PURPOSE

To ensure Roar Supports Pty Ltd, employees and contractors (team members) of Roar Supports Pty Ltd, and participants, their family members and/or nominees are aware of how we collect, use, store, protect and disclose personal information.

SCOPE

This Code of Conduct applies to all Roar Supports Pty Ltd team members.

POLICY STATEMENT

This document is aligned with the Privacy Act 1988 and other relevant laws. This document will:

- Describe the types of personal information we collect, store, use and disclose.

- Outline our procedures for handling personal information.

- Explain what personal information we collect, why it is held by us, how it is used and how it is protected.

- Outline when and how we may disclose personal information.

- Provide information about how you can access, and correct if necessary, your personal information.

- Explain how you can lodge a complaint if you believe your personal information has been wrongly collected or inappropriately handled.

RESPONSIBILITIES

Roar Supports Pty Ltd must:

- Ensure team members have access to adequate training and upskilling in order to understand the principals and procedures outlined in this policy and take the necessary action when these are not upheld.

- Ensure appropriate systems and processes are in place to protect the personal information collected and stored by Roar Supports Pty Ltd.

- Take appropriate steps to address any complaints or concerns about Roar Supports Pty Ltd’s compliance with this policy.

All team members must:

- Be aware of, have access to and comply with the Privacy and Information Management Policy.

- Report any actual or suspected breach of the policy to the Company Director (Sarai Yates) as soon as is practicable.

- Ensure they outline this policy in an appropriate way to participants, their family and/or nominee prior to requesting personal information.

- Ensure participants, their family and/or nominee are aware of their rights under this policy Policy.

POLICY APPLICATION

Definitions

‘Personal information’ means information (or an opinion) we hold (whether written or not) from which a person’s identity is either clear or can be reasonably determined.

‘Sensitive information’ is a particular type of personal information – such as health, race, sexual orientation or religious information.

Collection of personal information

Personal information may be collected by a team member of Roar Supports Pty Ltd or by a contractor acting on our behalf. It may be collected directly from the participant, their nominee or from other people authorised by the participant, which may include service providers, medical professionals, family, friends etc.

Roar Supports Pty Ltd may also obtain information collected from the NDIS, other government agencies, third parties or from publicly available sources. This will only occur where the participant or their nominee has given consent or where Roar Supports Pty Ltd is required or authorised to do so by law.

Roar Supports Pty Ltd will only collect personal information for the purposes directly related to the delivery of our services to NDIS participants.

By signing the ‘Consent Form’ and/or ‘Service Agreement’ the participant or their nominee is consenting to the collection, storing, use and disclosure of any personal information provided to Roar Supports Pty Ltd required to deliver the contracted services.

Types and purposes of information collected by Roar Supports Pty Ltd

We collect and store a broad range of personal information relating to:

- Employment and management of personnel matters for our team members and contractors

- Performance of our legislative and administrative functions

- Participants accessing our services

- Management of audits (both internal and external)

- Correspondence from participants, their family members, nominees, service providers and other authorised sources

- Complaints (including privacy complaints) made and feedback provided to us

- Requests made to us to amend or update personal information

- Policy development

- Quality assurance and service improvement processes

The information collected may include, but is not limited to:

- The name, address and contact details, eg phone and email address, of participants, their family members and/or nominees

- Information about the participant’s personal circumstances e.g. marital status, age, gender, occupation, accommodation and relevant information about a partner or children

- Information about the participant’s identity e.g. date of birth, country of birth, driver’s licence

- Information about cultural, gender or spiritual requirements of the participant, their family members and/or nominee

- NDIS participant number

- The nature of their eligible impairment/disability

- Information about assistance provided to the participant under their NDIS plan, including stated supports and funding amounts

- Information about payments and subsidies received by the participant eg Disability Support Pension, Taxi User’s Subsidy Scheme

Roar Supports Pty Ltd will use and disclose personal information for the purposes for which it is collected. Information about the purpose of the collection of information will be given at the time it is collected. Roar Supports Pty Ltd will only use personal information for secondary purposes where we are able to do so in accordance with the Privacy Act. This may include situations where the secondary purpose has been consented to by the participant, their family and/or nominee, where the secondary purpose is directly related to the primary purpose and it would be reasonably expected that we would use or disclose the information, where we are required or authorised by law, or where the information needs to be used or disclosed to prevent a serious threat to safety.

How Roar Supports Pty Ltd collects personal information

Roar Supports Pty Ltd collects personal information in many ways including over the telephone (including text messages), via email, from our website, from correspondence posted to us, during face to face meetings (whether formal or informal), from the NDIS portal and from surveys administered by us.

Information collected by contractors Under the Privacy Act, Roar Supports Pty Ltd is required to take contractual measures to ensure that contracted service providers (including subcontractors) comply with the same privacy requirements applicable to all team members.

When Roar Supports Pty Ltd enters into an agreement with a contracted service provider, we will impose contractual obligations on the contractor to ensure they comply with relevant privacy obligations when collecting, using, disclosing and holding personal information relating to NDIS participants.

