Policies and Procedures

Purpose

• The purpose of this policy & procedure is that each participant has access to support that promote, uphold and respect their legal and human rights. The provision of support promotes, upholds, and respects individual rights to freedom of expression, self-determination and decision-making.

Scope

• This document applies to:

• All Access Foundation WA staff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their family

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

Policy & Procedure

• Each participant’s legal and human rights are understood and incorporated into everyday practice.

• Communication with each participant, the provision of supportthat is responsive to their needs and is provided in the language, mode of communication and terms that the participant is most likely to understand. This is undertaken via Participant Handbookwhich was designed so it is easy to read and understand. An interpreter/translator is provided upon request.

• Each participant is supported to engage with their family, friends and chosen community as directed by the participant in Form27.Initial Assessment and Support Plan, Form22.Service Agreement and Participant Handbook.

• Access Foundation WA must ensure that the following practices are taken to support the participant and their family and/or carer:

• Train, support and encourage all staff and workers to implement this policy & procedure in their practices reflected in theirJob description, Worker Handbook and Form08.Induction Checklist.

• Communicate the success factors individually with the participants to find out what it looks like through Form27.Initial Assessment and Support Plan and Form26.Goal Plan for Participant. Support and assistance (e.g.,involvementofasupportperson,interpreter,or advocate) will be provided to the participant if required. Interpreters would be available as below:

  • The Translating and Interpreting Service (TIS National) is an interpreting service provided by the Department of Home Affairs.https://www.tisnational.gov.au/

• Access Foundation WA ensures that participant’s health and well-being is important for all staff and workers, therefore steps are taken to support this approach by reviewing and understanding Worker Handbook and undergoing an induction using Form08.Induction Checklist.

• Access Foundation WA ensure that staff and workers empower participants skills by knowing their goals and working towards those goals. These goals can be reviewed and updated during support plan review.

• Access Foundation WA ensure that participants’ independence is supported by workers.

• Access Foundation WA ensure that staff and workers support participants’ freedom and respect their beliefs and values by adhering to the policies and procedures.

• Access Foundation WA ensure that staff and workers understand that participants are treated equally even if they have a disability and should be supported at all times.

The above items which are related to the way that a participant and/or participantshave been treated by the worker will be reviewed and assessed during the worker’s performance review via Form10.Worker Performance Assessment.

Purpose

• The aim of this policy & procedure is that each participant has access to support that respect their culture, diversity, values and beliefs.

Scope

• This document applies to:

• All Access Foundation WA staff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

Policy & Procedure

Culture, diversity, values, and beliefs policy

• To provide a diverse and inclusive service to participants and their families Access Foundation WA promotesthe following:

• Support cultural diversity and promote the inclusive environment

• Support participants’ to play an active role in the community

• Finding participants’ needs from consulting with their family members and carers

• Create an inclusive workplace for all staff and workers and respect their cultural beliefs and language difference

• Ensuring that there is not any difference in service provision between participants and the rest of the people in the society

• Support people with CALD and Aboriginal and/or Torres Strait Islander (ATSI) background with their culture and spiritual beliefs

• At the direction of the participant, the culture, diversity, values and beliefs of that participant are identified and sensitively responded to.

• Each participant’s right to practice their culture, values and beliefs while accessing support is supported. At Access Foundation WA,during the initial assessment participants are encouraged to talk about their culture, diversity,values and beliefs by usingForm20.Participant Intake Form.

• Access Foundation WA ‘s participantswhose English is not their primary language will beprovided with interpreter/translator support (if required) or in case of a meeting, these people would be able to bring a member of their family who speaks English.

Individual Values and Beliefs management

• Access Foundation WA will:

• Group people with different languages to foster respect for diversity in the organisation

• Will find people cultural and linguistic needs to collaborate with other organisations to meet their needs

• Identify and collaborate with LGBTQI+ mainstream support and advocacy programs

• Actively prevent instances of violence, abuse, neglect, discrimination and exploitations as per our processes.

• Ensure keeping personal information of participants confidentially to avoid any misuse from their sexual orientation and cultural information

• Support Aboriginal and/or Torres Strait Islander heritage needs by working respectfully with their families and individuals

• Enhance the cultural awareness of staff, workers and volunteers when providing services to those who are of an Aboriginal and/or Torres Strait Islander heritage, through Worker Handbook, induction, and regular training

• Using respectful language when talking about people’s sexual orientation

Purpose

• The aim of this policy & procedure is that each participant accesses supports that respect and protect their dignity and right to privacy.

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Privacy Act 1988

• Freedom of Information Act 1982

• Form18. Participant Information Consent Form

• Form19.Privacy & Confidentiality Agreement

• Form02.Complaint Report Form

Policy & Procedure

Privacy and Confidentiality Policy

• Access Foundation WAis committed to providing quality services and respectingparticipants’ rights. Participants’ right to privacy and confidentiality will be recognized, respected and protected in all aspects.

• At Access Foundation WA, all information will be handled based on the NDIS Quality and Safeguarding Framework.

• Consistent processes and practices are in place that respects and protects the personal privacy and confidentiality of each participant.
  
  

• Access Foundation WA ensures that all confidential documents are handled safely in our operations.
  
  

• Access Foundation WA will not disclose any confidential information to any persons who are not employed by Access Foundation WA or participant unless consent has been obtained.

• Access Foundation WA will not take any interest in the review of confidentialand sensitivedocuments of the company.

• Access Foundation WA is committedto maintainingthe confidentiality of medical results

• Access Foundation WA will not disclose, copy, release, sell, alter, or destroy any confidential information, either electronic or paper-based unless there ismanagement approval.

• Access Foundation Wa is committed to protecting the privacy of participants and workers.

Worker’s responsibilities

• All workers will complete Form19.Privacy & Confidentiality Agreement to ensure the confidentiality requirements are understood and adhered to.

• Worker’s responsibilities are as below:

• Workers will not disclose any confidential information to any persons who are not employed by Access Foundation WA or participant unless consent has been obtained. Privacy & Confidentiality Information includes but is not limited to:

1. Participant personal information,and medical examination results

2. Workers, Contractors and Volunteers

3. Business information such as financial records, reports, memos, contracts, computer programs and technology

4. Company processes and operations

5. Company intellectual property

6. Service specifications; and

7. Any other information regarding company activities that can have a detrimental impact on the company.

Management team responsibilities

• All inquiries or complaints about privacy and confidentiality should be directed to the Managing Director and Form02.Complaint Report Form to be completed.

• In case Access Foundation WA identifies that there is a breach of information or unauthorised access to the information of participants, will take measures to reduce the chance of harm to people. In these cases, the Australian InformationCommissioner might be involved.

• It is the participant’s right to choose if they want to be involved in an NDIS audit.

• Each participant understands and agrees to what personal information will be collected and why, including recorded material in audio and/or visual format through Participant Handbook, Form20. Participant Intake, andForm27.Initial Assessment and Support Plan.
  
