Policy statement

Upswing is committed to providing a safe and secure environment for all its Employees, Members, Visitors, Volunteers and particularly to Children.

Upswing’s Privacy Policy aims to demonstrate respect for privacy and confidentiality to ensure trust in our service and encourage open exchange of information with staff/volunteers, which may be important for the care of a child. This service is committed to safeguarding the information provided to us about members and children under our care, as well as that of Upswing’s staff and volunteers.

This policy demonstrates how Upswing collects, stores, uses and discloses the personal information we collect during your interaction with our services. This policy is aligned with relevant state/territory legislation and/or licensing regulations.

Rationale

Upswing runs co-working and childcare sessions at multiple locations in Australia. Upswing employs staff who care for children at each location.  The Commonwealth Privacy Act 1998 (“Privacy Act”), Australian Privacy Principles and any relevant registered privacy codes govern the way we must manage your personal information. 

Collection of information

The personal information that the service collects are:

  • contact details of children, families, staff/carers, students, volunteers and management;
  • children, families, staff/carers, students, volunteers, emergency contacts contact details;
  • children’s health status, immunisation and developmental records and plans, external agency information, custodian arrangements, incident records, and medication records;
  • staff/carers documentation relating to recruitment and selection, performance reviews, qualifications, work history, child protection checks, health status, immunisation records and workers’ compensation claims;
  • student and volunteer work history, child protection checks; and
  • information relating to families’ Child Care Benefit (CCB) status and any other additional funding arrangements.

Upswing ensures that all information collected from persons will be considered private and confidential and not disclosed without the prior knowledge or consent from the individual or legal representative. For children, their legal representative is their parent or guardian.

Upswing will inform persons, prior to collecting information, of the circumstances when information will be disclosed to other parties. This may include where staff/carers’ qualifications or first aid status may be disclosed to a selection committee or to families in a newsletter. It may also include any issues of a child protection nature, where information obtained by the service is required to be disclosed to the relevant government authorities.

Before collecting personal information, Upswing will inform stakeholders:

  • of the purpose for collecting information;
  • what types of information will be disclosed to the public or other agencies;
  • when disclosure will happen;
  • why disclosure needs to occur;
  • how information is stored;
  • the strategies used to keep information secure;
  • who has access to the information;
  • the right of the individual to view their personal information
  • the length of time information needs to archived; and
  • how information is disposed of.

It is understood by Upswing employees, children and families that there is a shared responsibility between the service and other stakeholders that the Privacy Policy and procedures accepted as a high priority.

In meeting the service’s duty of care, it is a requirement under the Commonwealth Privacy Act 1988 that management and employees implement and endorse the service’s Privacy Policy.

Strategies: Family and children

In order to maintain confidentiality and privacy for families and children, Upswing will implement the following strategies:

  • Collection of personal information will be only to the extent that is required in line with relevant legislation and for the service to run effectively.
  • Upswing will take steps to ensure the personal information collected is accurate by checking upon enrolment, and at least annually that contact information, immunisation records and health status are up-to-date and will remind families to keep us informed of any changes.
  • The use or disclosure of personal information will only be for the purpose it was originally collected, unless the individual consents or unless it is needed to prevent a health threat, or is required or authorised under law.
  • Personal information will be kept in a secure and confidential way and any redundant paper copies will be destroyed by shredding or incineration.
  • Individuals can request access to their personal information in writing. Upswing will protect the security of the information by checking the identity of the individual and ensuring they do not change or remove required information without consent.
  • Confidential conversations that staff members have with family members or other staff members will be conducted in a quiet area away from other children, family members and staff.
  • Upswing does not permit the use of photographs, videos, or any other information that may identify children or families in any medium including online social media sites, unless families have provided specific permission for this to occur.
  • Upswing will handle privacy complaints promptly and consistently, following its complaints policy and procedures.

Strategies: Service staff

To maintain confidentiality and privacy to employees, potential employees, students and volunteers the following strategies will be implemented:

  • Potential employee application forms, employee information forms and all other information will be stored securely.
  • Examples of personal information collected by Upswing can include: contact details; recruitment and selection documentation; qualifications, employment history, child protection checks; wages/salary, tax file number, superannuation, bank account details; performance reviews; health insurance; health status; immunisation records; and workers’ compensation claims.
  • Potential applicants will be asked for their consent before their references are checked.
  • Each employee, in regard to their personal information, will be informed as to what is kept confidential and why, what information they have access to in line with their responsibilities and how this information should be used, as well as knowing where and how confidential information is stored.
  • Each employee is required to sign a Confidentiality Statement, which outlines how they are not to give information or evidence relating to children to anyone other than the parent/guardian, unless prior written approval by the responsible parent/guardian is obtained. Exceptions may apply where legal intervention is required.
  • Each employee will be informed of the expected Code of Conduct relating to the sensitivity and confidentiality in handling information related to children, families and Upswing management or staff.
  • Employees or management are not permitted to discuss the service or its staff on social media sites. Failure to adhere to this policy would be seen as unprofessional behaviour and may result in disciplinary action.

External agencies

  • Upswing may collect information about children and families from external agencies, such as inclusion and support facilitators, or health care professionals.
  • Permission may need to be obtained from the family for the service and the external agency to communicate with one another and exchange information about the child in order to benefit the development of the child.

Storage and security of personal information

  • Upswing’s record keeper, nominated at the Director of the Company, will be responsible for ensuring personal information is collected and stored securely
  • Upswing will collect customer information via secure online forms. Parents are to HubWorks they enter information about themselves, their child and payment details. All information is stored on HubWorks’ secure servers and backed up regularly. Data is stored for 7 years.
  • HubHello/HubWorks! uses 256-bit level encryption and all HubHello data is hosted onshore in Amazon Web Servers (AWS) here in Australia under the IT Security Legislation for Early Childhood.
  • HubHello data backups are stored offsite and within the two AWS data centres located in geographically separate locations in New South Wales.
  • HubHello teams with AWS on keeping the platform safe and uses common security practices – encrypting the web traffic, use of ssh, ssl, private key and updating of the system to the latest updates and patches regularly.
  • Any paper copies of information are securely stored at Upswing’s offices and destroyed by shredding or incineration after 7 years.

Policy Review

This Privacy Policy will be reviewed annually at the Annual General Meeting (AGM). The Organisation’s governing body will inform all interested parties when the date of review will occur, and any changes recommended by

the interested parties should be submitted in writing to the governing body for consideration one month before the review date. Any proposed changes will be submitted to the AGM for approval before being implemented.