Privacy Policy

Personal information is information or an opinion that identifies an individual. Examples of the personal information we collect include names, addresses, email addresses, phone numbers, emergency contacts, and details about your care needs.

We collect this information in a number of ways: by telephone, by email, through our website, from publicly available sources, and from third parties such as family members, your authorised representative, your treating doctor or other health and care providers involved in your support.

We collect your personal information for the primary purpose of providing our in-home care and support services to you, arranging and coordinating that care, communicating with you and your family, and, where you have agreed, sending you information about our services. We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing list at any time by contacting us in writing.

When we collect personal information we will, where it is appropriate and possible, explain why we are collecting it and how we plan to use it.

Health information is a type of sensitive information. It includes information or an opinion about your physical or mental health, any disability, your care and support needs, medications, and any health services you have received or will receive. Because we provide in-home care, this is among the most important information we hold, and we treat it with particular care.

We collect health information only where it is reasonably necessary to plan and deliver safe, appropriate support, and where you (or your authorised representative) have consented, or where the collection is otherwise permitted by law. Health and care records are kept separately and securely, and access is limited to the people who genuinely need it to provide or manage your care.

In handling health information we follow the Privacy Act 1988 (Cth) and the Australian Privacy Principles, together with the Health Records Act 2001 (Vic) and the Health Privacy Principles, which apply to health information in Victoria.

Sensitive information is defined in the Privacy Act to include information or an opinion about things such as an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union or professional body, criminal record, and health information.

We will use sensitive information only:

• For the primary purpose for which it was obtained.
• For a secondary purpose directly related to the primary purpose.
• With your consent, or where it is required or authorised by law.

Where it is lawful and practicable, you have the option of dealing with us without identifying yourself, or by using a pseudonym, for example when making a general enquiry.

Due to the nature of the health services we provide, it is generally impracticable for us to deal with individuals who have not identified themselves. Accurate identification is required to ensure the safety and continuity of clinical care, to comply with our legal and professional obligations under applicable health legislation, and to meet the requirements of Medicare and private health insurance billing.

Where it is reasonable and practicable, we collect your personal information directly from you. In some circumstances we may be provided with information by a third party, for example a family member, your authorised representative, a hospital, a referrer or another care or health provider. In such cases we will take reasonable steps to make you aware of the information provided to us by that third party, and the purpose for which it was provided.

From time to time, we may receive personal or health information that we did not solicit. Where we receive unsolicited personal information, we will promptly assess whether that information is of a kind we could have collected under our standard collection practices.

If we determine that we could not have collected the information, and it is not contained in a Commonwealth record, we will destroy or de-identify it as soon as practicable, provided it is lawful and reasonable to do so. If we could have collected it, we will handle it in line with this policy.

Your personal information may be disclosed in a number of circumstances, including:

• To carers, support workers, contractors and service providers who help us deliver or manage your care.
• To family members, your authorised representative or other people involved in your care, where you have consented or it is reasonably necessary for your care.
• To third parties where you consent to the use or disclosure.
• Where it is required or authorised by law.

We will not sell your personal information. Where we share information with a service provider, we take reasonable steps to ensure they handle it consistently with this policy and the law.

We use third-party providers (for example, cloud storage, email and software providers) to help us run our business. Some of these providers may store or process information on servers located outside Australia, which means your personal information could be disclosed to, or accessed from, overseas recipients.

Where personal information may be disclosed to overseas recipients, we take reasonable steps to ensure it is handled appropriately and consistently with the Australian Privacy Principles. The specific countries in which our providers may store data are to be confirmed and will be listed here once finalised.

From time to time we may collect government related identifiers, such as a Medicare number or an Individual Healthcare Identifier (IHI). We will not adopt a government related identifier as our own way of identifying you, and we will use or disclose these identifiers only where it is permitted under the Privacy Act 1988 (Cth) and other applicable law, for example to deliver, claim for or coordinate your care.

Your personal information is stored in a manner that reasonably protects it from misuse, interference and loss, and from unauthorised access, modification or disclosure. We use a combination of physical, electronic and procedural safeguards, and we limit access to the people who need it to do their job.

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify it. Most personal information is stored in client files, which are kept for a minimum of 7 years.

We take reasonable steps to keep your information safe. If a data breach occurs that is likely to result in serious harm to any individual whose personal information is involved, we will respond in line with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

Where an eligible data breach occurs, we will notify the Office of the Australian Information Commissioner (OAIC) and the affected individuals as soon as practicable, and let them know the steps they can take in response.

When you visit our website, we may collect limited information automatically through cookies and similar technologies, such as your IP address, the pages you view and how you arrived at our site. We use this information to help our website work properly and to understand how it is used so we can improve it.

We may use website analytics tools to gather general statistics about visitors. This information is generally aggregated and does not identify you. You can set your browser to refuse cookies or to alert you when cookies are being used, although some parts of our website may not function as intended if you do.

You may access the personal information we hold about you and ask us to update or correct it, subject to certain exceptions. To request access, please contact us in writing.

Comfort Care at Home Pty Ltd will not charge a fee for your access request, but may charge an administrative fee for providing a copy of your personal information. We may require identification from you before releasing the requested information. If we refuse access, we will explain why in writing where it is reasonable to do so.

It is important to us that your personal information is up to date. We will take reasonable steps to make sure the information we hold is accurate, complete and current. If anything we hold is out of date or incorrect, please let us know as soon as practicable so we can update our records.

If you believe we have not handled your personal information in line with this policy, the Australian Privacy Principles or the Health Privacy Principles, please contact us using the details below. We take privacy concerns seriously and will respond as quickly as we can.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner at oaic.gov.au. For concerns about health information in Victoria, you can also contact the Office of the Victorian Information Commissioner at ovic.vic.gov.au or the Health Complaints Commissioner at hcc.vic.gov.au.

Our website may contain links to other websites that we do not operate. We are not responsible for the content or the privacy practices of those websites, and we cannot account for how authorised or other third parties handle information once you leave our site. We encourage you to read the privacy policy of any website you visit.

This policy may change from time to time, and the current version is always available on our website. We encourage you to review it from time to time so you stay informed about how we handle your personal information.