At Capital Nordic Walking (CNW) we aim to ensure absolute confidentiality and safety of all our clients’ personal information. This policy addresses the management of personal information by our employees.
As an Allied Health Provider, we always aim to be consistent with the Australian Privacy Principles in the Privacy Act 1988.
While this policy focuses on the management of clients’ health information, it also relates to other personal information on clients and to photos and videos of events which may identify individuals.
For client safety and to assess the best program for an individual, CNW will ask the new client to consent to sharing relevant health information with the course instructor.
CNW will also ask the client to provide personal information so that they can be contacted by email and phone, and for billing purposes.
From time to time, CNW may seek the client’s permission to photograph or video a CNW event when this may result in identification of the client. This will be done to provide news of the event and for promotional purposes. If the client does not wish to give their consent, they may lawfully refuse, and they will still be able to participate in the event.
All hard copies of information are stored safely and securely by CNW and kept for a minimum of 7 years after last contact with us. In the case of a child, files are stored for 7 years after the final contact after the child has turned 18 (25 years of age).
CNW software stores some personal records. All electronic records are kept indefinitely and are made inactive at the discretion of CNW. If necessary inactive electronic records are made active again using our computer software.
No record will be destroyed at any time without the permission of CNW management.
If CNW ceases to operate, clients will be contacted individually or, if this is not practical, a public notice will be placed in the local newspaper indicating that the records will be deleted.
When hard files are due to be destroyed they are shredded as directed by CNW.
The course instructor will take steps to ensure that clients can discuss issues relating to their health and that the course instructor can record relevant personal information, in a private setting where unauthorised people cannot access the information.
For example: the course instructor will ensure that a conversation on a private matter is conducted in a manner that prevents the conversation from being overheard by other clients, unless the client indicates at the time of the conversation that they are happy for this information to be heard by others.
Clients are informed of who in CNW has access to their records. Such information is displayed on the CNW website.
Clients will be informed, and consent gained if CNW undertakes research and quality improvement activities which will use client information.
If a research project is conducted by CNW under the approval of an institutional ethics committee, participating staff of CNW must be aware of the requirements to obtain consent specified in the research protocol and must ensure that consent is properly obtained.
Where possible, identifying information will always be removed from personal health information being used for research and QA activities. Where this is not possible, staff accessing personal health information are aware that they are under an obligation of confidentiality not to disclose the information. Breaches of that obligation may result in dismissal. CNW will ensure that any external auditors and researchers are also under an explicit written obligation of confidentiality, with appropriate penalties for disclosure.
CNW will ensure that personal information is disclosed to third parties only where consent of the client has been obtained. Exceptions to this rule occur when the disclosure is necessary to manage a serious and imminent threat to the client’s health or welfare; or is required by law. Information disclosed to Medicare or private health insurers will be limited to the minimum required for the client to obtain insurance rebates.
Information supplied in response to a court order will be limited to the matter under consideration by the court.
It is CNW policy that all clients have access to the personal information contained on their file. CNW will provide an up-to-date and accurate summary of the client’s personal information on request or whenever appropriate.
CNW will either show the client the record or arrange for provision of a copy and explain the contents to the client. A charge may be incurred by the client for any copying requested by the client.
Clients may request CNW to update the personal or health information held about them on file at any time by providing suitable documents. For example, they may email their new contact details to the Course instructor or provide the Course instructor with a copy of a medical report.
CNW staff will protect personal health information against unauthorised access while it is being stored and transmitted.
Staff will ensure that records or any other papers containing personal health information are not left where they may be accessed by unauthorised persons.
Access to personal information by CNW staff will be the minimum necessary for the performance of their duties.
Fax, email and telephone messages will be treated with security equal to that applying to written records.
Computer screens will be positioned in a way which prevents unauthorised viewing of a client’s personal information. Staff will ensure that computers left unattended cannot be accessed by unauthorised persons.
Staff will ensure that personal information held by CNW is secured against loss or alteration of data.
Client records will not be taken away from CNW offices except if this is necessary to assist a client and if this is the case the records will be kept securely during this time. The responsible CNW staff will ensure that the record is returned to the office and left in an appropriate place for filing. Papers containing personal information are either securely disposed of or filed promptly after each client contact.
Staff will ensure that the computers are secured with a password and that the office is locked when leaving.
The data on the computer system will be backed up daily. The computer system is regularly updated with virus and firewall protection.
On induction, all staff who participate in CNW activities are trained in the importance of confidentiality. All staff sign a confidentiality statement stating that breaching confidentiality will result in termination of the employment/contractual/volunteering* arrangement.
*Throughout this document, the word staff applies to employees of CNW, to any contractor engaged by CNW and to any volunteer who may assist CNW in our work.
Questions? Please do not hesitate to contact us if you have any privacy concerns.