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Privacy Policy

PRIVACY AND CONFIDENTIALITY - WEBSITE

This Privacy Policy applies to all personal information collected by Good Directions Pty Ltd (we, us or our) via the website located at www.gooddirections.com.au (Website).

1. What information do we collect?

The kind of Personal Information that we collect from you will depend on how you use the website. The Personal Information which we collect and hold about you may include: name, email address, phone number, address, login credentials.

For each visitor to reach the site, we expressively collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalized content to you while you are at this Site

2. Types of information

Good Directions is bound by the Privacy Act 1988 (Cth), the Privacy Amendment Act 2012 and the Privacy Regulation 2013 and other applicable privacy laws which set out a number of principles concerning the privacy of individuals and the appropriate collection, storage, disclosure and disposal of information.

The Privacy Act 1998 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

  1. whether the information or opinion is true or not; and
  2. (ii) whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this privacy policy.

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by us only:

  1. for the primary purpose for which it was obtained;
  2. for a secondary purpose that is directly related to the primary purpose; and
  3. with your consent or where required or authorised by law.

3. How we collect your Personal Information

  1. We may collect Personal Information from you whenever you input such information into the Website, related app or provide it to Us in any other way.
  2. We may also collect cookies from your computer which enable us to tell when you use the Website and also to help customise your Website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.
  3. We generally don’t collect Sensitive Information, but when we do, we will comply with the preceding paragraph.
  4. Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party, in cases like this we will take steps to make you aware of the information that was provided by a third party.

4. Purpose of collection

  1. We collect Personal Information to provide you with the best service experience possible on the Website and keep in touch with you about developments in our business.
  2. We customarily only disclose Personal Information to our service providers who assist us in operating the Website. Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
  3. By using our Website, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from use.We do not use sensitive Personal Information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe button link.

5. Security, Access and correction

  1. We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained in, we will take reasonable steps to destroy and anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept for a maximum of seven years to fulfill our record keeping obligations.
  2. The Australian Privacy Principles:
    1. permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
    2. allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
  3. Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.

6. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as on the contact details set out at the bottom of this policy. All complaints will be considered by Peter Knight and we may seek further information from you to clarify your concerns.

If we agree that your complaint is well founded, we will, in consultation with 7. 8. you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

7. Overseas transfer

Your Personal Information may be transferred overseas or stored overseas for a variety of reasons. It is not possible to identify each and every country to which your Personal Information may be sent.

If your Personal Information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your Personal Information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your Personal Information is mishandled in that jurisdiction.

If your Personal Information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia's, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.

9. Changes to this Privacy Policy

Good Directions reserves the right to make amendments to this Privacy Policy for the Good Directions website at any time. If you have objections to the Privacy Policy for the Good Directions website, you should not access or use the Site.

10. How to contact us about privacy

Good Directions welcomes your comments regarding this Privacy Policy for the Good Directions website.

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us by calling 1800 1234 05 or by email: This email address is being protected from spambots. You need JavaScript enabled to view it..

PRIVACY AND CONFIDENTIALITY - THE HUB

As per the 'Good Directions Policies and Procedures Manual', all information about a person [medical, personal, financial or otherwise] who is provided with a service by Good Directions is to be treated in the strictest confidence. Each person provided with a service by Good Directions will be given the same level of privacy, dignity and confidentiality as expected by other members of the community. This right also covers information, which Good Directions staff may obtain, or be provided with during the course of their duties, concerning the families, friends, advocates or guardians of such individuals.

Policy for Maintaining Client Information

Each client [or his/her representative] is to be kept fully informed about:

  • what information Good Directions maintains about the individual;
  • the reasons why such information is being kept;
  • where the information is being kept;
  • who can access the information;
  • the right of the individual [or his/her guardian/person responsible] to inspect their personal records and ‘file notes'; and,
  • the right to complain if the individual’s privacy, dignity and confidentiality is not being respected by Good Directions staff.

Information recorded by Good Directions staff about an individual, will be the minimum necessary to enable the efficient and effective provision of services to him/her. Such information will be provided to other staff on a ‘need-to-know’ basis only. If being aware of particular information about an individual is necessary for a staff person to be able to provide an appropriate service to him/her, then that staff person has a ‘need to know’. All records and ‘file notes’ remain the property of Good Directions and cannot be removed, either in part or whole, by any client or his/her representative. The written consent of the client [or that of his/her guardian person responsible], is required before any information about the individual is sought from, or released to, another service agency or external person by Good Directions staff.

The exceptions to this policy are only those provided for by other agreements or at law. (refer to Good Directions Policy and Procedure Manual, page 30, 'Confidentiality of Information'.

