Privacy Policy

1. Our commitment to your privacy

SA Community Support Pty Ltd (SA Community Support, we, us or our) respects your privacy and is committed to protecting the personal and health information entrusted to us.

We provide community nursing, in-home care and support services in South Australia and work with clients, families, carers, representatives, health professionals, referral partners and other organisations involved in coordinating care.

This Privacy Policy explains how we collect, hold, use and disclose personal information, how we protect that information, how you can request access to or correction of information we hold about you, and how you can raise a privacy concern or complaint.

We handle personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

As a health service provider, SA Community Support may collect and hold health information and other sensitive information. We recognise that this information requires a high level of privacy and security. Private-sector health service providers are subject to the Privacy Act even in circumstances where the small-business exemption might otherwise apply.

2. Who this Privacy Policy applies to

This Privacy Policy applies to personal information we collect or hold about people including:

• current, former and prospective clients
• family members, carers and representatives
• guardians, attorneys, supporters and other authorised representatives
• people referred to us by health professionals or other organisations
• people who contact us through our website
• GPs, hospitals, nurses, allied-health professionals and other referral partners
• employees and prospective employees
• contractors and service providers
• suppliers and professional advisers
• other people who interact with SA Community Support.

3. What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Some personal information is classified as sensitive information and receives additional protection under Australian privacy law.

Health information is a type of sensitive information and includes information or opinions about a person's health, illness, disability, health services provided or to be provided, and other information collected in connection with providing a health service.

Because SA Community Support provides community nursing and care services, health information forms an important part of some of the records we maintain.

4. What information we may collect

The information we collect depends on your relationship with SA Community Support and the services being requested or provided.

We may collect:

Personal and contact information

This may include:

• name
• date of birth
• residential or postal address
• telephone number
• email address
• preferred method of communication
• preferred language and communication requirements
• emergency contacts
• family, carer and representative details
• information about guardians, attorneys or other authorised representatives.

Care and service information

This may include:

• information about your support needs
• care preferences
• personal goals
• daily-living requirements
• current care arrangements
• services requested or received
• care plans and service instructions
• information about other organisations involved in your care
• funding or program information relevant to services
• service-delivery records.

Health and clinical information

Where reasonably necessary to assess, coordinate or provide care, we may collect information including:

• medical history
• diagnoses and health conditions
• medications and allergies
• hospital and discharge information
• clinical assessments
• nursing assessments and progress notes
• wound and skin-integrity information
• clinical photographs where appropriate
• diabetes-related information
• continence and catheter information
• nutrition and enteral-feeding information
• mobility and falls information
• pressure-injury risks
• cognitive, behavioural or communication information relevant to safe care
• clinical observations
• treatment plans and instructions
• medication charts
• pathology, specialist or other clinical information where relevant
• information provided by GPs, hospitals, specialists, nurses, pharmacists and allied-health professionals
• clinical incidents and risk information
• other information reasonably necessary to provide safe and appropriate care.

We seek to collect only information reasonably necessary for our functions and activities and in accordance with applicable privacy requirements.

5. How we collect personal information

Where reasonable and practicable, we collect personal information directly from the individual concerned or their authorised representative.

We may collect information through:

• telephone conversations
• email
• face-to-face communication
• our website
• online enquiry and referral forms
• paper or electronic referral forms
• clinical assessments
• care planning
• nursing visits
• service-delivery records
• correspondence
• complaints and feedback
• employment applications
• other interactions with SA Community Support.

We may also receive information from appropriate third parties, including:

• family members and carers
• authorised representatives
• GPs
• hospitals and discharge teams
• medical specialists
• nurses
• allied-health professionals
• pharmacists
• care coordinators
• registered aged-care providers
• government agencies or programs
• other health and care organisations involved in coordinating or providing care.

Where information is collected from someone other than the individual, we will handle it in accordance with applicable privacy requirements.

6. Professional and healthcare referrals

SA Community Support accepts referrals from healthcare professionals and other appropriate referral sources.

A professional referral may contain personal and sensitive health information about the person being referred.

