Privacy Policy

POLICY STATEMENT
At Sincerity Care Group (SCG), we recognise the importance of your privacy and
understand your concerns about the security of the personal information you
provide to us. We comply with the Australian Privacy Principles (APPs) as contained
in the Privacy Act 1988 (Cth), the Information Privacy Principles (IPPs) as contained
in the Information Privacy Act 2000 (Vic), and the Health Privacy Principles (HPPs)
as contained in the Health Records Act 2001 (Vic).
The APPs, IPPs and HPPs detail how personal, sensitive and health information may
be collected, used, disclosed, stored and destroyed, and how an individual may gain
access or make complaints about the information held about them.
This policy details how SCG manages personal information about you (including
sensitive information and health information); whether you are:
➢ A participant of SCG.
➢ A contractor or business partner of SCG.
➢ A staff member of SCG.
DEFINITION OF :
➢ Personal information is information or an opinion about an identified
individual, or about an individual who is reasonably identifiable.
➢ Sensitive Information- a sub-set of personal information, is information or
an opinion about an individual’s racial or ethnic origin, political opinions,
political association membership, religious beliefs or affiliations, philosophical
beliefs, professional or trade association membership, trade union
membership, sexual orientation or practices or criminal record, and includes
health information and genetic information.
➢ Health Information is information or an opinion about an individual’s health
or disability, the health services provided or to be provided to them, their
expressed wishes for the provision of future health services, personal
information collected to provide a health service, personal information
collected in connection with organ and body-part donation, and predictive
genetic information.
➢ Consent: means written and verbal consent.
✓ An individual’s personal information can generally be used or disclosed
for any purpose to which he or she has consented.
✓ Consent must be obtained before the personal information is used or
disclosed and is best obtained at the time of collection.

✓ Consent must be voluntary (not given under pressure) informed (the
consequences of providing consent have been explained) and current
(not provided earlier under different circumstances.
✓ The Privacy Act applies to children in the same way it applies to adults.
To determine if a child is competent to make their own privacy
decisions, regard should be had to the child’s maturity, understanding
of the issues, degree of autonomy and sensitivity of the information.

WHAT INFORMATION WE COLLECT AND HOLD
Clients and other parties
If you are a client or a prospective client, then the kinds of personal, sensitive and
health information we collect from you or about you depend on the services you
have engaged us to provide.
The kinds of personal, sensitive and health information that we commonly collect
and hold from you or about you include: your name, address, phone, mobile
numbers, email address, your family composition, nationality and cultural
background, religious beliefs and affiliations, date/s of birth, gender/s, occupation/s,
employment details, financial records, income details, asset listings, taxation
records, bank account details, insurance policies, medical history, disability status,
criminal record and Court records, etc, applicable welfare and agency referrals, and
the history of and your relationship with others involved in your matter. We may
also collect other personal, sensitive or health information, depending on the nature
of your matter.
Even if you are not a client of ours, or even if we have only limited contact with you,
we may still collect, hold, use and disclose personal, sensitive and health
information about you. This will commonly occur where we are engaged to act
against you or in a matter with which you are otherwise involved. In these cases,
we may collect personal, sensitive and health information from you directly, or
about you from our client, other third parties or publicly available sources. We may
do this without your consent and without notifying you of the collection of this
information.
Staff
The kinds of personal, sensitive and health information that we commonly collect
and hold from or about prospective and current staff include: name, address,
phone, and mobile numbers, email address, occupation, professional association
membership, emergency contact, next-of-kin details and photographs.
Contractors
The kinds of personal, sensitive and health information that we commonly collect
and hold from or about prospective and current contractors include: name,
address, phone, mobile numbers, email address, occupation, professional
association membership, emergency contact and next-of-kin details, medical and
health history information, and bank account and credit card details.

When you browse our website or contact us electronically, we may record:
statistical data, the date and time of your visit to the site, the pages you accessed
and documents downloaded, the previous sites you have visited and the type of
browser you are using. Note that none of the statistical information we collect
allows us to identify a visitor to our website. The information we collect from your
visit to our website is used by us to help administer and improve the website.
In our website, we do not use 'Cookies'. Cookies are small text files placed on your
hard drive by website hosts. Cookies recognise a repeat visitor to its site and
enable sites to store information on the user's computer so that the information can
be referenced later.
If you are concerned about the security of any personal information you submit by
email, please contact us using an alternative method (eg. telephone, secure post or
encrypted message).
HOW WE COLLECT AND HOLD INFORMATION
Information you provide
We will generally collect personal, sensitive and health information only directly
from you, unless it is unreasonable or impracticable for us to do so. For example,
we collect personal, sensitive and health information from you or about you from
correspondence that you submit to us, meetings and interviews with us, telephone
calls with us, the instructions you provide to us, and from submissions you make on
our website.
Information provided by other people
In some instances, we may receive personal, sensitive and health information about
you from third parties, such as associated businesses, government agencies,
welfare agencies and referrals (eg. other law firms or financial counsellors). We
may also receive personal, sensitive and health information about you from your
family members, authorised third parties and publicly available sources.

