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Privacy Policy

WARRINA HOMES INCORPORATED

PRIVACY, DIGNITY AND CONFIDENTIALITY – QSP3.02

POLICY

Warrina Homes Inc. recognises and respects the right of each resident to be treated with dignity and respect and for their privacy to be preserved at all times. All staff at all times will seek the resident’s permission before delivering care.

PROCEDURE

SECTION 1 : INTRODUCTION

Warrina Homes Inc. shall ensure all residents’ privacy, dignity and confidentiality is maintained at all times.

SECTION 2 RESPONSIBILITIES

All staff are responsible for ensuring that residents’ rights to privacy and dignity are upheld and respected.

SECTION 3 : REFERENCES

Quality System Policy Manual

Warrina Homes Privacy Policy

Aged Care Act 1997, as amended

Privacy Act 1988 as amended

Aged Care Standard 3.6

SECTION 4 : REQUIREMENTS 

4.1  Privacy and Dignity

Residents will, when required, be assisted in conducting personal activities such as bathing, toileting, dressing, grooming and treatments in private.

Residents shall have privacy whilst using the telephone.

Staff practices will reflect the residents’ right to privacy and dignity.

Residents will be suitably dressed and groomed.

Residents may be assisted to maintain private relationships with access to areas for personal visits.

Respectful relationships will be encouraged between staff, the residents and their families.

Each resident will be offered a secure space in their room to which they retain the key, to secure personal valuables.

Residents’ personal information and medical records will be stored securely and access restricted to authorised personnel, refer to Procedure QSP1.11 – Records.

Residents’ personal clothing and belongings shall be labelled discreetly and utmost care taken with them, refer to Procedure QSP2.01 – Resident Admission.

The palliative and terminal care practices at the facility will support each resident’s right to die with dignity, refer to Procedure QSP2.06 – Palliative Care

Consent is gained by the resident or advocate on admission to use private information – in the delivery of care and services at Warrina Homes (Refer to the Residential Care Services Agreement and Privacy Policy). A further consent is gained by the resident or advocate following admission (Form 3.02.2) to take photographs during lifestyle activities or events for in-house display or promotional purposes only.

4.2 Confidentiality

Confidentiality will be maintained by adhering to the following:

  • Refraining from providing information about the admission of a person to Warrina Home Inc., other than to those associated with the care or treatment of the person, or members of the persons immediate family
  • Refraining from discussing a resident’s diagnosis, prognosis, and treatments, with anyone except the other members of the care team in the course of the resident’s care.
  • Information on these matters will be shared with members of the immediate family only with the consent of the resident or their appointed advocate. Only the Registered Nurse/Care Team Leader may disclose such information.
  • Refraining from providing persons other than immediate members of the resident’s family with details from residents’ files, and only with the consent of the resident, or their appointed advocate (see also Section 4.4 below).
  • Only senior supervisory staff may disclose any information from residents’ files and only nursing staff and medical practitioners have access to residents’ files. Refer to the Staff Handbook and Staff Application form for statement on maintaining Confidentiality.
  • Referring all questions relating to resident care to the Registered Nurse/Care Team Leader. Under no circumstance should other staff participate in conversation with members of the community regarding a resident, either specifically or in general.
  • Refraining from publishing or providing any information or report to any person for publication on any resident in the care of Warrina Homes Inc., unless authorised by the Chief Executive Officer (see also Section 4.4 below).
  • Refraining from discussing private affairs or personal matters, administrative or management matters concerning a staff member with other staff, residents, or residents’ families.

4.3 Practical Considerations

Staff to knock on the resident’s door and wait for a response before entering the resident’s room.

Conversations with residents are to be in an appropriate manner. Residents are to be addressed by their preferred name, and condescending names such as dear, good girl/boy are not to be used.

Private property belonging to an individual resident will not be taken, lent, borrowed or given to other people without the owner’s permission.

Residents are assisted to undertake personal activities including bathing, toileting and dressing in private. Privacy curtains (where applicable) will always be used and the bed/bathroom doors closed when in use.