Procedures for obtaining, storing and managing confidential client information

  • Requesting and Obtaining Confidential Information
    • Obtaining personal information from a client is to take place in an area that provides privacy and confidentiality. Any specific requests from the client as to the privacy requirements in this process should be accommodated e.g. the preference for the presence of a particular carer, guardian/person responsible or advocate.
    • Good Directions staff members will only obtain Information regarding a client’s personal affairs with the consent of the client or his/her guardian/person responsible. A “Consent to Release/Request Information Form” must be completed by the staff member identifying the information required and be signed by the client or his/her guardian/person responsible (refer to Attachment 1 for Consent Form). Once signed the consent form will be placed in the appropriate section of the client’s file.
    • When Good Directions staff members request information, the client (or their guardian/person responsible) has a right to withhold information for privacy reasons and cannot be coerced into disclosing information, which they choose to withhold.
    • Good Directions staff members are to make clients (or their representative) aware that by giving their consent to receive a service from Good Directions and provide confidential information for that service, the information will be used by Good Directions only, unless otherwise requested by the client.
  • Use of Confidential Information
    • Good Directions staff members can use client information that does not directly or indirectly identify a client for purposes such as planning, service review and evaluation.
    • Good Directions staff members will only use information regarding the personal affairs of a client for the purpose for which it was obtained, unless specific consent from the client or his/her guardian or person responsible is obtained. Such information will usually be limited to the assessment of the client’s need for a service, personal information identifying the client, medical and diagnostic information and information related to the provision of services to the client.
    • Good Directions staff members will use client information that does not directly or indirectly identify a client for statistical information with the Minimum Data Set Good Directions Pty Ltd Good Directions 32 of 489 (required by NDIS), Census Data or other information required to be gathered by Good Directions for statistical purposes.
    • The Service Coordinator Good Directions will ensure that new, casual and Agency staff is only provided with client information that is required to perform their duties without infringing on client confidentiality. This information may include the client profile, specific medication/medical needs, program needs, routine activities and preferences.
  • Management of Confidential Information
    • It is the responsibility of the Service Coordinator Good Directions and/or other designated Unit staff to maintain the file and records of client.
    • Client files and records must be securely stored in a filing cabinet, which is to be kept locked when the Unit office is unattended.
    • Loss or theft of a client file or record must be immediately notified to the Service Coordinator Good Directions, giving information about when it was last seen, where it was stored and the actions taken by the staff member. The Service Coordinator Good Directions will notify the Head Relevant Entity and provide a briefing report on the circumstances and actions taken. Police will be notified of the theft of a client file or record.
    • The client file is the responsibility and property of Good Directions and, although the client has the right of access to personal records, it remains the property of Good Directions when the client exits the service and will be archived.
  • Access to Confidential Information
    • The Service Coordinator Good Directions will be notified when a client (or their guardian or person responsible) seeks access to their file or records. The Service Coordinator Good Directions must be consulted regarding the arrangements for the release of information and verification of that person’s authority to have the power of access must be made.
    • Another person on behalf of the client may also make a request for access with the consent of that client or his/her guardian/person responsible. In such event, the consent of the client must be verified and the purpose for disclosure to the third party must be confirmed with the client or his/her guardian/person responsible. This information must be recorded on the ‘Consent to Release/Request Information Form’.
    • Other than in exceptional circumstances, requested information on an individual should only be provided by mail to another service agency or external person, and must be clearly marked ‘strictly personal and confidential’. The information must be forwarded/addressed to a specific contact person.
    • If the requested information is to be provided by facsimile, identifying information [e.g. name, address, age, gender, telephone number etc.] of the concerned individual should be ‘blacked out’ prior to the information being faxed. A complete hard copy should then be forwarded by mail to the enquirer as per the aforementioned procedure.
    • If a client transfers between Good Directions, their case file will be transferred to the receiving unit.
    • If a client is transferring out of Good Directions at the request of the client or his/her legal guardian, then a discharge summary of the current situation will be provided to the new service provider to assist the new service in being able to meet the needs of the client.
  • Entries to Client Files
    • Information recorded by Good Directions staff on any client must be accurate, brief or to the point [i.e. only record important information that other support staff ‘need to know’]. The information is to be objective, legible, identify the person recording the information and the date. The information recorded must be for the sole purpose of helping to ensure that the best possible services are provided to the client.
    • The client file and records maintained by Good Directions on each client will be Good Directions Pty Ltd Good Directions 33 of 489 regularly reviewed to identify redundant/unnecessary information which will then be archived.
    • No client file notes or records about an individual will be photocopied unless the copy is to be forwarded by a Good Directions staff member to another service agency or external person with the written consent of the concerned individual [and/or their guardian/person responsible].
    • No file notes or records are to be removed from the place where they are normally kept secured, unless it is to photocopy same for the abovementioned purpose, or to archive such file notes or records for storage when they are no longer required for service provision [e.g. the individual has left Good Directions].
    • Good Directions staff members who are found to have breached the privacy, dignity and confidentiality of an individual client or who have knowingly recorded information on such an individual that is discriminatory, in accurate or misleading, may be liable to disciplinary action.