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The Greek Welfare Centre is the welfare and community services arm of the Greek Orthodox Archdiocese of Australia. The Greek Welfare Centre is bound by and is committed to upholding all of the provisions of the Commonwealth Privacy Act 1988.
The Greek Welfare Centre collects only information that is relevant for its purposes and does not collect information by unfair or illegal means or for any purpose other than the provision of services to its consumers.
The Greek Welfare Centre treats all personal information provided to it as confidential.
It ensures that all of its records and any information provided to it are kept in a secure manner and are available only to persons properly authorised to have access to such information. This applies to electronic as well as hard copy records and includes not only consumer files but all records containing personal information. Password and other appropriate protections are used for electronic records.
The Greek Welfare Centre takes all necessary steps to ensure that the information it keeps is accurate and up to date.
The Greek Welfare Centre will not disclose personal information to any other person or organisation without the consent of the individual or the person responsible for the individual, except where this is necessary to provide the service to the individual, or where required by law. We will advise the individual when this is the case.
Individuals have the right to view personal information held by the Greek Welfare Centre about them. Anyone wishing to inspect their records may ask the Manager of the Greek Welfare Centre. It is the policy of the Greek Welfare Centre that a member of staff be present when an individual is inspecting his or her records. Copying of documents will generally not be allowed.
There are circumstances in which the Greek Welfare Centre may refuse a request for access to all or part of personal information, but in those circumstances, the Greek Welfare Centre will provide a written explanation of the decision to refuse.
If an individual considers that any information the Greek Welfare Centre has about him or her is incorrect the Centre will, if appropriate, amend it or, if not appropriate, will provide a reason why the records should not be altered, and note on the file the individual’s objection.
Detailed consumer records are destroyed when they are no longer needed.
If you have queries or complaints relating to our collection or use of your personal information please inform The Manager, Greek Welfare Centre, 96 Wright Street, ADELAIDE SA 5000. If you are dissatisfied after receiving our reply you may appeal by writing to the Manager of Complaints, Office of the Federal Privacy Commissioner, GPO Box 5218, Sydney NSW 1042 or by phoning the Commissioner’s Hotline on 1300 363 992.
Procedure
The following procedures are to be applied when collecting, using, disclosing and storing information about people. As soon as practicable after the initial contact with a consumer, or at the assessment stage, the consumer (or person responsible) must be made aware of the Greek Welfare Centre’s Privacy Policy and Collection Statement, which is also available in Greek so that he/she can make an informed decision about granting or withholding consent.
Note: The National Privacy Principles (2.5) define a person as being responsible if the person is:
(a) a parent of the individual; or
(b) a child or sibling of the individual and at least 18 years old; or
(c) a spouse or de facto spouse of the individual; or
(d) a relative of the individual, at least 18 years old & a member of the individual’s household; or
(e) a guardian of the individual; or
(f) exercising an enduring power of attorney granted by the individual that is exercisable in relation to decisions about the individual’s health; or
(g) a person who has an intimate personal relationship with the individual; or
(h) a person nominated by the individual to be contacted in case of emergency.
(Other relatives who can be defined as “responsible” are in paragraph 2.6 of the National Privacy Principles).
Intake – a general statement will be given to the consumer about the Centre’s privacy policy, as attached at end of this document.
The assigned caseworker – will either hand the consumer the Collection Statement or explain it to them orally. If consent is granted orally, this must be noted, along with the date, on the consumer’s file.
Groups – The Centre’s privacy policy will be explained to the groups. Consent can be granted orally by those present, which will be noted on file along with the date it was given, as attached at end of this document.
If a consumer (or person responsible) does not grant consent then the Centre must inform the consumer (or person responsible) that the Centre may not be able to provide a full service or any service at all. This must be noted on the consumer’s file.
A consumer can withdraw their consent at any time by contacting the Centre. This must be noted on the consumer’s file.
Information must not be collected by unfair or illegal means or for personal, not work-related, purposes. In addition, information must not be collected in an unreasonably intrusive way, and all discussions with consumers must be conducted in a private area.