Residents’ personal information will be treated with confidentiality.

When residents, because of their psychological disability, behave in an obtrusive manner and enter other rooms uninvited or behave inappropriately, staff may have to take specific action to ensure residents’ rights are met.

To prevent the unauthorised entry of individuals into another resident’s room, staff may consider with the resident’s consent:

–           Closing the door

–           Locking the door

Residents walking or moving from the bedroom to the bathroom will wear clothing, e.g. dressing gowns, so as to protect the dignity and privacy of the individual.

Medical Record Files are to be locked in filing cabinets at all times when unattended.

All aspects relating to residents’ care needs are to be documented on the Care Plan (Form 2.03.1), to ensure that privacy is maintained. Signs should not appear on beds or doors that may identify residents’ personal care needs.

Clothing Protectors should not be called “bibs” or “feeders”. A resident is not “fed” a meal, rather he / she is assisted with their meal.

Staff are not to converse with each other about work or personal life matters over a resident or in the residents’ communal area unless it is relevant to delivery of care at that time.

Intrusion during delivery of personal care or toileting by another staff member is not permitted unless assisting with care.

All treatments are to be carried out in the resident’s room (or utility room where appropriate). Treatments are not to be carried out in communal areas.

Communal lounge and dining rooms are not to be used during meal times as thoroughfares, except in an emergency. Staff and visitors should wait until all residents have vacated these areas before entering.

4.4  Warrina Homes Incorporated Privacy Policy

Warrina Homes Incorporated is committed to upholding all of the Privacy Principles (APPs) of the Privacy Act 1988 (Cth) regarding the manner in which personal information is handled and how the organisation responds to requests to access and correct personal information.

Warrina Homes Incorporated’s Privacy Policy is available for viewing on the organisation’s website at www.warrinahomes.com.au. A printed copy of the Policy may also be obtained free of charge upon request.

The following details the organisation’s practices and procedures in relation to the collection and management of personal information:

What personal information do we collect?

Warrina Homes only collects such personal information, including sensitive information, which is reasonably necessary for the organisation to fulfil one or more of its functions or activities. The organisation only collects such information from the individual concerned or from another person who is authorised (e.g. by Power of Guardianship, etc.) to act on the individual’s behalf.

The information we need about individuals may include, but is not necessarily limited to, the following:

  • Name and address details;
  • Date of birth;
  • Details of relatives and other persons we may need to contact in an emergency;
  • Details of medical practitioner(s)
  • Details of guardians and attorneys
  • Health information and other necessary personal information required to provide services to them;

In seeking personal information from an individual, or from a person authorised by the individual, Warrina Homes Incorporated will advise of the purposes for which the information is collected and of any consequences for the individual if the information is not collected. Such consequences may mean that some services cannot be provided to the individual.

If Warrina Homes Incorporated receives unsolicited information about an individual and determines that, under its collection procedures, such information could have been solicited from the individual, Warrina Homes Incorporated may retain such information. If not, and the information is not contained in a Commonwealth record, it will be de-identified and destroyed.

Warrina Homes Incorporated does not use or disclose government related identifiers unless it is reasonably necessary in order for the organisation to fulfil its activities or functions (e.g. the use of a resident’s Department of Health client identification number to verify the identity of the individual in relation to payments received by the organisation from the Commonwealth).

What do we do with the information which we collect?

The main purpose for which we collect information is to enable us to provide services to you. Some information may also need to be provided to government agencies under particular laws or we may need to use the information ourselves for internal business purposes, such as quality assurance.

Where we take photographs we will seek consent for use in publications.

Warrina Homes Incorporated does not use for direct marketing purposes any of the personal information which it collects.

Who has access to the information collected?

Only those people who are authorised to refer to your personal information will have access to this information. This will include staff who provide services to residents.

Organisations external to Warrina Homes Incorporated that may receive personal information include SA Ambulance, hospitals, doctors, pharmacists and their dispensaries, and associated care providers.

