1. DOCUMENT INFORMATION

1.1 OVERVIEW

The purpose of this document is to outline how Working Life manages clients’ personal information, in accordance with Australian Privacy Principles.

1.2 SCOPE

Compliance with this standard is mandatory for the following:

- All staff at Working Life.

- All contractors and third parties to Working Life.

- Any other entities who store, processes and transmit information collected or owned by Working Life.

1.3 REFERENCES

Commonwealth Privacy Act 1988
Australian Psychological Society(APS) – Code of Ethics (2007)
Australian Health Practitioner Regulation Agency (AHPRA) Code of Conduct

1.4 DEFINITIONS

Personal information is defined as information which identifies or could reasonably be used to identify you or another person.

1.5 SUPPORTING POLICIES, DOCUMENTS, AND INFORMATION

This policy statement document forms part of Working Life’s Integrated Management System (IMS) and should not be read in isolation. Other related policies and documents include:

- Information Security Policy and Procedures

- Confidentiality agreement

- Quality Management Procedures

1.6 VALIDITY AND DOCUMENT MANAGEMENT

The owner of this document is the Managing Director, who must check and, if necessary, update the document at least annually or when major changes are implemented that affect privacy principles.

Approval

The signature below certifies that this policy has been reviewed and accepted.

Amendment Record

A record of contextual additions or omissions is below:

2. POLICY STATEMENT

Working Life are committed to ensuring clients’ personal information is appropriately managed in accordance with law and professional ethical guidelines. Working Life are committed to protecting clients’ personal information from misuse, interference or loss, and from unauthorised modification, access or disclosure.

2.1 WHAT PERSONAL INFORMATION WE COLLECT AND WHY

ITo provide optimal injury management, psychological and people/organisational development services, Working Life will collect the following information from clients or referrers:

- Your name, address, and date of birth.

- Your contact details.

- Current and past medical / psychological information.

- Your educational and occupational history.

- Legal history (in the case of medico-legal services).

In addition, Working Life will in all likelihood, collect the following personal information:

- Psychosocial history

- Responses and results from psychological tests and questionnaires.

- Information pertaining to your response to treatment.

All of the above information is used to inform accurate management, assessment, diagnosis, and treatment plans for Working Life clients. Not having this information may increase the risk that our services are sub optimally delivered.

2.2 HOW WE COLLECT PERSONAL INFORMATION

We will collect information from you where it is reasonable and practical to do so. We may also need to collect information from others who have been involved in your management, like doctors, employers, solicitors, allied health practitioners and insurers. We will endeavour to keep clients reliably informed of the information collected and the source of that information and, where appropriate, will seek and obtain written informed consent to contact and retrieve that information.

2.3 HOW WE STORE PERSONAL INFORMATION

All Working Life consultants will take reasonable steps to protect the personal information of clients from misuse, interference or loss and from unauthorised modification, access or disclosure. This is achieved through our implementation of this policy, Information Security Policy and Procedures, Confidentiality Agreements and our Quality Management System and Procedures.

Paper documents containing personal information listed above will be stored under lock. Electronic information containing personal information listed above will be stored and backed up securely, in accordance with:

Workers Compensation and Injury Management Act 2023.
Australian health Practitioners Regulation Agency (AHPRA) – Code of Conduct - 2022
Australian Psychological Society’s (APS) Code of Ethics (2007).
Exercise & Sports Science Australia (ESSA) – Code of Professional Conduct and Ethical practice 2024
Australian Association of Social Workers (AASW) – Code of Ethics 2020

Working Life maintain and follow a Data Breach Plan as part of their information security management practices. The Data Breach Plan is built in line with the Office of the Australian Information Commissioner’s national requirements (https://www.oaic.gov.au/privacy/notifiable-data-breaches/).

2.4 HOW WE USE AND DISCLOSE PERSONAL INFORMATION

Working Life will use and disclose personal information for the primary purpose of providing optimal injury management, psychological and other people/organisational services. This may require some level of reporting that is prepared by the Working Life consultant and sent to key parties (referrer or referring agent, plus others involved in the client’s care) where applicable. Where information is required to be released, Working Life will obtain your written consent and authority to do so before proceeding. This consent can be revoked at any time. All information obtained will be relevant to supporting individuals within the relevant treating frameworks.

