Privacy policy

At The Aged Care Group PTY LTD (MACG), we recognise the importance of your privacy and understand your concerns about the security of the personal and health information you provide to us. MACG complies with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth) (Privacy Act) and the Health Privacy Principles (HPPs) as contained in the Health Records Act 2001 (Vic) (Health Records Act), (collectively, Privacy Laws). The APPs and HPPs detail how personal and health information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal and health information held about them.

This policy details how MACG manages personal and health information about you. This policy may be updated from time to time. We recommend that you refer to our website for the most recent updated version at https://www.maacg.com.au/privacy-policy.

Definitions

“Personal information” generally includes information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

“Sensitive Information”, a sub-set of personal information, is information or an opinion about an individual’s racial or ethnic origin, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices or criminal record, and includes health information, genetic information, biometric information and biometric templates.

“Health Information” is generally information or an opinion about an individual’s health or disability, the health services provided or to be provided to them, their expressed wishes for the provision of future health services, personal information collected to provide a health service, personal information collected in connection with organ and body-part donation, and predictive genetic information.

What personal and health information does MACG collect and hold?

MACG collects a wide variety of personal, sensitive and health information which relates directly to its functions and activities. MACG’s functions and activities generally include those associated with residential services. The information MACG may collect will vary depending on how MACG interacts with you. 

If you are a resident or a prospective resident or a recipient of MACG’s other services, then the kinds of personal information we commonly collect and hold from you or about you include: your name, address, date of birth, emergency contact, personal representative details, power of attorney details, next of kin details, photographs, phone, fax and mobile numbers and email address. 

In the course of providing MACG’s services, we also commonly collect and hold personal information regarding: government related identifiers (drivers licence, passport, Services Australia Customer Reference Number, Pension Number, Medicare Number), financial information (income statements, bank summaries, superannuation statements, taxation records, Services Australia records, Medicare service records), health information (health insurance details, medical records, medication records, dietary requirements, Medicare, pain assessments, referrals, allergies, vaccinations, COVID and influenza status), other information (taxi card, photographs, voice and image recordings and wellbeing and lifestyle activities). MACG may also collect other personal or sensitive information, depending on the nature of the relationship with you.

In addition to the above, MACG may collect personal information from or about the family members and friends of the residents such as name, influenza and COVID health information, and photographic and video images.

If you are a prospective or current employee, contractor, student or volunteer to MACG, we commonly collect your name, address, date of birth, contact telephone numbers, email address, emergency contact and next of kin details, previous occupation(s), qualifications, eligibility and fitness to work in Australia, citizenship and visa status, background police, criminal and bankruptcy checks, dietary requirements, allergies, vaccination, COVID and influenza status and other health or medical conditions relevant to your position. MACG will also collect relevant information for payment of wages, accounts and service fees, superannuation, taxation, etc). 

When you browse MACG’s website or contact MACG electronically, or engage with MACG on social media, we record: geographical tagging and statistical data from your activity including your computer system internet address, your top level domain name (for example .com, .gov, .au, etc), the date and time of your visit to the site, the pages you accessed and documents downloaded, the previous sites you have visited and the type of browser you are using. Note that none of the statistical information MACG collects allows it to identify a visitor to MACG’s website. The information MACG collect from your visit to its website is used by MACG to help administer and improve the website.

MACG use cookies to collect non personal information, and anonymous information about visits to its website and to track how you reached its website.  Cookies are small text files placed on your hard drive by website hosts. Cookies recognise a repeat visitor to its site and enable sites to store information on the user’s computer so that the information can be referenced later. You will be given the option to disable cookies when you visit MACG’s website, but this may prevent proper functionality of the website.  In particular, you may not be able to store your preferences, and some of the pages might not display properly. If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

MACG’s website also contains links to other websites of interest. However, once you have used those links to leave MACG’s site, you should note that MACG does not have any control over that other website. Therefore, MACG cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website/s in question.

How does MACG collect and hold personal and health information?

