Rotana Care Privacy and Policy
1.0 Introduction
Welcome to Rotana Care's Privacy Management Plan. This document outlines how we handle and protect your personal and health information in line with the Privacy and Personal Information Protection Act 1998 (PPIP Act) and the Health Records and Information Privacy Act 2002 (HRIP Act).
This Plan details:
◌ Our policies and practices for adhering to these privacy laws.
◌ How we ensure our staff are informed about these policies.
◌ Our procedures for managing internal privacy reviews.
◌ Additional matters relevant to safeguarding the personal and health information we manage.
We will provide a copy of this Plan to the Privacy Commissioner as soon as it is prepared and whenever updates are made.
2.0 Responsibility
The General Manager of People & Culture at Rotana Care is responsible for the ongoing review and maintenance of this Privacy Management Plan, with support from our Continuous Quality Improvement Committee.
3.0 Guiding Principles
3.1 Managing Personal and Health Information
◌ Definition: Personal information, as defined by the Privacy Act 1988, includes any data or opinion about an individual whose identity is apparent or can be reasonably determined from the information provided.
◌ Consent: Rotana Care will collect sensitive information only with explicit consent from the individual.
◌ Types of Information: We may collect various types of personal information such as names, contact details, health information, and background data. This information is used strictly for providing our services, handling complaints, or for recruitment purposes.
◌ Information Handling: We may receive information directly from individuals or third parties. Any unnecessary personal or health information will be de-identified, discarded, or managed according to Australian Privacy Principles (APPs) 5-13 and Health Privacy Principles (HPPs).
◌ Protection: We take robust measures to safeguard personal information against misuse, loss, unauthorized access, and modification. This includes secure filing systems and password-protected digital systems.
◌ Destruction or De-identification: We will destroy or de-identify personal information when it is no longer required.
◌ Correction: We will take reasonable steps to ensure that personal information is accurate, up-to-date, complete, and not misleading.
3.2 Access and Correction of Personal and Health Information
◌ Access: Individuals can request access to their personal and/or health information in writing. We will respond within 30 days, unless:
◌ The request is deemed vexatious.
◌ Disclosure may harm the individual or the public.
◌ Disclosure may impact the privacy of others.
◌ It is prohibited by law.
◌ The information is related to ongoing legal proceedings and not accessible via discovery.
◌Refusal: We may deny access if:
◌ It would reveal our negotiation strategies or breach legal restrictions.
◌ Access would compromise ongoing investigations or enforcement activities.
◌ It would disclose commercially sensitive evaluative information.
3.3 Review Rights and Complaints
◌ Review Process: If you are dissatisfied with our conduct, you may request a review in writing within 6 months of becoming aware of the issue. The review will be handled by a qualified Rotana Care employee who is not involved in the matter.
◌ Outcome: If the review is not completed within 60 days, you may apply to the Tribunal for an administrative review.
◌ Post-Review Actions: After the review, we will:
◌ Take no further action.
◌ Issue a formal apology.
◌ Implement actions to address the issue.
◌ Provide undertakings and administrative measures to prevent recurrence.
◌ Compensation: We do not offer monetary compensation if the applicant is a convicted inmate or associated with one, or if the issue concerns conduct involving a public sector agency related to a convicted inmate.
◌ Notification: Within 14 days of completing the review, we will inform you in writing of:
◌ The review findings and our reasoning.
◌ The actions we plan to take and our rationale.
◌ Your right to seek an administrative review by the Tribunal.