PRIVACY policy

At Menarock LIFE Aged Care, we are committed to ensuring that your personal information is protected. Your privacy is important to us, so we’ve developed this Privacy Policy, which explains how we collect, use, share, disclose and protect your personal information. Please take a moment to read through this Policy in its entirety.

Unless you notify us otherwise, we will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Privacy Policy.

1. Introduction

Menarock LIFE Aged Care (Menarock) is committed to ensuring that your personal information is protected and that we are being transparent about the information we hold about you. Your privacy is valued and safeguarded in accordance with, the Privacy and Data Protection Act 2014 and the Health Records Act 2001.
This Privacy Policy applies to the personal information we collect and hold about individuals that:

(i) visit our website (https://menarocklifeagedcare.com.au/),
(ii) utilise any Menarock services,
(iii) elect to receive direct marketing and subscribed mailings from us as set out in this Privacy Policy
(iv) apply for employment with Menarock,
(v) Collection by or on behalf of a law enforcement agency, subject to the relevant legislative requirements.

Please read this Privacy Policy carefully, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so you are informed about how and why we collect, store, use and share your personal information. This Privacy Policy also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

This Privacy Policy is issued on behalf of Menarock LIFE Aged Care so when we refer to “Menarock”, “us”, “we” or “our” in this Privacy Policy, we mean the Menarock LIFE Aged Care responsible for your personal information.

Where the collection and use of personal information is not addressed by this Privacy Policy, the privacy notice made available when your personal information is collected will apply.

2. Principles of Data Protection

When using the term “personal data” or “personal information” in this Privacy Policy, we mean information (including opinions) that relates to you and from which you could be identified, either directly or in combination with other information which we may have in our possession.
To help you understand how we handle your personal information more clearly, below is a summary of the data protection principles which guide how we use your personal information. These principles provide that personal data should be:

  • Used lawfully, fairly and in a transparent way;
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • Relevant to the purposes we have told you about and limited only to those purposes;
  • Accurate and kept up to date;
  • Kept only as long as necessary for the purposes we have told you about; and
  • Kept securely.

We have put policies and procedures in place to adopt these principles in our everyday processing activities set out in this Privacy Policy. Our website may provide links to third-party websites.  Menarock is not responsible for the conduct of non-Menarock companies linked to the website and you should refer to the privacy notices of these third parties as to how they may handle your personal information.

3. What personal information do we collect

Menarock will only collect personal information, subject to the consent of each individual, that is necessary for the provision of high-quality services and care or to meet other business needs. Such personal information may include health or sensitive information. When collecting personal information Menarock will inform individuals of the purpose for collecting the information, how it will be used, and if it may be accessible to them on written request.

We may collect personal information about you when:

  • The personal data is provided by you (e.g. when you apply for a position and register with us, including additional communications via email, telephone or online);
  • The personal data is collected in the normal course of our relationship with you (e.g. in an interview, provision of services);
  • The personal data is collected from your named referees or representative;
  • The personal data has been made public by you (e.g. contacting Menarock via a social media platform);
  • The personal data is received by us from third parties, including to verify information you have provided (e.g. recruitment agencies, your former employer, law enforcement agencies, disclosure and barring service checks);
  • The personal data is collected when you visit our website or use any features or resources available on or through the website (including the careers page, subscribing to marketing), some of which may be personal data; or
  • The personal data may be created by us, such as records of your communications with us or reports from your job interviews, provision of services;
  • Demographic information;
  • Financial information such as payment history, credit history etc;
  • Sensitive personal information such as health information, biometric information;
  • Providing personal information about others such as authorised representatives;
  • Incident reports, surveys, feedback forms;
  • Through CCTV surveillance at a Menarock facility;
  • When contact is made with Menarock services via email, telephone or mail;
  • As part of participating in a program, activity or event organised or authorised by Menarock
  • As part of a student placement, contractor or a volunteer position with Menarock;
  • Visitors and other public who enter our premises to maintain infection control and records of who is in the premises at any given time and compliance with government directions and laws.
  • Contractors, service providers and their representatives so that appropriate financial and business records can be maintained, and we can ensure appropriately qualified contractors are engaged.
  • We also collect sensitive information so that we can manage infection control at our premises and comply with any government directions and laws.
  • Employees and employment applicants when applying for employment including contact details, resume, qualifications, licenses, training records, national police check, relevant medical history.

4. Data Collection – Website

The following sets out the types of personal data we collect on our website:

Personal details include your title, full name, date of birth, age, gender, address, telephone numbers, email address, language and dialect spoken, preferences, subscriptions, images and recordings, the name and contact details of family members, dependents, and emergency contacts, consents, permissions or preferences that you have specified, as well as website access details and security information. 

Personal contact information. If you sign up to receive our newsletter, emails, or text messages, we will collect your name, email address, mailing address, phone number, and any other information needed to contact you about our services. This includes personal data that you make public or provide, such as when you apply for a role and register with us, including any additional communications made via email, telephone, direct messaging on social channels, or demographic information. We also collect personal data when you visit our website or use any features or resources available on or through the website (including the careers portal or subscribing to marketing).  

Payment information. To engage in our Services, you will need to provide us with payment information (like your bank account or credit card information). Please note that your financial information is collected and stored by a third-party payment processing company. Use and storage of that information is governed by the third-party payment processor’s applicable privacy policy. 

Survey information. You may provide us with other personal information when you fill in a form, respond to our surveys or questionnaires, provide us with feedback, participate in promotions, or use other features of the Services. 

5. How We Collect Personal Information

We may collect personal information when you:

  1. telephone us or interact verbally or make contact by mail or email;
  2. access our website or use it to communicate with us, such as through our general enquiries ‘Contact Us’ form on our website;
  3. arrange a private tour of one of our facilities;
  4. apply to live in one of our residences or requests for one of our other services to be provided to you;
  5. enter one of our residences or support centre office
  6. make enquiries or complaints.

In most cases, we collect information directly from you. Where we collect personal information from another person or organisation, it is dealt with in accordance with the requirements of the Privacy Act.

We may collect information about you from publicly available sources, in the course of conducting market research and from current and prospective suppliers of goods and services to Menarock.

There may also be occasions where we collect information about you from third parties. For example, we may collect personal information from:

  • customers’ healthcare providers and other persons/organisations who provide care and services to customers
  • the Commonwealth Government regarding our customers’ eligibility to pay certain fees and charges
  • customers’ representatives (e.g. a legal guardian or family member)
  • other government agencies (either Commonwealth or State)
  • a contracted service provider that provides services on our behalf, or assists us with our human resources communications, IT or other corporate activities; and
  • from other aged care providers and aged care referral services.

6. Menarock Website

When visiting the Menarock website, the system may record certain information about accessing the site, including the web pages visited and the time and date of the visit. This information is used to help analyse and improve the performance of the website.

In addition, ‘cookies’ may be used on the website. Cookies are small text files that assist the website to retain user preferences to improve the user experience. In some cases, the cookies used may collect some personal information. This information is treated in the same way as other personal information collected. Cookies can be disabled on internet browsers to prevent this information being collected if the service user chooses. This may affect the website experience by removing the benefits of enhanced browsing.

Websites linked to the Menarock website operate in accordance with their own privacy standards, policies or procedures, and Menarock takes no responsibility for the collection, use, disclosure or security of any personal information that you provide to a third-party website. We recommend that you review the privacy policies of each website you visit.

7. Purposes and Use of Personal Information

Menarock uses personal information only for the purposes for which it was collected and would be reasonably expected (and as otherwise required, permitted or authorised under law). A more specific purpose may be stated when personal information is collected.

Menarock may use personal information to:

  • verify identity
  • complete background checks
  • operate and administer our services and other functions/programs relating to our services
  • provide information and communications in relation to our services and Menarock
  • comply with laws and regulations including compulsory notices from courts of law, tribunals or government agencies
  • respond to emergency situations involving or requiring medical treatment
  • respond to a threat to health or safety
  • for investigations into suspected or actual unlawful activity
  • complaint management
  • security purposes
  • for the purposes of obtaining professional advice, including obtaining legal advice and participating in legal proceedings
  • in the case of CCTV footage, to investigate incidents, accidents and work issues that arise in providing our services
  • arrange for insurance, progress insurance claims and meet occupational health and safety obligations
  • detect, investigate and prevent fraudulent transactions and other illegal activities on the Services and to protect the rights and property of us and our customers. 
  • carry out our obligations arising from any contracts entered into between you and us, including for billing and collection. 

Menarock may use health information to ensure that services are conducted safely and in accordance with any special health requirement of customers. Health information may also be kept for insurance purposes. In addition, de-identified health information and other sensitive information may be used to carry out research, conduct surveys, to prepare submissions to government, or to plan programs or activities.

8. Uses of Personal Information for Marketing & Opting Out

Menarock may use personal information to provide better services and for marketing purposes (including disclosure of such information to service providers). This may include to:

  • send you our newsletter, or other information or marketing about our Services that you think may be of interest to you. 
  • reply to your questions, inquiries, or customer service requests or to send you notices, updates, security alerts, or support and administrative messages. 
  • provide you with information about the Services that you request from us or which we feel may interest you. 
  • monitor and analyse trends, usage and activities in connection with our Services and to improve the Services. 
  • facilitate contests, sweepstakes, and promotions, and to process entries and provide prizes and rewards. 
  • seek your voluntary participation in advertising campaigns, marketing events, launches, client testimonials and focus groups

When you sign up for a promotion or subscribe to our newsletter or marketing/promotional messages, we use your personal information to help us decide which products, services and offers may be of interest to you. 

We will send marketing messages to you if you have asked us to send you information, bought goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion. If you opt out of receiving marketing messages, we may still send you non-promotional emails. We will ask for your consent before we share your personal information with any third party for their direct marketing purposes. 

You may unsubscribe from marketing messages through a link we include on messages we send you. You can also ask us to stop sending you marketing messages at any time by contacting us at: enquiry@menarock.com.au. 

9. Sharing Personal Information

Personal information is shared in accordance with this policy so that customers receive safe and effective services and supports that optimise the customers independence, health, safety, wellbeing and quality of life.

When the customer begins their services, and throughout their time with us, we share information about and from the customer and/or representative so health care professionals and others can deliver services and supports that match their needs and choices.

Staff effectively hand over information about the customer’s condition, needs, goals and preferences to organisations or providers who deliver services and supports, e.g. when going to and returning from hospital or other external providers.

When customers go on planned leave, we hand over information to the customer and/or representative. We hand over information to staff at change of shift or change in the customer’s condition, needs goals or preferences.

The staff source from the customer and/or their representative, information about services and supports they need, for example:

  • Care needs, whether ongoing or acute
  • Laundry and cleaning preferences
  • Activities they prefer and choose to do
  • People who are important in their life
  • Community activities
  • Dietary requirements
  • Any allergies, especially food allergies

10. Disclosure of Personal Information

We will only disclose personal information to a third party in very limited circumstances, or where we are permitted to do so by law. In relation to customers, we disclose relevant personal information to other persons/organisations who are involved in providing health services and other care and services to our customers. This can include their doctor and allied health service providers.

In the case of all individuals, we may also disclose personal information to:

  • Comply with State/Commonwealth Government directions or their agencies or statutory/regulatory bodies, hospitals or other health care settings and health professionals
  • Companies we engage to carry out functions and activities on our behalf such as banks and payment providers, information technology providers
  • Our professional advisers, including our accountants, auditors, lawyers and insurers
  • Organisations or in other circumstances permitted by law.
  • Government, regulatory and law enforcement bodies where we are required in order:
    • To comply with our legal obligations;
    • To exercise our legal rights (e.g. pursue or defend a claim); and
    • For the prevention, detection and investigation of crime.

In addition, Menarock may also disclose personal information:

  • with express or implied consent
  • when required or authorised by law e.g. court order
  • to an enforcement body when reasonably necessary
  • to lessen or prevent a threat to an individual or public health or safety
  • where a permitted health situation exists.

We may transfer your personal information to third parties in connection with or during negotiations of, any merger, sale or transfer of company assets, financing or acquisition of all or a portion of our business by another company. 

11. Cross Border Disclosures

Currently there are no occasions where we disclose personal information to an overseas entity. In the event of such a circumstance, we will ensure such parties are subject to a law, binding scheme or contract that effectively upholds principles for fair handling of the information that are suitably similar to the Australian Privacy Principles.

