Cura In-home Care (‘Cura’) is committed to protecting privacy, and the personal information that our organisation collects, holds, uses and discloses, with respect to clients and workers. This policy describes the requirements and guidelines for dealing with privacy within Cura.
Cura will apply the following principles during the information management lifecycle, when handling personal information (including sensitive information as defined under the Privacy Act 1988).
Cura will:
Be open and transparent in the management of personal information during the information management lifecycle.
We provide this Privacy policy on our website to ensure all participants are aware of the way in which Cura collects, holds, uses and discloses personal information.
Along with our policy we have a detailed privacy procedure, and we document our privacy commitment in our service agreement with our clients.
Only collect personal information that is reasonably necessary to undertake its business activities for the delivery of services to clients or the provision of a safe workplace.
Personal information is information, including but not limited to sensitive information, which directly or indirectly establishes the identity of a person. Personal information includes sensitive information which is information or an opinion about an individual’s ethnic origins, religion, sexual orientation, health and genetic information, amongst other things.
We collect personal information that is considered reasonable for us to provide in-home aged care services or to provide volunteering services to seniors, we will do this in a lawful and fair way. This may include information such as your name, address, date of birth, or government identification documents, plus sensitive information including collecting information about your health.
Seek consent to the collection of personal and sensitive information, unless consent is exempt in that it is impractical for Cura to deal with an individual if they do not provide personal or sensitive information.
At the time we collect sensitive information from you we will seek your consent. If you or your legal representative are unwilling or unable to provide consent, we may not be able to deal with you without the collection of this information.
In some instances, the need to seek consent may be exempt in that it may be impractical for Cura to deal with you if the information is not provided. For example, you are not willing to provide Cura government identifiers for aged care purposes.
We may gather information and statistics about all visitors to our Website which may include the use of cookies. Cookies are small amounts of information which Cura in-Home Care stores on your computer. They allow us to monitor Website traffic and to personalise the content of the site for you. Such information disclosed to third-parties will be in the aggregate form and will not involve individual names or identifying information. You have the option when first visiting our website or through your own internet browser to decline or delete the acceptance of cookies.
Ensure that stakeholders are informed as to why the information is collected.
When collecting your personal information we will let you know why we are collecting the information. Most of the information we collect from you will be for the purpose of providing services to clients or for the provision of a safe workplace. At times we will collect information from you to share with third-party providers that also provide services to clients on our behalf such as clinical or allied health services or to third-party training providers for the purpose of training in the workplace.
At times we may collect personal information from you for the purposes of informing you of the services we provide that you may be interested in, for example upcoming Cura Connective events or potential networking events.
We may disclose your information for the purposes of display on our social media platforms such as Facebook, Instagram and Linkedin, in the form of photography and videography. We may collect information that you provide to us via these social media sites. Any personal information that you provide via social media will be subject to the privacy policy of those third-party sites.
Handle personal information that has been received without being requested, by retaining the information with the stakeholders consent or destroying the information if not reasonably required to be held, and advising stakeholders that may be unaware that the personal information has been received by Cura.
Cura may be provided with unsolicited personal information about you without being requested to provide the information. This may be through conversation with us or from an external third-party.
If we believe we should retain this information we will seek your consent. If we do not reasonably require this information we will destroy it. If the information has been received by an external third-party we will endeavour to inform stakeholders that we have received and destroyed their unsolicited personal information.
Treat personal information as strictly confidential and only use or disclose personal information for purposes directly related to the reasons for collecting the personal information.
All information collected from you will be handled with the utmost professionalism.
Personal and Sensitive information will only be used or disclosed for the purpose of providing services to clients or for the provision of a safe workplace.
Obtain consent if personal information is to be used for another purpose, unless the use or disclosure is required or approved by law.
Unless the purpose of use and disclosure of personal information is for providing services to clients or for the provision of a safe workplace, including use on social media and for internal marketing purposes, we will seek your consent.
We will not seek your consent when use or disclosure of the personal information is required, or authorised by, or under an Australian law or a court/tribunal order
Only disclose personal information outside of Australia for the purposes of data storage in relation to electronic systems used to provide services to you.
We will take reasonable steps to ensure that the overseas recipient does not breach the Australian laws in relation to the information.
Cura uses cloud data storage and third-party cloud based systems that may store personal information in overseas data storage facilities. When this occurs, we will take reasonable steps to ensure that your personal information is protected and the third-party overseas provider does not breach Australian privacy laws.
We will not use or disclose personal information outside of Australia for any other reason.
Not adopt, use or disclose government related identifiers as personal information within our own systems.
Australian government agencies may use specific identifiers when they handle your personal information, such as your My Aged Care number, Services Australian number or your Tax File number.
Cura will not adopt your government related identifiers as our own identifier within our own systems. We will not use or disclose those identifiers with any other external third-party, except for the government when we deal with them for the purpose of providing services to clients or for the provision of a safe workplace.
Ensure that the personal information it collects, uses and discloses is accurate, up-to-date and complete.
We will take reasonable steps to ensure that personal information we collect, use and disclose is accurate and up to date. We will confirm this information with you when we take it from you.
For correctness we may ask you to provide your personal information to us in written form with supporting evidence, rather than us transcribing your information.
We may seek updates to your personal information from time to time to make sure we have the most current personal information about you.
Ensure that reasonable steps are taken to address stakeholders’ written requests to correct personal information that might be inaccurate, out-of-date, incomplete, irrelevant or misleading.
If you find that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, please let us know in writing and provide us the correct information so we can remediate the information.
Store the personal information it holds securely, protecting it from misuse, interference and loss, plus unauthorised access, modification or disclosure.
We use electronic and paper-based systems to store your personal information. We have mechanisms in place such as physical security alarms and locked access ways, plus electronic security such as passwords, multifactor authentication and back up protocols to protect your personal information.
Provide timely due consideration to stakeholders’ written requests to their personal information as defined.
Cura will provide timely due consideration to valid written requests for personal information. Consideration and approved provision of personal information will be endeavoured to be completed within 10 business days.
Destroy any personal information when this information is no longer needed to undertake business activities or required to be held by legislation.
When we no longer need to hold your personal information we will take reasonable steps to destroy or deidentify your personal information.
Where Cura suspects a notifiable data breach has occurred, and personal information has been compromised, accessed, used or disclosed without authorisation, or is lost, we will notify the Office of the Australian Information Commissioner and any affected stakeholders when a data breach involving personal information is likely to result in serious harm.
If a stakeholder feels that their personal information has been mishandled during the Information Management Lifecycle, they should provide feedback or make a complaint in line with the Cura Complaints and Feedback Policy.