Privacy of Information Policy
Careline Team Inc.
The Careline Team Inc (The Careline Team) mission is to:
• Provide caring, volunteer based chat services whereby clients may receive prayer and conversation via telephone and the internet.
• Develop and implement relevant modes of electronic communication for specific people groups in the Australian community so that conditions of loneliness and spiritual need can be addressed and care groups and relevant prayer and conversation services maintained.
• Be a direct referral service to both qualified counseling services and Christian churches in Australia
In fulfilling its mission it respects the privacy of its callers/clients, staff and visitors. Its Privacy of Information Policy as enumerated below fulfils the requirements of the Commonwealth Privacy Act (Amendment 2000) and related Victorian Government legislation (Information Privacy Act 2000)
The Careline Team Inc. reserves the right to amend its Privacy of Information Policy as required.
1. Collection of Information
The Careline Team will only ask for and collect information that is necessary to the provision or quality improvement of the telephone service.
Uses of information:
• To provide the best possible service to the callers/clients, within professional and industry standards
• For reasons related to the life and safety of the caller/client or a third party
• To protect the safety and well being of Careline Team members
• To inform Careline Team supervision, assessment and training
• To support efficient and effective management of our service
• To support strategic planning and service development
De-identified and aggregated data on calls to the Careline Team services may be used for internal and external research purposes that will guide service quality improvement and service development.
Information collected about an individual from a secondary source will also be made available to the individual except where making the individual aware of the matters would pose a serious threat to the life or health of the individual.
2. Use and Disclosure of Information
The Careline Team will only use or disclose information for the purpose of discharging its mission or where it is required to under government legislation or regulation.
The Careline Team will only disclose personal information to others outside the Careline Team if:
• the caller/client gives consent (whether express or implied)
• one of the exceptions under NPP2 apply which include but are not limited to:
o uses or disclosures required by law
o those disclosures necessary to prevent or lessen a serious or imminent threat to someone’s life, health or safety
o for research purposes (provided legal conditions are met).
In accordance with NPP2 the Careline Team may disclose health information to a ‘person responsible’ for an individual (including a partner, family member, care, guardian or close friend) under certain circumstances if that individual is incapable of giving or communicating consent.
Where disclosure of information is perceived as an appropriate step in discharging the mission of the Careline Team, approval to do so will be obtained from the Privacy Officer. If disclosure of information is required for a secondary purpose (i.e. for actions outside of the discharge of the mission of the Careline Team and/or to individuals or institutions external to the Careline Team) the Careline Team will not disclose such information without the specific consent of the individual unless the release of the information relates to the public interest such as law enforcement, public safety, research or emergency situations.
The Careline Team will not disclose information for the purpose of direct marketing without the consent of the individual.
3. Data Quality
The Careline Team will at all times use its best endeavours to ensure that the personal information it collects, uses and discloses is accurate, complete and up to date.
The Careline Team will, on an annual basis, confirm the accuracy of personal information by requesting that each individual about whom information has been collected reviews and confirms/amends such information.
4. Data Security
The Careline Team ensures that all personal information and records are protected from unauthorised disclosure or loss by permitting access to either electronic or hard copy information only to authorised personnel. All information will be maintained in a secure environment. Electronic and hard copies maintained about personal information will be kept separate to the main register.
The Careline Team maintains a firewall on its local area computer network to ensure unauthorised external access does not occur.
If personal information held by The Careline Team becomes redundant to the discharge of its mission then such information will be destroyed or made anonymous
5. Policy Documentation/Openness
The Careline Team maintains a policy folder containing its Privacy of Information Policy, all requests for access to information, and other documents pertaining to Privacy of Information. The Privacy of Information Policy is available upon request and is also available on the Careline Team’s web page at www.carelineteam.org.au
The Careline Team, upon receipt of a complete ‘Personal Information Request Form’ and appropriate identification will provide access to information pertaining to that individual. Such requests can only be honoured by the individual seeking access to their own information or by carers/guardians with the consent of the individual.
6. Access to Information/Correction
The Careline Team will, subject to the appropriate procedures being complied with, provide access to an individual’s information to that individual except where such access:
• poses a threat to the life or health of the individual,
• would have an impact upon the privacy of other individuals,
• is frivolous or vexatious,
• relates to existing or anticipated legal proceedings or to the current negotiations between the individual & the Careline Team,
• is unlawful,
• would impede or prejudice any investigation of unlawful activity or is likely to cause damage to the security of Australia.
The Careline Team will not charge for a request for personal information held on that person and will omit from future records any information that is established as being incorrect or will correct such information. If the correctness of information is contested then a note to this effect will be appended to the information. The Careline Team will inform the individual concerned of all changes to the information record maintained on that individual.
All Careline Team staff and volunteers are required to keep caller personal information confidential.
Confidentiality of information collected during a call, and the anonymity of a caller will be upheld at all times except in cases where:
1. A caller is at imminent risk of injury or death by suicide
2. A caller makes specific threats to harm third parties
3. A caller is at imminent risk of injury or death by another person
4. There are reasonable grounds for believing that child abuse is occurring and/or where an intervention may be required to ensure a child’s safety.
5. Situations where there is a legal imperative to provide information
6. Circumstances where it is necessary to discuss matters related to the call or caller for the purposes of providing the best possible service to the client, including through supervision processes or to ensure the safety and well-being of telephone counsellors.
Wherever possible the Careline Team will advise callers of the above limits of confidentiality
When requested, the Careline Team undertakes to provide to its volunteers and staff a personal identification symbol that is independent of identification issued by other agencies. Where, in the course of discharging its obligations, the Careline Team collects other agency identifications such identification will not be disclosed without the direct approval of the individual.
Where it is lawful and reasonable to do so, the Careline Team will enable individuals to remain anonymous in their dealing with the organisation.
10. Trace border data flows
The Careline Team will not transfer personal information to another organisation or individual in another country unless:
• the individual consents, or
• beneficial (to the individual) contractual obligations require such a transfer, or
• the transfer is generally for the benefit of the individual or consent cannot be obtained for medical reasons but would likely be obtained if it were practical.
11. Sensitive Information
The Careline Team will only collect sensitive information about an individual where:
• the individual has consented, or
• the collection is required by law, or
• the information may prevent or lessen a serious and imminent threat to the life or health of an individual, or
• information is required by law.
Sensitive information will not be disclosed without the consent of the individual.
In the normal course of discharging its responsibilities the Careline Team does not collect health information unless such information is required to safeguard the health of the individual. Any such information will not be disclosed without the consent of the individual unless it is to preserve the health of that specific person or it is provided to a state registered health care worker or organisation.
The Careline Team reserves the right to amend its policy on the Privacy of Information. The Careline Team maintains a grievance/complaints process whereby individuals may register their dissatisfaction with either the process pertaining to the Privacy of Information Policy or with the Policy itself by informing the Manager of the Careline Team or the President of the Board of The Careline Team in writing of their dissatisfaction.
Formulated and Approved by the Board of The Careline Team Inc. in November of 2009.