Policies &
Procedures.
© Both Ends of the Leash (2023)
Both Ends of the Leash – Policies, Procedures and Guidelines Preamble 3
Privacy Policy
Information Management (Record Keeping)
Record Management Policy – Training Records
Record Management Policy – Certification Records
Record Management Policy – Handler Identity Cards
Record Management Policy – Correspondence, Complaints & Disability Certificates
Record Management Policy – How Records are Obtained
Record Management Policy – How Records are Used
Record Management Policy – How Records are Stored
Record Management Policy – Retention of Records
Complaint Management Policy
Table Of Contents
Both Ends of the Leash is an organisation that assists individuals with disabilities who have a goal to train their own dog to public access standards. We are committed to this objective and agree that employees and trainers should have a lived experience with disability. As quoted by author and Nobel Prize awardee John Ernst Steinbeck;
“You can only understand people if you feel them within yourself.”
Being an individual with a disability who has lived the contrast of life with and without an assistance dog; Both Ends of the Leash will create understanding supportive relationships with individuals whose lives are made difficult due to their disability and together we will adventure and learn how to make our paths straighter and easier to climb. The policies, procedures and guidelines within this document are the framework for the manner in which every person and dog that Both Ends of the Leash comes into contact with will be appreciated and supported. Their wellbeing above all else is and remains the primary focus for all interactions and services provided.
Both Ends of the Leash – Policies, Procedures and Guidelines Preamble
Both Ends of the Leash will maintain strict adherence to the guidelines of the Federal Privacy Commissioner regarding National Privacy Principles within the 1 Privacy Act 1988 (Cth) without exception. There are thirteen (13) 2 Australian Privacy Principles (APP’s) outlined here.
Privacy Policy
Principle
Title
Purpose
APP1
Open and transparent management of personal information.
Ensures that APP entities manage personal information in an open and transparent way. This includes having a clearly expressed and up to date APP privacy policy.Ensures that APP entities manage personal information in an open and transparent way. This includes having a clearly expressed and up to date APP privacy policy.
APP2
Anonymity and pseudonymity
Requires APP entities to give individuals the option of not identifying themselves, or of using a pseudonym. Limited exceptions apply.
APP3
Collection of solicited personal information
Outlines when an APP entity can collect personal information that is solicited. It applies higher standards to the collection of sensitive information.
APP4
Dealing with unsolicited personal information
Outlines how APP entities must deal with unsolicited personal information.
APP5
Notification of the collection of personal information
Outlines when and in what circumstances an APP entity that collects personal information must tell an individual about certain matters.
APP6
Use or disclosure of personal information
Outlines the circumstances in which an APP entity may use or disclose personal information that it holds.
APP7
Direct marketing
An organisation may only use or disclose personal information for direct marketing purposes if certain conditions are met.
APP8
Cross-border disclosure of personal information
Outlines the steps an APP entity must take to protect personal information before it is disclosed overseas.
APP9
Adoption, use or disclosure of government related identifiers
Outlines the limited circumstances when an organisation may adopt a government related identifier of an individual as its own identifier, or use or disclose a government related identifier of an individual.
APP10
Quality of personal information
An APP entity must take reasonable steps to ensure the personal information it collects is accurate, up to date and complete. An entity must also take reasonable steps to ensure the personal information it uses or discloses is accurate, up to date, complete and relevant, having regard to the purpose of the use or disclosure.
APP11
Security of personal information
An APP entity must take reasonable steps to protect personal information it holds from misuse, interference and loss, and from unauthorised access, modification or disclosure. An entity has obligations to destroy or de-identify personal information in certain circumstances.
APP12
Access to personal information
Outlines an APP entity’s obligations when an individual requests to be given access to personal information held about them by the entity. This includes a requirement to provide access unless a specific exception applies.
APP13
Correction of personal information
Outlines an APP entity’s obligations in relation to correcting the personal information it holds about individuals.
© Both Ends of the Leash (2024) _ Policies and Procedures v.3
Information Management (Record Keeping)
Individuals who seek services from Both Ends of the Leash will provide a variety of personal information which every reasonable step will be made to ensure the information collected is accurate, up-to-date, complete and relevant, and obtained only for the purpose it is intended.
For the Individual who will become the “handler” of the dog we will obtain their full legal name, current address for postage and where the assistance dog will reside. The date of birth of the handler, their telephone number and email address will be collected along with their instruction on the manner in which they prefer to be contacted (phone, text or email). All necessary information will be collected by completion of proforma expression of interest and enrolment forms and will be stored in paper and electronic format.