Storage and Security

Roar Supports Pty Ltd takes all reasonable steps to protect the personal information held in our records against loss, unauthorised access, use, modification or misuse.

Roar Supports Pty Ltd stores personal information in both paper-based and electronic, including records that may be stored in the cloud.

The following outlines the procedures related to storage and security of personal information:

- Participant information collected is kept in an individual participant record.

- A participant record may include personal information, notes, investigations, emails, reports, correspondence, photographs, video footage.

- A firewall is used within Roar Supports Pty Ltd’s computer system, as a means of protecting information stored on the computer.

- Other security related procedures, such as user access passwords and multi-factorial authentication to assist with the protection of information.

- Paper records are kept in locked cabinets and access to keys is restricted Participant information is stored for seven years post the date of last discharge.

- In the case of participants aged under 18 years, information is kept until their 25th birthday and 7 years post discharge.

- Participant related information or any papers identifying a participant are destroyed by a medical grade shredder and deleted from the computer and all databases.

- User access to all computers and mobile devices holding participant information is managed by passwords and automatic inactive logouts.

- Access to personal information held by Roar Supports Pty Ltd is restricted to authorised team members or contractors on a need to know basis.

Information Quality

Roar Supports Pty Ltd takes all reasonable steps to ensure that personal information collected is accurate, up to date, complete, relevant and not misleading.

Roar Supports Pty Ltd responds to requests to correct personal information as soon as it is reasonable and appropriate to do so.

Internal audits may be conducted from time to time to determine the accuracy and integrity of information which will ensure any quality issues are identified and resolved in a timely manner.

Links to External Websites and Social Networking Services

Roar Supports Pty Ltd’s website may contain links to other websites or social networking services.

Participant’s, their family and/or nominee, as well as team members, will be informed that Roar Supports Pty Ltd is not responsible for the content and privacy practices of these websites and services.

It is recommended that the full terms and conditions of any external websites or social networking services are read and understood before proceeding to access them.

Electronic Communication

There are risks associated with sharing or providing personal information in any form, but particularly over the internet, including email. Roar Supports Pty Ltd will inform participants, their family and/or nominees of these risks at the initial planning meeting. To mitigate these risks, participants, their family and/or nominee will be advised they can choose to communicate face to face, by post, phone or text to minimise the risks.

Gaining and Using Consent Provided

Roar Supports Pty Ltd will follow these procedures when gaining and using consent to liaise with third parties.

Prospective participants contacting Roar Supports Pty Ltd with an enquiry are not required to disclose any personal information at the time, however, once a decision has been made to utilise Roar Supports Pty Ltd’s services, personal and sensitive information will need to be collected to ensure the best outcomes are possible.

Roar Supports Pty Ltd provides all participants, their family and/or nominee with verbal and written information regarding our ‘Privacy and Information Management Policy’ at the initial planning meeting, prior to the Service Agreement being signed.

Written information is provided in the ‘Consent Form’ and 'Service Agreement'.

The opportunity to ask questions in relation to privacy is provided.

During the initial planning meeting, the participant, their family and/or nominee will be asked to provide consent for direct liaison with specific third parties. Details of these organisations and individuals will be documented on the ‘Consent Form.’ A completed and signed copy of this form will be provided. Additional consent can be sort at any time and will be documented in the participant file.

Consent to liaise can be withdrawn by the participant, their family and/or nominee at any time and this will be documented in the participant file.

Unauthorised Access, Use or Disclosure of Personal Information

Roar Supports Pty Ltd takes seriously any unauthorised access, use or disclosure of personal information.

If a team member becomes aware of a breach, the company director (Sarai Yates) must be notified immediately.

The individuals affected will be contacted immediately, as soon as is practicable, and inform them of the steps taken to resolve the breach and limit the potential for any future breaches.

Access to and Correction of Personal Information

Under the Privacy Act, all participants, their family and/or nominees have the right to access the personal information about them we hold on file.

Information regarding their rights and access to their personal information is provided in the ‘Consent Form’ at the initial planning meeting.

Managing a Complaint About a Breach of Privacy

If a participant, their family and/or nominee has a complaint regarding the way in which their personal information is being handled by Roar Supports Pty Ltd, in the first instance they are to contact the company director (Sarai Yates). The complaint will be dealt with as per Roar Supports Pty Ltd’s ‘Feedback and Complaints Policy’.

If the parties are unable to reach a satisfactory solution through negotiation, the person may request an independent mediator, such as the Office of the Australian Privacy Commissioner or the NDIS Quality and Safeguards Commission to investigate the complaint.

Roar Supports Pty Ltd will provide every cooperation with this process.

Training and Upskilling of Team Members

All team members will undergo training related to privacy and confidentiality requirements at the time of induction and then annually as per the Annual Training Plan.

