Privacy Policy

We are committed to ensuring that we abide by the Privacy Act 1988 (“the Act”) and the Australian Privacy Principles (“APPs”) contained in that Act. We respect the importance of privacy and the sensitivity relating to the collection, use, disclosure and security of personal and sensitive information, which we might collect as part of our activities. 

This Privacy Policy (“policy”) applies to information collected by Home Care Helpers Pty Ltd ABN 65 631 604 469 (“Home Care Helpers”). It outlines how we manage your personal information and protect your privacy. Respecting and protecting the privacy and confidentiality of personal information is an important part of our philosophy at Home Care Helpers. 

In this policy, “we” and “us” refers to Home Care Helpers and “you” refers to any individual about whom we may collect personal information from.

What personal information is collected?

We collect and store personal and sensitive information in several ways, depending on what our relationship is with you, for example:

· Information given to us when requesting access to our services.

· Information provided when applying for employment with our organisation.

· Information properly gathered from public domain sources when investigating potential service or product suppliers.

The kind of personal information we collect and hold will depend upon the query and services that you request from us and may include:

· Name;

· Date of birth; 

· Address; 

· Phone number; 

· Email address.

Depending on the purpose of our interaction, we may also collect additional personal information such as your: 

· Care plan and healthcare preferences;

· Medications;

· Previous and current medical history and details of treatment and health services received;

· Information about other healthcare professionals and health service providers involved in the care;

· Attorney, guardian or other person responsible for healthcare decisions;

· banking details relevant to administering payment arrangements. 

We are committed to preserving your privacy and complying with all legal requirements, and we will only use your personal and sensitive information for a permitted purpose for which the information was collected, or where authorised or required by law.

Employees

If you are seeking employment opportunities with Home Care Helpers, we will collect personal information from you such as:

· Name, 

· Contact details, 

· Qualifications, 

· Work history and 

· Referees you have provided to us during the recruitment process. 

We may also collect sensitive information about you as part of our background checking process with your consent. This information may be disclosed to and obtained from third party agencies that we engage to conduct screening checks on our behalf. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future. Before offering you a position, we may collect additional details such as:

· Tax file number, 

· Superannuation information and 

· Other information necessary e.g. to conduct a Police Check and a Working With Children Check,

· Bank account, and

· Emergency contact details. 

Generally, we will collect this information directly from you. We may also collect personal information from third parties in ways which you would expect for example referees you have nominated. 

Other individuals

Home Care Helpers may collect personal information about other individuals who are not clients of Home Care Helpers. This includes,

· Individual service providers and contractors to Home Care Helpers; 

· Other individuals who interact with Home Care Helpers on a commercial basis; and 

· Healthcare professionals who have referred clients to us or who are providing services to our clients. 

The kinds of personal information we collect will depend on the capacity in which you are dealing with Home Care Helpers. Generally, it would include:

· Name, 

· Contact details, 

· Professional details, and 

· Information regarding our interactions with you.

Home Care Helpers only collects personal and sensitive information that is necessary for us to provide our services to our clients.

How is personal information collected?

Home Care Helpers usually collects your personal information in a number of ways either:

· directly from you, 

· your family member, attorney, guardian or person responsible for your healthcare decisions,

· healthcare professionals and health service providers involved in your care,

· the Aged Care Assessment Team which assessed your need for care,

· Government agencies responsible for administering relevant entitlements and benefits.

The information may be provided to us by:

· phone, 

· email,

· in an application form, or 

· in person. 

We may need to disclose your personal information to other parties 

· in order to provide services to you, 

· as a consequence of providing services to you, or 

· in relation to your employment. 

Third parties to whom we make such a disclosure may not use your personal and sensitive information for any purpose other than that for which you provided it to us.

Otherwise, we will only share your personal and/or sensitive information in accordance with your express consent and instructions, or as applicable under the exceptions provided for in the APPs.

What if you do not provide certain information?

Providing accurate and complete information is important for the safety, quality and effectiveness of the services we provide. If you provide incomplete or inaccurate information, we may not be able to provide you with the services you requested until you provide the details we require.

How do we use and disclose your personal information?

Home Care Helpers collects personal information about clients in order to assess and manage your needs when we are providing our services to you. For example, we collect information about your health 

· to ensure that our services respond to your healthcare needs; 

· to ensure that our services are consistent with other healthcare services you receive; and 

· to minimise the need for you to provide the same information on multiple occasions.