Alternative Handlers are nominated when the person with the disability is not physically able to control the dog, such as in the case where the individual is a child. In this circumstance all the same information that is collected for the individual who is handler will be collected for the person identified as the ‘alternative handler.’ All necessary information will be collected and stored in paper and electronic format. About the Disability the individual for whom the assistance dog is being trained, Both Ends of the Leash will collect evidence confirming the disability exists and the benefit an assistance dog is likely to offer. This information can be discreet and provide on a proforma that is signed and stamped by a treating doctor or practitioner. This information can also be provided in letter form on the practitioner’s letterhead. All necessary information will be collected and stored in paper and electronic format.
About the Dog that is being trained for public access certification, Both Ends of the Leash will obtain details about the breed of dog, it’s date of birth, current and ongoing health information and treatments, microchip number, vaccination record, parasite and intestinal worming regime and any previous training the dog has had and who it has been provided by. Where possible the details of the breeder will also be collected and stored in paper and electronic format.
Agencies and Organisations may also provide information about the individual and their dog for a variety of reasons. This information will be stored in paper and electronic format.
Identity Card supply requires information to be stored that is relevant to dog and handler, necessary information will be collected and stored in paper and electronic format.
Consent to disclose information may be requested by the individual or parent of the individual as the need arises. These inquiries may be made in writing by email naming the third party and the manner in which the information is to be disclosed. In writing or in person. All consent to disclose requests will remain part of the file, stored in paper and electronic format.
Photographs of the individual who has the disability, the handler (if not the same person) and of the dog are required to produce identity cards. These photographs will be stored electronically and in print format where necessary or possible.
Staff and representatives of Both Ends of the Leash who provide personal information such as bank account details, address and contact information including telephone numbers, physical and email addresses are afforded all of the same privacy rights under the Privacy Act 1988. These records will be held in physical or electronic format.
Minimum Record Retention as outlined in section 31 of the Guide, Hearing and Assistance Dogs Regulation 5 Both Ends of the Leash adheres to a minimum seven (7) year record retention period.
Record Management Policy – Training Records
The following list represents the kind of information that will be obtained from you and stored by Both Ends of the Leash to facilitate the keeping of adequate records during the training process.
(a) the name and breed of the dog;
(b) the date of birth or the approximate age of the dog;
(c)the training history of the dog, including—
(i) whether a public access test has been conducted for the dog; and
(ii) if a public access test has been conducted—whether the dog has passed each element of the test;
(d) the veterinary history of the dog;
(e) the name, if known, of the person for whom the dog is being trained;
(f) whether the dog is being trained as a guide, hearing or assistance dog (the dog’s classification)
Record Management Policy – Certification Records
The following list represents the kind of information that will be obtained from you and stored by Both Ends of the Leash to fulfil the necessary requirement of certification when a dog passes the Public Access Test.
(a) the name and breed of the dog;
(b) the date of birth or the approximate age of the dog; (c)the training history of the dog, including—
(i) the public access test conducted for the dog; and
(ii) whether the dog has passed each element of the test; (d)the veterinary history of the dog;
(e) the name of the person for whom the dog was certified;
(f) the classification for which the dog was certified.
Record Management Policy – Handler Identity Cards
This is an example of the information that will be held by Both Ends of the Leash to enable the production and supply of Handler Identity Cards:
a) name to whom the card was issued
b) description of handler’s dog
c) card issue and expiry information
d) retention timeframes for records
e) certified ID documents
f) photographs
Record Management Policy – Correspondence, Complaints & Disability Certificates
Both Ends of the Leash will retain and store various documents, for example:
(a) all documents sent to, or received from, the department by the trainer;
(b) any written complaints received by the trainer about the provision of a training service by the trainer;
(c) a certificate of disability for a person who is the handler of a guide, hearing or assistance dog certified by the trainer.
Record Management Policy – How Records are Obtained
Information obtained by Both Ends of the Leash is provided by the applicant or their authorised representative throughout the training and certification period.
Record Management Policy – How Records are Used
These records are used to complete the necessary administration tasks involved in providing services and keeping satisfactory evidence to support the process of certification as an assistance dog.
Record Management Policy – How Records are Stored
Records are stored electronically within a password encrypted database; physical documents are scanned and backed up to secure cloud based storage with physical registered stored in a key-locked filing cabinet.