This may include:

• identifying and contact information
• reason for referral
• diagnosis and relevant medical history
• clinical information
• medication information
• discharge documentation
• care plans
• treatment instructions
• risk and safety information
• requested nursing or support services
• details of treating professionals
• information about existing services and care arrangements.

We use referral information to review the person's needs, communicate with relevant parties, determine whether we may be able to provide the requested services and, where appropriate, establish and coordinate care.

Health professionals and other organisations providing information to SA Community Support are responsible for ensuring they have an appropriate authority or lawful basis for disclosing that information.

7. Why we collect, use and disclose personal information

We may collect, use and disclose personal information where reasonably necessary to:

• respond to enquiries
• receive and assess referrals
• communicate with prospective clients
• determine whether requested services are appropriate and available
• assess nursing and support needs
• develop, implement and review care plans
• provide community nursing
• provide in-home care and support
• coordinate services
• communicate with clients, representatives and carers
• communicate with GPs, hospitals and other treating health professionals
• monitor and respond to changes in health or support needs
• manage clinical and safety risks
• respond to incidents
• coordinate hospital-to-home transitions
• manage appointments and service delivery
• administer relevant funding and service arrangements
• invoice and process payments where applicable
• maintain clinical, operational and business records
• manage complaints, feedback and quality improvement
• meet legal, regulatory, contractual and reporting obligations
• manage employees and contractors
• manage our business operations
• maintain and improve our services.

We generally use or disclose personal information for the purpose for which it was collected, or for another purpose permitted under applicable privacy law.

8. Working with other care and service providers

Providing safe and coordinated care sometimes requires SA Community Support to work with other organisations and healthcare professionals.

Depending on the circumstances, and where authorised or otherwise permitted by law, relevant information may be shared with:

• GPs
• hospitals
• medical specialists
• nurses
• allied-health professionals
• pharmacists
• registered aged-care providers
• care coordinators
• emergency services
• other organisations involved in providing or coordinating the person's care.

We seek to limit information sharing to information reasonably necessary for the relevant purpose.

Where multiple organisations are involved in a person's care, different organisations may maintain their own records and have their own privacy obligations.

9. Support at Home services

SA Community Support may provide services under arrangements with a registered Support at Home provider.

Where we provide services as an associate provider or local service partner, relevant personal and health information may be shared between SA Community Support and the registered provider where reasonably necessary for:

• onboarding and service commencement
• care planning
• service coordination
• safe delivery of services
• review of care needs
• management of risks or incidents
• funding and budget administration
• invoicing and reimbursement
• quality and safety
• regulatory or contractual requirements.

The registered provider and SA Community Support may each maintain records relevant to their respective roles and responsibilities.

10. Our clinical records

Where SA Community Support provides clinical or nursing services, we may maintain an electronic clinical record containing information necessary to provide and document care.

Clinical records may include:

• assessments
• care plans
• progress notes
• observations
• medication information
• wound information and clinical photographs
• relevant hospital and discharge documentation
• correspondence with treating health professionals
• clinical risk information
• incident information
• other records relevant to the care provided.

We use secure third-party information systems and service providers to assist us in managing clinical information.

Access to clinical information is intended to be limited to authorised personnel who require the information for their role.

11. Clinical photographs

In some circumstances, clinical photographs may assist with assessment, monitoring, treatment or continuity of care—for example, monitoring a wound or skin condition.

Where appropriate, SA Community Support may collect and retain clinical photographs as part of the person's clinical record.

We seek to:

• take photographs only where there is a legitimate clinical purpose
• obtain appropriate consent or other lawful authority
• limit photographs to what is reasonably necessary
• store clinical photographs securely
• restrict access to authorised personnel
• avoid unnecessary storage of clinical photographs on personal devices.

Clinical photographs are treated as health information and handled accordingly.

12. Website enquiries and online referrals

When you use our website to contact SA Community Support or submit a referral, we may collect the information you provide.

Depending on the form used, this may include personal and health information.

Information submitted through our website is used for purposes such as:

• responding to your enquiry
• reviewing a referral
• contacting the person being referred
• determining the appropriate service pathway
• coordinating assessment or care.

