Privacy & Child
Safety Policies
Privacy Policy
Privacy and Confidentiality Guidelines
Build It Up Music Therapy’ is committed to providing quality services to you. This policy outlines our ongoing obligations to you in respect of how we manage your personal information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
What is personal information and why do we collect it?
‘Personal information’ is information or an opinion that identifies an individual. Examples of personal information we collect includes names, addresses, email addresses, and phone numbers. This personal information is obtained in many ways, including via telephone, email, and our website (www.builditupmusictherapy.com.au). We don’t guarantee website links or policy of authorised third parties.
We collect your personal information for the primary purpose of providing our services to you. We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure, including contacting preschool centres, teachers and other health professionals.
When we collect personal information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
What is sensitive information?
‘Sensitive information’ is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.
Sensitive information will be used by us only:
For the primary purpose for which it was obtained.
For a secondary purpose that is directly related to the primary purpose.
With your consent; or where required or authorised by law.
Third parties
Where reasonable and practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of personal information
Your personal information may be disclosed in several circumstances, including the following:
Third parties where you consent to the use or disclosure; and
Where required or authorised by law.
Security of personal information
Your personal information is stored in a manner that reasonably protects it from misuse and loss from unauthorised access, modification, or disclosure. All personal information is stored in our administration software, ‘Splose’, which encrypts and protects all the details linked to your child’s file.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is, or will be, stored in client files which will be kept by us for a minimum of seven years.
Access to your personal information
You may access the personal information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
‘Build It Up Music Therapy’ will not charge any fee for your access request. However, to protect your personal information, we may require identification from you before releasing the requested information.
Maintaining the quality of your personal information
It is an important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can renew our records and ensure we can continue to provide quality services to you.
Policy updates
This policy may change from time to time.
If you have any queries or complaints about our Privacy Policy, please contact us at admin@builditupmusictherapy.com.au.
To support the privacy and confidentiality of individuals:
We are committed to complying with the privacy requirements of the Privacy Act, the Australian Privacy Principles and for Privacy Amendment (Notifiable Data Breaches) as required by organisations providing disability services
We are fully committed to complying with the consent requirements of the NDIS Quality and Safeguarding Framework and relevant state or territory requirements.
We provide all individuals with access to information about the privacy of their personal information.
Individuals have the right to request access to their personal records by requesting this with their contact person.
Personal information will only be used by us and will not be shared outside the organisation without your permission unless required by law (e.g. reporting assault, abuse, neglect, or where a court order is issued).
Images or video footage of participants will not be used without their consent.
NDIS participants have the option of being involved in external NDIS audits if they wish.
Security of Information
To keep information secure:
We take reasonable steps to protect the personal information we hold against misuse, interference, loss, unauthorised access, modification and disclosure.
We ensure personal information is accessible to the participant and is able for use only by relevant workers.
We ensure security for personal information includes password protection for IT systems.
We ensure personal information no longer required is securely destroyed or de-identified.
We store personal information in safe administration software systems, such as 'Splose'.
Data Breaches
As part of information security responsibilities:
We will take reasonable steps to reduce the likelihood of a data breach occurring including storing personal information securely and accessible only by relevant workers.
If we know or suspect your personal information has been accessed by unauthorised parties, and we think this could cause you harm, we will take reasonable steps to reduce the chance of harm and advise you of the breach, and if necessary the Office of the Australian Information Commissioner.
Breach of Privacy and Confidentiality
A breach of privacy and confidentiality is an incident:
Follow the Manage incident process to resolve
May require an investigation
An intentional breach will result in disciplinary action up to and including termination of employment.
GDPR Compliance
Our administration software program, Splose, is well-recognised for having a safe and secure system for allied health companies, such as 'Build It Up Music Therapy'.
The General Data Protection Regulation (GDPR) is a landmark regulation in the EU and UK, setting a comprehensive scope of standards that protect the rights, privacy and security of personal data. Splose meets the GDPR’s requirements by implementing stringent data protection measures, transparent policies, and robust security protocols to ensure user consent, data access, portability, and erasure.
