MEALS ON WHEELS DUBBO INC PRIVACY POLICY

Meals On Wheels Dubbo Inc (MOW) is committed and dedicated to your privacy.  We collect personal and sensitive information for the purpose of ensuring our clients receive the best possible service.  Information on staff and volunteers is held on a confidential basis.  The nature of the information we collect is primarily for the purpose of conducting client assessments, preparing client care plans, and keeping up-to-date and accurate records of our clients in order to continue to provide the best service and innovative new products and services.

What Information We Collect
We collect such personal information as name, phone numbers, physical and/or email addresses and customer activity.  When it is provided for the purpose of payment for services, some financial information is retained for processing the payment and as a record or receipt of payments made, such as would be found on our bank statements.  Financial information is not stored anywhere else and is not collected for any other reason.
The initial Client Assessment and reassessments cover the following points:

• The interviews carried out in the client’s own home, or another place where privacy can be guaranteed, between the Coordinator, the client and his/her advocate and any other person requested to be present by the client.
• The interview covers any/only information needed to determine the best possible service for the client.  This information may include, but is not limited to, name and other personal contact details, age, dietary requirements, special needs, and other relevant considerations related to the service.
• The client is informed of their rights and the service’s policy in association with privacy and confidentiality.
• The client is informed that information is collected and will be passed on to the Department of Health (DoH) for the purpose of My Aged Care.
• The client has the right to withhold any information for privacy reasons and is not penalized for doing so and may request the information provided not be forwarded to DoH.
• A consent form should be signed by the client (or advocate) to record the client has consented to the information used for the purposes of My Aged Care. (A consent form provides ‘proof’ that a valid consent was obtained, when it was obtained and by whom, if this is ever challenged.)

How Your Information Is Collected
The personal information we collect comes directly from our customers.  It is provided to us via the direct written and/or verbal communication with us.  We do not buy lists or receive information from any other sources other than from you directly.  The quality and accuracy of the data we collect is based on the information you provide to us.  Meals On Wheels Dubbo take every reasonable step to ensure we have captured the information correctly, and are happy to amend the information at any time as required or requested by you, as detailed further in this policy.

Who Your Information Is Shared With
All personal information we collect remains entirely within Meals On Wheels Dubbo Inc.  It is not shared with any other individual, institution or organisation, nationally or internationally, at anytime without your expressed written permission, other than where permitted or required by law, or as otherwise specified in this document. 
Some of these exceptions are:

• To the Department of Health for the purpose of My Aged Care.
• Referrals only when the client’s permission is obtained, can information be passed to another provider, if it is felt the client would benefit from that service.  A consent form should be signed by the client (or advocate) to record the client has consented to information being given to another service.
• In the event of an emergency, the release of client information may occur to next-of-kin or authorised delegate (Enduring Power of Attorney) identified by the client at the initial interview.
• In the case of actual or suspended abuse between client and carer, the staff may inform the emergency services without the direct permission of the client as per the Interagency Policy on “Responding to Actual or Suspect Situations of Abuse of Adult Clients and Carers.”
• If the staff have concerns for the safety of a client, yet the client is unwilling to consent to a referral to be made to the appropriate agency, the staff may make the referral without the client’s consent.
• For clients with dementia / an intellectual disability, where the staff feels that they may not have the capacity to give consent to pass information to another service provider, duty of care overrides confidentiality, and the information may be passed on.
• Client information can be released without the client’s permission of subpoenaed for certain legal proceedings.

How Your Information Is Stored
Your personal information is stored securely to protect your personal information from loss, misuse, unauthorised access, modification or disclosure.  Meals On Wheels Dubbo Inc has implemented technology and security policies, rules and measures to protect the personal information we have under our control from:  unauthorised access, improper use, alteration, unlawful or accidental destruction and accidental loss.  We will remove personal information from our system where it is no longer required (except where archiving is required).
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• Information held on a client is stored in a locked filing cabinet or on a password secured computer at the Meals On Wheels Dubbo Inc office.
• Information can only be accessed by the staff members providing a service to the client.
• Only information relevant to setting up the most appropriate service and maintaining it is held and is regularly reviewed so that it is as up-to-date as possible.
• If a service to a client has stopped being provided, but may need to be resumed at a future date, information relating to the client will be kept in the filing cabinet for a period of five years before being archived.  Information regarding clients is destroyed seven years after they stop using the service.

Who Has Access To Your Information
Only authorised employees of Meals On Wheels Dubbo Inc, or other authorised personnel, have access to your personal information, and only for activities related to the primary purpose of collection.
You also have the right to access your personal information held by us, as well as to request a copy of that information and to amend it.  Should you wish to have access to this information, please contact the Meals On Wheels Dubbo Inc Service Manager.
Further access to information points are outlined here:

• The client has the right to access any personal information held about him/her by Meals On Wheels Dubbo Inc and can do so upon written request.  The information must be provided within five working days of the request.
• The client can insist on having his/her personal and sensitive information amended if it is incorrect.
• Files may leave the office for a genuine work-related purpose.  The files must be carried in a secure fashion and not left unattended.  Client’s files must be in a non-identifiable format.

Staff & Volunteer Specific Conditions
In regard to client information, the following conditions apply:

• Staff are made aware of the policy on confidentiality and privacy when first joining the service.
• Staff should not discuss any element of a client’s details with anyone outside the service without the client’s permission.

In regard to staff and volunteer information held, the following conditions apply:

• Information on a staff member is only kept if relevant to their duties.
• Personal information is stored in a locked filing cabinet or password secured computer at the Meals On Wheels Dubbo Inc office.
• Staff should not give any staff or volunteer details including addresses or phone numbers to any client or other organisations.
• Staff will not discuss with people outside the service, any information concerning the financial and confidential arrangements of the service.

In regard to volunteers, the following conditions apply:

• Volunteers are made aware of the policy on confidentiality and privacy when first joining the service and through the Volunteer Handbook.  They are reminded regularly of the issue in the Volunteer Newsletter.
• Volunteers should not discuss any element of a client’s details with anyone outside the service without the client’s or staff’s permission.
• Information on volunteers is only kept if relevant to their duties.
• Personal information is stored in a locked filing cabinet or password secured computer at the Meals On Wheels Dubbo Inc office.

Anonymity
All clients of Meals On Wheels Dubbo Inc have the right to remain anonymous in their relationships with the business, where practicable to do so.  For more detailed information on this, please contact the Meals On Wheels Dubbo Inc Service Manager

Sensitive Information
Meals On Wheels Dubbo Inc collects sensitive information directly from the client or their advocate during the initial client assessment, reassessment, or during client visits.  The purpose of this information is solely for the purpose of providing the best service to the customer.
Only information relevant to setting up the most appropriate service and maintaining it is held and is regularly reviewed so that it is as up-to-date as possible.  Examples of this type of information include, but are not limited to:

• Dietary Requirements
• Special Needs
• Disabilities (i.e. Dementia, Intellectual Disability)
• Any other relevant sensitive information required to provide the most appropriate service.