Privacy Policy for Blue Gum Early Intervention

Effective Date: 09 May 2025

Privacy Policy

1.  Purpose

In order for Blue Gum Early Childhood Intervention to provide an effective and high-quality service, and to maintain appropriate accountability, we must collect, store and sometimes share, relevant personal information about our participants and team members. The purpose of this policy is to help us be consistent and careful in the way we manage what is recorded about anyone, and how we decide who can see or hear this information. 

Our participants have legislated rights to privacy. It is essential that we protect and uphold these rights, and also that we act correctly in those circumstances where the right to privacy may be overridden by other considerations. 

To uphold the rights of participants to privacy, each team member working for and with Blue Gum Early Childhood Intervention, needs an appropriate level of understanding about how we meet our legal obligations.

2. Scope

The organisation has effective information management systems that maintain appropriate controls of privacy and confidentiality for stakeholders. This policy will apply to all participants and team members working for and with Blue Gum Early Childhood Intervention.  All information, whether written, verbal or electronic, is covered by this policy.

3. Definitions

Child: A person under the age of 18 (unless otherwise specified in relevant legislation).

Team member: Any person who is working, whether directly employed, contracting, volunteering or undertaking a student placement, for Blue Gum Early Childhood Intervention.

Direct manager: The person a Blue Gum Team member reports to, either a People Lead or Director.

4. Policy

Blue Gum Early Childhood Intervention is committed to protecting and upholding the rights of our participants to privacy in the way we collect, store and use information about them, their needs and the services we provide to them. We want our participants to have confidence that we take these responsibilities seriously. 

Specifically, we will:

• Explain this policy to participants and the measures we put in place to protect their privacy,
• Explain to participants the circumstances and legal obligations that may require us to share their information.
• Explain this policy and our behaviour expectations to team members working for Blue Gum Early Childhood Intervention.
• Require that team members confirm their commitment to upholding this policy in writing.
• Ensure that when participants and their families are interviewed or discussing matters of a personal or sensitive nature with team members that this is done in a private area in order to avoid being overheard.
• Require that Blue Gum Early Childhood Intervention team members record information about participants and others carefully, accurately and sensitively- using professional language and capturing the details necessary to ensure high quality services can be delivered.
• Use technology such as password protection and secure storage to protect private information.

Blue Gum Early Childhood Intervention may be legally required to disclose information about a participant:

• At the participant’s request, for example as part of hand-over to another service provider
• In accordance with a participant’s recorded directions, for example an instruction to inform a family member.
• In a medical emergency in order to ensure correct treatment where the participant is unable to communicate their needs and in the unlikely situation that no better placed person, such as family or other formal or informal supporters are present.
• If required to do so by law.

5. Procedures

Blue Gum Early Childhood Intervention manages our obligations in relation to protecting the privacy of our participants by making sure that we meet the Australian Privacy Principles specified in the Federal Privacy Act of 1988 which requires that:

1. Personal Information is managed in accordance with the Privacy Act and in an open and transparent way, and that the organisation has an up to date Privacy Policy detailing;

• The kinds of personal information Blue Gum Early Childhood Intervention collects and holds,
• How it collects and holds personal information,
• The reasons for collection, use and disclosure of information,
• How an individual may access and/or correct personal information about them,
• How an individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint,
• Whether the entity is likely to disclose personal information to overseas recipients, and if so, the likely recipients and their location(s).
  2. Blue Gum Early Childhood Intervention provide individuals with the option of not identifying themselves, or of using a pseudonym, unless there is a legal requirement that individuals identify themselves.
  3. Blue Gum Early Childhood Intervention refrains from collecting personal information (other than sensitive information) unless the information is reasonably necessary for, or directly related to, one or more of the entity’s functions or activities. The collection of sensitive information about individuals must be carried out by legal means, with consent, and be reasonably necessary for, or directly related to, one or more of Blue Gum Early Childhood Intervention’s functions or activities; or be required by law.
  4. Blue Gum Early Childhood Intervention decides whether unsolicited personal information it receives could legally have been collected, and if not, then this information must be appropriately destroyed.
  5. At the time of collecting information, Blue Gum Early Childhood Intervention notify the individual that they are collecting information about them, why, how it will be stored, the circumstances under which it may need to be shared, how the individual may access or correct the information and how they may make a complaint.
  6. Blue Gum Early Childhood Intervention avoids collecting information for one purpose and then use or disclose it for another purpose without the consent of the individual, unless required by law.
  7. Blue Gum Early Childhood Intervention must avoid disclosing information for the purpose of direct marketing without the consent of the individual.
  8. If Blue Gum Early Childhood Intervention needed to disclose information to an overseas recipient, that reasonable steps be taken to ensure the overseas recipient does not breach the Australian Privacy Principles.
  9. Blue Gum Early Childhood Intervention avoids disclosing or adopting a government related identifier of an individual as its own identifier of the individual, unless required or authorised to do so by law, or unless disclosure is essential to carrying out its functions.
  10. Blue Gum Early Childhood Intervention takes steps to ensure that the personal information that the entity collects is accurate, up-to-date, complete and relevant.
  11. Blue Gum Early Childhood Intervention takes steps to protect personal information from misuse, interference and loss; and from unauthorised access, modification or disclosure.
  12. Blue Gum Early Childhood Intervention give individuals access, on request, to their own information and any charge imposed for doing so must not be unreasonable.
  13. Blue Gum Early Childhood Intervention allow individuals to correct personal information that is held about them, and if requested to do so by the individual, must notify third parties of the correction.
  14. Blue Gum Early Childhood Intervention allows individuals to remove consent to collect personal information and data at any time, and if requested to do so by the individual, must notify third parties of the withdrawal.
  15. In accordance with the NDIS Act 2013, Blue Gum Early Childhood Intervention must retain records for three (3) years. In the event that a person who has ceased to be a registered NDIS provider, they must keep records that the person was required to retain under section 73Q immediately before the person ceased to be a registered NDIS provider. The records must be kept for 3 years commencing on the day that the person ceased to be a registered NDIS provider.
  16. If a participant’s health information was collected when they were under the age of 18, the Blue Gum Early Childhood Intervention must retain the health information until the participant is 25 years old.

