Privacy

Definition

RSL LifeCare Limited (ACN 000 048 957) (RSL LifeCare, we) respects the privacy of individuals and is committed to protecting personal information. RSL LifeCare is required to comply with the obligations of the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) (the Act). This privacy policy sets out when and how RSL LifeCare will collect, hold, use and disclose your personal information, as well as how you can contact RSL LifeCare in relation to your personal information or in order to make a complaint about a breach of privacy. RSL LifeCare provides Residential Care, retirement villages, in home care and veteran services, in this policy we will refer collectively to these as services.

Who does this policy apply to?

This privacy policy applies to anyone who provides personal information to RSL LifeCare including residents, clients, visitors, next of kin, guardians, health professionals, employees, employment applicants and volunteers. This privacy policy also applies to anyone who has access to personal information held by RSL LifeCare such as contractors, suppliers and employees in order to establish the expectations of the management of personal information held by RSL LifeCare.

What personal information is collected?

1. RSL LifeCare collects a variety of personal information to enable it to provide its services and operate its business. The type of information we collect depends on how you interact with us. You may have made inquiries about our services, made a donation, we may provide services directly to you, you may represent a person who receives our services, or you have applied for a job with us. Personal information we may have collected from you can include your:
   • name and date of birth;
   • contact details;
   • photograph;
   • marital status;
   • records of military service;
   • family details including personal information relating to, or about, your next of kin or your legal guardian or person appointed as power of attorney;
   • financial information including pension and DVA details;
   • education history, previous work experience, reference checks; and
   • tax file number.
2. If you are applying for employment with RSL LifeCare may also need to collect sensitive personal information from you such as your criminal record.
3. If we provide healthcare services to you, RSL LifeCare will need to collect health information from you in order to ensure you receive the appropriate services and care which we do on a regular basis to ensure such information is relevant and up-to-date. This may include your:
   • medical/dental records;
   • information about health services you’ve received in the past, are receiving in the present or will receive in the future;
   • specialist report and test results;
   • prescriptions and pharmaceutical requirements;
   • genetic information;
   • wishes about future health services including potential organ donation.
4. In this policy, when we refer to information, we mean personal information, sensitive personal information and health information as required by the context.

How personal information is collected and held

1. We collect personal information about you directly from you or your legal guardian– this can be in person, over the telephone, via a web portal, from emails, or from documents you provide to us. We will only collect personal information that is reasonably necessary for us to provide our services to you and conduct our business.
2. Sometimes it may be necessary to collect your information from others, including your family or carers, your representatives, your allied health or medical practitioners, other Residential Care or retirement village providers, government departments such as Centrelink, Medicare, DVA or your accountant. In relation to employment applications we may collect information about you from recruitment agencies or referees. In such cases RSL LifeCare will only collect the personal information required to provide the services or assess your employment application.
3. If you provide us with personal information about another person, you represent, and we collect it on the basis, that you have the individual’s consent for us to collect and handle their personal information accordance with this policy.

Use and disclosure of personal information

1. It is necessary to use personal information in order to appropriately manage our business and provide
   the services. Examples of uses of personal information include:
   • assessing your eligibility to receive RSL LifeCare’s services;
   • determining amounts payable by you for RSL LifeCare’s services;
   • communicating with you regarding the services being provided, including regarding your
     satisfaction with the services and options for new services;
   • identification of individuals in order to maintain security at our facilities;
   • for fundraising and communications purposes; and
   • tailoring RSL LifeCare’s services to your needs.
2. RSL LifeCare may also use and disclose your personal information to third parties in the following
   circumstances:
   • by providing your contact details or other information to a Resident’s Committee to facilitate
     communication, where you are a resident of a retirement village;
   • discussing the services being provided to you with your family, representative or guardian;
   • to provide or facilitate the provision of medical care or other services to you;
   • to effectively communicate with third parties, such as health practitioners involved in your care;
   • as required to appropriately deal with government agencies such as Centrelink, the Department
     of Health and the Residential Care Quality and Safety Commission;
   • to assess your suitability for employment, or volunteer work, with RSL LifeCare;
   • to manage its business operations, such as disclosures required to government bodies, our
     insurers, clinical, legal and financial advisors;
   • where you have given your consent for us to use or disclose your information; and
   • where use or disclosure is required or authorised by law.
3. Further to the uses above RSL LifeCare may use or disclose personal information in relation to applying for appropriate government subsidies available to it under the Residential Care Act 1997. These subsidies, and the disclosures made to obtain them, are necessary to enable RSL LifeCare to continue to provide a high level of service to its clients in accordance with its not-for-profit purpose. Wherever reasonable and practicable RSL LifeCare will either limit the personal information disclosed to that which is absolutely necessary or will undertake to de-identify the information prior to its disclosure.
4. RSL LifeCare will only disclose personal information which is reasonably and practicably necessary to fulfil the purpose of the disclosure.

Direct Marketing

1. RSL LifeCare does not sell, trade or transfer personal information to third parties for the purposes of direct marketing.
2. RSL LifeCare may from time to time use personal information, including sensitive information, to notify you of changes to our services provided to you, or to bring to your attention new or additional services which may be beneficial. All such communications will include an option for you to opt out or “unsubscribe” from receiving any future direct marketing from RSL LifeCare.

Security of personal information

1. RSL LifeCare takes the security of your personal information seriously and is committed to protecting it from unauthorized access and use. RSL LifeCare has put in place appropriate physical, electronic and managerial policies and procedures to secure personal information. These policies and procedures include, but are not limited to:
   • storing any electronic information on password protected and secure servers;
   • ensuring any physical copies of personal information are kept in a secure area and archived according to RSL LifeCare’s document retention, destruction and archiving policy;
   • ensuring that all subcontractors are obliged to comply with the Act and where possible to this policy; and
   • ensuring that any access to personal information by RSL LifeCare employees, contractors and advisors is limited to those employees with a need to know that information for the provision of services.
2. Although RSL LifeCare endeavours to take steps to provide a secure environment to hold your personal information, there is no guarantee that the electronic information about you is totally secure due to the nature of the internet. However, once we detect any unauthorised access or any kind of potential abuse, we will notify you and at the same time take the appropriate remedial steps as early as practicably possible.
3. RSL LifeCare uses third party systems to process some of the data we collect, including some providers that are based outside of Australia such as Europe and the United States. In all instances we ensure the contractor has appropriate controls in place to comply with the standards imposed by the Act and our Privacy Policy.
4. Personal information may be retained for such periods as required by relevant laws. If RSL LifeCare no longer requires personal information for any purpose, we will take steps to permanently de-identify or securely destroy the information in line with organisational procedures unless RSL LifeCare is required by law or court or tribunal order to retain such information.

Access, accuracy and correction of personal information

1. RSL LifeCare will take reasonable steps to ensure that all personal information held is accurate, complete and up-to-date, accordingly RSL LifeCare may from time to time contact you directly for the purposes of verifying your information.
2. You have a right to request access to your personal information and request changes. Correction requests should be made in writing to RSL LifeCare’s Privacy Officer (details below). We will respond to your request to correct your personal information we hold within 10 business days after the request is made.
3. When requesting access or correction of personal information RSL LifeCare will require you to verify your identity.
4. While RSL LifeCare will generally comply with your request for access to personal information, RSL LifeCare does have the right under the Act to refuse access in certain circumstances. If this is the case we will inform you and explain the reasons why.

Anonymity and pseudonymity

If you do not provide us with the personal information we require, it may affect our ability to provide you with the services you are seeking. RSL LifeCare will however be able to discuss its services in a general nature, including costs and charges which it might ordinarily charge for those services, prior to obtaining your identity.

Changes to our Privacy Policy

We may amend, modify or replace this privacy policy at any time. Updates will take effect from the date the amended, modified or replacement privacy policy is published on our website.

Contact Us

1. If you wish to contact us to make a complaint about RSL LifeCare’s collection, use or disclosure of any personal information, or about any potential breach of the policy, you have a right to contact the RSL LifeCare Privacy Officer. The Privacy Officer may request additional information to assist with the proper investigation of the complaint and take such reparatory action as necessary.
2. Once a complaint is received the RSL LifeCare Privacy Officer will investigate the circumstances of the complaint and determine whether a misuse of personal information has occurred and if so how it may be rectified and whether/what action should be taken in relation to any RSL LifeCare employee or representative involved. RSL LifeCare will endeavour to investigate and respond to your complaint within 10 Business Days.
3. Should you not be satisfied with RSL LifeCare’s handling of your complaint then you are entitled to refer the matter to the Office of the Australian Information Commissioner by submitting an online form thought the Information Commissioner’s website www.oaic.gov.au.
4. RSL LifeCare’s Privacy Officer can be contacted using the details below.
   Phone: 02 9919 3742
   Email: [email protected]
   Mail addressed to:
   Privacy Officer
   RSL LifeCare
   Level 5, 120 Pacific Hwy
   St Leonards NSW 2065

Organisations RSL LifeCare Veteran Services may share information with/act on a RSL LifeCare Veteran Services client’s behalf:

• Department of Veteran Affairs
• Centrelink
• Department of Defence
• Australian Defence Force (ADF)
• Australian Taxation Office (ATO)
• Medicare Australia
• NSW Department of Communities and Justice (DCJ)
• Veterans Review Board
• Child Support Agency
• National Centre for Veterans’ Healthcare (NCVH)
• Community Housing Provider
• ComSuper or other superannuation provider
• Doctors, hospitals, health care providers including psychiatrists, psychologists
• Family members or friends
• Support workers
• Financial Rights Legal Centre
• Veteran Support Team – The Salvation Army Australia Territory
• Ex-Service Organisations (ESO) and community service organisations including but not limited to:
  • Open Arms
  • Salvation Army
  • Legacy
  • Bravery Trust
  • ADF Assistance Trust
  • Local RSL Sub-Branch
  • RSL NSW
  • Defence Member Family Service
  • Australian War Widows