  

• The documents will be handled in a way that:

• No record will be lost, modified, or disclosed unauthorised

• Any access to the documents will be provided in a way that doesn’t breach the disclosure of the records
  
  

• Nosale or payment will be tolerated by any member of Access Foundation WA for personal information disclosure.

• Not all information will be collected unless:

• It is required for service provision

• It will be handled securely in the database of Access Foundation WA.

• The following criteria apply to any personal information disclosed to a third party:

• Personal consent using Form18. Participant Information Consent Form is provided by the participant

• We are authorised to provide all that information by law

Purpose

• The aim of this policy & procedure is that each participant is supported by the provider to make informed choices, exercise control and maximise their independence relating to the supports provided.

Scope

• This document applies to:

• All Access Foundation WA staff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• Form18. Participant Information Consent Form

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Human Rights and Equal Opportunity Commission Act 1986

• Freedom of Information Act 1982

Policy & Procedure

Decision-Making Policy

• Access Foundation WA is committed to our participants having control over the services provided to them and the decisions that might affect their life.

• Access Foundation WA is committed to making sure that participants are satisfied with the services received

• Access Foundation WA find out about the participant’s preferences and take appropriate measures to provide that participant with those preferred services.

• Access Foundation WA is committed to providing services to participants that are aligned with their needs and preferences.

• Active decision-making and individual choice are supported for each participant including the timely provision of information using the language, mode of communication and delivered in a manner that the participant is most likely to understand.

• Each participant’s right to the dignity of risk in decision-making is supported. When needed, each participant is supported to make informed choices about the benefits and risks of the options under consideration.

• Each participant’s autonomy is respected, including their right to intimacy and sexual expression.

• Each participant has sufficient time to consider, review and seek the advice of their options, at any stage of support provision, including assessment, planning, provision, review and exit.

• Each participant’s right to access an advocate (including an independent advocate) of their choice is supported, as it is their right to have the advocate present.

Independence and Informed Choices Management

• It is everyone’s right to choose their own personal, gender, sexual, cultural, and religious identity. It applies to people with disability too and they can make their decision regardless of their situation.

• Participants have the right to make their own decisions, to be free, live the life they choose and have the same rights and freedoms as any other member of the community.

• Participants and their carer will be advised by Access Foundation WA about other services or agencies either in the organisation or outside the organisation to be able to make informed decisions.

• If the participant is assessed as not capable of making his or her decision, a substitute decision-maker will be required and Access Foundation WA will support them either formally or informally.

• In the case that a participant is assessed as not being capable of decision making, different people would be able to be nominated as a substitute by their priority as below:

• Any guardian who is appointed by an authority

• Anyone who has a continuing relationship with the participant

• An unpaid carer who has been arranged the care regularly

• A close friend or relative

Right to Access an Advocate Policy

• New participants will be consulted about their right to use advocates via the Participant Handbook.

• Access Foundation WA will consult new participants about the roles of advocates and how to get an advocate.

• It is a participant’s right to choose their advocates, change their advocates or withdraw their advocate’s authority

• Access Foundation WA participant’s decision making, and service planning will be coordinated with the participant’s advocate

• Any assistance by an advocate should be registered and documented

• If a participant doesn’t have anyone to accept their advocacy, Access Foundation WA will introduce someone as an advocate.

Free Advocate Management

• Advocacy is the act of helping a vulnerable group of people to be heard in a decision that may affect their life.

• The participant can nominate an advocate if they need to via Form13.Advocate Nomination Form.

• There are different types of advocacies as follows:

• Individual advocacy: is to prevent and address any discrimination or abuse a person with a disability

• Systematic advocacy: is influencing and changing the systems to benefit people with a disability as a group within the society

• Family advocacy: is the act of a family member advocating on behalf of a person with a disability

• Group advocacy: is the act of advocating for people with disability in a group including people who are sharing an accommodation

• Citizen advocacy: when people of a community advocate on behalf of a person with a disability

• Legal advocacy: is the act of present advocacy by a lawyer including giving legal advice, positive changes to legislations to people with disability

Participant Consent Policy

• Participant’s rights are as follows:

• The participant should make an informed decision before giving the consent

• If any participant requires additional time for any consent, enough time should be provided to make the best decision and have enough time for consultation

• Withdrawal of consent is part of the participant’s right at any time

• Participants can evaluate the risks associated with their decision and take assessed risks

• Access Foundation WA responsibilities for participant consent are as follows:

• A participant consent using Form18. Participant Information Consent Form will be obtained in case the decision is related to any medical or dental treatment, behaviour support and accommodation arrangements

• Before disclosure of any personal information to other parties consent is required.

• Any personal information could be disclosed without consent only if there is one of the following:

• The person is at risk of harm or injury; or

• It is required by law

Purpose

• The purpose of this policy & procedures is that each participant accesses supports free from violence, abuse, neglect, or exploitation. People should always feel safe regardless of their gender, disability, age and sexual orientation.

Scope

• This document applies to:

• All Access Foundation WA staff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• https://www.legislation.gov.au/Details/C2019C00332Incident Management Policy and Procedure

• National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Disability Discrimination Act 1986

• Racial Discrimination Act 1975

• Sex Discrimination Act 1984

• Age Discrimination Act 2004

• Crimes Act 1958

Policy & Procedure

Violence, Abuse, Neglect, Exploitation Policy

• It is the Access Foundation WA’s commitment to ensure that everyone feels safe, treated fairly and the organisation is free of abuse, exploitation and neglect.

• Participants with a lack of communication should be well supported to detect and prevent abuse.

• TheManaging Director deals with the abuse, exploitation, and neglect reports seriously and confidentially and takes the best measures to mitigate the issue and take actions accordingly.

• Incident Management Policy and Procedureare established to investigate and report the abuse, exploitation, and neglect related issues.

• Training is required for everyone in Access Foundation WA about all policies and procedures and relevant rules, regulations,and guidelines to recognize, prevent and minimise abuse, exploitation, and neglect through the induction system.

• One trained Manager should be appointed to deal with any abuse related issues.

• Everyone has a responsibility about abuse, exploiting and neglect as follows:

• The victim should be supported by all staff, workers and members of the organisation

• If required, the responsible Manager should inform relevant authorities, carers of the victim including their family and guardians or their substitute decision-makers (if applicable)

• If a participant doesn’t have any guardian or an advocate, it is the provider’s responsibility to organise an advocate or assist the other providers and support coordinators to organise and advocate. For more information refer to Right to access an advocate.

• All staff, workers, and witnesses should cooperate with relevant authorities in the process of investigation.

Violence, Abuse, Neglect, Exploitation Management

• Following measures could be taken for responding to abuse, exploitation, and neglect:

• Incident Management Policy and Procedureare established to investigate and report the abuse, exploitation, and neglect related issues.

• Ensure that everyone feels confident to raise a complaint about abuse, exploitation, and neglect without fear of being disadvantaged by following complaint management procedures.