Child Safety Policy
Our Commitment to Child Safety
We are committed to supporting an environment that promotes the safety and wellbeing of children and young people as our priority. This policy has been developed to ensure that our organisation is a safe and welcoming place for children and young people, and one where children and young people are equally valued, respected and encouraged to participate. This commitment extends to all children and young people regardless of their abilities, sex, gender, or background.
National Principles for Child Safe Organisations
The National Principle for Child Safe Organisations this policy is based on are as follows:
Child safety and wellbeing is embedded in organisational leadership, governance and culture.
Children and young people are informed about their rights, participate in decisions affecting them and are taken seriously.
Families and communities are informed and involved in promoting child safety and wellbeing.
Equity is upheld and diverse needs respected in policy and practice.
People working with children and young people are suitable and supported to reflect child safety and wellbeing values in practice.
Processes to respond to complaints and concerns are child focused.
Staff and volunteers are equipped with the knowledge, skills and awareness to keep children and young people safe through ongoing education and training.
Physical and online environments promote safety and wellbeing while minimising the opportunity for children and young people to be harmed.
Implementation of the national child safe principles is regularly reviewed and improved.
Policies and procedures document how the organisation is safe for children and young people.
When is a child or young person at risk?
A child or young person is at risk when they have suffered, or there is a likelihood they will suffer, harm. The relevant harm may be physical, emotional or psychological. A child or young person is also at risk where the parent or guardian is unable or unwilling to care for the person.
Reporting concerns about children and young people at risk
We are committed to providing a supportive and safe environment for staff and volunteers who disclose harm or risk to children and young people. All suspicions that a child or young person is at risk must be reported to key management and to the appropriate state/territory child protection hotline.
All concerns that do not meet the threshold of child at risk, but which involve a concern about the welfare or safety of a child are to be reported to key management.
What is a child safe environment?
Child safe environments are safe and friendly settings where children and young people are protected and feel respected, valued and encouraged to reach their full potential. To provide an environment safe for children and young people, we will:
Take a preventative, proactive and participatory approach on child wellbeing and safety issues
Seek out and embrace the opinions and views of children and young people on issues relating to our services that they consider important or impact them
Take action to protect children and young people from harm.
Working with children and young people
The standards and requirements identified below in our commitment to child safety identify the professional boundaries, ethical behaviours that are accepted and behaviours that are unacceptable. All staff are required to abide by and follow these standards and requirements.
Child safe code of conduct
As part of our commitment to child safety, all workers and volunteers in the organisation WILL:
Act in accordance with child safety and wellbeing policies and procedures at all times.
Behave respectfully, courteously and ethically towards children and their families and towards other staff.
Listen and respond to the views and concerns of children, particularly if they communicate (verbally or non-verbally) that they do not feel safe or well.
Promote the human rights, safety and wellbeing of all children in the organisation.
Demonstrate appropriate personal and professional boundaries.
Consider and respect the diverse backgrounds and needs of children.
Create an environment that promotes and enables children’s participation and is welcoming, culturally safe and inclusive for all children and their families.
Involve children in making decisions about activities, policies and processes that concern them wherever possible.
Contribute, where appropriate, to policies, discussions, learning and reviews about child safety and wellbeing.
Identify and mitigate risks to children’s safety and wellbeing as identified by risk assessments and Risk management policies and processes.
Respond to any concerns or complaints of child harm or abuse promptly and in line with the Complaint management policy and Manage complaint process.
Report all suspected or disclosed child harm or abuse as required by relevant state and federal legislation and the Report incident process.
Comply with protocols on communicating with children.
Comply with relevant state and federal legislation and policies and procedures on record keeping and information sharing.
All workers and volunteers in the organisation will NOT:
Engage in any unlawful activity with or in relation to a child.
Engage in any activity that is likely to physically, sexually or emotionally harm a child.
Unlawfully discriminate against any child or their family members.
Be alone with a child unnecessarily.
Arrange personal contact, including online contact, with child participants for a purpose unrelated to work activities.
Disclose personal or sensitive information about a child, including images of a child, unless the child and their parent or legal guardian consent or as a result of reporting requirements.
Use inappropriate language in the presence of children, or show or provide children with access to inappropriate images or material.
Work with children while under the influence of alcohol or prohibited drugs.