WHY WE COLLECT, HOLD, USE & DISCLOSE INFORMATION
We collect, hold, use and disclose personal, sensitive and health information from
you or about you where it is reasonably necessary for us to carry out our business
functions and activities, and to provide the support services. For example, we
collect, hold, use and disclose your personal, sensitive and health information as
necessary to act for you or for our client in a matter against you.
S
We work closely with many other businesses and agencies, such as other Support
Coordinators, Behaviour Therapist, Psychologists, Occupational Therapists, other
Support Providers, Police, and welfare agencies etc. We routinely disclose your
personal information to these third parties where it is reasonably necessary for
them to assist us to provide our services to you, or to enable them to provide
related service offerings that you have requested.

We may collect sensitive information from you or about you where there is a legal
requirement to do so, or where we are otherwise permitted by law. In all other
situations, we will specifically seek your consent.
We also collect, hold, use and disclose your personal, sensitive and health
information for purposes related to the provision of our services that you would
reasonably expect, such as file research, services planning, our own internal
administrative and accounting functions, our professional obligations, data backups,
marketing and promotions, educational briefings and other service offering updates,
conducting client satisfaction surveys and feedback requests, statistical collation,
government reporting and website traffic analysis.
Where we wish to use or disclose your personal, sensitive and health information for
other purposes, we will obtain your consent.
We may also disclose your personal information to third parties (including
government departments, enforcement bodies and professional registration and
accreditation bodies) where required or permitted by law. Commonly, we will also
disclose your personal information as required under taxation, superannuation,
personal assistance, stamp duty, local government, industrial relations and
conveyancing laws etc.
If we do not collect, hold, use or disclose your personal, sensitive and health
information, or if you do not consent to the provision of such information, then we
may not be able to answer your enquiry, complete the transaction you have entered
into, or provide the support service that you have engaged us to provide.
HOW WE HOLD AND STORE INFORMATION
Your personal, sensitive and health information is held and stored on paper, by
electronic means or both. We have physical, electronic and procedural safeguards
in place and take reasonable steps to ensure that your personal, sensitive and
health information is protected from misuse, interference and loss, and from
unauthorised access, modification and disclosure.
DESTRUCTION AND DE-IDENTIFICIATION
We will retain your personal, sensitive and health information whilst it is required
for any of our functions, or for any other lawful purpose. For example, we
necessarily retain records of client names and the names of opposing parties
indefinitely, so as to avoid conflicts of interest.
We will also retain your personal, sensitive and health information for the time
periods required by law (commonly, 7 years).
We use secure methods to destroy or to permanently de-identify your personal,
sensitive and health information when it is no longer needed.

REQUESTS FOR ACCESS AND CORRECTION
We have procedures in place for dealing with and responding to requests for access
to, and correction of, the personal, sensitive and health information held about you.

Your right to request access may arise under Privacy legislation, your retainer with
us, or the common law.
In most cases, we expect that we will be able to comply with your request.
However, if we do not agree to provide you access or to correct the information as
requested, we will give you written reasons why. To assist us to keep our records
up-to-date, please notify us of any changes to your personal, sensitive and health
information.
COMPLAINTS AND CONCERNS
We have procedures in place for dealing complaints and concerns about our Privacy
practices. We will respond to your complaint in accordance with our policies.
➢ Clients have a right to lodge a complaint if they believe their rights relating to
their privacy have been breached.
➢ SCG and staff, are responsible for ensuring all clients are aware of this right
and are fully informed on how to lodge a complaint.
➢ All complaints must be in writing (assisted by a staff member, if required),
signed by the individual and clearly set out the breach of their privacy that is
the cause of their complaint.
➢ Complaints must be immediately referred to the CEO and Founder of SCG
who will acknowledge receipt of the complaint and respond to it.
➢ It is the intention that complaints are resolved internally and before reference
by the individual to the Privacy commissioner.