MACG aims to collect personal and health information only directly from you, unless it is unreasonable or impracticable for us to do so. For example, we collect personal and health information in a number of ways, including:

• directly from you, from correspondence that you submit to MACG, meetings and interviews with MACG, telephone calls with MACG, the instructions you provide to MACG, submissions you make on MACG’s website, social media interactions and registration and feedback forms you may fill in for marketing-related activities and events.
• from your authorised representative, family member(s) or friend(s) (if it is unreasonable or impracticable to obtain the information from you)
• from participation in MACG’s services 
• from your attendance at MACG events and activities 
• from and related to your employment or engagement with MACG
• from third parties such as hospitals, Aged Care Assessment service, doctors, allied health providers or other public or private referral agencies 
• from government sources such as Services Australia, Medicare, My Aged Care and the State and Federal Police
• via MACG’s website, when you subscribe to receive emails or newsletters 
• through images and recordings. 

You can be anonymous or use a pseudonym when dealing with MACG, unless:

• the use of your true identity is a legal requirement; or
• it is impracticable for MACG to deal with you on such basis.

For example, you may be able to make general enquiries about MACG on a ‘no-name’ basis. However, to receive MACG’s residential and aged care services, MACG does require the collection of your personal and health information detailed in this policy. 

MACG primarily collects sensitive information about an individual with the individual’s consent, if that information is reasonably necessary for, or directly related to, one or more of MACG’s functions or activities. You may be asked to provided personal information about other individuals to us (e.g. contact details of next of kin or preferred contact). If so, MACG relies on you to inform those other people that you are providing their personal information to MACG and to advise them about MACG’s privacy policy. 

Why does MACG collect, hold, use and disclose personal and health information?

MACG collects, holds, uses and discloses personal and health information from you or about you where it is reasonably necessary for MACG to carry out its business functions and activities, and to provide its services. MACG uses and discloses your personal and health information only for the purposes for which it was collected or for any other purpose that is otherwise directly related to MACG’s functions or activities or otherwise permitted by law. Where MACG wishes to use or disclose your personal and health information for other purposes, MACG will ask for yours or your authorised representatives’ consent. 

For residents who live in residential aged care, respite care or palliative care, MACG collects information to assess your requirements and to undertake care planning. As part of the care planning, staff will talk to other internal and external service / health providers who are expected to disclose any concerns that may arise in carrying out your care plan. Staff may also need to consult your doctor, other health professionals and relevant service providers in order to monitor, plan, implement and evaluate your care needs. MACG may also be bound to comply with mandatory reporting and information sharing schemes to protect residents’ wellbeing. 

Information collected is used to provide services to you and to provide you with information about those services and to assist with your enquiries. Information will also be used to improve or develop MACG’s services, and to monitor and evaluate MACG’s performance and quality. MACG will also use information collected from or about you to charge and bill for its services provided to you (if relevant) and to collect any monies owing to MACG.

If MACG does not collect, hold, use or disclose your personal information, or if you do not consent to the provision of such information, then MACG may not be able to answer your enquiry, complete the services you require, or facilitate your participation in any of MACG’s services, events and/or activities.

For example, if you are a resident, the collection and use of your personal and health information is necessary to provide MACG’s services, to comply with government requirements, and to ensure your care needs are met. 

MACG may disclose personal and health information to:

• your authorised representative with your consent or when you ask us to; 
• hospitals or other health care providers and health professionals; 
• professional advisors including MACG’s accountants, auditors and lawyers;
• MACG’s contracted vendors and service providers; 
• MACG’s insurers; 
• Government departments and regulatory authorities; and/or 
• those permitted by law.

Direct Marketing 

MACG may contact you to provide you with information about other services offered by MACG that may benefit you and your family. This includes information or services that can help improve your wellbeing.  When MACG contacts you, it may be via mail, telephone, or email. When you become a resident of MACG you consent to us using your personal information for direct marketing (as described in this policy), unless you have contacted MACG to withdraw your consent. If you do not wish to receive marketing materials from MACG you can contact MACG at any time to advise of this at the contact details provided in this policy. When you contact MACG to make this request, MACG will action your request within five working days. Opt-out procedures will also be included in all MACG’s marketing and promotional communications. 