Record Management Policy – Retention of Records
Records are held for a minimum seven (7) year period as detailed in Section 31(2)(c) of the Act and Regulation 5.
© Both Ends of the Leash (2024) _ Policies and Procedures v.3
Complaint Management Policy
Introduction and Scope
The purpose of this policy is to ensure that Both Ends of the Leash provides a means for external stakeholders to lodge complaints and to have these addressed and appropriately resolved if at all possible. Complaints are seen to play an important role in contributing to the Organisation’s improved operations.
This policy has been framed around natural justice principles and individuals’ rights as they are specified within the context of the Queensland State Disability Services Act (2006); the Australian Disability Services Act (1986), and the Human Rights Act (2019).
Definition
A complaint is an expression of dissatisfaction with (for example) a decision, service or product. A person does not have to call their dissatisfaction a ‘complaint’, in order for it to be handled as a complaint by Both Ends of the Leash.
Statement
Both Ends of the Leash is committed to ensuring that its stakeholders, without prejudice, are able to discuss their concerns and lodge complaints if they consider that their rights have been adversely affected or the standards of a service have not been fulfilled or for any reason they are unsatisfied with their interaction with the Organisation and/or a matter related to the Organisation’s operations.
Both Ends of the Leash welcomes feedback and advice whether it is complimentary or a complaint because it provides a means by which the organisation can continually improve its service and quality levels. It will respond to complaints in a fair, prompt and positive manner for the achievement of a resolution wherever possible.
Record Retention
Records relating to any complaint made will be held for a minimum seven (7) year period as detailed in Section 31(2)(c) of the Act and Regulation 5.
3 https://www.dsdsatsip.qld.gov.au/our-work/disability-services/disability-connect-queensland/disability-
services-act-2006
4 https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/BN/07
08/DisabilitySupportServicesAustralia
5 https://www.legislation.qld.gov.au/view/pdf/asmade/act-2019-005
1.1 Principles
To protect the rights of both the complainant and respondent, the following important principles and intentions will be observed.
a) Complaints must clearly identify the issue and provide the available related information
b) The person-centred approach to complaint management supports individuals and meets their needs, thus enabling both parties to work cooperatively within the process
c) All complaints will be handled with absolute fairness and in accordance with the principles and intentions of natural justice:
the decision making process is free from bias
all parties have the right to be heard
the respondent has a right to know the details of the complaint
all parties are informed of the basis on which a decision is made.
d) If required, complainants will be provided with assistance to lodge their complaint.
e) The complaints process will be fully accessible to people with a disability and/or people from cultural and linguistically diverse backgrounds. If required, translators or interpreters will participate in the complaints process.
f) The rights of all parties to have others present or act on their behalf is acknowledged, supported and encouraged.
g) The process will ensure complaints are handled fairly, reflecting the rights of both the complainant and the respondent(s) and undertaken:
in an open and consistent manner, with no retribution for people expressing their views
promptly and courteously
in a manner that ensures the rights of all people are acknowledged, honoured and protected.
h) The details of the complaint (both discussions and records) shall be kept confidential from anyone who is not required to be involved in its resolution. Permission will be obtained from the relevant party/ies before any sensitive information is released to help resolve a dispute.
i) Complaints will be considered within the context of a continuous improvement framework.
j) Both Ends of the Leash employees receiving complaints must be treated with respect. Abusive, aggressive or disrespectful behaviour towards staff during interactions will not be tolerated.
1.2 Complaint Lodgement
Lodgement methods include:
a) face to face communication;
b) telephone 0450 124 866
c) print; Att: Diane Petersen, Both Ends of the Leash, 17 Ewan Street, Margate, Q. 4019
f) electronic formats (including the website’s online feedback form or the organisation’s generic email address: di@bothendsoftheleash.com.au).
1.3 Contact with Complainant
The person managing the complaint must contact the complainant within two business days to:
a) acknowledge its receipt; and
b) provide his/her name, title and contact details; and
c) obtain further information, if required, in order to help assess the manner in which the complaint will be addressed; and
d) provide an estimated timeframe until resolution; and
e) check if the complainant requires further assistance or support while the matter is under investigation; and
f) if the matter is not resolved within the estimated timeframe, provide a status report with revised timeframe, and repeat each ten business days if necessary until the matter is closed.
1.4 What might constitute a complaint
a) Services or supports that were not provided in a safe and respectful way
b) Services and supports that were not delivered to an appropriate standard
© Both Ends of the Leash (2024) _ Policies and Procedures v.3