1. Purpose and context
1.1. Driving Well Occupational Therapy is committed to ensuring the privacy and confidentiality of all personal information affiliated with Driving Well Occupational Therapy business undertakings.
1.2. Driving Well Occupational Therapy 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 Driving Well Occupational
Therapy collects and manages personal information.
1.4. The point of contact regarding any queries regarding this policy is Jennifer Gribbin, Owner,
Driving Well Occupational Therapy phone: 0407 671 621 Email: [email protected]
2. Australian Privacy Principles
2.1. As a private sector health service provider and under permitted health situations, Driving Well Occupational Therapy is required to comply with the APPs as prescribed under the Act.
2.2. The APPs regulate how Driving Well Occupational Therapy may collect, use, disclose and store personal information and how individuals, including Driving Well Occupational Therapy’s patients may:
address breaches of the APPs by Driving Well Occupational Therapy;
access their own personal information; and,
correct their own personal information.
2.3. 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 patient’s:
a. race;
b. religion;
c. political opinions;
d. sexual preferences; and/or,
e. health information.
Information deemed 'sensitive information' attracts a higher privacy standard under the Act and is subject to additional mechanisms for the patient’s protection.
3. Types of Personal Information
3.1. Driving Well Occupational Therapy collects information from each individual user to be able to provide a platform to access the Get Driving online therapy toolkit.
3.2. This only includes collecting information about a user's name and email address, in order to provide them an account for accessing learning resources.
4. Collection & Retention
4.1. This information will be collected either through Driving Well Occupational Therapy's secure records, where the client is a current client of DWOT and has consented to purchasing the toolkit.
4.2. In other instances, clients who are not existing clients, can enter their details (name and email address) to create an account.
No other information about the external clients is required or held by Driving Well Occupational Therapy; these details are maintained in the Thinkific course platform only.
5. Purpose of Collection, Use, and Disclosure
5.1. Driving Well Occupational Therapy only uses a user's personal information for the purpose they have provided the information for unless one of the following applies:
accessing the Get Driving online therapy toolkit or the Senior Driver's online course
5.4. Other Third Parties
Driving Well Occupational Therapy permits other third parties of the user to utilise the resources; these third parties
may include:
parent(s);
child/ren;
other relatives;
close personal friends;
guardians; or,
support workers.
However, Driving Well Occupational Therapy does not permit the creation of multiple accounts; any additional accounts related to the user will be deleted.
5.5. Other Uses of Personal Information
In order to provide the best possible environment to teach users, Driving Well Occupational Therapy may also use personal/health information where necessary for:
Updates to course materials may be conducted from time to time, and users may be notified of updates / additions to their course via email.
activities such as quality assurance processes, accreditation, audits, risk and claims management, user satisfaction surveys and staff education and training;
invoicing, billing and account management;
the purpose of complying with any applicable laws – i.e. in response to a subpoena or compulsory reporting to State or Federal authorities.
If at any point or for any of the aforementioned reasons Driving Well Occupational Therapy uses or discloses personal/ health information in accordance with the APPs, Driving Well Occupational Therapy will provide written notice for the patient’s consent for the use and/or disclosure.
6. Access and Changes to Personal Information
6.1. If an individual patient 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 patient access to personal information is:
Jennifer Gribbin
Director Driving Well
0407 671 621
6.3. Once an individual patient requests access to his/her personal information Driving Well Occupational Therapy 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 patient’s personal circumstances brought to Driving Well Occupational Therapy’s attention. All changes to personal information will be subject to patient’s consent and acknowledgement.
7. Complaints Handling
7.1. Patients who would like to make a complaint about a perceived breach of the Australian Privacy Principles through Driving Well Occupational Therapy, can do so by contacting the Director at Driving Well Occupational Therapy (see 6.1 above).
7.2. Driving Well Occupational Therapy 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 Jenny Gribbin and informed of our processes for handling any breaches. If at any stage a user identifies a breach of their privacy, they are requested to speak to the practice manager about lodging their concerns formally.
8. Personal Information and Overseas Recipients
8.1. Use of Overseas Parties: Driving Well Occupational Therapy engages with overseas entities, with which personal or health information would be transferred, appointed or disclosed. These overseas entities include:
MailChimp – used to disseminate Driving Well Occupational Therapy newsletters controlled by Jenny Gribbin, Director Driving Well Occupational Therapy. this information is saved to the cloud in Australia.
The aforementioned entities engaged overseas are subject to the legislative requirements as stipulated by the APPs.
9. Disposal of Personal/Health Information
9.1. If Driving Well Occupational Therapy receives any unsolicited personal information that is not deemed appropriate for the permitted health situation, Driving Well Occupational Therapy will reasonably de-identify and dispose of the information accordingly.
9.2. If Driving Well Occupational Therapy holds any personal or health information that is no longer deemed relevant or appropriate for the permitted health situation, Driving Well Occupational Therapy will reasonably de-identify and dispose of the information accordingly.
10. Access to Policy
10.1. Driving Well Occupational Therapy provides free copies of this Privacy Policy for patients and staff to access, which can be/will be located/provided:
www.drivingwell.com.au
Policy and Procedure Manual
Hard Copies provided upon request
11. Review of Policy
11.1. Driving Well Occupational Therapy in accordance with any legislative change will review the terms and conditions of this policy to ensure all content is both accurate and up to date.
11.2. Notification of any additional review(s) or alteration(s) to this policy will be provided to patients and staff within 2 weeks’ notice. If a change occurs patients are required by Driving Well Occupational Therapy to review this Privacy policy. Staff are required to sign once they have reviewed the Privacy policy.