Home Care Helpers may collect, use and disclose your personal information for purposes such as:

· to provide services to you that you request from us

· to comply with our statutory and related obligations

· to assist third parties to provide services you may request from them

· to implement and manage your employment with us

· to comply with applicable accounting and business standards for management and record keeping. 

· to verify your identity;

· to process your applications for our services;

· to administer and manage the provision of our services;

· to respond to queries or complaints;

· to your nominated doctor, specialist or other health professional;

· to provide you with updates and marketing material, including offers of other services and to improve and personalise our services;

· to comply with laws and regulatory requirements or complying with any request made by a governmental authority;

· to comply with Home Care Helpers risk management policies and procedures;

· to conduct service and market research;

· if applying for employment with Home Care Helpers, to complete appropriate background checks.

Your personal information will usually be shared with other persons involved in your care. Generally, this will only happen in ways you would reasonably expect or otherwise with your consent. For example, we may disclose your personal information

· to your GP or to a medical specialist involved in your care; 

· to a hospital or aged care facility if you are referred for higher levels of care; or 

· to other healthcare professionals who are involved in your care such as 

- occupational therapists, 

- pharmacists, 

- physiotherapists, 

- optometrists,

- podiatrists, 

- dentists, or 

- emergency ambulance officers.

In the event of an emergency, we may provide personal information to other healthcare professionals and health services with or without your consent.

Home Care Helpers may also use and disclose your personal information for a range of administrative, management and operational purposes. This includes:

• Planning, managing and rostering of staff;
• Billing, payments and debt recovery management;
• Liaising with government agencies in the administration of funding programs;
• Administering subsidies and benefits to which you may be entitled from government agencies;
• Safety and quality assurance and improvement activities;
• Training staff and other workers;
• Liaising with insurers and legal representatives;
• Responding to enquiries from external agencies, such as the Australian Aged Care Quality Agency, Aged Care Complaints Scheme and the Office of the Aged Care Commissioner;
• Obtaining advice from consultants and other professional advisers; and
• Responding to subpoenas and other legal orders and obligations.

Overseas transfer of personal information

Home Care Helpers does not disclose personal information to persons or entities in foreign countries. In some cases, Home Care Helpers may utilise 'Cloud' storage solutions for data storage purposes, and the relevant servers may be located overseas. In such cases, Home Care Helpers will review these arrangements to ensure appropriate security protections are in place to protect the personal information of its clients. 

Use of service providers

We may contract out some of our administrative and support functions such as mailing, administration services, document and data storage, background checking or identity verification services to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.

Keeping us up-to-date

Personal information such as your contact details may change from time-to-time and we ask that you keep us informed of any changes. It is imperative that you provide us with up-to-date information where you have previously provided information about another person related to your service such as your doctor, specialist or next of kin. Changes to some details may require additional documentation for verification and may be required to be made on a specific form, for example change of bank account from which direct debits are deducted. 

Storage and security of information

Home Care Helpers stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as 'Cloud' service providers for data storage and management purposes) and Home Care Helpers maintains effective control of the information under contractual arrangements. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure. Home Care Helpers primarily collects and holds your personal information in electronic form. Information held in electronic form is held securely on servers and computer systems. Certain information is collected and held in paper-based documents such as application forms and progress notes, which may be converted to electronic form and the original paper-based documents securely destroyed. Information which is retained in paper-based form is held securely on our premises or in archive facilities in Australia. We maintain physical security over our paper and electronic data stores at our premises. We also maintain computer and network security such as user identifiers and passwords to control access to our computer systems. 

Due to the nature of the services we provide, some documents such as your care plan, progress notes or medical records recording your personal information may be left with you in your home. We cannot ensure the security of personal information which is left with you in your home. The Privacy Amendment (Notifiable Data Breaches) Act 2017 requires us to let you know if your information is impacted by a data breach. This means we will let you know in the way we normally communicate with you, if:

· There is unauthorised access to or disclosure of your information; or your information is lost and unauthorised access or disclosure is likely to occur; and

· There is a reasonable chance that this could cause you serious harm (which can include physical, physiological, emotional, economic or reputational harm); and

· We have been unable to remedy the situation in line with the Act.

