Lifeline Telephone Counselling Privacy Statement

25 June 2007

Protecting caller privacy and confidentiality is fundamental to the way Lifeline cares for people.

This document sets out how Lifeline handles personal information about callers who phone Lifeline.

Rationale

Lifeline is made up of a national network of Lifeline Centres and a national office, Lifeline Australia, which together operate the Lifeline telephone counselling service.

Lifeline understands that people are concerned about their privacy and therefore abides by the National Privacy Principles (NPPs) in the Commonwealth Privacy Act (1988).

This Privacy Statement is to ensure that callers to the Lifeline Telephone Counselling service can receive open and accurate information about what personal information may be collected during a call to a telephone counsellor, and how and for what purpose that information will be used.

Privacy statement

NPP1 & NPP10 Collection and use of personal information (health information)

During a call, the Lifeline telephone counselling service may collect personal information about callers.

Lifeline will only collect information that is considered necessary for the provision of a quality counselling service, or for directly related secondary purposes.

What kind of information may be collected during calls?

A telephone counsellor may keep notes on aspects of the call such as:

• call time, day and duration
• caller situation as told to Lifeline
• issues and outcomes of the call
• information about a person’s health, disability, or use of health services

Lifeline may also ask a caller for information about themselves:

• age
• gender
• the postcode the caller is calling from
• current marital status
• current employment situation
• current living arrangements
• whether the caller is of Aboriginal or Torres Strait islander origin, and
• the language usually spoken at home (if other than English)

NPP 2 Use and Disclosure

Lifeline will only ask for and collect information that is necessary to the provision or quality improvement of the telephone counselling service.

Uses of information:

• To provide the best possible counselling service to the caller, within professional and industry standards in counselling practice
• For reasons related to the life and safety of the caller or a third party
• To protect the safety and well being of telephone counsellors
• To inform counsellor supervision, assessment and training
• To support efficient and effective management of our service
• To support strategic planning and service development

De-identified and aggregated data on calls to the Lifeline telephone counselling service may be used for internal and external research purposes that will guide service quality improvement and service development.

Confidentiality

All Lifeline staff and volunteers are required to keep caller personal information confidential.

Confidentiality of information collected during a call, and the anonymity of a caller will be upheld at all times except in cases where:

1. A caller is at imminent risk of injury or death by suicide
2. A caller makes specific threats to harm third parties
3. A caller is at imminent risk of injury or death by another person
4. There are reasonable grounds for believing that child abuse is occurring and/or where an intervention may be required to ensure a child's safety.
5. Situations where there is a legal imperative to provide information
6. Circumstances where it is necessary to discuss matters related to the call or caller for the purposes of providing the best possible service to the client, including through supervision processes or to ensure the safety and well-being of telephone counsellors.

Wherever possible Lifeline will advise callers of the above limits of confidentiality
 

Disclosure

Lifeline will only disclose personal information to others outside Lifeline if:

• the caller gives consent (whether express or implied)
• one of the exceptions under NPP2 apply which include but are not limited to:
  • uses or disclosures required by law
  • those disclosures necessary to prevent or lessen a serious or imminent threat to someone’s life, health or safety
  • for research purposes (provided legal conditions are met).

In accordance with NPP2 Lifeline may disclose health information to a ‘person responsible’ for an individual (including a partner, family member, care, guardian or close friend) under certain circumstances if that individual is incapable of giving or communicating consent.

NPP3 – Data Quality

Lifeline will take reasonable steps to ensure that personal information on callers is accurate. Telephone counsellors will be trained and supervised in information collection practices.

Lifeline provides standardized definitions of data and a structured call record for the collection of call information, to minimize anomalies and variations in approach to data quality.

NPP 4 – Data Security and Confidentiality

Lifeline will take reasonable steps to protect the personal information it holds from misuse and loss, as well as from unauthorized access, modification or disclosure.

Lifeline protects the personal information it collects (in both paper and computer form) from misuse and loss, as well as from unauthorized access, modification and/or disclosure. Some of the ways we do this are by:

• Implementing computer system safeguards, including password protection and controlled user access.
• Monitoring computer information systems to test and evaluate data security in line with the appropriate industry standards
• Having lockable physical security for paper records
• Ensuring that information is transferred securely.

NPP 5 - Openness

Lifeline will provide callers to the telephone counselling service with a pre-recorded message advising that personal information may be collected during the call.

If a caller listens to the pre-recorded message on the phone and continues with the call after they have heard this message this constitutes “implied consent” for:

• The collection of information i.e. taking of notes during the call, and
• Call monitoring (a supervisor may listen in to the telephone counsellors side of the call only, or to both sides of the call (the caller and the TC).

Notes may be taken on calls without the consent of the caller if:

• There is a risk to life and safety of a caller or a third party
• Lifeline considers that the information is necessary in the course of providing the service to the caller, or
• It is assessed that there is risk of criminal intent

Sharing of personal information within the Lifeline National Network

In order to answer as many calls as possible Lifeline has a national telephone network. Therefore, information about calls is routinely shared between Lifeline centres as part of the operation of the national telephone counselling service.

When sharing health information Lifeline will abide by the Privacy Amendment (Private Sector) Act 2000, which amends the Privacy Act 1988.

As a general rule Personal Information collected during calls may be shared only within the organisation for reasons related to supervision, debriefing, the provision of quality care to the caller, and for reasons associated with the life and safety of the caller or third party/ies.

