WIRU Community Health & Well-Being - Privacy Policy

Our commitment to your privacy

WIRU Community Health & Well-Being Pty Ltd (WIRU) is committed to protecting the privacy, confidentiality and security of the personal and sensitive information entrusted to us.

As a registered NDIS provider delivering Specialist Navigation, we may receive information that is personal, sensitive and, at times, complex. We recognise the responsibility that comes with holding this information and take reasonable steps to ensure it is collected, used, stored and disclosed appropriately.

WIRU handles personal information in accordance with applicable Australian privacy requirements, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Information we may collect

To provide Specialist Navigation and operate our organisation, WIRU may collect personal and sensitive information including:

• name, date of birth and contact details

• NDIS participant and plan information

• health, disability and support information

• information about services, providers and support arrangements

• information provided by participants, nominees, guardians and authorised representatives

• reports and information provided by health, allied health and other professionals

• information relevant to housing, guardianship, justice, mental health or other mainstream systems where this relates to the participant's circumstances

• correspondence, case notes, assessments, referrals and service records

• billing and administrative information.

We only seek information that is reasonably necessary for providing our services, meeting our professional and regulatory responsibilities, or operating WIRU.

How we collect information

Information may be provided directly by the participant or, where appropriate, by an authorised person such as a nominee, guardian, advocate, family member, NDIA representative, health professional, service provider or other professional involved in the participant's support.

Where required, WIRU will obtain appropriate consent before requesting or sharing participant information.

How we use your information

WIRU may use participant information to:

• provide Specialist Navigation

• understand a participant's circumstances, goals and support needs

• coordinate NDIS, mainstream and community supports

• communicate and collaborate with relevant services and professionals

• make referrals with appropriate consent

• monitor and report on the implementation of NDIS supports

• prepare reports or information required by the NDIA

• support multidisciplinary planning and case conferencing

• maintain appropriate service and case records

• meet NDIS registration, quality, safeguarding and audit requirements

• meet legal and professional obligations

• manage service agreements, billing and administration.

Information is only used or disclosed for the purpose for which it was collected, a related purpose reasonably expected in the circumstances, with consent, or where otherwise authorised or required by law.

Working with other professionals and services

Specialist Navigation often requires collaboration across multiple systems.

With appropriate consent or other lawful authority, WIRU may communicate with relevant parties such as the NDIA, Plan Managers, guardians, nominees, health professionals, allied health practitioners, behaviour support practitioners, hospitals, mental health services, housing services, government agencies, justice and correctional services, advocates, legal professionals and other services involved in the participant's support.

We seek to share only information reasonably necessary for the relevant purpose.

Electronic records and Splose

WIRU uses Splose, an electronic practice management system, to manage participant records, service information, documentation and related administrative information.

Splose states that data for Australian users is stored in Australia using Amazon Web Services (AWS) infrastructure. Splose also advises that data is encrypted while in transit and at rest and that it complies with the Australian Privacy Principles.

Access to participant information within WIRU is limited to authorised personnel according to their roles and responsibilities.

Like many cloud-based technology providers, Splose uses third-party service providers in Australia and overseas for aspects of its services. Splose's Privacy Policy contains further information regarding third-party providers and international transfers.

WIRU takes reasonable steps to ensure that technology used in delivering our services is appropriate for the nature and sensitivity of the information we hold.

Information security

WIRU takes reasonable steps to protect personal and sensitive information from misuse, interference, loss, unauthorised access, modification or disclosure.

This includes organisational controls around access to participant information, secure electronic record keeping and appropriate privacy and confidentiality practices.

Splose states that its Australian user data is stored redundantly using AWS data centres and protected by encryption, with access and permission controls available within the platform.

Confidentiality

WIRU's Specialist Navigators are qualified Social Workers and are expected to maintain appropriate professional standards regarding confidentiality, privacy and ethical practice.

Confidential information will not ordinarily be shared with another person or organisation without consent or other appropriate authority, except where disclosure is authorised or required by law or is otherwise permitted under applicable privacy requirements.

Consent and authorised representatives

Some participants may have nominees, guardians or other formally appointed decision-makers.

WIRU will take reasonable steps to understand the relevant decision-making arrangements and ensure information is shared with appropriately authorised people.

Where possible and appropriate, we continue to involve the participant and recognise their preferences, rights and voice in decisions affecting them.

Accessing or correcting your information

Participants may request access to personal information WIRU holds about them and may ask for information to be corrected if they believe it is inaccurate, incomplete or out of date.

Some legal exceptions may apply to access requests.

Please contact WIRU if you would like to request access to or correction of your information.

Retention of records

WIRU retains participant and organisational records for the periods required by applicable legislation, NDIS requirements and professional obligations.

When information is no longer required to be retained, WIRU will take reasonable steps to securely destroy or de-identify it where appropriate.

Privacy breaches

If WIRU becomes aware of a privacy or information security incident, we will assess and respond to the incident in accordance with our legal and regulatory obligations.

Where notification is required, affected individuals and relevant authorities will be notified in accordance with applicable requirements.

Questions, concerns or complaints

If you have a question about how WIRU collects, uses, stores or shares your information, or you have a privacy concern, please contact us.

‍Privacy Officer
‍WIRU Community Health & Well-Being Pty Ltd
Suite 1/74 O'Connell Street
North Adelaide SA 5006
‍
‍P: 08 7093 6527
‍E: hello@wiru.org

‍We will take privacy concerns seriously and seek to respond appropriately and in a timely manner.