Roar Supports Pty Ltd Complaints Policy

COMPLAINTS POLICY & PROCEDURE

Roar Supports Pty Ltd is committed to ensuring that any person(s) or organisation on using the services provided by Roar Supports Pty Ltd, or whom may be affected by its operations has the right to lodge a complaint and to have their concerns addressed in ways that ensure access and equity, fairness, accountability, and transparency.

The organisation on will provide a complaints management procedure that:

- Is simple and easy to follow.

- Is available to all clients and stakeholders via the Roar Supports Pty Ltd website.

- Ensures complaints are fairly assessed and responded to in an appropriate timeframe.

- Is procedurally fair and follows principles of natural justice.

- Complies with legislative requirements.

OUR COMMITMENT

If a complaint is made to Roar Supports Pty Ltd, it is expected that we will:

- Treat the complainant with respect.

- Provide transparency around what to expect whilst complaint is being handled.

- Carry out the complaint handling process in a fair and open way.

- Provide reasoning for any decisions made.

- Protect the privacy of the complainant.

- Not vilify or treat the complainant any differently after making the complaint.

WHAT CAN I MAKE A COMPLAINT ABOUT?

You can make a complaint to Roar Supports Pty Ltd about the way a worker behaves, delivers services or neglects to deliver services. You are also welcome to provide feedback to assist us in improving our services.

MAKING A COMPLAINT

A person wishing to make a complaint may do so in writing or verbally (if an interpreter is required, please advise so we are able to assist you to access one). A complaint can be made to:

- The staff member they were dealing with at the time, unless the complaint is regarding this person, or

- Sarai Yates, the owner of Roar Supports Pty Ltd via this form.

If you do not feel comfortable making a complaint directly to us you can get help from a family member or friend, another service or you can contact the NDIS Quality and Safeguards Commission via:

- Phoning 1800 035 544 (free call from landlines) or TTY 133 677 (interpreters can be arranged)

- National Relay Service and ask for 1800 035 544

- Or the online form at www.ndiscommission.gov.au/about/complaints

Written complaints may be sent to Roar Supports Pty Ltd via email to [email protected] or via the feedback form on the Roar Supports Pty Ltd website (www.roarsupports.com.au).

Verbal complaints can be made in person or over the phone (please use the mobile number on our website's Contact page).

HOW WILL THE COMPLAINT BE MANAGED?

1. Registration of Complaint

• The complaint will be entered in to the Roar Supports Pty Ltd Complaint Register. The information recorded in this register will include the date of complaint received, persons making complaint, persons involved, details of the complaint, the action taken, the date of resolution and reasoning for this outcome, the method of complainant being notified of outcome, and their response thereafter. Copies of all correspondence and other materials received by Roar Supports Pty Ltd in connection with any complaints received will be kept for 7 years. The complaints register and any documentation will be confidential and kept behind restricted access by Sarai Yates.

• The person managing the complaint will let the complainant know that their complaint has been received and provide information about the process and expected time frame.

2. Investigation of Complaint

• The complaint will be examined within 5 business days of the complaint being received.

• The complainant will be informed in writing (via email or letter) within 10 business days of the complaint being received advising what is being done to investigate and resolve the complaint, and the expected time frame for resolution.

• As far as reasonably possible, complaints or appeals will be investigated and resolved within 20 business days of being received.

If the time frame cannot be met, the complainant will be informed of the reasons why and of the alternate time frame for resolution.

3. Resolving the Complaint

• Ensuring a decision is made or that complaint is referred to the appropriate people / parties for a decision within 20 business days of the complaint being received.

• Informing the complainant of the outcome, reasons for any decisions and the options available should the complainant wish to dispute the outcome or require further action.

4. What if I am unhappy with the resolution?

• If the complainant is not satisfied with the outcome of their complaint, a further complaint may be lodged with the NDIS Quality & Safeguards Commission. The Commission’s office will then determine if it has the power to investigate your complaint.

ACCOUNTABILITY AND LEARNING

Analysis and Evaluation of Complaints

Roar Supports Pty Ltd will ensure that complaints are recorded in a systematic way, to ensure information is easily retrievable for reporting and analysis.

Reviews will be completed upon the number of complaints received, the outcome of complaints (including those resolved at the frontline), any issues arising from such complaints, and any systematic issues identified.

Regular analysis of these reviews will be undertaken to monitor trends, measure the quality of services provided and make improvements.

MONITORING OF THE COMPLAINT MANAGEMENT SYSTEM

Roar Supports Pty Ltd will continually monitor our complaint management system to:

- Ensure effectiveness in responding and resolving complaints.

- Identify and correct deficiencies in the operation of the system.

Monitoring may include the use of audits and complaint satisfaction surveys.

CONTINUOUS IMPROVEMENT

Roar Supports Pty Ltd is committed to improving the effectiveness and efficiency of our complaint management system. To this end, we will:

- Support the making and appropriate resolution of complaints.

- Implement best practices in complaint handling.

- Regularly review the complaints management system and complaints data.

- Implement appropriate system changes that may be required as a result of our analysis of complaints data and continual monitoring of the system.