In such circumstances we will also inform the Office of the Australian Information Commissioner of the data breach. Home Care Helpers will hold your personal information until it is no longer needed or where personal information is no longer required to be retained, we will take reasonable steps to de-identify the information or put it beyond use. Generally, if you are a client, your personal information will be held for a minimum of 7 years from the date of last entry in your record in compliance with legal requirements to maintain such records. 

Openness

This policy sets out Home Care Helpers policies on the management of personal information and is made freely available on our website, or in hardcopy if requested.

Access and correction

Subject to some exceptions, you may access the personal information concerning you that we hold, or request corrections to it. Generally, Home Care Helpers will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:

· it would be unlawful to provide the information;

· providing access would be likely to prejudice an investigation of possible unlawful activity;

· the information is relevant to legal proceedings and would not be accessible in the normal discovery process;

· releasing information would impact on the privacy of other individuals;

· it would pose a serious and imminent threat to the life or health of any individual;

· the request is frivolous or vexatious; or 

· if a request for access would divulge a commercially sensitive decision-making process.  

In the circumstances that we do not give you access to your information, Home Care Helpers may provide an explanation rather than direct access to the information.

If you believe the personal information we hold is inaccurate, incomplete, not up to date or misleading, you may request that the information be amended and we will take reasonable steps to correct the information. If you and Home Care Helpers disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.

Please contact us if you would like to request an update or seek access to the personal information we hold about you.

Anonymity and pseudonymity

Access to the Home Care Helpers public website and some other interactions with Home Care Helpers may be done anonymously, or in the case of general enquiries, using a pseudonym. You can enquire about our services anonymously or by use of a pseudonym. We may be able to discuss services that might be suitable, including costs which might be charged for those services. We may not be able to respond to specific queries unless you provide us with certain information. If we engage in a contract for the delivery of services by you or by us, or in an employment contract, you are required to provide us with details of your true identity. We cannot provide services to someone without confirming their identity.

Use of our website

We will collect some information from you when you visit the Home Care Helpers website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity. The only personal information which we collect about you when you use the website is what you tell us about yourself, for example, 

· by completing an online enquiry form, 

· signing up for our email communications, or 

· sending us an email. 

Home Care Helpers uses the data collected for statistical analysis and business purposes. We may also use your personal information to contact you via email or phone to seek feedback relating to improving the customer experience. The data is accessible only to authorised Home Care Helpers employees. Information which is automatically collected may be published internally as aggregated and de-identified information to assist with improving the services offered by Home Care Helpers.

You may visit our website www.homecarehelpers.com.au without identifying yourself. If you identify yourself for example, by providing your contact details in an enquiry, any personal information you provide to Home Care Helpers will be managed in accordance with this Privacy Policy. 

Our website may contain links to third-party websites. Home Care Helpers is not responsible for the content or privacy practices employed by websites that are linked from our website. Home Care Helpers uses several advertising companies for our online advertising. These advertising companies may use cookies to collect information such as browser type, date and time of your visit, your interactions with banner advertisements and if you have visited our website through an online advertisement. None of the information collected by the advertising companies will personally identify you. 

Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Our third party tracking tool providers use cookies to collect information. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web browser. However, if you reject all cookies you may not be able to use some areas of our websites.

Contacting us

If you would like more information about our Privacy Policy or how we manage your personal information, our Director is available Monday to Friday, from 9am to 5pm and can be contacted on 0492 946 325. Alternatively, you can send an email to: info@homecarehelpers.com.au

Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Director on 0492 946 325 or you can send an email to: info@homecarehelpers.com.au and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following;

· your complaint should be made in writing to the Director (via post or email)

· we will attempt to respond within 30 days from receipt of your request

· if you feel your concerns have not been resolved, the complaint may be taken to the Office of the Australian Information Commissioner (OAIC)

· alternatively, you may also take the complaint to an external dispute resolution service, such as the Australian Financial Complaints Authority (AFCA)

· AFCA provides fair and independent financial services complaint resolution that is free to consumers. There are some time limits for lodging certain complaints, please consult the AFCA website to find out if or when the time limit relevant to your circumstances expires. For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au. Alternatively, AFCA may be contacted at 1800 931 678 or info@afca.org.au. If you believe we have not complied with the Australian Privacy Principles in respect of your personal and/or sensitive information, or you have any questions or feedback concerning our handling of your personal information, please contact us using the contact information on our website.

Changes to our Privacy Policy

Home Care Helpers may make changes to this policy from time to time for any reason. You can access the most up to date copy of this policy by visiting our website www.homecarehelpers.com.au