Separating safely - protecting personal details 102-22060707

Item

Scenario

1

Changing address

If an address has already been incorrectly updated, please see Privacy Incidents immediately.

A customer submits a Separation details (MOD S) form online and attempts to update their address. The customer is unable to update their address online so calls Centrelink to have this completed. The Service Officer updates the customer's address but does not process the MOD S that is already on the file.

The privacy risk/s that may occur include:

• The new residential address is updated before the customer is unlinked from their former partner. This may result in the customer's new address flowing onto the ex-partner's record and being available to them on their online accounts if the update is not processed correctly. This places the customer's privacy at risk
• The postal address is not updated, and a rent certificate letter is sent to the postal address and is received by the ex- partner. This letter has personal information, including the customer's new address, placing their privacy at risk
• If the customer has family and domestic violence concerns, their personal safety may also be at risk

Note: action must be taken to protect the customer's personal information before the customer's address is updated. This may include processing the MOD S, changing PPE/PPU to 'no' or removing a nominee arrangement.

2

Medicare Group Card

A customer updates their address online and a message is displayed advising that the update will flow to other people on the Medicare card, at this point they stop the online update and call the agency. The customer notifies of a separation and requests an address change. The Service Officer updates the customer's address.

The privacy risk/s that may occur include:

• The customer's new address will flow to the former partner's record and be available through their online account. This places the customer's privacy at risk
• The customer may receive Medicare correspondence for their former partner. This places the former partner's privacy at risk
• If the customer has family and domestic violence concerns, their personal safety may also be at risk

Note: the Service Officer must move the customer to their own Medicare card before updating their address to avoid their details being available to their former partner.

3

Nominee Arrangements

A customer's partner is their correspondence nominee. The customer completes a Family Tax Benefit (FTB) claim online, identifying that they have separated and will be sharing care of the children. The customer does not recall the nominee arrangements being in place so did not answer the question within the FTB claim regarding nominees. As the customer has not requested a change to their nominee arrangement as part of the claim, no nominee responses flow through to the Service Officer processing the claim.

The privacy risk/s that may occur include:

• The nominee arrangements are not reviewed as part of the FTB processing, so the FTB grant letter is sent to the former partner. This letter discloses personal information about the customer, placing the customer's privacy at risk
• The nominee will continue to have access to the customer's personal information via online accounts and by calling or attending a Service Centre. This places the customer's privacy at risk
• If the customer has family and domestic violence concerns, their personal safety may also be at risk

Note: the Service Officer processing the FTB claim must review the record for linkages to other people such as nominee arrangements, and confirm with the customer if they want these ceased before processing the FTB claim.

4

Authorised Representative Arrangements

A customer has an existing child support assessment from a previous relationship. The disbursement payments go into the joint account the customer has with their current partner, who is also an authorised representative for the customer. After the customer separates from their current partner, the customer lodges an online child support assessment for their child. The customer indicates family and domestic violence concerns in the child support assessment.

A Service Officer is unsuccessful contacting the customer to discuss their new assessment. The Service Officer successfully contacts the former partner to discuss the information provided within the assessment.

The privacy risk/s that may occur include:

• As the Authorised Representative arrangement was not ceased, the customer's personal information may be disclosed to their former partner. This places the customer's privacy at risk
• The customer indicated family and domestic violence concerns in their assessment and the former partner was contacted. This places the customer's (and children's) personal safety at risk

Note: the Service Officer must not contact the former partner where family and domestic violence concerns are identified in child support assessments. The Service Officer must end the Authorised Representative arrangement before updating the customer's personal information.