• Any reports of abuse, exploitation and neglect will be treated seriously and sympathetically and will be investigated thoroughly and confidentially using Incident Management Policy and Procedure.

• Disciplinary action including termination from work will be taken against anyone found to be guilty of abusing, exploiting, and neglecting participants, staff and workers or volunteers.

• Access Foundation WA ensures that everyone in the organisation including workers and participants are working in a workplace free of bullying, harassment, and discrimination. In this policy & procedure, the standards for having a better workplace for both workers and participants with a positive environment will be described.

Scope

• This document applies to:

• All Access Foundation WA staff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

• It is also applicable when people are interacting in the public area and/or when providing services

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Disability Discrimination Act 1986

• Racial Discrimination Act 1975

• Sex Discrimination Act 1984

• Age Discrimination Act 2004

Policy & Procedure

Bullying, Harassment and Discrimination Policy

• Access Foundation WA is committed to promoting an environment free from bullying, harassment and discrimination for all employees and participant

• Access Foundation WA is committed to implementing training and awareness-raising strategies to ensure that all workers and staff are aware of their rights and responsibilities regarding bullying, harassment and discrimination

• Access Foundation WA is committed to complying with all relevant legislation and industry standards

• All forms of discrimination, harassment and bullying by or toward workers, the participant is considered unacceptable and will not be tolerated under any circumstances.

• Everyone has the same right and responsibilities relating to sexual harassment.

• Any discrimination, bullying, harassment and/or discrimination should be discussed with the Managing Director or by submitting an incident through the Incident Management Policy and Procedure.

• Victimizationincludes threatening any of who has made a complaint or helped another person to make complaints including the ones who may be involved in the investigation process is subject to discrimination, harassment and/or bullying.

• Breach of this policy & procedure in any form may lead to termination of employment.

Sexual Harassment

• Sexual harassment can be any of the following activities:

• Repeated unwilling requests of going out

• Request for sex

• Insult or taunt of sexual nature

• Sending sexual text messages

• Viewing offensive pictures and objects

• Touching or hugging someone unwillingly

• Access Foundation WA haszero tolerancefor sexual harassment, meaning that just one attempt is enough

• At Access Foundation WA, in the workplace or between colleagues and participants at work or outside the workplace, everyone is covered against sexual harassment.

• Everyone should be treated with respect in Access Foundation WA.

Bullying

• Bullying can happen in various types of behaviour including:

• Sarcasm

• Isolation

• Threat, abuse, or shout

• Unconstructive criticism

• Constant pressure on the workers

• Bullying is against Work Health and Safety Laws. There are different forms of bullying including face to face, on social media, in emails, on the phone and unfair work activities.

Discrimination

• Discrimination can happen either directly or indirectly. Direct discrimination happens when a person is treated more unfair than other people in a similar situation while indirect discrimination happens when a person is being disadvantaged by imposing a practice against a lawful characteristic.

• Lawfulcharacteristics are as follows:

• Any types of disability or disease

• Having status of a carer or a parent

• Race, skin colour, nationality, culture, ethnic background

• Religion

• Pregnancy and breastfeeding

• Sexual orientation

• Political beliefs

• Marital status
  
  

• Treating a person unfair because they havelawful characteristics that you don’t like, is against the law and could be a form of discrimination.

• Everyone should be recruited based on merits regardless of their characteristics. For example, they should be recruited based on their skills and abilities.

• Asking personal questions about their ethnicity, sexual orientation, disability or else, is against the law unless it is a requirement of the position.

• Any discrimination, bullying, harassment and discrimination should be discussed with the Managing Director or by submitting an incident through the Incident Management Policy and Procedure.

• Breach of this policy & procedure in any form may lead to termination of employment.

• Victimizationincludes threatening any of who has made a complaint or helped another person to make complaints including the ones who may be involved in the investigation process is subject to discrimination, harassment and/or bullying.

Preventive Responsibilities

• Preventive responsibilities of Access Foundation WA’s management team against bullying, harassment and discrimination are as follows:

• Train staff and workers in the policies & procedures and regulations to know their obligations via the Worker Handbook and Form08.Induction Checklist.

• Follow-up any harassment, bullying and discrimination complaints and investigate the incidents using the complaint and incident mangemange procedures.

• Ensure that no discrimination takes place in the process of recruitment and it’s based-on merit points.

• Enhance the complaint resolution process by following complaint management procedures.

• Take quick steps if becoming aware of any inappropriate behaviour.

• Preventive responsibilities of Access Foundation WA workers against bullying, harassment and discrimination are as follows:

• Follow the guidelines defined by the management regarding bullying, harassment, and discrimination

• Support victims if become aware of any bullying, harassment, and discrimination by having meetings with them and ensuring them that adequate measures will be taken

• Ensure that confidentiality is followed in handling complaints and if they become aware of any harassment, bullying and discrimination by completing Form19.Privacy & Confidentiality Agreement.

Staff and Workers Right

• It is staff and workers’right to:

• Be recruited on a merit base, not by personal characteristics

• Work in a safe environment free from bullying, harassment and/or discrimination

• Be able to raise complaints without fear of victimisation

• Work in an environment without the restriction of any kind related to their ethnicity, religion, disability and/or sexual orientations.

Purpose

• The aim of this policy & procedure is that each participant’s support is overseen by robust governance and operational management systems relevant to the size, and scale of Access Foundation WA and the scope and complexity of supports delivered.

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• Corporations Act 2001

• The Australian Consumer Law

• NDIS Terms of Business

• NDIS Guide to Suitability

• Australian Accounting Standards

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Quality Management Policy & Procedure

• Form05. Business Plan

• Form17.Legislative Compliance Register

• Form29.Conflict of Interest Register

Policy & Procedure

General Information

• An effective system is in place for Access Foundation WAto manage and support the business accountability, effectiveness and supervision through Internal Audit, Management Review Meeting, and participant feedback system, which ensures that:

• Access Foundation WAis compliant with the regulation and legislation

• Support and development of its staff and workers.

• High quality and safer service delivery to the participant.

Management Responsibilities

• Access Foundation WAis managed by the Managing Director, who has assigned a management team.

• The ManagementTeam will ensure that the objectives and targets of the organisation are defined.

• It is the management team’s responsibility to ensure that business operations are aligned with the objectives and targets using Form05. Business Plan.

• A Management Review Meeting will be held by the management team to ensure that a high quality of services will be provided by Access Foundation WA to the participants, and there is an active communication channel in place.

• The responsibilities of the Managing Director are:

• Human Resources & well-being of the staff and workers

• Maintenance of the property

• Service delivery to the participant

• Strategic planning

• Ensuring that the policies and procedures are reviewed and updated

• Financial matters including payroll

• Staff and worker training remain the responsibility of the management team.

• Any issues related to the finance, IT and quality of service will be provided to the management team by all staff and workers, including customer complaints.

