People are central to our organisation and we are committed to ensuring the health, safety and wellbeing of everyone in our work environment.
We will continually promote practices which inspire people to achieve the best possible performance and outcomes. It is this commitment that drives us to support behaviours and practices associated with high performance in workplace safety and wellbeing.
Chief Executive Officer
Providing information that is easy to access and understand is important to Bolton Clarke. We want you to use this information to make better decisions about your health and care. This will assist you to actively participate in society.
If there is information on this website that you cannot access or you do not understand, call us on 1300 22 11 22. If you require a telephone interpreter to speak with us, call the National Language Line, or the National Relay Service.
We are proud to be a diverse organisation with many areas of society represented across our clients/residents and our employees. We value diversity.
All our information is presented in plain language so that it can be understood by as many users as possible. We aim to improve the low health literacy rates in Australia.
Some information on our website is provided in languages other than English. Our information is translated by professional translators and meets Translation Standards. For more information about Translation Standards click here. Australians speak over 300 languages. To provide equity of access to our information, users are able to use google translate software.
You can listen to some information on our website, click here to see our range of talking books. Some information is presented in a visual format using photos. This assists people with vision impairment and those with no formal education in English or a language other than English.
Some documents on this website are available in PDF formats. You need Adobe Acrobat Reader software on your computer or device to view PDFs. You can download the software for free from the Adobe website, click here.
Our website aims to meet the Web Content Accessibility Guidelines. For more information about these Guidelines in English or another language, click here.
How to call us if you need assistance
This Policy governs how members of the Bolton Clarke Group, being RSL Care RDNS Limited ABN 90 010 488 454, Royal District Nursing Service Limited ABN 49 052 188 717 and RDNS HomeCare Limited ABN 13 152 438 153 (we, us, our) collect, store, use, disclose and manage personal information. This Policy also outlines and explains the types of personal information we collect, the purposes for which it is collected, how you can request access to and correct personal information that we hold about you and how you can make a privacy complaint or contact us with your enquiries or concerns.
We take your privacy seriously and are committed to open and transparent management of personal information. When dealing with personal information, we comply with the Privacy Act 1988 (Cth) (Act), the Australian Privacy Principles in the Act, and all other applicable legislation, including State and Territory health records legislation.
Our suppliers and contractors are required to enter into written contracts ensuring their strict compliance with privacy laws.
This Policy does not apply to personal information that is exempt under the Act, including the personal information of our employees relating to their former or current employment with us.
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable:
Sensitive information is a subset of personal information and includes:
What constitutes personal information will vary, depending on whether any individual can be identified or is reasonably identifiable in the particular circumstances.
The personal information that we collect and hold will depend on your relationship with us, the nature of the product or service we are providing or activity you are involved in and the legal obligations we may have.
However, we generally collect and hold both personal and sensitive information, including:
If lawful and reasonable to do so, we will destroy and de-identify all unsolicited personal information we receive if we would not normally collect this information to perform one of our functions or activities or if the information is sensitive and no consent has been given.
We will not collect personal information unless it is reasonably necessary for one of our functions or activities. We will usually only collect sensitive information with your consent. All personal information will only be collected through lawful and fair means.
The sources from which we collect personal information will depend on the circumstances of the collection and may include the following:
We will try to collect your personal information directly from you, or alternatively, with your consent. We will collect personal information from you:
Where it is unreasonable or impracticable to collect information directly from you, we may obtain personal information about you from a third party. For example, we may collect personal information about you:
We automatically gather anonymous information to monitor use. For example, the numbers and frequency of visitors to our website. This collective data helps us determine how our audiences use parts of our website, so we can improve our services. We may publish or provide this aggregate data to other people or organisations.
If you are receiving aged care or health services from us, it is not practical for you to remain anonymous because we need to keep a record of the care and services provided to you.
We may be able to accommodate you using a pseudonym. However, if you choose not to provide your real identity this may impact the quality of the services provided to you and relevant billing and claiming.