Please only provide information relevant to the enquiry or referral.

Where supporting documents can be uploaded, these may include documents such as referral letters, care plans or relevant clinical documentation.

Submitting a referral does not automatically mean that SA Community Support has accepted the referral or agreed to provide services.

13. Cookies, analytics and website technologies

Our website may use cookies and similar technologies to operate the website, understand how it is used, improve its performance and help us understand the effectiveness of our communications and advertising.

These technologies may collect information such as:

• IP address
• browser type
• device information
• pages visited
• time and date of visits
• general location derived from technical information
• referring website or advertising source
• interactions with website pages or advertisements.

We may use third-party analytics and advertising services for these purposes.

Some of these providers may use cookies or similar technologies and may process information in accordance with their own privacy practices.

Where practicable, we seek to configure our website so that advertising and analytics technologies do not intentionally receive sensitive health information entered into clinical or referral forms.

You can generally control or disable cookies through your browser settings. Disabling some cookies may affect website functionality.

14. Direct marketing

We may use contact information to communicate with people about SA Community Support services, resources, news or other information where permitted by law.

Where required, we will obtain consent before sending marketing communications.

You can ask us to stop sending direct marketing communications at any time by:

• using an unsubscribe function provided in the communication; or
• contacting us at connect@sacommunitysupport.com.au.

Opting out of marketing communications does not prevent us from sending communications reasonably necessary for care, referrals, appointments, service delivery, safety or administration.

15. Who we may disclose personal information to

Depending on the circumstances, we may disclose relevant personal information to:

• the individual concerned
• their authorised representative
• family members or carers where appropriately authorised or otherwise permitted
• GPs
• hospitals
• medical specialists
• nurses
• allied-health professionals
• pharmacists
• registered aged-care providers
• organisations involved in coordinating or providing authorised services
• emergency services
• government agencies or regulators where required or authorised
• insurers and professional advisers
• auditors
• contractors and service providers
• information technology, cloud, communications, website and data-storage providers
• other parties where the individual has consented or where disclosure is otherwise permitted or required by law.

We do not sell personal or health information.

16. Third-party technology and cloud services

SA Community Support uses third-party technology and service providers to support our operations.

These may include services used for:

• clinical information management
• secure data storage
• email and communications
• document management
• website hosting
• website analytics
• online advertising
• business administration
• accounting
• service coordination.

We take reasonable steps when selecting and using service providers having regard to the nature and sensitivity of the information involved.

However, third-party providers operate their own systems and may have their own privacy and security practices.

17. Overseas processing and disclosure

Some third-party technology, communications, analytics, cloud or support-service providers may process or access limited personal information using infrastructure or personnel located outside Australia.

Where SA Community Support is likely to disclose personal information to an overseas recipient, we will manage that disclosure in accordance with applicable Australian privacy requirements.

The countries involved may vary depending on the technology and service providers we use from time to time.

Where practicable and appropriate, we prefer systems that provide suitable protections for sensitive health and clinical information, including Australian data hosting where this is relevant to the service.

We will review this section as our technology systems and service providers develop.

APP 1 requires an APP entity's privacy policy to address whether personal information is likely to be disclosed to overseas recipients and, where practicable, specify the countries involved.

18. How we protect personal information

SA Community Support takes reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

Depending on the information and systems involved, our safeguards may include:

• access controls
• individual user accounts
• multi-factor authentication
• password and authentication requirements
• role-based access
• encryption provided by relevant systems
• secure electronic information systems
• physical security for paper records
• limiting access according to a person's role and responsibilities
• confidentiality obligations
• workforce privacy and security education
• device-security requirements
• secure information-sharing practices
• system audit and access controls
• backup and business-continuity arrangements
• procedures for responding to privacy and cybersecurity incidents
• secure destruction or de-identification when appropriate.

No information system or method of electronic transmission can be guaranteed to be completely secure. We therefore review our information-handling practices and safeguards having regard to the nature and sensitivity of the information involved.

