Policy Statement & Purpose

Pride Aged Living takes its obligations under the Privacy Acts seriously and is committed to ensuring that personal or sensitive information is collected, held, used, and disclosed in accordance with the Privacy Act.

This policy sets out how Pride Aged Living will comply with its obligations under the Privacy Acts. The policy applies to all persons involved in or interacting with Pride Aged Living. This includes Pride Aged Living clients and their employees, aged care consumers and any nominated representatives, family, friends, carers, prospective candidates for employment, contractors, employees and any person who provides Pride Aged Living with their personal information, including via the Pride Aged Living website.

This policy was last updated in August 2024. Pride Aged Living may update this Privacy Policy at any time.

1. Definitions

AN-ACC means Australian National Aged Care Classification.

APPs means the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

OAIC means Office of the Australian Information Commissioner.

Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable. For the purposes of this Policy, personal information includes sensitive information.

Pride Aged Living means Pride Aged Living Pty Limited ABN 91 614 300 033.

Privacy Acts means Privacy Act 1988 (Cth), any applicable legislation relating to health records, and any other relevant privacy legislation.

Sensitive information is a type of personal information about an individual’s:

Racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual preferences or practices; or criminal record;
Health information about an individual;
Genetic information (that is not otherwise health information); or
Biometric information.

2. Types of personal and sensitive information

Pride Aged Living collects and holds the personal information of clients, employees and prospective employees, aged care consumers, contractors, and website users. The personal information Pride Aged Living may collect and hold about you includes the following:

Clients

Pride Aged Living’s clients are usually aged care providers. In order to provide services to Pride Aged Living clients, Pride Aged Living must collect certain information about them, consumers of care and service, and their employees and volunteers, which may include:

Name;
Date of Birth;
Aged Care Assessment Team records entered on the ‘My Aged Care’ system;
Residency Agreements; and
Photographs (for inclusion in Pride Aged Living reports).

Employees

Pride Aged Living collects and holds certain personal information about employees and applicants for employment with Pride Aged Living, including:

Name;
Date of Birth / Country of Birth;
Address and contact details;
Details of Next of Kin;
Occupation;
Employment history;
Employment Application Form;
Citizenship, Passport and/or Visa permit;
Employment References;
Tax File Number;
Bank Account Details;
HR/Personnel Records including Superannuation Fund; and
Qualifications, Training and Competency records.

Pride Aged Living may also collect sensitive information, such as:

Medical history or fitness for work information;
Immunisation records;
National Police Certificate (Criminal History Record Check); and
Workers compensation or injury information.

Consumers of aged care and services

As part of providing services to its clients, being aged care service providers, Pride Aged Living collects personal information about the people that Pride Aged Living’s clients are providing services to, being aged care consumers and their relatives and representatives. That information may include:

Name;
Address and contact details;
Details of Next of Kin;
AN-ACC classifications;
Financial and Billing information including Income and Asset Notifications; and
Photographs.

Pride Aged Living may also collect sensitive information, such as:

Health information, including, but not limited to:
- Accident and incident forms;
- Medication Charts;
- Clinical information including assessments and monitoring charts;
- Care Plans; and
- Progress Notes.
Information such as an aged care consumer’s racial or ethnic origin, religious beliefs or affiliations and sexual orientation or practices, only if, and to the extent that this is relevant to Pride Aged Living engaging with and working alongside the client to improve, assess and deliver services to the consumer; and
Care recipient ID numbers, in connection with AN-ACC classifications,
Payment statements from Services Australia, and
Legislative documents including: mandatory reports, feedback logs, risk registers.

Contractors

Pride Aged Living collects and holds personal information about contractors wishing to supply products and/or services to Pride Aged Living as well as their employees, including:

Name;
Address and contact details.
Qualifications, licenses, etc.
Contractor Agreement;
National Police Certificate (Criminal History Record Check); and
Insurances including Workers Compensation, Professional and Public Liability.

Website users

Pride Aged Living uses cookies on its website. Cookies are a small file that is placed on your computer by a web server when you access a website. You can usually modify your browser to prevent this happening. The information collected in this way can be used to identify you unless you modify your browser settings. Cookies collect user information and data for statistical and analytic purposes, including:

Name;
Email address;
Server address;
Top level domain name (for example .com);
Date and time of your visit to the Pride Aged Living website;
Pages you access and the documents downloaded;
Previous sites you have visited; and
Browser type.