• In the management team meeting, stakeholders will be engaged if required to improve the service outcome. Stakeholders include participant, their families and carers, advocates, workers, service providers and government representatives.

SWOT Analysis

There are two types of environmental factors:

• External factors: the “opportunities” and “Risk” presented by the environment external to the organisation

• Internal factors: the “strengths” and “weaknesses” of the organisation

The Managing Director and Management Teamidentifies the key internal and external factors that are relevant to its purpose and its strategic direction which affect its ability to achieve the intended result(s) of its management system. Internal environmental factors are normally easier to control than external environmental factors.

External Environment Analysis

The managing Director and Management Teamscans the external environment to understand the external forces of change so that they may develop effective responses which secure or improve their position in the future. External Environment includes:

• Macro Environment

• Microenvironment

The Managing Director and Management Teamprepares a list of Opportunities and Threats in Form05. Business Plan.

Macro Environment includes the following factors:

• Legal/Political Factors: Government regulations and legal factors are assessed in terms of their ability to affect the business environment and trade markets. The main issues addressed in this section include political stability, tax guidelines, trade regulations, safety regulations, and employment laws.

• Economic: Through this factor, businesses examine the economic issues that are bound to have an impact on the company. This would include factors like inflation, interest rates, economic growth, the unemployment rate and policies, and the business cycle followed in the country.

• Social: With the social factor, a business can analyse the socio-economic environment of its market via elements like customer demographics, cultural limitations, lifestyle attitude, and education. With these, a business can understand how consumer needs are shaped and what brings them to the market for purchase.

• Technological: How technology can either positively or negatively impact the introduction of a product or service into a marketplace is assessed here. These factors include technological advancements, the lifecycle of technologies, the role of the Internet, and the spending on technology research by the government.

Microenvironment includes the following factors:

• Bargaining Power of Supplier: Assessing how easy it is for suppliers to drive up prices. This is driven by the number of suppliers of each key input, the uniqueness of their product or service, their strength and control over you, the cost of switching from one to another, and so on. The fewer supplier choices you have, and the more you need suppliers' help, the more powerful your suppliers are.

• Bargaining Power of Customer/Buyer: Assessing how easy it is for buyers to drive prices down. Again, this is driven by the number of buyers, the importance of each buyer to your business, the cost to them of switching from your products and services to those of someone else, and so on. If you deal with a few, powerful buyers, then they are often able to dictate terms to you.

• Power of Existing Competitors: What is important here is the number and capability of your competitors. If you have many competitors, and they offer equally attractive products and services, then you'll most likely have little power in the situation, because suppliers and buyers will go elsewhere if they don't get a good deal from you. On the other hand, if no one else can do what you do, then you can often have tremendous strength.

• The Threat of Substitute Products or Services: This is affected by the ability of your customers to find a different way of doing what you do – for example, if you supply a unique software product that automates an important process, people may substitute by doing the process manually or by outsourcing it. If a substitution is easy and substitution is viable, then this weakens your power.

• The threat of New Entrants to This Industry: Power is also affected by the ability of people to enter your market. If it costs little in time or money to enter your market and compete effectively, if there are few economies of scale in place, or if you have little protection for your key technologies, then new competitors can quickly enter your market and weaken your position. If you have strong and durable barriers to entry, then you can preserve a favourable position and take fair advantage of it.

Internal Environment Analysis

Strengths and Weaknesses of processes are identified by Managing Director using Form05. Business Plan.

The following questions should be asked while identifying strengths and weaknesses for each process:

Strengths

• What advantages does your organisation have?

• What do people in your market see as your strengths?

• What do you do better than anyone else?

• What unique or lowest-cost resources can you draw upon that others can't?

Weaknesses

• What could you improve?

• What should you avoid?

• What are people in your market likely to see as weaknesses?

• What factors lose you sales?

Developing Objective and Targets

• The business objective and targets are developed in Form05. Business Plan.

• The objectives are defined and the target for each item is determined. The objectives are to be:

• Specific: Target a specific area of improvement

• Measurable: a progress indicator is to be defined or suggested

• Achievable: Assuring that the objective is to be achieved

• Realistic: objective should be defined realistically in a way that could be followed

• The management team is responsible for:

• Ensuring Access Foundation WAisfollowing the organisational strategies

• Ensuring that there is appropriate service delivery in place.

• Ensuring that service integrity and quality is being assessed regularly.

• Providing leadership and supervision to the staff and workers to create an environment of innovation and positive relationships.

• Providing the services related to support and management of complex cases, including emergencies.

• Providing a proper service to the participant to maintain their satisfaction

• Access Foundation WA’s staff and workers are responsible for:

• Supporting participants with their life either in Access Foundation WA’sbases or their own home in a way that a valued lifestyle is developed for them.

• A good relationship with participants helps to provide a supportive environment

• Involving participants to make choices in operations related to their care and life and reviewing and updating their goals.

Business Insurance

• According to the NDIS Quality and Safeguards Commission, all NDIS registered service providers need:

• Public liability insurance: A certificate of currency for current insurance that meets the minimum level of cover commensurate to the scope of the provider. Providers should seek professional advice as to the type and amount of insurance that is necessary.

• Professional indemnity insurance: A certificate of currency for current insurance that meets the minimum level of cover commensurate to the scope of the provider. Providers should seek professional advice as to the type and amount of insurance that is necessary.

• Personal accident insurance or worker's compensation insurance: if a provider has staff. A certificate of currency for current insurance that meets the minimum level of cover commensurate to the scope of the provider. NDIS providers should seek professional advice as to the type and amount of insurance that is necessary.

• Comprehensive car insurance: if provider is providing travel and transport arrangements to the participants, must ensure that car being used for this purpose has a comprehensive car insurance.

Compliance Management

• Access Foundation WAhas established, implemented and maintained a process to identify legislative requirements and have access to all legal and other requirements that apply toAccess Foundation WA’s operations using Form17.Legislative Compliance Register.

• The register will be reviewed and updated once a year. The evaluation will be carried out by the Management Team and the results will be reported to Managing Director.

• If there are any changes/ updates in the legislative requirements, relevant policies and procedures will be reviewed and revised accordingly.

• All Workers are responsible for managing compliance within their areas of influence by following the current policies and procedures. The changes and updates will be communicated to the workers and staff through meetings or receiving email updates.

• Legislative compliance is maintained and updated through:

• Reviewing NDIS Commission Website

• Ongoing consultation and communication with Industry Specialists/Legal representatives

• Legal updates provided by government publishing

• External third-party audit

Delegation of Responsibility and Authority Policy

• This policy identifies the requirements for delegated responsibility and authority to another suitable person in the absence of a usual position holder in place.

• Workers with the same qualifications and experience will be assigned as a delegate to ensure the same level of support is provided to the participants and adequate training will be provided to them.

• Delegation of Responsibility and Authority Policy within Access Foundation WAis intended to achieve the following objectives:

• Ensure supports are provided based on the least intrusive options.