APP 11 requires organisations to take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

19. Paper records

Although SA Community Support seeks to use appropriate digital systems for clinical and business information, some information may exist in paper form.

Where paper records containing personal or health information are used, we take reasonable steps to protect them from unauthorised access, loss or disclosure.

This may include secure storage, controlled access, secure transport and confidential destruction when records are no longer required and may lawfully be destroyed.

20. Retention and secure disposal

We retain personal and health information for as long as reasonably necessary to:

• provide and document services
• maintain continuity of care
• satisfy clinical and professional requirements
• meet aged-care, contractual or regulatory requirements
• satisfy applicable legal and record-keeping obligations
• manage complaints, incidents or legal matters.

Different types of records may be subject to different retention periods.

Where personal information is no longer required and we are not required or authorised to retain it, we take reasonable steps to securely destroy or de-identify it.

21. Data breaches and privacy incidents

SA Community Support takes suspected privacy and data-security incidents seriously.

If we become aware of a suspected breach involving personal information, we will take reasonable steps to:

• contain the incident
• investigate what occurred
• assess the potential consequences
• take appropriate remedial action
• reduce the likelihood of recurrence.

Where an incident is an eligible data breach under the Privacy Act's Notifiable Data Breaches scheme, we will comply with applicable notification requirements, which may include notifying affected individuals and the Office of the Australian Information Commissioner.

Private-sector health service providers covered by the Privacy Act are also subject to the Notifiable Data Breaches scheme.

22. Access to your personal information

You may request access to personal information SA Community Support holds about you.

We may need to verify your identity before providing access.

In some circumstances, access may be refused or limited where permitted or required by law. If this occurs, we will generally explain the reason and available complaint mechanisms as required by applicable law.

To request access, contact our Privacy Officer using the details at the end of this policy.

23. Correcting your information

We take reasonable steps to ensure that personal information we hold is accurate, up to date, complete, relevant and not misleading having regard to the purpose for which it is held.

If you believe information we hold about you is inaccurate, incomplete, outdated, irrelevant or misleading, please contact us.

We will consider the request and take appropriate steps in accordance with applicable privacy law.

24. Anonymity and pseudonyms

Where lawful and practicable, you may interact with SA Community Support anonymously or by using a pseudonym—for example, when making a general enquiry that does not require us to know your identity.

However, we generally need to identify a person before providing nursing, care or personalised support because sufficient information is required to provide services safely, accurately and appropriately.

APP 2 provides individuals with an option of anonymity or pseudonymity in appropriate circumstances, subject to specified exceptions.

25. Privacy and children or people requiring decision-making support

Where a person is unable to independently provide consent or manage aspects of their information, we may communicate with an authorised representative, guardian, attorney, supporter or other person authorised under applicable law.

We will seek to respect the person's rights, preferences, dignity and involvement in decisions to the extent appropriate to their circumstances.

26. Privacy complaints

If you believe SA Community Support has not handled your personal information appropriately, please contact our Privacy Officer.

We ask that you provide enough information for us to understand and investigate the concern.

We will seek to:

1. acknowledge the complaint;
2. review the circumstances;
3. obtain further information where required;
4. investigate the matter; and
5. provide a response within a reasonable timeframe.

We aim to resolve privacy concerns fairly and respectfully.

If you are not satisfied with our response, you may be able to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

Office of the Australian Information Commissioner — Privacy complaints

The OAIC generally expects people to first give the organisation concerned an opportunity to address the complaint before lodging a privacy complaint with the OAIC.

27. Third-party websites

Our website may contain links to websites operated by government agencies, healthcare organisations or other third parties.

SA Community Support does not control those websites and is not responsible for their privacy practices.

We encourage you to review the privacy information provided by a third-party website before providing personal information to it.

28. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• our services
• our technology
• our information-handling practices
• applicable legislation
• regulatory requirements
• our relationships with service providers.

The current version will be published on our website and will show the date it was last updated.

We encourage you to review this Privacy Policy periodically.

29. Contact SA Community Support about privacy

If you have a question about this Privacy Policy, would like to request access to or correction of your information, or wish to make a privacy complaint, please contact: