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Privacy Policy


Applies To:

NT Friendship & Support (NTFS) Management Committee members, staff members, carers, volunteers and NDIS Participants/Participant’s Representatives.

Documentation and Policy

Personal and Health Collection Statement

Privacy Consent Form

Appendix 1: Self Audit Guided Questions

Appendix 2: Access Check list

Appendix 3: Privacy Audit and Breaches Information / Questions


National Standards for Disability Services 2013

National Standards for Out of Home Care - 2015

Home Care Standards – 2015

Australian Charities and Not-For-Profits (ACNC) Governance Standards


Disability Services Act (NT) 2012

Health and Community Services Complaints Act (NT)

NT Care and Protection of Children Act (2007)

Carers Recognition Act (2006)

NT Charter of Rights for children and young people in care in the Northern Territory

Commonwealth Privacy Act (1988) Australian Privacy Principles

NT Information Act (2002)

Contractual Obligations:

Contract with Commonwealth Department of Social Services (Social Support Individual and Community and Home Support for people 65 years or 50 years and over for ATSI people)


Fee for service arrangements with the Northern Territory Government Territory Families (Out of Home Care for Children aged 0-18 years)


Any reasonable recommendation, guideline or policy set down by the Australian Information Commissioner


Other legal agreements as entered into by the organisation during the life of this policy.



Policy Statement

NT Friendship & Support Inc (NTFS) is committed to protecting and upholding the right to privacy of participants, clients, staff, volunteers, Management Committee, members and representatives of agencies we deal with. NTFS is subject to legislation applying to the organisation and its client group.  The organisation will follow the guidelines of the Australian Privacy Principles in its information management practices.

For the purpose of this policy; clients, Staff, volunteers, carers, Management Committee members, Contractors and stakeholders shall be referred to as “Individual”


NTFS will ensure:

  • it meets its legal and ethical obligations as an employer and service provider in relation to protecting the privacy of individuals

  • individuals are provided with information about their rights regarding privacy

  • where possible individuals are provided with privacy when they are being interviewed or discussing matters of a personal or sensitive nature

  • all individuals understand what is required in meeting these obligations.

This policy conforms to the Commonwealth Privacy Act (1988) and the 13 Privacy Principles which underpin 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.



Australian Privacy Principles (APP)

APP 1 Open and Transparent management of personal information

NTFS will take reasonable steps to implement practices, procedures and systems relating to our functions or activities that:

  • Compliance with all the APP’s

  • Ability to deal with inquiries or complaints from individuals about their compliance with APP’s

APP2 – Anonymity and Pseudonymity

An individual can use services anonymously or under the name of an alias where lawful; however; NTFS are unable to provide services for individuals under this AAP as out funding contracts require individuals to identify themselves appropriately

AAP 3 – Collection of unsolicited personal information

The most obvious method is collecting information directly from an individual such as through a form or initial assessment for services

AAP 4 – Dealing with unsolicited personal information

Receiving personal information pertaining to an individual which has not been sought. If this is the case the information should be destroyed or de identified

AAP 5 – Notification of the collection or personal information

At or before the time of collection of personal information NTFS needs to take reasonable steps to inform the individual of the Collection Statement

AAP 6 – Use or disclosure of personal information

Holding of personal information about an individual that was collected for a particular purpose (Primary purpose), this information must not be used or disclosed for another purpose (secondary purpose) unless:

  • Consent has been sought to use the disclosure of the information

  • One of the circumstances set out in APP 6.2 or 6.3 applies in relation to the use or disclosure of the information

APP 7 – Direct Marketing

               Personal information may not be used or disclosed for direct marketing

AAP 8 – Cross border disclosure of personal information

Personal information may not be disclosed to a person overseas, as once the information has left Australia it is no longer has the protection afforded by the Privacy Act

APP 9 – Adoption, use or disclosure of Government related identifiers

Identifiers such as Medicare or tax file numbers, DVA numbers cannot be used to identify an individual. NTFS need to adopt its own personal identifier number

APP 10 – Quality of personal information

               Information that is collected is accurate, complete and up to date

APP 11 – Security of personal information

Take reasonable steps to protect the information from misuse, interference and loss from unauthorised access, modification or disclosure.

APP 12 – Access to personal information

The Privacy Act provides individuals with the right to access their personal information – this applies to information collected after 21 DECEMBER 2001 and any information collected prior to that date which is still in use. An individual has the right to seek access to only their personal records.

APP 13 – Correction of Personal information

An individual has the right to request a correction of their personal information if it is inaccurate, out of date, incomplete, irrelevant or misleading. NTFS must take reasonable steps in the circumstances to correct the information.



Dealing with personal information

In dealing with personal information, all NTFS staff, carers, volunteers and affiliates will:

  • ensure privacy for individuals when they are being interviewed or discussing matters of a personal or sensitive nature

  • only collect and store personal information necessary for the functioning of the organisation and its activities

  • use fair and lawful ways to collect personal information

  • collect personal information only by consent from an individual

  • ensure that individuals know what personal information is held, what purposes it is held it for and how it is collected, used, disclosed and who will have access to it

  • ensure that personal information collected or disclosed is accurate, complete and up-to-date, and provide access to any individual to review information or correct inaccurate information about themselves

  • take reasonable steps to protect personal information from misuse and loss and from unauthorised access, modification or disclosure

  • destroy or permanently de-identify personal information no longer needed and/or after legal requirements for retaining documents have expired.


Responsibilities for managing privacy

  • All staff, carers and volunteers of NTFS are responsible for the management of personal information to which they have access. This includes information used for the conduct of research, consultation or advocacy work

  • The Executive Officer is responsible for content in NTFS’ publications, communications and web site and must ensure that:

  • appropriate consent is obtained for the inclusion of any personal information about any individual including NTFS personnel

  • information being provided by other agencies or external individuals conforms to privacy principles

  • that the website contains a Privacy statement that makes clear the conditions of any collection of personal information from the public through their visit to the website.

  • The Executive Officer in conjunction with Management Committee members are responsible for safeguarding personal information relating to Individuals

Privacy Contact Officer Shall:

  • be appointed by the Executive Officer and is the first point of contact when privacy issues arise either internally or externally

  • ensure all staff are familiar with the Privacy Policy and administrative procedures for handling personal information

  • ensure all staff and volunteers inform clients and other relevant individuals with information about their rights regarding privacy

  •  investigate queries or complaints about a privacy issue.

Privacy information for client carers and volunteers

Before or on entry to NTFS services individuals will be given a copy of the Personal and Health Collection Statement of what information is being collected, how their privacy will be protected and their rights in relation to this information. 

Privacy for interviews and personal discussions

To ensure privacy for individuals when discussing sensitive or personal matters, the organisation will ensure that:

  • information that is of a personal or sensitive nature is not discussed in public areas, including within NTFS workplaces

  • private interview space (where possible) for discussions with individuals and their advocates

  • private spaces are provided for staff meetings that involve the discussion of clients

  • private spaces will be sought for face to face or telephone discussions relating to individuals

  • in instances where appointments with individuals are required outside of office opening hours, or in a person’s home, every effort should be made to ensure that conversations are conducted in a private area.

Conduct Internal Privacy Audit and review of this policy

  • NTFS will conduct an internal audit of its process against the 13 APP. This will be a continuous process to ensure practices meet all of the requirements of this policy and utilising Appendix 1: Self Audit guided questions

Compare current practices with the requirements of the 13 Australian Privacy Principles

  • As part of the internal audit process practices will be tested against the 13 APP’s on a rotating process

Consult with stakeholders regarding organisational practices

  • Consultation with the Stake Holder Advisory group will feed into the audit process and practices of the organisation

Regular audit of the organisational complaints process

  • Consultation with clients, staff, volunteers and stakeholders will feed into the regular audit and continuous improvement of the complaints process

Inform clients, staff, volunteers, Management Committee members and contractors of the Privacy Policy and complaints procedure

  • All individuals will be given a copy of the privacy policy and information regarding the organisations complaints procedure

Training of Staff

  • Induction of new individuals will be imbedded into induction and Orientation

  • regular re training of existing staff (annually) to ensure all staff are up to date and have a working knowledge of this Policy


Confidentiality of Individuals Records


NT Friendship & Support Inc utilises a cloud based Client Management System (CMS) which is quality assured to ISO 27001. All information is stored within Australia.


First layer

  • Each staff member has a password to access the organisational electronic system

Second layer

  • Each Staff member has a user name and password to access our CMS

  • Levels of access and authority within the system ensure staff can only access information relevant to their role and service

  • Footprint information can be reported on any part of the system


  • Staff must ensure that they log off each time they leave their desk

  • Staff have access to only their individual passwords

  • Filing cabinets containing personal information is locked at the end of each day, and key stored securely

  • All staff sign for any key usage

  • Staff asset register is kept ensuring tracking on data management equipment such as Laptops and mobile phones

  • If staff are in a situation where they believe that they might have to divulge information about a client that they ordinarily would not disclose, they should seek the advice of their manager before making the decision to do so

  • Organisational arrangements for maintaining individual’s privacy and confidentiality will be reviewed on a tri-annual basis as part of a privacy audit, or sooner where an individual has a query on the privacy and confidentiality of their information

  • Organisational internal privacy audit is an ongoing operational process. Any breaches in this policy will be addressed and changes made where appropriate


Breaches of the Australian Privacy Principles


  • Individuals are within their rights under the Privacy Act to direct privacy related complaints to the organisation concerned. Where possible NTFS should attempt to rectify the problem, and satisfy the complainant’s request.

  • NTFS have a procedure in place to ensure that all staff are well trained to facilitate this process.

  • NTFS will ensure that all new staff are well trained in the policy and procedure, and all existing staff are notified when there are any changes or amendments to the procedure

  • If the complainant is not happy with the response then they may take their complaint to the Office of the Australian Information Commissioner. 

  • If the complaint is upheld by the Office of the Australian Information Commissioner, the possible outcomes include: an apology, a change to the respondent's practices or procedures, staff training, or compensation for financial or non-financial loss

  • If you want to make a complaint to us about how we have handled your private information please put this in writing (please let us know if you need support to do this) to:


Process for correction of your personal and /or health information

You have the right to ask NTFS to correct personal or health information.

  • You can ask for this by contacting us – we must respond within 30 days.

  • This request must be made in writing (if you need support please let us know)

  • NTFS must take all reasonable steps to correct the information if considered it incorrect, unless there is a Law that allows or requires us not to


Process for access to your personal and /or health information

You have the right to ask NTFS to have access to your personal and or health information

  • You will need to put your request in writing (if you need support please let us know)

  • We must respond within 30 days of your request

  • You will be asked to verify your identity

  • It may be appropriate or necessary for NTFS to refuse individuals access to their records in certain circumstances, or restrict access to part of the records only, where providing access to the records would:

- Be unlawful (refer to any relevant legislation in your jurisdiction)

 - Pose a serious and imminent threat to the mental health or life of an individual

- Have an unreasonable impact on privacy of others (for example where services are                                         provided to couples, families or groups)

- Be frivolous or vexatious 

- Be prejudicial to an investigation or prosecution of alleged unlawful activity

  • Once NTFS receive your access request we will carefully review the records to consider the above. If NTFS deny the above we will notify you of the outcome, and must provide our reasons in writing to you within 30 days.

  • Access Modes

    • NTFS must provide access in the nominated method including;

    • Together- NTFS and individual and go through the records/file and explain relevance

    • Verbally – NTFS read the records/file out to the individual and explain the relevance

    • Print Copy- Individual may have the records/file printed

    • Summary- A summary can be provided

  • The Privacy Act allows for charges to be made in relation to Access

    • Photocopying fees – but not excessive

    • Fees for staff time to sit with individuals to read and go through records

    • Time to prepare for the access

  • NTFS cannot charge individuals a fee for making the request

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