1 Purpose of Policy

Federal and state legislation allows Caraniche clients to have reasonable access to personal information held about them. This policy outlines what information Caraniche will collect from clients, how it will be used and stored and how it can be accessed by clients.

2 Commencement of Policy

This Policy will commence on 23 August 2015.

3 Application of Policy

The Privacy Policy for Clients applies to all Caraniche clients seen by Caraniche staff in community settings.

4 Collection of Personal Information

4.1 Personal Information Collected for Service Delivery
Caraniche collects a range of personal information during service delivery. This information includes, but is not limited to:

• Contact information (e.g. address, phone number, email, fax);
• Attendance dates and times;
• Case notes (i.e. brief records of the content of sessions) and assessments notes (i.e. personal information taken to assist the process of working with the client);
• Psychological tests;
• Reports and certificates (i.e. material written by Caraniche, or material received from another service); and
• Correspondence and referral information

This information is stored or uploaded onto client’s electronic case file within the Caraniche Client Management System.

4.2 Personal Information Collected for Administration and Billing
Caraniche collects a range of personal information related to scheduling and payment for service provided to clients. This often includes, but is not limited to:

• Billing information (e.g. address, payer, method of payment, payment rates);
• Attendance dates and time; and
• Contact information (e.g. address, phone number, email, fax).

This information is recorded in the Caraniche Accounting Package and in the Caraniche Client Management System. The client’s name may also be recorded in the room booking data base against the date and time of the scheduled session.

4.3 Personal Information Collected for Other Agency or Organisation Payments for Services Provided to Clients
Caraniche is sometimes required to collect specific personal information via the paying agency or organisation. While the process can vary from agency to agency there are three main variations

1. Where the client (i.e. the person(s) receiving the service) is provided with the service anonymously and scheduling and billing are organised through a reference number;
2. Where the client is identified by name and Caraniche provides the agency or organisation with information on the dates and times of attendance; or
3. Where the client is identified by name and Caraniche provides the agency or organisation with specified details of the service and the client (e.g. where the service being provided is a psychological report).

Clients should ask their clinicians which variation applies in their specific circumstances.

4.4 Personal Information Collected for Research and Evaluation
Caraniche collects some personal information to be used in research and evaluation. Where information is collected for research or evaluation purposes clients will be invited to participate. If a client agrees to participate a consent form signed by the client is required. Clients can withdraw consent for their information to be used for research and evaluation purposes at anytime.

4.5 Personal Information Collected for Management, Clinical and Quality Assurance
Caraniche has management, clinical audit and quality assurance processes that rely on access to individual client files and case discussion with staff members. When personal information is used the purpose is not to know or draw upon individual client information. The information is used in a collective manner or at group level.

5 Accessing Personal Information held by Caraniche

Clients and their legal guardians are entitled to request access to personal information held by Caraniche. To gain access to the personal information held in a Caraniche Treatment File (electronic or hardcopy) the client or the legal guardian can either:

• Make a request directly to the treating clinician and have access to the file (or parts of the file) within a treatment session; or
• Request access in writing by contacting the Caraniche Privacy Officer.
• There are some situations where Caraniche will not provide access to certain information on a Treatment File. They include, but are not limited to:
• When access would or could comprise a serious threat to life or to health (e.g. of the client, or to others named in documentation on the Treatment File);
• When issues regarding access relate to the requirements of the Australian Psychological Society (APS) Code of Conduct, law enforcement, legal proceedings or other public interest matters.

Information about accessing the contents of a client Treatment File is also available via the Victorian Privacy Commissioner or Health Services Commissioner, and the Office of the Australian Information Commissioner.

6 Storage and Maintenance of Personal Information held by Caraniche

Caraniche will work with clients to ensure that personal information held is accurate, complete and up-to-date. If there are inaccuracies a client or legal guardian can request that a note is placed on the Treatment File incorporating their comments, and/or corrections.

Caraniche will take all reasonable steps to protect the personal information it holds from misuse, loss, or unauthorised access, modification or disclosure.

Caraniche will take all reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the agreed purposes. In accordance with the Health Records Act 2001 and the Australian Psychological Society (APS) Code of Ethics client files are destroyed 7 years after the last contact with the client; or in the case of a minor for at least 7 years and until the child reaches the age of 25.

7 Hardcopy Client Files

Prior to 2005 all Caraniche Treatment files were kept in hard copy. Where a hard copy treatment file exists from a previous episode of treatment or contact, clients will be given the option of having the previous file material uploaded into their electronic treatment record.

8 Relevant Legislation

Relevant Victorian legislation

• Information Privacy Act 2000
• Health Records Act 2001

Relevant Commonwealth legislation

• Privacy Act 1988
• Privacy Amendment Act 2012

9 Contact Details

Contact the CARANICHE PRIVACY OFFICER
Level 1, 260 Hoddle Street, Abbotsford 3067
Phone: 03 8417 0500

Email: admin@caraniche.com.au