Interested parties

Pride Aged Living collects personal information about other people who may be interested in Pride Aged Living services when they get in contact, sign up for the newsletter or attend a Pride Aged Living event. Pride Aged Living also obtains information from the organisers of other events that we participate in, such as conferences, where you have consented to them passing on this information. This information may include:

Name;
Phone number;
Email address; and
Current occupation.

3. Collection of personal and sensitive information

In most cases, Pride Aged Living will only collect information directly from you with your consent. However, personal information may also be gathered from:

Pride Aged Living clients, in the course of providing services;
Personal interaction, including when Pride Aged Living staff visit the premises of clients and interact with consumers and staff;
Forms (either physical or online), mail correspondence, emails and other electronic communications, written records of telephone conversations;
Cookies on the Pride Aged Living website;
Feedback provided by clients to Pride Aged Living in relation to the services provided;
Inquiries or discussions about Pride Aged Living and/or the services Pride Aged Living provides;
Publicly available sources of information;
Interactions online or with social media channels that Pride Aged Living offers or monitors;
From job applicants and employees, referees, employment agencies and through background checks and police checks;
Direct contact in the course of providing Pride Aged Living Services; and
From current and prospective suppliers of goods and/or services.

Generally, Pride Aged Living only collects personal information to the extent it is required to perform consultancy services for clients, and to comply with legal obligations. Pride Aged Living collects your personal information and will use and disclose your personal information for its primary purpose of collection as well as for any related secondary purposes.

The potential consequence of not allowing Pride Aged Living to collect and hold your personal information is that Pride Aged Living may be unable to provide you with services.

4. Use of personal information

Pride Aged Living will not use or disclose your information for an unrelated secondary purpose unless it has obtained your written consent or an exception applies — such as where it is impracticable to obtain your consent and Pride Aged Living believe that collecting, using or disclosing your information is necessary to lessen a serious threat to the life, health or safety of any individual.

Pride Aged Living will only use your personal information where it is reasonably necessary and either with your consent or as permitted by law.

Clients

If you are an employee, contractor or representative of a client, Pride Aged Living will use your personal information to provide, manage and administer services to that client, including providing reports, and to operate an efficient and sustainable business. Pride Aged Living may also use that personal information to market itself and its services to you.

Employees and contractors

If you are an employee or an applicant for employment with Pride Aged Living, then Pride Aged Living may use your personal information to:

assess your suitability to perform the duties required and deliver care and services to clients, where required;
meet Pride Aged Living’s obligations under relevant laws;
improve the services offered, through quality improvement activities such as training; and
assess and manage the supply of goods and services by a prospective or current contractor.

Consumers of aged care and services

If you are an aged care consumer receiving services from one of Pride Aged Living’s clients, or you are the relative or representative of an aged care consumer, then Pride Aged Living will use your personal information to engage with and work alongside the client to improve, assess and deliver services to you, including providing reports to the client.

Interested parties

If Pride Aged Living has your contact details because you have contacted Pride Aged Living, signed up for the newsletter or attended a Pride Aged Living event, then Pride Aged Living may use those details to contact you or market itself and its services to you. Where Pride Aged Living has obtained your details from a third party, such as the organiser of an event, Pride Aged Living will only use that information to market to you if you have consented. Such consent may be express or implied.

5. Disclosure of personal information

Reports prepared by Pride Aged Living that contain the personal information of aged care consumers are generally only disclosed to the client that is providing services to those consumers.

However, Pride Aged Living may disclose personal information to third parties for the following purposes:

Responding to enquiries or reporting to any regulator, government department or other government body;
Fulfilling obligations to government authorities or as required by law or an order of a court/tribunal;
For the purposes of providing services, including to contractors, sub-contractors, suppliers of goods and/or services, and other persons that work or collaborate with Pride Aged Living for its internal business purposes;
To professional advisers, such as lawyers or auditors;
Where disclosure is necessary to prevent or lessen a serious threat to a person’s life or health;
Other situations where a reasonable person would expect Pride Aged Living to disclose the information as permitted by law; and
To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator.

