Privacy and Policy

1.3 Privacy and Dignity

Privacy and Dignity Policy and Procedure


1.0 Purpose

Territory Therapy Solutions provides our participants with access to services and supports that respect and protect their dignity and right to privacy.


2.0 Scope

This policy applies to all participants and staff of Territory Therapy Solutions and other service agency representatives.


3.0 Policy

Territory Therapy Solutions is committed to protecting and upholding all stakeholders’ rights to privacy and dignity, including participants, staff, management and representatives of other service agencies.

Territory Therapy Solutions is committed to protecting and upholding the participants’ rights to privacy and dignity as we collect, store and handle information about them, their needs and the services provided to them.

Territory Therapy Solutions requires staff and management to be considered and consistent when writing documents regarding a participant and when deciding who has access to this information.

Territory Therapy Solutions is subject to NDIS Quality and Safeguards Commission rules and regulations. Territory Therapy Solutions will follow the guidelines of the Australian Privacy Principles in its information management practices.

Territory Therapy Solutions will ensure that each participant understands, and agrees to, the type of personal information collected and the reasons for collection. If the material is to be recorded in an audio or visual format, the participant must agree to their involvement, in writing, before any material can be collected. The participant must also be informed at the time material is being recorded in an audio or visual format.

Territory Therapy Solutions will advise each participant of our Privacy Policy using the language, mode of communication and terms that the participant is most likely to understand (Easy Read documents are made available to all participants).

Territory Therapy Solutions will ensure that:

  • it meets its legal and ethical obligations as an employer and service provider, concerning protecting the privacy of participants and organisational personnel
  • participants are provided with information about their rights regarding privacy and confidentiality
  • participants and organisational personnel are provided with privacy and confidentiality is assured when they are being interviewed or discussing matters of a personal or sensitive nature
  • all staff, management and volunteers understand the requirements to meet their obligations
  • participants are informed of Territory Therapy Solutions’s confidentiality policies using the language, mode of communications and terms they are most likely to understand
  • Territory Therapy Solutions will attempt to locate interpreters and will use easy access materials.This policy conforms to the Federal Privacy Act (1988) and the Australian Privacy Principles, which govern the collection, use and storage of personal information.This policy will apply to all records, whether hard copy or electronic, containing personal information about individuals and to interviews or discussions of a sensitive personal nature.


4.0 Procedure


4.1 Dealing with personal information

In dealing with personal information, Territory Therapy Solutions staff will:

  • ensure privacy for the participants, staff, or management when they are being interviewed or discussing matters of a personal or sensitive nature
  • collect and store personal information that is only necessary for the functioning of the organisation and its activities
  • use fair and lawful ways to collect personal information
  • collect personal information only with consent from the individual
  • ensure that people know of the type of personal information collected, the purpose ofkeeping the information, the method used when information is collected, used ordisclosed, who will have access to information
  • ensure that personal information collected or disclosed is accurate, complete, andup-to-date and provide access to the individual to review information or correct wronginformation about themselves


  • take reasonable steps to protect all personal information from misuse, loss andunauthorised access, modification or disclosure
  • destroy or permanently de-identify personal information no longer needed or afterlegal requirements for retaining documents that have expired
  • ensure that participants understand and agree with the type of personal informationbeing collected and the reason/s for collection
  • ensure participants are advised of any recordings in either audio or visual format, andthe participant’s involvement in any recording format has been agreed to, in writing, before collection of material takes place.


4.2 Participant records

  • Participant records will be kept confidential and only handled by staff directly engaged in the delivery of service to the participant. Information about a participant may only be made available to other parties with the consent of the participant, or their advocate, guardian or legal representative. A written agreement providing permission to keep a recording must be stored in the participant’s file.

All hard copy files of participant records will be kept securely in a locked filing cabinet located in the office of Territory Therapy Solutions.


4.3 Responsibilities for managing privacy

All staff members are responsible for the management of personal information to which they have access. The Directors and Management Team is responsible for the content appearing in Territory Therapy Solution’s publications, communications, and on our website, and must ensure:

  • appropriate consent is sought and obtained for the inclusion of any personal information about any individual, including Territory Therapy Solutions personnel (see Consent Policy and Procedure).
  • information provided by other agencies or external individuals conforms to our privacy principles.
  • our website contains a Privacy Statement that clearly outlines the conditions regarding any collection of personal information from the public captured via their visit to the website.The Director and Management Team are responsible for safeguarding personal information relating to Territory Therapy Solutions’s staff, management and contractors. The Director and Management Team will be responsible for:
    • ensuring that all staff members are familiar with the Privacy Policy and administrative procedures for handling personal information
    • providing participants and other relevant individuals with information about their rights regarding privacy and dignity
    • handling any queries or complaints about a privacy issue.4.4 Privacy information for participantsDuring the first assessment, participants are notified of the information being collected about them, how their privacy will be protected, and their rights concerning this data. Information sharing is part of our legislative requirements. Participants must provide consent to any information sharing between our organisation and government bodies. The participant is informed they can opt-out of any NDIS information sharing during audits.


4.5 Privacy for interviews and personal discussions

To ensure privacy for participants or staff when discussing sensitive or personal matters, Territory Therapy Solutions will only collect personal information which is necessary for the provision of supports and services and which:

  • is given voluntarily
  • will be stored securely on the Territory Therapy Solutions information software..When in possession, or control, of a record containing personal information, Territory Therapy Solutions will ensure that the record shall be protected against loss, unauthorised access, modification or disclosure, by such steps as is reasonable in the circumstances. If a record must be provided to a person in connection with the provision of a service to Territory Therapy Solutions, everything reasonable will be done to prevent unauthorised use or disclosure of that record.Territory Therapy Solutions will not disclose any personal information to a third party without an individual’s consent, unless that disclosure is required or authorised by, or under, law.