• Ensure the efficiency and effectiveness of support.

• Ensure that workers have been provided with the level of authority necessary to discharge their responsibilities.

• Better understanding of supervision and delegation responsibilities.

• Feel confident in working safely with the participant.

• All delegates shall act in good faith using all reasonable skills when exercising delegated authority.

• The requirements set out in this policy apply to all workers. Delegation is managed through Form28.Delegations of Authority Registerand Form86. Delegation of Authority declaration form.

Conflict of Interest Policy

• Staff and workers should avoid any conflict of interest in their duties and personal interests.

• All employees will act in the best interests of participants and other customers, ensuring that participants are informed, empowered and able to maximise choices and controls. Staff members will not (by act or omission) constrain, influence or direct decision-making by a person with a disability and/or their family to limit that person’s access to information, opportunities, and choices and controls.

• None of the staff and Workers shall misuse the position that ends to any personal benefit for themselves or anyone associated with them.

• The priority of all staff and workers shall be the advantage of the Access Foundation WA.

• Workers and staff should not misuse Access Foundation WAproperty, information, and data for their personal use.

• Any conflict of interest should be reported to the management team to avoid any possible conflict. If any conflict is recorded in Form29.Conflict of Interest Register, a Form34.Conflict of Interest Declaration Form must be completed.

• Everyone in Access Foundation WA including workers, staff, management team and contractors shall have considered their actions as follows:

• What kind of conflict with my duties will be perceived?

• Is there any personal benefit involved in their action of duties?

• Is my involvement in any of the actions reasonable?

• Neither we nor our worker will accept any offer of money, gifts, services, or benefits that would cause any one of us to act in a manner contrary to the interests of an NDIS participant. Further, staff and workers will not have any financial or personal interest that could directly or indirectly influence or compromise the choice of provider or provisions of support to a participant. This includes the obtaining or offering of any form of commission by staff and workers or us.

Management Review Meeting

• In the annual management review meeting using Form25.Management Review Meeting Minutes, the following agenda shall be included:

• Any reported incidents in the incident management system and corrective actions,

• Any reported complaints and the root cause of this complaint

• The outcome of the internal and external audit

• The status of the corrective actions shall be checked regularly until it is finalised and verified by the management.

• Following decisions shall be taken in the management review Meeting:

• Any required changed

• Any required additional resources

• Any improvement opportunities to prevent incidents and complaints occurrence

Use of Care for Travel and Transport arrangement

It is Blissful4You’s responsibility to ensure that all vehicles being used for travel and transport arrangements for participants is registered and also insured for business purposes.

Purpose

• This policy andProcedure involve identifying and managing risks as part of risk management. There is a wide range of risks involved in the risk management process, including operation, workers, and participants’ risk. Risks are inevitable, but risk management aims to control the risks and mitigate them. Risk Management has a wide range of benefits from a reduction in downtime to increasing innovation, quality, and efficiency as a result of continuous improvement.

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Word/Term	Definition
Risk	Risk is any internal or external situation or event that has the potential to have a negative impact by causing harm to people associated with the organisation or participant, preventing the organisation from successfully achieving its outcomes and delivering its services, reducing the organisation’s viability, or damaging its reputation.
Risk Assessment	Process of analysing and evaluating the likelihood and impact of potential risks
Risk treatment	A measure, work process or system that eliminates risk, or if this is not possible, reduces the risk so far as is reasonably practicable.

c

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• Corporations Act 2001

• The Australian Consumer Law

• NDIS Terms of Business

• NDIS Guide to Suitability

• Form01.Risk Register

• Form14. Hazard identification report

Policy & Procedure

Occupational Health and Safety Policy

Access Foundation WAis committed to supporting the health, safety, and welfare of all people we employ and to the people affected by our undertakings.

Access Foundation WAcontinuously supports improvements in workplace health and safety by adopting a planned systematic approach to Occupational Health and Safety. This approach includes risk management and consultation.

As part of our overall commitment Access Foundation WAis committed to:

• Complying with all relevant OH&S legislation, regulations, codes of practice, and guidelines.

• Documenting, implementing, and communicating OH&S policy to all employees.

• Regularly monitoring and revising our policy by legislative and organisational changes or as appropriate.

• Establishing measurable objectives and targets aimed at eliminating work-related injury and illnesses.

• Provide adequate training, information, instruction and supervision to all employees and visitors to ensure work is carried out safely

• Ensure all accidents, hazards and near misses are recorded and reported and an investigation is carried out to determine possible causes.

• Maintain a safe working environment by reporting hazards or unsafe work practices promptly to their manager or supervisor.

• Report all workplace injuries, near misses and illnesses caused by work immediately to your manager.

Risk Assessment Process

• Access Foundation WAtake its responsibility to identify and manage all types of organisational risks - including compliance, financial, safety, health, environmental and operational risks - very seriously.

• Access Foundation WAwill engage with staff and workers and relevant stakeholders to identify risks to operations and to communicate risk management strategies.

• Risk management shall:

• Be embedded within its operations, processes, and systems

• Have clear accountability, ownership, and governance

• Be systematic, transparent, and consistently applied

• Include effective consultation and communication

• Support evidence-based decision-making; and

• Facilitate continual improvement.

• To manage and control risks and opportunities, the company uses Risk Management Model shown below:

• Where relevant, the risk management system includes measures for the prevention and control of infection and outbreaks.

• Supports and services are provided in a way that is consistent with the risk management system.

• Appropriate insurance is in place, including professional indemnity, public liability and accident insurance.

Identifying Risk to Participants, Workers and The Provider

• A list of organisational risks including compliance, financial, safety and health, environmental, and operational risks (risks to participants, financial and work health and safety risks, and risks associated with the provision of supports) is identified in Form01.Risk Register.

• All areas of the organisations will be addressed, and can be grouped according to the following broad categories:

• Strategic

• Compliance

• Financial

• Operational

• Participant

• Staff and Workers

• Specific risks to each participant are identified using Form27.Initial Assessment and Support Plan.

• It is all staff and workers s’ responsibility to report any risk to participants, workers and the provider to their relevant supervisor or manager.

• New hazards can be identified using Form14. Hazard identification report.

Assessing the Risk

• Assess risk according to the consequences and likelihood of the hazard/aspect occurring. The level of experience and the capabilities of all workers is taken into consideration throughout this process. The risk rating is recorded on Form01.Risk Register.

Risk Calculation Process

Steps 1 – Estimate the consequences

Step 2 – Estimate the likelihood

Step 3 – Determine the risk rating

Treatment of the Risk or Control Measure

• All identified risks are to be assessed, and treatment shall be taken for them as a part of the relevant person responsibility. Management or treatment options for risks expected to have positive outcomes include:

• Starting or continuing an activity likely to create or maintain this positive outcome

• Modifying the likelihood of the risk, to increase possible beneficial outcomes

• Trying to manipulate possible consequences, to increase the expected gains

• Sharing the risk with other parties that may contribute by providing additional resources which could increase the likelihood of the opportunity or the expected gains

• Retaining the residual risk.