It is noted that in some circumstances Working Life Consultants are required by law to disclose personal information without the consent of the client. This includes:

Abused children and vulnerable adults – if we are made aware that a child, or a vulnerable adult is being or has been abused, we will report this information to appropriate authorities. In WA, Psychologists are mandatory reporters. We will report all reasonable beliefs of child sexual abuse to appropriate authorities.
Duty to warn and protect – if a client discloses stern intentions or a plan to harm another person, we will attempt to warn the intended victim and report this to appropriate authorities. Also, if a client discloses or implies a serious plan for suicide, we are required to notify the appropriate authorities and make reasonable attempts to safeguard life.
Minor/Guardianship – parents or legal guardians of non-emancipated minors have the right to access client records.
Subpoena – if you are involved with the Legal/Court system, your records could be subpoenaed. If this is requested, we are compelled to release information as required by the Court System.

Specifically, Psychologists may disclose personal information if a “permitted general situation” exists such as to “lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety”. This threat does not need to be imminent.

2.5 PROFESSIONAL DUTY OF CARE

All the Directors of Working Life are guided by the relevant Code of Ethics relating to the:

- Appropriate collection of private information related to the provision of services

- The Release of Information to Clients and the Collection of client information from associated parties.

- Appropriate record-keeping.

All Working Life consultants maintain high standard of professional backing. Consultants hold and maintain professional registrations with appropriate accrediting bodies throughout Australia. This is mandatory to prevent the public from being placed at risk of harm. Registered health practitioners are required to maintain professional behaviour and conduct as defined in the relevant Code of Conduct.

2.6 HOW TO ACCESS YOUR PERSONAL INFORMATION

Clients have a right to access your personal information held by Working Life. Such requests need to be put in writing for security and recording purposes and to assist in finding the information for you.

Working Life may refuse the request for such information, or limit the information so provided, where it is legally entitled to do so. We will endeavour to provide reasons for refusal. For example, release of information may be denied or limited where such release may have an unreasonable impact on the privacy of others or is considered frivolous or vexatious.

2.7 WEBSITE

2.7.1 WHEN YOU VISIT OUR WEBSITE

When you visit our website (www.working-life.net), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

2.7.2 COOKIES

We may from time-to-time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may at times use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

2.7.3 THIRD PARTY SITES

Our site may at times have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

2.8 RESEARCH AND PERSONAL INFORMATION

On occasion, Working Life will engage in research activities to improve the quality service provision. In such cases, personal information of clients will be used. In this context, the information will not be released to third parties but will be retained within Working Life for the sole purpose of quality evaluation and improvement of services.

In addition, Working Life may engage in academic or scientific research. In such cases clients will be asked to sign a consent form allowing the use of their personal information for the purposes of a specific research project. Such research will be required to have obtained the prior approval of a Human Research Ethics Committee within the Department of Health or the relevant University.

2.9 HOW TO MAKE A COMPLAINT ABOUT PRIVACY

Clients have a right to make a complaint about the handling of their personal information. Complaints can be made to Working Life via email (mail@working-life.net). We will endeavour to respond appropriately to reasonable complaints (i.e., not of a frivolous or vexation nature) within 30 days of the receipt of the email.

Other agencies to which clients may bring complaints are as follows:

- The Office of the Australian Information Commissioner (www.oaic.gov.au)

- Australian Health Practitioner Regulation Agency (www.ahpra.gov.au)

- Australian Association of Social Workers (www.aasw.asn.au)

- Exercise and Sports Science Australia (www.essa.org.au)

- Australian Rehabilitation Providers Association (www.arpa.org.au)

3. COMPLIANCE RESPONSIBILITIES

Management/Supervisors are responsible and accountable for:

- ensuring the business complies with all legislation relating to privacy;

- developing, implementing and maintaining the IMS to manage privacy risks;

- providing sufficient resources to ensure management of privacy is a central part of the organisation;

- ensuring this policy, IMS and associated policies and procedures is effectively communicated and trained to all workers; and

- ensuring any complaints are investigated and lessons are learnt within the organisation.

Employees / Contractors are responsible for:

- understanding and complying with the responsibilities detailed in this policy, IMS, and other associated policies and procedures;

- conducting their duties in a manner that maintains confidentiality and privacy of client’s personal information.

Download a copy of our Privacy Policy here.