Only personal information that is relevant and as comprehensive as possible in regard to the case matter at hand must be kept.
If information about a third party is being disclosed then reasonable attempts must be made to contact the third party, who will be informed of the Centre’s Privacy Policy and given the Collection Statement. However, this procedure must not be followed where making the individual aware of the matters would pose a serious threat to the life or health of any individual, or where no reasonable steps are available.
Consent can be granted by signing the Collection Statement or it may be granted orally. A witness must countersign the written consent, whenever practical. When the consent is granted verbally, the staff member must note this on the Collection Statement and the date that this was granted.
In general, personal information must only be used and disclosed for the purposes for which it was collected. This also means staff will not talk with colleagues about particulars of consumers.
Personal information must only be used or disclosed for other purposes if, for example:
• the individual has granted consent, or
• the Centre is required by law, or
• the Centre believes that using the information is essential to lessen or prevent serious threat to an individual’s life, health or safety, or to public health or safety.
[For a full list see National Privacy Principle 2].
When a staff member is required by law to use personal information, a note must be made about this on the consumer’s file.
The Centre must take whatever reasonable steps it can, to ensure personal information collected, used or disclosed is accurate, complete and up-to-date.
If there are any doubts about the accuracy of the information, then all attempts must be made to establish the information’s authenticity. Special care must be taken to consider the source of the information, its currency and the purpose for which it was collected. If seeking to act upon information, care must be taken to ensure that details have been brought up-to-date in consultation with the consumer.
The Greek Welfare Centre ensures that personal information is kept in a secure manner and is only accessible to properly authorised persons. This applies to electronic as well as hard copy records. Personal information is kept locked in filing cabinets, where only authorised staff members have access. In addition, the computer room has a locked door, preventing unauthorised access. Passwords and other protections are used for electronic records. Detailed consumer records are destroyed when they are no longer needed.
The Centre’s Privacy Policy (which is translated in Greek) and governs the Centre’s handling of personal information is displayed in the Centre’s reception area. The Collection Statement (which seeks consent) at, or as soon as practicable after, the initial contact with the consumer is given to consumers.
People have a right to access information kept about them. Anyone wishing access may ask the Manager of the Greek Welfare Centre, who will ensure that a staff member is present when the individual is viewing the information. Consumers may take notes, however, copying of records will generally not be allowed.
In circumstances where the Greek Welfare Centre refuses a request for access to all or part of personal information (e.g. where providing access would pose a serious threat to the life or health of any individual, or other reasons as outlined in the Commonwealth Privacy Act, or other law) the Greek Welfare Centre will provide a written explanation about its decision to refuse access.
If a consumer is not satisfied, the consumer can appeal in writing to the Manager of Complaints, Office of the Federal Privacy Commissioner, GPO Box 5218, Sydney NSW 1042 or by phoning the Commissioner’s Hotline on 1300 363 992 and hcscc Health & Community Service Complaints Commissioner, PO Box 199 Rundle Mall Adelaide SA 5000 or call the Enquiries Service on 8226 8666.
A consumer can ask that records be amended if they can establish that the records are inaccurate, incomplete or not up-to-date. The Greek Welfare Centre must take reasonable steps to correct the information. However, if the Greek Welfare Centre considers it not appropriate to amend the records, the individual’s concern must be noted, a reason given why the records should not be altered and the individual’s objection must be noted on the file.
The Greek Welfare Centre does not adopt as its own identifier of an individual, or use or disclose an identifier that has been assigned by a Commonwealth Government Agency such as Medicare numbers.
Whenever it is lawful and practicable, individuals can interact anonymously with the Greek Welfare Centre.
The Greek Welfare Centre must provide personal information to a recipient organisation in a foreign country only in circumstances where the recipient country has the same or greater protection afforded to this information or if the individual consents to the transfer of the information.
All current staff, volunteers, and management of the Greek Welfare Centre must sign a Deed of Confidentiality outlining the seriousness of abiding by the Commonwealth Privacy laws and the consequences of breaching these as soon as practicable after appointment.
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