• Management options for risks having negative outcomes look similar to those for risks with positive ones, although their interpretation and implications are completely different. Such options or alternatives might be:

• to avoid the risk by deciding to stop, postpone, cancel, divert, or continue with an activity that may be the cause for that risk

• to modify the likelihood of the risk trying to reduce or eliminate the likelihood of the negative outcomes

• to try modifying the consequences in a way that will reduce losses

• to share the risk with other parties facing the same risk (insurance arrangements and organisational structures such as partnerships and joint ventures can be used to spread responsibility and liability)

• to retain the risk or its residual risks

Review and Monitor of Risk assessment

• The management team ensures that the risk assessment register (Form 01) is regularly reviewed to check their effectiveness and, as necessary, revised.

• Support delivery is linked to a risk management system which includes:

• Incident Management

• Complaints Management

• Work Health and Safety

• Human Resource Management

• Financial Management

• Information Management

• Governance

• The effectiveness of risk assessment shall be checked on an ongoing basis and should be revised if required. The revision could take place in the following circumstances but is not limited to these:

• Current control measure is not effective

• A change has happened in the risks or hazard

• An extreme incident occurs

• If the consultant or auditor believes that a revision is required

• Provide regular reports and updates to assure that risks are being appropriately managed and treated.

Different types of Risk and Mitigation

Purpose

• This policy & procedure aims to provide participants with benefits from a quality Management system that provides continuous improvement involving:

• Conducting participant survey and valuing their feedback

• Understanding strengths and weaknesses

• Finding the requirements of the participants and addressing them

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

N/A

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Corporations Act 2001

• The Australian Consumer Law

• NDIS Terms of Business

• NDIS Guide to Suitability

• Form16. Internal Audit Schedule

• Form15. Internal Audit report

• Form03.Improvement Report Form

• Form25. Management Review Meeting Minutes

Policy & Procedure

Quality Policy

• It is Access Foundation WA’s commitmentto incorporate the requirements of the standard into the business with a continuous improvement system. These commitments are as follows:

• Ongoing improvement and revision of the policies & procedures, processes, and services

• Ensuring that all policies & procedures comply with the relevant legislation, obligations, and standards

• Maintaining, monitoring, and improving the stakeholder’s satisfaction and creating a close relationship with staff and workers

• Conduct regular internal audits to find and resolve any nonconformities and prevent the recurrence

• Train the staff and workers on an ongoing basis to meet the requirements

• The ManagementTeam have responsibilities against the continuous improvement as follows:

• Provide the atmosphere of involvement for staff and workers to improve company objective & Target

• Ensure that services and supports provided to the participants comply with the requirement of NDIS standards and guidelines.

• Reviewing and implementing a risk management plan

• Reviewing organisational objectives and targets to ensure that Access Foundation WAoperations are aligned with them

• Train staff and workers to implement policies & procedures in the Access Foundation WA’s operations

• Identify organisation’s objectives and targets

• Reviewcomplaints and corrective actions to prevent a recurrence

• Review incidents and corrective actions to prevent a recurrence

• Staff and workers have responsibilities against the continuous improvement as follows:

• Report any improvement opportunities to the management team

• Participate in the internal audits if required

• Ensure that customer feedback and complaints are reported to the management team

• Ensure that incidents are reported to the management team

Internal Audit

• InternalAudits will be conducted to determine whether business operations and processes are compliant with the NDIS standards, guidelines, and relevant legislation. The internal Auditor should be trained and shall be independent of the process that they are auditing.

• The Internal Audit should be conducted every year to determine the compliance of the organisation with NDIS standards using Form16. Internal Audit Schedule. Any non-conformities in the management system of Access Foundation WAshould be recorded in Form15. Internal Audit report and Form03.Improvement Report Form. Then, this record should be reported to Access Foundation WA’s management team for implementing corrective actions. In the management review meeting, the outcome of the audit should be reviewed, and corrective actions shall be checked.

Regular Internal Activities

• The following activities shall be conducted as frequently as specified in the table below:

Continuous Improvement

• All policies & procedures of Access Foundation WAwill be reviewed every year by the management team as well as the feedback of workers and all stakeholders.

• The Access Foundation WA’s satisfaction will be assessed based on customer and staff feedback to find areas of improvement.

• Continuous improvement will be undertaken by considering outcomes, risk-related data, evidence-informed practice, incident management and feedback from participants and workers. For this purpose, Form03.Improvement Report can be used.

• Internal audit and management review meetings are also conducted annually to ensure the continuous improvement of supports and services provided by Access Foundation WA.

• Access Foundation WA’s staff/management will continue to review and update all policies, procedures and related documentation to ensure appropriate customization is addressed to adhere to our specific operational practices. This includes rollout to the NDIS Commission or any other changes.

Purpose

• The purpose of this document is to ensure that participants information is properly recorded, identified, current and kept confidential. Management of each participant’s information ensures that it is identifiable, accurately recorded, current and confidential. Each participant’s information is easily accessible to the participant and appropriately utilised by relevant workers.

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• Form18. Participant Information Consent Form

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

Policy & Procedure

Information Management

• Access Foundation WA is committed to protecting the security of its information and information systems.

• Documents are stored with appropriate use, access, transfer, storage, security, retrieval, retention, destruction, and disposal processes. This is addressed by having passwords and antivirus in place for electronic devices. For hard copies (if applicable), the files will be stored in secured cabinets and access will be provided to the relevant workers.

• According to the above direction all staff and workers are committed to:

• Use of all reasonable, appropriate, practical, and effective security measures to protect our important processes and assets to achieve our security objectives.

• Protecting and managing information assets to enable us to meet our contractual, legislative, privacy and ethical responsibilities and satisfy applicable IS requirements and legal requirements

• Protect the system against unauthorized access.

• Report and investigate information security breaches.

• Record keeping processes underpin day-to-day actions and Access Foundation WAhas an ongoing commitment to continuous improvement in this area.

• A confidentiality agreement has been signed by all workers using Form19.Privacy & Confidentiality Agreement.

• Records including all completed forms and templates either in hard copy or electronically are maintained for 7 years. For instance, complaint records and incident records shall be kept for 7 years.

• Information Management system should be in a way that:

• limit the access to the information

• the computer should be always password locked

• modems shall have security in place

• a strong password shall be applied to the wireless network

• All personal information of participants staff and workers shall be:

• Safely stored to restrict the access for any misuse

• Not shared with any third party unless the participant or staff and workers has given consent

• Retained for a limited period

• Destroyed properly if not required, for example, shredding

• A printed version of the personal confidential information shall be stored securely when not in use, for example in a lockable cabinet.

• Information security shall be treated as a vital part of the system.

• The Managing Director can conduct a random information security evaluation.

• Social media for marketing should be used by authorised people.

• Confidential information including personal information shall not be posted on social media.