With caller consent, personal information may also be shared with:

• Personal information about the caller may be shared with other Lifeline Centre programs or services that the caller is using.  For example: face to face counselling services; the Suicide Crisis Support
• Other organizations who are also working with the caller (for example, Mental Health Services).

Call Monitoring

Occasionally, calls may be monitored by Lifeline supervisors for the purpose of assessment or training of telephone counsellors. Continuation of a call following a caller listening to the Lifeline Welcome message constitutes ‘implied consent’ for monitoring of the call. The message invites callers to let the counsellor know if they do not want the call monitored. Calls will not be monitored if the caller does not want this to happen. In circumstances where the life and safety of the caller or a third party is at risk Lifeline may still monitor the call without caller consent.

Audio Recording of calls

Lifeline Centres will not record either side of telephone counselling calls for supervision or training purposes. 

The only exception would be if Lifeline Centres record calls for academic research purposes. Recording of calls is however discouraged and is to be avoided if possible.  Recording for research purposes may only be undertaken:

• with informed express consent of the parties being recorded, and if
  
• the research has been approved by an accredited academic institution with approval of an authorised Ethics Committee, and with
• Lifeline Australia approval.

These recordings (for research purposes) will be kept strictly confidential, will be stored securely for 7 years and then destroyed.

Frequent callers to the telephone counselling service

Staff or supervisors may ask a caller for consent to provide their name and/or contact details if a caller has been calling the service regularly and it is assessed that some form of care plan would be beneficial. Consent will be sought for care plans where practical and reasonable.

Use of Call Data for Service Development and Research

Lifeline may use de-identified aggregated call data for service development and research purposes. This data does not allow for the identification of individuals and their personal information. Lifeline may under certain conditions make aggregated call data available to researchers, either internally or externally, to assist with learning more about the effectiveness of its service to callers.

Length of time call records are kept

Lifeline keeps call records for 7 years.

In the case of identified frequent callers to the Lifeline telephone counselling service, Lifeline will keep this information for 7 years from the date of last contact, and in the case of children, until they attain 25 years of age.

NPP 6 - Caller access to records and corrections

Callers may request access to personal information contained in call records, unless particular circumstances (exemptions) apply that allow Lifeline to deny access or to limit the extent to which access is provided. 

In accordance with the provisions of NPP6 Lifeline will decide on the most appropriate format and the manner in which to present the information to the caller. For example: with legitimate reason Lifeline may choose to provide a summary of information or discuss information with the caller, or only provide certain parts of the information.

Lifeline will provide access and allow individuals to correct personal information and health information held about them, if they believe it is not accurate, complete or up-to-date in accordance with the provisions of NPP6.

Lifeline may withhold access to all or part of the health information on the record if there is a legitimate reason.

Lifeline will need to determine the identity of the person requesting access to call records, with reasonable certainty.

Access will generally be granted within 30 days of a request.

Lifeline may impose a reasonable charge for access to cover administration costs.

NPP 7 - Identifiers

Lifeline does not use any prohibited identifiers (for example caller tax file numbers or health care card numbers).

NPP 8 – Anonymity

Many callers choose to remain anonymous when calling Lifeline.  Lifeline will honour this preference except where the life or safety of the caller or a third party is at risk or under certain other circumstances supported in law. 

Callers to the Lifeline telephone counselling service are not required to give their name or other information about their personal identity in order to receive service.

Notes may be taken during a call and Personal Information on the caller collected.  This information may be sufficient to reasonably identify the caller.  Lifeline therefore provides a confidential service, but cannot guarantee an anonymous service for its callers.

Lifeline telephone counselling service staff and supervisors may have access to a callers’ phone number if the number is not ‘blocked’ or if the caller has provided his/her number to the service.

Full telephone numbers and contact details of callers will not be made known to telephone counsellors under any circumstances.

Callers will be asked to provide some demographic information about themselves to the telephone counsellor during a call.  This information is de-identified and used for service improvement purposes only.  The demographic information will not be recorded if the caller does not give consent to collection.

The anonymity of a caller will not be maintained under these circumstances.  There are some limits. These are outlined in the section on confidentiality.

NPP 9 – Transborder data flows

Lifeline does not transfer call record data outside of Australia without the caller’s consent.

Modifications to this document

Lifeline may modify this Privacy Statement and the way it handles personal information at any time at its sole discretion. Such modifications will be consistent with current privacy legislation and will be easily identified as subsequent versions.

Last modified June 25th 2007 

How to find out more

More information about privacy can be obtained from the Federal Privacy Commissioner’s website at www.privacy.gov.au

Any queries about this Privacy Statement should be directed to Lifeline's National Privacy Officer. Phone: (02) 6215 9427 email: privacy.officer@Lifeline.org.au

Or, write to: The Privacy Officer, Lifeline Australia, PO Box 173 Deakin West ACT 2600.

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Definitions

‘Access’: This involves a health service provider giving an individual information about themselves. (Access may include inspecting personal information or having a copy of it).

‘Anonymity’:(in this policy) means when someone's name is not given or known

‘Disclosure’: In general terms a health service provider discloses personal information when it releases information to others outside the organisation. Disclosure does not include giving an individual information about themselves (this is ‘access’ see above).

‘Personal information’: means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained. 

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Privacy Amendment (Private Sector) Act 2000 This Act allows the sharing of information with others, where necessary, while outlining the privacy issues and safeguards to consider in these circumstances.