Warrina Homes Incorporated is not likely to disclose personal information to overseas recipients.

How do we ensure the quality of the information which we collect?

Through its internal compliance procedures, and through regular communication with staff and residents, Warrina Homes Incorporated seeks to ensure that the information it holds about individuals is up to date, complete, accurate and relevant for the use or disclosure by Warrina Homes Incorporated.

How is personal information protected?

All personal information held is continually supervised.  Only authorised staff have access to personal information while we hold the information.

All personal information held is kept secure. Written records are stored in locked filing cabinets or in other locked storage. All written information is destroyed by burning, pulping or shredding if it is no longer needed.

Warrina Homes Incorporated’s electronic information technology platform is managed by an external IT consulting company whose responsibilities include the provision and maintenance of high level security controls for the protection of all electronic data, including personal information, held by the organisation. Regular meetings are held with the external IT company by Warrina Homes Incorporated management to monitor the company’s performance and to ensure the adequacy of the security of the organisation’s electronic information technology platform. Warrina Homes Incorporated’s electronic data security practices include the following:

  • The organisation’s information technology infrastructure employs the latest available operating systems, software and web browsers, and these are continually updated and enhanced. The organisation also uses the latest (and continually updated) version of antivirus software.
  • The organisation’s information technology servers are housed at the organisation’s corporate head office in a dedicated, locked secure room, with the premises being protected by a 24 hour monitored external alarm system. All electronic information transmitted between the organisation’s different sites utilises a secure, encrypted, firewall-protected private network connecting the sites.
  • Any modifications requested by staff to the organisation’s IT infrastructure require authorisation by senior management before they can be implemented.
  • All information held on computer is password protected by strong passwords, with these passwords being periodically changed.
  • Access by staff to different levels of the organisation’s electronic database is restricted on a “need to know” basis.
  • If a person’s employment with the organisation ceases, that person’s computer user account is immediately de-activated.
  • All data on the organisation’s database is backed up daily (full backup) with the backup data being securely stored offsite away from the original data source.
  • Any information held in electronic form on any of the organisation’s technology equipment is removed before any such equipment is disposed of or leaves the organisation’s control.

Can individuals have access to their records?

Individuals may at any time request access to information we hold about them and such assess will be given, unless an exception to the right to access applies under the Australian Privacy Principles. If such an exception applies, Warrina Homes Incorporated will give the individual written notice that sets out the reasons for the refusal (except to the extent that, having regard to the grounds for refusal, it would be unreasonable to so) and the mechanisms available to complain about the refusal and the basis for the refusal.

We will not charge for access, but if they wish to have copies of their record they may be requested to pay the costs of obtaining such copies.

If they only wish to see their record this may be arranged with our staff.  If they wish to have a greater degree of access we will ask them to make a written request of what they require so that we may retrieve their file and keep a record of their request.

Individuals may wish to correct information held by us about them. If they find an error in our records we will ask them to please advise us in writing of the error and we will include that advice with our records.  Should the record need to be disclosed to others the correction will be forwarded with the original record.

How do we deal with a complaint?

We ask individuals to contact us first in the event that they have a complaint about the way we deal with privacy issues. The complaint will be referred to the appropriate Senior Manager who will seek to resolve any issue with the individual, but if we cannot resolve the issue the individual has a right to contact the Office of the Australian Information Commissioner to address the issue.

SECTION 5 RECORDS

Form 1.03.1                Staff Employment Application Form

Form 1.12.2                Residential Care Service Agreement Warrina Homes

Form 2.03.1                Care Plan

Form 3.02.1                Privacy Policy Statement

Form 3.02.2                Resident Photo Authorisation

Records shall be filed for 2 years, archived for 7 years and identified by description and date archived.

SECTION 6  DOCUMENTATION

QSP 1.11                       Records

QSP 2.01                       Resident Admission

QSP 2.06                       Palliative Care

Staff handbook

Issued:                       December 2017      

Review Date:           December 2020