• Portable devices including smartphones, laptops and portable storage devices shall be password locked.

• During the intake process (including interviews and meetings with the participant), each participant is informed of how their information is stored and used, and when and how each participant can access or correct their information and withdraw or amend their prior consent.

Passwords Policy:

• Always strong password shall be used. It means, it should be at least 8 characters including

• Lower case letter (abcdefghi….)

• Uppercase letter (ABCDEFGHI…)

• Numbers (1234567890)

• Symbols (! @#$%^&*()_)

• The following password elements are prohibited:

• Common elements (i.e., words, names, sports, movies & shows, groups, songs, etc.)

• Elements relating to the user (i.e., user id, graduation, birthdays, phone numbers, pets, etc.)

• Keyboard patterns (i.e., 1q2w3e4r)

• Repeating patterns (i.e., ah*fJDS1, ah*fJDS2, etc.)

• The following practices are prohibited:

• Recording user IDs or passwords on paper stored in a secure environment

• Group accounts or shared passwords (passwords provide accountability, user to the system)

• Distribution of passwords by e-mail or other insecure methods (i.e., fax)

• Use of the same password on multiple systems

• Passwords should be regularly changed, for example, every 6 month

• Passwords should not be kept on a piece of paper lying around

Participant Information Consent

• Each participant’s consent is obtained to collect, use, and retain their information or to disclose their information (including assessments) to other parties, including details of the purpose of collection, use and disclosure. Form18. Participant Information Consent Form will be used for this purpose.

• Each participant is informed in what circumstances the information could be disclosed, including that the information could be provided without their consent if required or authorised by law.

• Participant’s consent rights are as follows:

• The participant should make an informed decision before giving the consent

• If any participant requires additional time for any consent, enough time should be provided to make the best decision and have enough time for consultation

• Withdrawal of consent is a part of the participants right at any time

• Participants can evaluate the risks associated with their decision and take assessed risks

Purpose

• The purpose of this policy & Procedure is to set out how a person can provide feedback and makecomplaintsaboutanyaspectofAccess Foundation WA’soperationsandtheprocessthatAccess Foundation WAwill taketo acknowledge, assess and resolve the complaint in a fair, efficient and timely manner.

• This document outlines the policy & Procedure of making complaints and providing feedback to Access Foundation WA about their operations and the processes.

• The responsibility of effective implementation of complaint management procedure is with the Managing Director of their delegate.

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants and their families

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018

• Effective Complaint Handling Guidelines for NDIS Providers

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Form02.Complaint Report Form

• Form03.Improvement Report Form

Policy & Procedure

Feedback and Complaint Policy

• The Best practices and continuous improvements that are promoted by the management team create a supportive and respectful culture in Access Foundation WA that supports the workers, stakeholders, and participants to be open to make complaints and feedback and report any issues.In the performance assessment of the management team, this will be assessed and reviewed.

• Access Foundation WAis committed tohandling all complaints and feedback until it is resolved completely.

• The information related to the complaints and feedback will be dealt with confidentially in a way those are discussed directly with involved people.

• If the consent has been provided, a third party would be able to lodge complaints and feedback on behalf of another person.

• Tracking and analysing feedback and complaint data could identify any ongoing issue. As a part of the continuous improvement process, the feedback, complaints, and dispute resolution will be discussed in management team meetings regularly.

• Information about this policy & Procedure will be shared with any participant or stakeholder wishing to lodge feedback.

Complaint Handling (Easy-To-Read Version)

• Quality is about receiving good services that:

• meet the needs of the participant

• give people with disability choice and control.

• We make sure our workers:

• give good quality services and supports

• keep people with disability safe

• We protect any personal information people give us – we keep your information private.

• You can complain about your services and supports when:

• something has gone wrong

• something is not working well

• something has not been done the right way

• something makes you unhappy

• you have been treated badly.

• What do we do about complaints?

• We listen to complaints

• help people fix their complaints

• teach workers about the best ways to handle complaints.

• How do you make a complaint to us?

• You can call us OR email us

• You can call us between 9 am and 5 pm, Monday to Friday.

Feedback and Complaint Management

• In the worker’s induction, all workers will be trained in this policy &procedure to provide the stakeholders with the information related to the feedback, complaints, and compliments. For this purpose, the Worker handbook is also used.

• Continuous improvement is an important part of the team meeting agenda covering workers and participant feedback and complaints. Complaints management is also on the management review meeting Agenda.

• If requested by workers, this information will be provided to them and will be displayed in Access Foundation WA’s premises at all times.

• A variety of formats including an easy English version as well as translated versions of the information related to the feedback and complaints will be provided to stakeholders including workers and participants. Interpreters and referrals are available, too.

• Workerswill provide all participants, their families, and carers with information when they first access the service and, throughout service delivery, remind them of the policy and their right to make a complaint without fear of affecting their service.

• All participants, their families and carers will be provided with the relevant policies &Procedures and their right to make complaints in the commencement of service as well as throughout the service delivery by Access Foundation WAworkers. For this purpose, the Participant handbook is also used.

• The roles and responsibilities of the workers when a complaint is received as well as their awareness of the policy & Procedure will be assessed in the performance reviews. If required, additional in-house training, on the job training and formal training will be provided. Managers and supervisors will be monitoring this.

• The general principles guiding actions under the NDIS Act also describe the rights of people with disability to:

• Realise their potential for physical, social, emotional, and intellectual development.

• Be supported to participate in and contribute to social and economic life to the extent of their ability.

• Be supported to exercise choices about taking reasonable risks in pursuit of their goals and the planning and delivery of their supports.

• Be respected for their worth and dignity and to live free from abuse, neglect, and exploitation.

• Be able to determine their own best interests, including the right to exercise choice and control to engage as equal partners in decisions that will affect their lives to the full extent of their capacity.

• Have their privacy and dignity respected.

• Have the role of families, carers and other significant persons in their lives acknowledged and respected.

• Have access to advocates and supports which promote innovation, quality, continuous improvement, contemporary best practice, and effectiveness.

Feedback Management Process

• Any stakeholder will be able to provide feedback at any time through:

• Workers

• Management team

• Public email address

• Mail

• Phone contact

• A Form03. Improvement Reportwill be completed by the receiving worker or the management team if the feedback is provided verbally.

• Support and assistance (e.g.,involvementofasupportperson,interpreter,or advocate) will be provided to people who should participate in the feedback mechanism if required.

Complaints Management Process

Receive and Record

• For an easy resolution without recourse to the Procedure of complaint management, individuals are encouraged to contact Access Foundation WAto lodge a complaint.

• Access Foundation WAwill handle all complaints until it is resolved completely.

• The complaint could be made by individuals at any time to the NDIS Commission, the Health and Community Services Commissioner.

• Individuals could use an advocate of their choice if they like to act on their behalf. The advocate could be a family member or friend or sourced from the National Disability Advocacy Program.