If you wish to use a pseudonym that is linked confidentially to your real identity, please let us know and we will discuss with you any arrangements that can be made.
We may use and disclose personal information for the particular purpose for which it was collected (Primary Purpose).
For customers, this will include the use and disclosure necessary to provide retirement and aged care services including accommodation, and where relevant, health care or wellness services. We may use or disclose your personal information:
For prospective employees, this may be for assessing and processing employment applications.
We will only generally use or disclose personal information collected for a Primary Purpose. However, it may be necessary in some cases to disclose personal information for a secondary purpose, including:
We will take reasonable steps to ensure that the personal information we collect is accurate, complete, up to date and relevant to the purpose for which it is to be used, both at the time of collection and use.
All personal information collected is securely stored on our electronic databases. In some instances, it may also be held in hard copy files in secure and locked facilities in Australia.
We will take reasonable steps to ensure that the personal information we hold is protected from misuse, loss, interference, unauthorised access, modification or disclosure.
We will notify you, as soon as reasonably practicable, if we find that there has been any unauthorised access, disclosure or loss of your personal information that is likely to result in serious harm to you.
If requested, we will let you know what kind of personal information of yours we hold, for what purpose, and how we handle that information. We will also make this Policy available to anyone who requests a copy of it.
You can request access to your personal information held by us, upon written request to our Privacy Officer. We may charge reasonable costs for carrying out your request. To obtain access to your personal information, you must provide us with proof of identity. This is necessary to ensure that your personal information is provided only to the correct individuals and that the privacy of others is protected.
If, upon receiving access to your personal information or at any other time, you believe your personal information is inaccurate, incomplete or out of date, you can notify our Privacy Officer to correct your personal information. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
We may decline a request for personal information in circumstances prescribed in the Act. If so, we will give you a written notice setting out the reasons for refusal and the complaint mechanisms available to you.
We may disclose personal information to entities outside of Australia, in which case we will take all steps that are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles, unless we reasonably believe the disclosure is necessary or authorised by Australian law.
There may be occasions where personal information is used for direct marketing purposes including direct contact, telephone enquiries, email, SMS, letters, internet and web interactions, surveys and other forms of communication. Any such use will be limited to circumstances where you would reasonably expect us to use or disclose your personal information for that purpose and it has been collected from you, or if you have otherwise consented or requested this information.
You have the right:
If you have consented to us providing direct marketing to you and you wish to stop receiving such marketing, please contact us on the details set out in this Policy or provided in the marketing communication.
If you believe we have at any time breached this Policy, you may lodge a written complaint with our Privacy Officer on the contact details in this Policy.
We will endeavour to acknowledge your complaint within 14 days of its receipt, and to make a determination on the complaint within 30 days of its receipt.
Level 3, 44 Musk Avenue Kelvin Grove QLD 4059
Phone: (07) 3251 6200
Further information about the Australian Privacy Principles and the application of the Act to us can be found at the website of the Office of the Australian Information Commissioner at http://www.oaic.gov.au.
This Policy will be reviewed every two years or when changes to legislation and regulation or the operating environment occur.
Members of the Bolton Clarke Group, being RSL Care RDNS Limited ABN 90 010 488 454, Royal District Nursing Service Limited ABN 49 052 188 717 and RDNS HomeCare Limited ABN 13 152 438 153 (we, us, our) collect personal information about individuals for a range of purposes to enable us to carry out our functions. We acknowledge and respect the privacy of individuals.
Further details about the collection of your personal information are provided below:
Who is collecting your personal information?
Members of the Bolton Clarke Group, being RSL Care RDNS Limited ABN 90 010 488 454, Royal District Nursing Service Limited ABN 49 052 188 717 and RDNS HomeCare Limited ABN 13 152 438 153.