Cross-border disclosure

You agree that sometimes it is necessary to transfer personal information overseas, including for storage and hosting of Pride Aged Living’s servers. Pride Aged Living will comply with this policy and the law, and take reasonable steps to ensure that the recipient does not breach the APPs in relation to that information.

Sale or Merger

Personal information Pride Aged Living has collected and holds may be disclosed to third parties in the event Pride Aged Living offers to sell and/or sells its business and/or assets, at or before the time of a merger, acquisition or sale.

6. Storage and security of personal information

Pride Aged Living will take all reasonable steps to protect the personal information Pride Aged Living holds from misuse and loss, and from unauthorised access, modification or disclosure. Pride Aged Living uses modern techniques and processes which meet current industry standards to ensure that your information is kept secure and confidential.

Pride Aged Living holds personal information in electronic and paper based records. Any personal information collected or held is protected by safeguards including physical, technical (firewalls, SSL encryption, etc.) and procedural methods.

If Pride Aged Living no longer requires, or has no further need for certain personal information, it may be de-identified or removed it from Pride Aged Living’s systems and all records of it destroyed. Pride Aged Living will only retain your information for as long as it is needed to provide services to its clients.

7. Access to personal information

Pride Aged Living takes all reasonable steps to provide access to your personal information. Except in certain situations, you have the right to access your personal information and ask Pride Aged Living to correct it. Requests for access to personal information should be made in writing to the Privacy Officer (see below). Pride Aged Living will take reasonable steps to update or correct any personal information it possesses that is inaccurate, incomplete, out-of-date, irrelevant or misleading, as soon as possible.

Pride Aged Living may charge you a fee to cover its costs in retrieving, assessing and providing you with the information, but will let you know the charge upfront and explain the reasons for it.

Pride Aged Living will not use or disclose a government issued identifier (a number assigned by a government agency to an individual as a unique identifier) unless the use or disclosure is necessary to fulfil its legal obligations (such as tax file numbers for employees) or is required under an Australian law.

8. Anonymity

Pride Aged Living will provide individuals the option of not identifying themselves, or of using a pseudonym, where it is lawful and practicable to do so.

9. Complaints and breaches of privacy

In the unlikely event of a data breach, it will be contained to prevent any further compromise of any personal information and will be investigated and managed to reduce or mitigate any further risk.

If the breach is deemed to be serious (an eligible data breach), Pride Aged Living will notify all relevant parties, including the OAIC as required under the Notifiable Data Breaches scheme, review the incident and take any additional action necessary to prevent future breaches.

If you believe that a breach of this policy or the Privacy Act has occurred, a written complaint should be made to the Privacy Officer. All complaints will be dealt with confidentially and promptly.

Privacy Policy Contact Person

Name: Melanie Freeman

Position: Practice Manager

Email: melanie.freeman@prideagedliving.com.au

Phone: 02 9068 0777

Pride Aged Living will promptly acknowledge receipt of your complaint and it will endeavour to deal with your complaint and to provide you with a response within a reasonable time period following receipt of your complaint (generally within 30 days of receipt). Where a complaint requires a more detailed investigation, it may take longer to resolve. If this is the case, then Pride Aged Living will provide you with progress reports.

Pride Aged Living reserves the right to verify the identity of the person making the complaint and to seek (where appropriate) further information from the complainant in connection with the complaint.

Where required by law, Pride Aged Living will provide its determination on your complaint to you in writing.

Please note that Pride Aged Living may refuse to investigate or to otherwise deal with a complaint if it is considered to be vexatious or frivolous.

If you are not satisfied with Pride Aged Living’s response, you can contact the Office of the Australian Information Commissioner. Further information can be found at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us.

10. Further information

Additional information about the operational aspects of this policy can be obtained from the Privacy Officer.

You can obtain further general information about your privacy rights and privacy law from the OAIC. The OAIC can investigate your privacy complaints about private sector organisations and government agencies if you:

call 1300 363 992
visit www.oaic.gov.au
email enquiries@oaic.gov.au
write to:
The Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001