• Workers will:

• Listen – openly and nicely to the complaint and the raised issue.

• Ask – what is the outcome that the complainant is seeking.

• Inform – the complainant about the complaint process, timing, and realistic expectations.

• Be accountable –show empathy toward the complainant or affected person and ensure that all commitments are made.

• Assess – the situations that cause any danger or require any specialised response.

• As the first step of complaint resolution, the management team will discuss the complaints with the other party involved in the complaint.

• The complaint will be treated as a formal complaint if it cannot be resolved promptly within a proper timeframe. If the individuals are not aware of their rights, the workers should advise them on how to lodge a complaint and assist them properly if they wish.

• A complainant needs to lodge a complaint using Form02.Complaint Report Form.

• Formal complaints can be lodged:

• either verbally or by sending a completed Form02.Complaint Report Form, in direct contact with a worker

• byemail

• Face to face with workers or management team

• by phone

• inwriting

• Individuals could use an advocate of their choice if they like to act on their behalf. The advocate could be a family member or friend or sourced from the National Disability Advocacy Program.

• The complaint will be referred to the Managing Director if it alleges an actual or possible criminal activity, abuse, or neglect. As per this policy & Procedure, the Managing Director will report the complaint to the NDIS and any other relevant authority for further investigation.

• The management teamwill:

• Record – all information that is relevant to the compliment or complaint, in its original and simplest form. Complaint records shall be kept for seven years from the day the record is made. Complaints are confidential.

• Store and protect – for more security, the complaint reports would only be accessible to relevant people.

• The management teamwill:

• Acknowledge – complaints are received within two business days to create a confident and trustworthy relationship with the complainant.

• Provide anonymity – If someone requested to be anonymous in their complaint application, their contact might not be accessible.

• Seek desired outcomes – It is important to be realistic in handling complaints. It means if required, the case should be referred to a suitable organisation to handle.

• Avoid conflict of interest – An independent investigator to the matter should be assigned, if necessary.

• Provide timeframes and expectations to the complainant where possible.

1. Resolve

• In resolving a complaint, Access Foundation WAwill:

• Involve the complainant –Informing them about the status of their complaint and discussing any miscommunicated information with them using Form03. Improvement Report Form

• Request additional information – if required and limit the timing by applying a time frame.

• Consider extensions – Only if there is any additional time required, with the provision of the explanation, communicate it to the complainant.

• Record – all actions and feedbacks regarding the complaint investigation in Form03.Improvement Report Form

• Focus – on the identified complaint matters only. A complaint is not an opportunity to review a whole case.

• For investigation and resolution, the management team will refer the complaint to the Managing Director, if they cannot resolve it.

• Investigation of complaints will not be conducted by a person about whom a complaint has been made. If required, the management team will determine the appropriate person to undertake the investigation.

• The management team will determine the appropriate person for the complaint investigation.

Communicate Resolution

• All complaints should be responded to by Access Foundation WA as soon as possible within 28 days from acknowledgment.

• An update to the complainant is required within 28 days if the complaint cannot be resolved in full. The date by which full response can be expected should be provided to the complainant. The response could be provided verbally in the first instance, but it shall be confirmed in writing.

• Any misunderstanding regarding the complaint could be supported by someone from Access Foundation WAif required. (e.g., interpreters, referral to advocates, etc.).

• Complaint resolution should include:

• Acknowledgement – of how the person is affected by the situation and what is their expectation of quality service

• Apology – In some cases can be a proper resolution or partial resolution to what people have suffered

• Answers – The information needed for addressing people’s concern or an explanation of what is happened; and

• Action – Agreement on actions that will make the concerns and service improvements

• Optionsforactionsrespondingtoacomplaintincludebutarenotlimitedto:

• explaining processes

• rectifying an issue

• providing an apology

• ongoing monitoring of issues

• training workers.

• Also, the below actions can be done:

• Before providing written advice, the outcome could be discussed verbally (if Possible), and further contact will be allowed after the receipt of the advice for conflict resolution.

• At the completion stage of the complaint investigation, the further action available to the complainant should be recorded. Another possible action could be to escalate the situation with an external agency or further revision within the organisation.

• Providing additional information that is not included in the first complaint as well as reviewing the soundness of the first investigation through further review.

• Opportunities will be identified from the complaint outcomes and distributed to the appropriate parties for ongoing improvement.

• Feedback from the complainant about the process should be sought.

Monitoring and Review

• Complaint and Feedback monitoring and review are on the Management Review Meeting Agenda, which will be discussed in detail. Form25.Management Review Meeting Minutes is used for this purpose.

• Following mechanisms would be followed by Access Foundation WA for measuring participants and stakeholders’ satisfaction:

• to receive suggestions for improvement and assess whether the participants are aware of their rights, regular participant’s feedback will be obtained.

• Management teammeetings may involveparticipantsandotherstakeholderrepresentatives

• The feedback, compliment and complaint system will be used to ensure continuous learning and accountability is in place by:

• Identification of opportunities for improvement as a result of a complaint

• Feedback analysis to monitor the service performance trends evaluation and identify improvement opportunities; and

• Continuous improvement plan assists in how the outcome of feedback is communicated with stakeholders. Positive feedback will be recorded for well-done activities.

• The risk assessment will be reviewed after any complaints.

• Complaint records will be kept for 7 years from the day the record is made.

• This Policy & Procedure will be reviewed annually.

Complaints Escalation and Dispute Resolution

• In case, if Access Foundation WAcould not satisfy the complainant, details of another agency will be provided to assist them in achieving the resolution.

• All complaints, including the escalated complaints, will be tracked from the same kind of report and the same method of communication will be applied.

• The participant can be made directly a complaint or feedback and send it to the NDIS Commission.

• A complaint can be made to the NDIS Commission by:

• Phoning:1800035544(freecallfromlandlines)orTTY133677.Interpreterscanbe arranged.

• National Relay Service and ask for 1800 035544.

• Completing a complaint contactform.

Purpose

• All accidents, incidents (including critical incidents) or near misses related to the provision of support or services needs further investigation to determine the root cause and implement the corrective actions.

• Each participant is safeguarded by the incident management system, ensuring that incidents are acknowledged, responded to, well-managed and learned from.

• The responsibility of effective implementation of incident management procedure is with the Managing Director of their delegate.

Scope

• This document applies to:

• All Access Foundation WAstaff and workers, whether permanent or casual, contractors, volunteers, or business partners.

• All participants, their families, and stakeholders in connection with the provision of NDIS supports or services.

Definitions

Relevant Documents, Legislations, regulations, and standards

• National Disability Insurance Scheme (Quality Indicators) Guidelines 2020

• National Disability Insurance Scheme Act 2013

• National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018.

• Incident Management System Guidance

• National Disability Strategy 2010-2020

• United Nations Convention on the Rights of Persons with Disabilities

• United Nations Universal Declaration of Human Rights

• Form04.Incident Report Form.

Policy & Procedure

Incident Management Process