● Line management with Supervisors
● Performance reviews.

In the event of any conflict or inconsistency of information, the policy statement and details prevail over the “what this means for you” statement.