Privacy and security
What does "held by provider" mean?
Recording that you hold a document instead of uploading it, and why we recommend it.
For much of your evidence you have a choice: upload a copy here, or record that you hold the document in your own system. For sensitive material we recommend the second option, and the product nudges you that way.
Why record rather than upload
- Privacy by design. The less personal information that moves between systems, the smaller the risk to the people you support.
- Auditors sight originals anyway. At Stage 2 an auditor generally looks at records in your own systems. A copy here does not replace that.
- You stay in control. Participant files, health information and identity documents stay where they already are.
What to record
When you mark something as held by you, record enough for an auditor to find it and for you to prove it exists:
- Where it is kept — the folder, the system, the locked cabinet
- The date you sighted or signed it
- Any reference, clearance number or expiry date
- Who is responsible for keeping it current
That is usually all an auditor needs from you in advance. They will ask to see the document itself during the audit.
What we recommend recording rather than uploading
- Identity documents such as passports, licences and Medicare cards — never upload these
- Behaviour support plans and clinical or health information
- Participant files, progress notes and risk assessments containing health details
- Worker screening clearances and working with children checks
What is usually fine to upload
Business documents that do not contain personal information about a participant: policies, blank templates, registers with initials only, insurance certificates, your business plan and your ABN record.
Either way, it counts
Recording that you hold a document counts towards your readiness in exactly the same way as uploading one. You are not penalised for protecting people's privacy — that is the point.