Collection of your personal information
Your personal information is collected:
a) from you when you provide personal information to us, including by completing agreements, applications, forms, surveys, competitions and questionnaires or you communicate with us by taking part in a discussion or forum or by email, telephone, in writing or in person;
b) when care is provided and when you report information to our staff including about your health;
c) from a member of your family, a carer, a close friend, your authorised representative or responsible person, next of kin, your nominated emergency contact person or the police, each of whom may be able to provide us with information relevant to you where it is unreasonable or impracticable to collect information directly from you;
d) from third parties, including other service providers or health professionals;
e) from relevant government departments, such as Medicare, the Department of Health and the Department of Social Services or your health insurer;
f) from third parties who you have asked to provide your personal information to us, including references or referrals; and
g) from you when you wish to be an employee, supplier or contractor of ours.
Authority for collection
As a retirement and aged care service provider, the Aged Care Act 1997 (Cth) and the Aged Care Principles, require us to collect personal information in certain circumstances. Where we provide health care services to you, we are required to collect and keep records of customers receiving our services.
We will handle any personal information collected in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and applicable State and Territory health records legislation.
When you apply for employment or engagement with us, we are required to collect and verify information about you such as your suitability, employment history, licences and qualifications.
Why do we collect your personal information?
We collect your personal information to provide retirement, aged care and health services to you. We also use the information for training and the management of our services.
For contractors and suppliers, we collect your personal information to assess your suitability, qualifications, licences and insurance details and, if applicable, subsequently administering and managing our engagement of you. For prospective employees, we collect your personal information to assess your suitability for the position for which you have applied.
What would happen if we did not collect your personal information?
If your personal information is not collected, we may not be able to provide the service, assistance, engagement or employment you seek.
Who will we disclose your personal information to?
Depending on the service or assistance sought, we usually disclose personal information to the following types of people or organisations:
a) funding and government departments such as the Department of Health, the Department of Social Services, Queensland Health, New South Wales Ministry of Health and Department of Communities, Child Safety and Disability Services;
b) to a member of your family, a carer, a close friend, your authorised representative or responsible person, next of kin, your nominated emergency contact person or the police;
c) to staff or other service or health providers involved in providing services to you or your care (including nurses, physiotherapists, occupational therapists) or administrative staff (involved in preparation of documentation, billing and other administrative and management duties); and
d) any third party that you request or authorise us to. For prospective employees, contractors and suppliers, we may disclose your information to third parties to assist us in considering you for a position (including suitability) and, if applicable, subsequently administering and managing our engagement or employment of you. For employees, we disclose your employment information when requested by another employer if you record us as a referee on your application with them.
We also disclose your personal information if required by or authorised by or under an Australian law or a court or tribunal order.
Access to and correction of your personal information
Our Privacy Officer handles any enquiries, requests and complaints relating to the Privacy Act. Our Privacy Officer can be contacted by:
Post: Level 3, 44 Musk Avenue, Kelvin Grove, QLD 4059
Phone: (07) 3251 6200
Overseas disclosure of your personal information
Generally, we do not disclose personal information to entities outside of Australia. However, if we need to disclose your personal information to an overseas recipient, we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles, unless we reasonably believe the disclosure is necessary or authorised by Australian law or a court or tribunal order.
Many people in Australia were born overseas and don’t speak English at home. Many of these older people cannot read English because of a lack of school education and opportunity. Poor language skills in English can be a barrier to getting health information and lead to poorer health outcomes. At Bolton Clarke we want to provide translated and easy to understand information wherever possible in many languages.
In order to provide easy to understand information Bolton Clarke has developed a Translation Standard. The standard ensures that our translations are of good quality and information is easy to understand. It was developed together with our consumers, staff and other organisations.
Our Translation Standard has 10 steps to ensure of translation is of good quality and can be understood by people with low levels of school education. The Translation Standard can assist consumers to make better choices and decisions about their health and care.
The following are the 10 steps of the Translation Standard that help produce good quality information:
All translations produced at Bolton Clarke are developed against the Translation Standard.