CCTV and Surveillance 

MACG has installed or may install surveillance devices in communal spaces of its residential aged care facilities. In these cases signage is in place at the entry of the facility which states surveillance devices are used in common areas of the establishment and/or in the outside vicinity. Surveillance feed from communal or outside areas is only reviewed if there is a complaint or an incident to assist with investigation. If additional or further surveillance in communal spaces or outside is to be installed, you will be informed of this change. MACG does not allow surveillance equipment to be installed in a resident’s room due to the intimate and private acts performed, for example, showering, bathing, etc. 

How does MACG hold and store personal and health information?

Your personal and health information is held and stored on paper, by electronic means or both. MACG has physical, electronic, technical and procedural safeguards in place for personal information and takes reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorised access, modification and disclosure.  For example:

• Data held and stored on paper is stored in secure rooms within the premises.
• Data held and stored electronically is protected by internal and external firewalls, high encryption and all access to electronic data including databases requires password access that meets Microsoft complexity standards.
• Access to personal information is restricted to staff and contractors whose job description requires access. MACG employees and contractors are contractually obliged to maintain the confidentiality of any personal information held by MACG.
• Data stored or archived off-site is contained within secure facilities. MACG also requires its storage contractors to implement privacy safeguards.

Destruction and De-identification

MACG will retain your personal and health information whilst it is required for any of its business functions, or for any other lawful purpose by taking reasonable steps including technical and organisational measures. 

MACG will also retain your personal and health information for the time periods required by law (commonly, seven years).

MACG uses secure methods to destroy or to permanently de-identify your personal and health information when it is no longer needed.  For example:

• Paper records are sent for secure destruction. In some instances, paper records and original transaction documents will be returned to you and/or relevant third parties.
• Electronic records retained for longer than 7 years may be archived to alternative storage and are subject to the procedural safeguards described above.

Requests for access and correction

MACG takes reasonable steps to ensure that the personal and health information it uses or discloses is accurate, complete and up to date, having regard to the purpose of the use or disclosure.

MACG also has procedures in place for dealing with and responding to requests for access to, and correction of, the personal and health information held about you. Your right to request access may arise under the Privacy Laws.

In most cases, MACG expects that it will be able to comply with your request. However, if MACG does not agree to provide you access or to correct the information as requested, MACG will give you written reasons why. For further information, please contact MACG’s Privacy Officer. 

To assist MACG to keep our records up-to-date, please notify MACG’s Privacy Officer of any changes to your personal and health information.

Data Breaches

In Australia, if MACG suspects that a data breach has occurred, MACG will undertake an assessment into the circumstances of the suspected breach within 30 days after becoming aware of the occurrence of the suspected breach. Where it is ascertained that a breach has actually occurred and where required by law, MACG will notify the Federal Privacy Commissioner and affected individuals in accordance with our legal requirements.

Under law and under an eligible data breach declaration, MACG may be asked to share and/or handle a limited amount of personal information to prevent or reduce the risk of harm to individuals whose personal information has been breached. 

Complaints and Concerns

MACG has procedures in place for dealing with complaints and concerns about our practices in relation to the Privacy Laws, and any alleged breach of this Policy. MACG will respond to your complaint in accordance with the relevant provisions of the APPs and the HPPs (as relevant). For further information, please contact MACG’s Privacy Officer.

If MACG is unable to resolve your privacy complaint, you have other options to escalate your complaint, depending on the personal and/or health information involved. This includes lodging a complaint with:

Contact

MACG’s Privacy Officer can be contacted to discuss or attempt to resolve any complaints relating to the collection, storage and use of your personal and health information. For further information, please contact:

Privacy Officer
MACG
Chadstone Tower 1, Level 8

LXD Business Centre (MACG)

1341 Dandenong Road, 

CHADSTONE, VIC 3148
P: (03) 5923 0019
E: mgalea@maacg.com.au

Last updated: January 2025