Privacy & Dignity Policy

1.1 Purpose

This Policy and the Policies and Procedures and related documentation set out in section 1.5 below (Related Documentation) supports CGM Disability Services to apply the Privacy and Dignity and Information Management NDIS Practice Standards.

1.2 Policy Aims

CGM Disability Services is committed to ensuring each Client is treated with dignity and respect, can maintain their identity, make informed choices about their care and services, and live the life they choose.

In this regard, CGM Disability Services is committed to ensuring it:

• has a culture of inclusion and respect for Clients;
• supports Clients to exercise choice and independence; and
• respects Clients' privacy.

1.3 NDIS Quality Indicators

In this regard, CGM Disability Services aims to demonstrate each of the following quality indicators through the application of this Policy and the relevant systems, procedures, workflows and other strategies referred to in this Policy and the Related Documentation:

2.1 Information We Collect

CGM Disability Services collects personal information that is necessary for the delivery of services and support to our Clients. The types of personal information we collect include:

• Contact details (e.g., name, address, email, phone number)
• Demographic information (e.g., date of birth, gender, language)
• NDIS-related information (e.g., NDIS number, plan details)
• Health and safety information (e.g., medical conditions, medications, allergies)
• Support needs and preferences

2.2 How We Use Your Information

The personal information we collect is used for the following purposes:

• To provide and coordinate services and supports
• To communicate with Clients and their representatives
• To manage and respond to enquiries and complaints
• To comply with legal and regulatory obligations
• For quality assurance and improvement purposes

2.3 Legal Basis for Processing Personal Information

CGM Disability Services processes personal information based on the following legal grounds:

• Consent: Clients have given clear consent for CGM Disability Services to process their personal information for a specific purpose.
• Contract: Processing is necessary for the performance of a contract with the Client, or to take steps at the request of the Client before entering into a contract.
• Legal obligation: Processing is necessary for compliance with a legal obligation to which CGM Disability Services is subject.
• Legitimate interests: Processing is necessary for the purposes of the legitimate interests pursued by CGM Disability Services or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Client.

3.1 When We Disclose Your Information

CGM Disability Services may disclose personal information to third parties where appropriate for the purposes set out above, including disclosure to:

• CGM Disability Services’s funding providers;
• Government and regulatory bodies, including the National Disability Insurance Agency, Medicare, the Department of Social Services, the Department of Health & Human Services, and the Australian Taxation Office;
• People acting on their behalf including their nominated representatives, legal guardians, executors, trustees and legal representatives;
• The police, or to the Disability Services Commissioner, or to comply with compulsory notices from courts of law, tribunals or Government Agencies;
• Financial institutions for payment processing;
• Referees whose details are provided to CGM Disability Services by job applicants; and
• CGM Disability Services's contracted service providers, including:
  • Information technology service providers
  • Invoice processing service providers
  • Conference, function and training organisers
  • Marketing and communications service providers including call centres
  • Research agencies
  • Freight and courier services
  • Printers and distributors of direct marketing material including mail houses
  • External business advisers (such as recruitment advisors, auditors and lawyers).

3.2 How We Store and Use Personal Information

CGM Disability Services holds personal information in a number of ways, including in hard copy documents, electronic databases, email contact lists, and in paper files held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities.

CGM Disability Services must take reasonable steps to:

• Make sure that the personal information that CGM Disability Services collects, uses and discloses is accurate, up to date and complete and (in the case of use and disclosure) relevant;
• Protect the personal information that CGM Disability Services holds from misuse, interference and loss and from unauthorised access, modification or disclosure; and
• Destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Australian Privacy Principles, subject to other legal obligations and retention requirements applicable to CGM Disability Services.

3.3 Access and Correction

Clients have a legal right to request access or correction of their personal information held by CGM Disability Services.

Clients may ask individuals to verify their identity before processing any access or correction requests, to ensure that the personal information CGM Disability Services holds is properly protected.

3.4 Complaints

If a Client has a complaint about how CGM Disability Services has collected or handled their personal information, it will be managed in accordance with the CGM Disability Services Feedback and Complaints Management System.