 

Blue Gum Early Childhood Intervention also operates in accordance with New South Wales Privacy law.

The Health Records and Information Privacy Act 2002 No 71 (HRIP Act).

The HRIP Act: 

• Gives you a right to apply to access and amend your own personal information
• Details the privacy principles public sector agencies must comply with
• Establishes the Privacy Commissioner with particular responsibility for Information Privacy in New South Wales
• Provides a complaint mechanism for formal complaints about breaches of the privacy principles or other requirements of the HRIP Act.
• In protecting the privacy of our participants, we ensure they are well informed about their rights and that we take our responsibilities seriously:
  • Every participant signing up with Blue Gum Early Childhood Intervention receives an explanation of their privacy rights, the information about them that is collected, stored and the circumstances under which it could be shared. Participants are also informed of the process for correcting information and making complaints.
  • Every team member for Blue Gum Early Childhood Intervention must read and be trained in applying this policy. They must also be trained in the Blue Gum Early Childhood Intervention Information Management Policy to ensure that participant information is recorded properly and stored securely, 
  • Team members are required to take calls and conduct participant meetings in the meeting rooms provided in the office, or in places where they cannot be overheard if they are not working off-site.
  • Blue Gum Early Childhood Intervention participants may also request a home visit and have given the numbers of Direct Managers as well as their therapy team so to communicate with either party with privacy.
• The offices of Blue Gum Early Childhood Intervention provide:
  • A private room for interviewing participants or talking with them about matters of a sensitive or personal nature.
  • Workstations within a private office space.
  • Lockable draw to hold participant files and employee files.
  • Once documents have been uploaded to a participant file, Blue Gum Early Childhood Intervention will shred information about a participant that no longer needs to be stored as a physical copy.

6. Privacy Statement

Blue Gum Early Childhood Intervention. provides high quality services to participants.  Part of our work requires that we collect private information about participants, team members, managers and volunteers.

Blue Gum Early Childhood Intervention undertakes that we will:

• Only collect personal information necessary to perform our services,
• Collect and store personal information carefully and so as ensure it is accurate and to avoid accidental disclosure or theft,
• Allow people whose personal information has been collected to access it and to provide corrections, if necessary,
• Only disclose personal information to other people or agencies with permission or as required by law,
• Operate in accordance with State and Commonwealth law,
• Maintain an up-to-date privacy policy, and act on it in the way we run our organisation,
• Educate team members and volunteers on the Privacy Policy and make it available to participants.

If participants believe Blue Gum Early Childhood Intervention has fallen short of these standards, they may complain to Blue Gum Early Childhood Intervention, and we will do our best to fix the problem.  If participants are still unsatisfied with a resolution, they may also complain to the NSW Privacy Commissioner via the Information and Privacy Commission at https://www.ipc.nsw.gov.au/privacy/citizens/make-complaint

7. References

• NDIS Act (2013)
• Privacy Act 1988 (Commonwealth)
• NDIS (Quality and Safeguards) Commission 2018
• Information and Privacy Commission at https://www.ipc.nsw.gov.au/privacy/citizens/make-complaint
• Health Records and Information Privacy Act 2002 No 71 (HRIP Act).