Ignore or disregard any suspected or disclosed child harm or abuse.
Recruitment and worker screening
The organisation will comply with and carry out Working With Children Checks in accordance with state/territory requirements of the National Disability Insurance Scheme Act 2013 (Cth).
All WWCC will be validated online and verified by management prior to a new worker or board member commencing in a child-related role.
Any existing worker who cannot renew their WWCC must notify key management as soon as possible, and any worker or volunteer with a WWCC bar or interim bar will be removed from child-related employment immediately in line with the standards outlined in the National Principles for Child Safety.
Our recruitment practices will take account of risks and other factors that impact on children and young people. Worker selection, referee checks and background checks will reflect our commitment to ensuring child safety and wellbeing. We will review our recruitment and human resources management practices regularly to make sure that we are aligned with best practice approaches for the protection of children and young people.
Any third party contractors engaged in providing supports to children will have appropriate measures in place to ensure the safety and wellbeing of children and young people.
Staff training
All staff will be made aware of their responsibilities to children and young people as part of their induction and ongoing training and development and will be required to acknowledge this policy alongside their record keeping, information sharing and reporting responsibilities.
Staff supervision and management will support employees to maintain a focus on child safety and wellbeing and to draw attention to breaches of the Code of Conduct within the organisation. We will provide a safe and supportive environment for workers to identify and disclose risk of harm to children and young people.
Online and social media safety
Online spaces provide additional challenges to maintaining the safety of children and protecting them from harm.
Social media also poses a variety of risks to children. It is vital that staff, parents and carers understand these risks and the responsibility to ensure there are codes of conduct in place for the use of social media when interacting with children and young people. These risks include:
Exposure to inappropriate content
Overfamiliar relationships between children and people in positions of power (e.g. children interacting with teachers on social media)
Cyber bullying
The sharing of inappropriate images
Physical health challenges, such as headaches
Mental health challenges, such as depression and social isolation
Data breaches and data misuse
Grooming.
'Build It Up Music Therapy' does not currently have a social media presence.
When in childcare centres, kindergartens or primary schools, we will note take any photos or video recordings. We are happy for these education settings to take photos of sessions and group programs, as long they are in line with the child safety policy and privacy policy of their own organisation.
Staff, parents and carers are responsible for teaching children social media safety. Some key principles of social media safety include:
Only sharing information the child would be happy for their grandparents, parents and teachers to see.
Understanding that people online can lie about their identities.
Remembering that a post, once published online, cannot always be taken back; even if a post has been removed, it may have already been saved and shared.
Ensuring that all social media accounts are set to ‘private’.
Understanding the importance of secure passwords.
Blocking people that exhibit negative behaviours, such as cyberbullying.
Considering that content can always be shared, even if it is sent in a private message.
In addition to the above, it is vital to have appropriate online privacy settings and child safety filters in place and discuss with the child the reasons these are in place.
All staff at our organisation will be trained to:
Support children to engage with online spaces in a safe manner.
Be engaged, open and supportive in relation to social media use.
Understand the devices and platforms children are using.
Set reasonable rules around social media use.
Understand the needs and preferences of each child in relation to social media use.
Understand and manage the risks associated with social media.
Respond to the misuse of digital devices and to unacceptable online behaviours in line with disciplinary policies.
Maintain clear processes for reporting online safety issues or breaches of acceptable use in line with incident reporting requirements.
Manage complaints and incidents in a compliant manner.
Any inappropriate use of social media by staff will be reported to the relevant authorities in line with the Complaints management and Disciplinary policies.
Communication and review of children and young people protection policy and systems
All new workers, including volunteers and contractors, will be trained on the requirements of this policy.
This policy will be made available to all participants and their families, along with any other additional information required.
Breach of child safe policy
Breach of this policy, or the Child safe code of conduct, may result in disciplinary action and/or referral to the appropriate government authority.
In addition to this, all adults in Australia with a reasonable belief that an adult has committed a sexual offence against a child have an obligation to report that information to the police (failure to report). Key management will commit an offence if they know of a substantial risk of child sexual abuse and have the power or responsibility to reduce or remove the risk, but negligently fail to do so (failure to protect).