The Translation Standard is shown by a tick symbol. This symbol is made up of 10 circles representing each of the steps of the Translation Standard. When the tick is displayed on a translation it shows users that the product has been developed following the 10 steps.
The Translation Standard and the tick symbol are registered as a trademark in Australia and New Zealand. If you are interested in learning more about the Translation Standard call 1300 563 448
Follow the links below for translated information about Bolton Clarke services:
The following are published articles on Translation Standard:
The Bolton Clarke Group, being RSL Care RDNS Limited ABN 90 010 488 454, Royal District Nursing Service Limited ABN 49 052 188 717 and RDNS HomeCare Limited ABN 13 152 438 152 (Bolton Clarke, we, us, our), is committed to organisational integrity and ethical behaviour by fostering an open and supportive culture in which people are able to raise concerns regarding actual or suspected unethical, unlawful or undesirable conduct without fear or detriment.
Everyone should feel comfortable about reporting misconduct. Bolton Clarke is committed to protecting and supporting the dignity, wellbeing, career and professional reputation of anyone reporting misconduct.
The objectives of this Policy are to:
To support these objectives, this Policy explains:
You can make a disclosure under this Policy if you:
If you have seen or have reasonable grounds to suspect misconduct, or an improper state of affairs or circumstances, concerning Bolton Clarke, we encourage you to make a disclosure in accordance with this Policy.
Reportable misconduct includes but is not limited to:
A disclosure that is not about reportable misconduct does not qualify for protection under the Whistleblower Legislation. Such disclosures may be protected under other legislation, such as the Fair Work Act 2009 (C’th)
Work-related grievances should be reported and dealt with in line with Bolton Clarke’s Workplace Complaints Standard, not under this Policy.
Persons reporting a work-related grievance do not qualify for the protections available to whistleblowers under the Whistleblower Legislation.
A ‘work-related grievance’ is a grievance about any matter relating to your employment, or former employment, which has implications for you personally.
Examples of work-related grievances include:
Work-related grievances which involve reportable misconduct may still qualify for protection under the Whistleblower Legislation if:
Allegations of Elder Abuse should be managed in line with the Mandatory Reporting in Residential Aged Care Guidelines or CP – E07 Elder Abuse.
You can make a disclosure:
2. to our independent whistleblower service provider – Your Call; or
3. to external authorities and entities.
Depending upon the nature of the misconduct, you are encouraged to make a disclosure to your leader. Everyone involved in a disclosure of misconduct must treat the matter confidentially.
If you do not feel safe or able to raise misconduct with your leader, you may make the disclosure to:
If for any reason you do not feel comfortable reporting internally, the matter may be reported anonymously through our independent disclosure management service – Your Call Whistleblowing Solutions (Your Call).
Your Call operates under a service agreement with Bolton Clarke and acts as an intermediary providing the means for you to retain your anonymity in making a disclosure. Disclosures received by Your Call are reported to Bolton Clarke in accordance with this Policy. Your Call also enables us, through the use of an online anonymous message board, to obtain further information from you and for you to receive updates from us.
Disclosures made through Your Call can be made through either of the following methods:
A. Online Report: at www.yourcall.com.au/report (24 hours a day, 7 days per week)
For step-by-step instructions as to how to make an online report through Your Call, refer to the Your Call Employee Handbook – making an online report. A copy of this Handbook is located here.
B. Hotline Reporting:
Contact Your Call on 1300 790 228 between the hours of 9:00 am to 12:00 am Monday to Friday (AEST excluding public holidays)
Organisation ID: RSLCRDNS
You can make a disclosure to the Australian Securities and Investments Commission (ASIC) and/or the Australian Prudential Regulation Authority (APRA) if the misconduct concerns:
The contact telephone number for ASIC is 1300 300 630 and for APRA is 1300 558 849.
You can make a disclosure in the public interest to a Federal, State or Territory Member of Parliament or to a journalist if:
It is important that you understand the above criteria must be satisfied before you can make a public interest disclosure.
