Privacy Policy

  Collecting and Handling Information

1. Policy Statement

1. This Policy sets out our framework for the protection of personal privacy and confidentiality of our Clients and ensures that our Clients, their families, carers, advocates and members of the public are aware of their right to have their personal information protected and treated confidentially.

2. Coastal Motion Therapy Services understands that Clients have a right to confidentiality and embraces the Australian Privacy Principles and the National Disability Insurance Scheme (Quality Indicators) Guidelines 2018. 

3. Coastal Motion Therapy Services recognises that confidentiality and proper communication is a fundamental component of service provision and that Clients have a right to be treated with dignity and respect.

4. Coastal Motion Therapy Services is responsible for protecting Clients’ information from misuse, interference, loss, and from unauthorised access, modification or disclosure.

5. There may be situations where Client information is required to be disclosed by law.

2. Definitions

1. Any reference to a Person-centred Approach also includes family-centred approach when considered in     relation to providing services to children.

2. Employee Records mean records kept by Coastal Motion Therapy Services relating to the employment of a staff member.

3. Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

4. Privacy Officer means the dedicated staff member who is the first point of contact regarding privacy matters.

5. Sensitive Information means information or opinions about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.

3. Communication

1. This Policy is available in pictorial and easy read format.

4. Collecting and Handling Information

1. As part of its daily operations Coastal Motion Therapy Services collects, stores, retains, uses and discloses Client, staff and supplier information some of which will be considered confidential. 

2. Coastal Motion Therapy Services may collect information using a variety of means, including:

 Face-to-face verbal communication;

 Telephone calls;

 Email;

 Written Communication via letters, application forms, website forms and messages.

3. Information collected through publicly available information sources shall not be considered confidential and shall be managed in accordance with the Australian Privacy Principles.

4. Coastal Motion Therapy Services shall take reasonable measures to ensure the integrity of Client information; it shall be kept accurate, complete and up-to-date.

5. An Authority to Release Information Form or acceptance of Consent to Exchange and Share Information section on our Client Intake form will be completed by Clients prior to information being collected from other sources or provided to other parties. This form shall be kept on the Client’s file.

6. When collecting information from a third party without direct consent or inquiry from the Client, Coastal Motion Therapy Services shall take reasonable steps to notify the Client of:

 Coastal Motion Therapy Services identity and contact details;

 The fact that the information has been collected from a third party;

 The lawful obligation Coastal Motion Therapy Services has to collect this information, if any;

 The purpose of collecting the information;

 The expected consequences of not collecting this information;

 Any other third party to which this information may be disclosed;

 This Policy that outlines how and why information may be collected;

 Whether the information is likely to be disclosed to overseas recipients and in which countries those recipients are likely to be located.

7. Coastal Motion Therapy Services shall only collect information about the Client that is directly relevant to effective service delivery and performing Duty of Care responsibilities.

8. In some cases, Coastal Motion Therapy Services may be unable to respond to a Client’s request or provide services without collecting information about the Client.

9. Client information received by Coastal Motion Therapy Services without prior request shall be considered unsolicited and shall be de-identified or destroyed unless:

 This information is publicly available and could have been collected in line with the Australian Privacy Principles; or

 This information is contained within a Commonwealth record.

5. Confidential Information

1. Confidential information may include:

 Personal information: name, date of birth, home address, telephone number, photographs, etc.;

 Information about medical conditions and health status;

 Information about personal preferences;

 Sensitive information.

2. Coastal Motion Therapy Services shall hold Client information only as long as it remains relevant to the delivery of services and fulfilling the Duty of Care unless other lawful obligations apply. Once it is no longer required to hold the information, Coastal Motion Therapy Services shall take reasonable steps to destroy or de-identify it.

3. Coastal Motion Therapy Services shall keep all documents containing confidential information stored privately in a locked filing cabinet (or similar place with restricted access); digital files containing confidential information shall be protected electronically by restricting the access to only those requiring it to perform their duties.

4. A Client may make a written request to access their confidential information kept by Coastal Motion Therapy Services. Within a reasonable timeframe, Coastal Motion Therapy Services shall provide a written response containing the requested information or an explanation of the circumstances that prevent Coastal Motion Therapy Services from disclosing it along with the details for how the Client can appeal that decision or make a complaint.

5. Queries or complaints regarding privacy can be addressed to the Company Director. Any matters unresolved may be referred to the Office of the Australian Information Commissioner.

6. Keeping Information Confidential

1. To keep information confidential Coastal Motion Therapy Services will:

 Not discuss a Client or their treatment with another person, even in a social setting, unless the Client has provided permission to do so i.e. in the case of an advocate, family member, friend or carer;

 Seek consent of the Client or family prior to obtaining information from any other source;

 Ensure confidential documents are out of sight and reach in public areas;

 Ensure Client information is not disclosed to agencies that are not involved with the Client;

 Ensure Client names or other identifying information is not to be displayed on notice boards, whiteboards, etc. where they are open to view by another Client or member of the public;

 Ensure photographic, video or other identifying images are not displayed or aired publicly without the prior written consent of the Client or family;

 Destroy personal information kept on file in a secure manner once it is no longer needed;

 Ensure that if public comments are requested, the Director is consulted and confidential information is not disclosed.

2. There may be instances such as mandatory notification where confidential information must be disclosed. Where this is applicable, Coastal Motion Therapy Services shall do so in compliance with the Appendix Issued Pursuant to the Information Sharing Guidelines and Child Safe Policy. These instances may include:

 A serious or imminent threat to an individual’s life, health or safety or a potential serious threat to public health or safety;

 Harm or risk of harm to a child;

 Preventing, detecting, investigating, prosecuting or punishing of criminal offences and other breaches of the law that attract a penalty;

 Preventing, detecting, investigating or remedying of seriously improper conduct or prescribed conduct;

 Preparation or conduct of proceedings before any court or tribunal.

7. Documents

 Authority to Release Information Form

 Child Safe Policy

 Client Complaints and Feedback Policy

 Duty of Care and Incident Management Policy.

8. References

 Australian Privacy Principles

 Disability Discrimination Act 1992

 Privacy Act 1998

Scott McDonald  Taylor Page

Director  Director

Effective Date: 07/05/2025