12. Criminal Conviction Information

We may be required to carry out vetting if you apply for a designated role which is conditional on such checks. This might involve the collection and use of sensitive information obtained from criminal records checks such as offences or alleged offence including any past or ongoing criminal proceedings. We carry out criminal records checks for the following purposes:

  • To comply with our legal obligation to ensure an individual is eligible to work in Australia; and
  • For our legitimate interest or that of a third party and as necessary to exercise our rights as an employer to carry out pre-employment screening including a full background and criminal records check, depending on the role: 
    • to establish whether an applicant has committed an unlawful act or been involved in dishonesty, malpractice or other seriously improper conduct; or 
    • to comply with government and registration purposes.
      
We have in place appropriate policy documents and safeguards which we are required by law to maintain when processing such data.

13. Photographs and Filming

Visitors are permitted to take photographs or video of a resident if the resident gives express consent and it is not disruptive to the staff and other residents. Residents and their visitors may not photograph or video:

  • Care
  • Treatment
  • Other residents
  • Staff

Without the express consent of the resident or staff member concerned. Staff identifying unauthorised photography or filming must immediately report this to their supervisor/manager.

14. Storage, Security and Protection of Personal Information

The storage, security and protection of personal information is important to Menarock.

Information is stored in different ways, including paper and electronic form. Safeguarding measures have been taken to protect the information held from misuse, loss, theft, unauthorised access, modification, destruction or unauthorised disclosure.

We manage the security of personal information through strict confidentiality requirements of our employees, volunteers and service providers, as well as security measures for system access and our website.

Information we collect from and about individuals may be stored electronically on multiple databases and combined or linked with other personal information held for the purpose of providing services such as billing, communication and provision of care.

To ensure security, integrity, and privacy of personal information, we periodically review and update security protocols of relevant processes and technologies to ensure that access to personal information is only provided to authorised personnel.

15. Access Requests and Correction of Information Held

We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under relevant privacy legislation.

A register of requests for personal information is maintained by the Privacy Officer. We will take all reasonable steps to ensure that the personal information collected, used or disclosed is accurate, complete, up-to-date, relevant and not misleading. We rely on the accuracy of personal information provided to us both directly and within Menarock. We encourage regular review and update of personal information.

A request for access to personal information is made by completing a ‘Request for Access to Personal Information Records’ form and returning this form to the Menarock Privacy Officer.

To protect staff and resident privacy, we will not process a request for access to personal information without proof of identification. Personal information will only be provided to the individual about whom the information relates or to the requesting person’s authorised representative or their legal representative if the person is deceased. The Privacy Officer will advise the applicant requesting the information of the evidence required to process the request.

We will respond to your request within a reasonable period (usually within 45 business days) and provide you with access to the information in the manner requested where it is reasonable and practicable to do so. If access is refused, we will give you a written notice which sets out the reasons for refusal.

Reasons for refusal to a request to access personal may include:

  • is unlawful
  • threatens or may threaten the health or safety of any individual
  • has an unreasonable impact upon the privacy of other individuals
  • the request is frivolous or vexatious
  • access is otherwise exempt under the Australian Privacy Principles.

For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part to cover costs such as staff time and photocopying. This fee will be discussed prior to preparing and providing the information.

16. Retention of Personal Information

Personal information will be retained for as long as necessary to provide required services and to comply with legal requirements.

If personal information is no longer required for any purpose, including legal or regulatory obligations, we will take reasonable steps to securely destroy or deidentify that personal information.

17. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check this page for the latest version of this Privacy Policy.

18. Feedback and Complaints

If you would like to provide feedback to us or have any questions, concerns or complaints regarding this Privacy Policy or how we manage your personal information, we encourage you to first contact our Privacy Officer.

If you lodge a complaint with the Privacy Officer, your complaint will be promptly acknowledged and dealt with within a reasonable period of time depending on the complexity of the matter. If you are dissatisfied with our response to your complaint, you have the right to make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at enquiries@oaic.gov.au. Where any such complaints are lodged, we will work with the Commissioner and the individual to resolve the issue.

19. The Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your personal information, please address these to:

The Privacy Officer
Menarock LIFE
13 Cornell Street
Camberwell VIC 3124

Phone: 03 9898 1000

Email: privacyofficer@menarock.com.au