You can make an emergency disclosure to a Federal, State or Territory Member of Parliament or to a journalist if:
“Journalist” means a person who is working in a professional capacity as a journalist for any of the following:
It is important that you understand the above criteria must be satisfied before you can make an emergency disclosure.
If you communicate with a lawyer for the purpose of obtaining legal advice or representation in relation to the operation of the Whistleblower Legislation, then any disclosure you make to a lawyer is protected under the Whistleblower Legislation.
A disclosure does not need to include absolute proof of misconduct. Where possible, the disclosure should include:
These details will assist us in deciding how best to deal with and resolve the disclosure.
There is no requirement for you to identify yourself in order for a disclosure to qualify for protection under the Whistleblower Legislation.
You may choose to remain anonymous while making a disclosure, over the course of the investigation into your disclosure and after the investigation is finalised. You can refuse to answer questions you feel could reveal your identity at any time, including during follow-up conversations with us.
If you wish to remain anonymous and engage in ongoing two-way communication with us, we recommend that you make your disclosure through our independent whistleblower service provider, Your Call.
Your identity will not be disclosed by us or by our independent whistleblower service provider, Your Call, unless:
We will protect your identity through the following measures:
An unauthorised disclosure by any Bolton Clarke Worker of:
is illegal and will be regarded as a disciplinary matter and dealt with in accordance with our disciplinary procedures.
If your identity has been unlawfully disclosed, you may lodge a complaint with Bolton Clarke by contacting the Head of Risk or by creating an additional report with Your Call. Alternatively, you may lodge a complaint with ASIC.
Bolton Clarke is committed to ensuring that any person who intends to or actually reports misconduct, acts as a witness, is mentioned or participates in any way with respect to a report of misconduct is not victimised and is protected from detriment.
Detriment includes but is not limited to:
Detrimental conduct does not include:
No Bolton Clarke Worker may engage in detrimental conduct against you.
We will protect you from detriment through the following measures:
You may seek independent legal advice or contact ASIC if you feel you have suffered detriment.
If you make a disclosure using one of the methods described in section 6 above that qualifies for protection under the Whistleblower Legislation:
The above protections are available to you even if your disclosure turns out to be incorrect.
However, none of the above protections shield you from the legal consequences of your own misconduct revealed by your disclosure.
If you are a Bolton Clarke Worker or an immediate family member of a Worker, support is available to you through our Employee Assistance Program.
Third party support providers such as Lifeline (13 11 14) and Beyond Blue (1300 22 4636) may also be able to provide support and assistance.
Use of these support services may require you to consent to the disclosure of your identity or information that is likely to lead to the discovery of your identity.
No action will be taken against any Workers who are implicated in the disclosures made under this Policy until an investigation has determined whether the allegations made in the disclosure are substantiated.
All disclosures of misconduct will be treated seriously and confidentially. All allegations will be investigated in a manner that is in accordance with the principles of fairness and natural justice.
Bolton Clarke will provide any Workers who are the subject of an investigation as a result of a disclosure:
Appropriate disciplinary action may be taken against any person found to have knowingly made a false or malicious disclosure.
Bolton Clarke will:
The investigation must be conducted in a constructive, impartial and lawful way according to the principles of natural justice and procedural fairness.
Bolton Clarke will:
It is a condition of employment that Bolton Clarke’s Workers must comply at all times with this Policy.
Breach of this Policy may be regarded as misconduct, which may lead to disciplinary action (including termination of employment). An individual may also be exposed to criminal or civil liability for breach of the Whistleblower Legislation.
This Policy is available internally through our employee intranet, Connect.
This Policy is also available to be viewed and downloaded from our external website.
Any amendments to this Policy shall be made known to Bolton Clarke Workers by posting an updated version of the Policy on our intranet and external website.
Head of Risk
Level 3, 44 Musk Avenue, Kelvin Grove QLD 4059
Phone: (07) 3251 6264
This Policy will be reviewed every two years or when changes to legislation or the operating environment occur.