1) Purpose

This policy ensures all care at NCD is clinically and culturally safe, free from racism and discrimination, and fully aligned with:

• AHPRA’s National Scheme Cultural Safety Strategy and definition ^{1 2}.
• Medical Board Code of Conduct obligations for respectful, non-discriminatory care and clear communication ³.
• The Australian Charter of Healthcare Rights (2nd ed.) ⁴.
• The NSQHS and NSQPCH Standards ^{5 6 7}.
• Australia’s Closing the Gap commitments and the National Aboriginal and Torres Strait Islander Health Plan 2021–2031 ^{8 9}.

2) Scope

Applies to all NCD staff, contractors, trainees, and students across in-clinic and telehealth services in NSW. It also governs all communications (verbal, written, digital, advertising, and social media).

3) Definitions

• Cultural safety: Determined by Aboriginal and Torres Strait Islander individuals, families and communities; requires ongoing critical reflection to deliver care free from racism ^{1 2}.
• Discrimination: Unlawful adverse treatment under Commonwealth and NSW law on grounds including race, sex, disability, age and other protected attributes ^{10 11 12 13 14}.
• Health information: As defined by HRIP Act 2002 (NSW) and the Privacy Act 1988 (APPs) ^{15 16 17}.

4) Legal & Regulatory Framework

Commonwealth: Racial Discrimination Act 1975; Sex Discrimination Act 1984; Disability Discrimination Act 1992; Age Discrimination Act 2004; Privacy Act 1988 (APPs).

NSW: Anti-Discrimination Act 1977; Public Health Regulation 2022; Health Records & Information Privacy Act 2002 (HRIP).

Regulators/Standards: AHPRA/Medical Board Code of Conduct; AHPRA Advertising & Social Media guidance; ACSQHC Charter & NSQHS/NSQPCH Standards; HCCC complaints and prohibitions.

5) Policy Statements

5.1 Zero Tolerance for Racism & Discrimination – NCD does not tolerate racism, harassment or discrimination in any form ^{1 2 10 11 12 13 14 18}.

5.2 Inclusive Language & Communication – Use respectful, inclusive language ^{19 20 21}.

5.3 Interpreters & Health Literacy – Accredited interpreters engaged per NSW PD2017_044 ^{22 23 24 25}.

5.4 Aboriginal & Torres Strait Islander Cultural Safety – Respect cultural authority, connection to Country and family ^{1 4 7 8 9}.

5.5 Disability, Age, Gender & Sexual Diversity – Care tailored with reasonable adjustments ^{12 14 19 21}.

5.6 Privacy, Images & Cultural Protocols – Health information managed under Privacy Act and HRIP Act ^{15 16 17 26 27}.

5.7 Advertising & Social Media – Compliance with AHPRA advertising and social media guidelines ^{28 29}.

5.8 Complaints & Escalation – HCCC complaints process accessible ^{30 31 32 33}.

6) Procedures

6.1 Intake & Identification of Needs – Ask patient preferences, pronouns, language, cultural needs ^{22 23 24 25 19}.

6.2 Communication & Consent – Plain language, translated materials, informed consent documented ^{3 4 22 23 24 25}.

6.3 Clinical Environment & Signage – Display NSW Code of Conduct and Charter ^{31 30 4}.

6.4 Documentation – Record cultural considerations, interpreter use, consent, accessibility adjustments ^{15 16 17 26}.

6.5 Staff Conduct & Social Media – Uphold cultural safety online and offline ^{28 29}.

7) Training & CPD

Mandatory annual cultural safety training, including Respecting the Difference (NSW) and reflective practice. Maintain CPD logs. Align with AHPRA Cultural Safety ACPD framework ^{34 35}.

8) Monitoring, Audit & KPIs

Quarterly audits of interpreter use, consent completeness, complaints, adjustments. Patient-reported measures (felt respected, understood info). Equity metrics across CALD and First Nations patients ^{5 6 7}.

9) Review

This policy is reviewed annually or sooner if laws or guidance change.

Sources

1. AHPRA, Cultural Safety Strategy, viewed 8 October 2025, https://www.ahpra.gov.au/About-AHPRA/Aboriginal-and-Torres-Strait-Islander-Health-Strategy ↩︎
2. AHPRA, National Scheme’s Aboriginal & Torres Strait Islander Health and Cultural Safety Strategy 2020–2025, viewed 8 October 2025, https://www.ahpra.gov.au/About-AHPRA/Aboriginal-and-Torres-Strait-Islander-Health-Strategy.aspx ↩︎
3. Medical Board of Australia, Good Medical Practice: Code of Conduct, viewed 8 October 2025, https://www.medicalboard.gov.au/Codes-Guidelines-Policies/Code-of-conduct.aspx ↩︎
4. ACSQHC, Australian Charter of Healthcare Rights (2nd ed.), viewed 8 October 2025, https://www.safetyandquality.gov.au/standards/charter-of-healthcare-rights ↩︎
5. ACSQHC, NSQHS Partnering with Consumers Standard, viewed 8 October 2025, https://www.safetyandquality.gov.au/standards/nsqhs-standards/partnering-consumers-standard ↩︎
6. ACSQHC, NSQHS Standards, viewed 8 October 2025, https://www.safetyandquality.gov.au/standards/nsqhs-standards ↩︎
7. ACSQHC, National Safety & Quality Primary and Community Healthcare Standards, viewed 8 October 2025, https://www.safetyandquality.gov.au/standards/primary-community-healthcare-standards ↩︎
8. Australian Government, Closing the Gap – National Agreement, viewed 8 October 2025, https://www.closingthegap.gov.au/national-agreement ↩︎
9. Australian Government Department of Health, National Aboriginal & Torres Strait Islander Health Plan 2021–2031, viewed 8 October 2025, https://www.health.gov.au/resources/publications/national-aboriginal-and-torres-strait-islander-health-plan-2021-2031 ↩︎
10. NSW Government, Anti-Discrimination Act 1977, viewed 8 October 2025, https://legislation.nsw.gov.au/view/html/inforce/current/act-1977-048 ↩︎
11. Commonwealth of Australia, Racial Discrimination Act 1975, viewed 8 October 2025, https://www.legislation.gov.au/Series/C2004A00274 ↩︎
12. Commonwealth of Australia, Sex Discrimination Act 1984, viewed 8 October 2025, https://www.legislation.gov.au/Series/C2004A02868 ↩︎
13. Commonwealth of Australia, Disability Discrimination Act 1992, viewed 8 October 2025, https://www.legislation.gov.au/Series/C2004A04426 ↩︎
14. Commonwealth of Australia, Age Discrimination Act 2004, viewed 8 October 2025, https://www.legislation.gov.au/Series/C2004A01237 ↩︎
15. OAIC, Australian Privacy Principles (APPs), viewed 8 October 2025, https://www.oaic.gov.au/privacy/australian-privacy-principles ↩︎
16. OAIC, Guide to Health Privacy, viewed 8 October 2025, https://www.oaic.gov.au/privacy/guidance-and-advice/guide-to-health-privacy ↩︎
17. NSW Government, Health Records & Information Privacy Act 2002, viewed 8 October 2025, https://legislation.nsw.gov.au/view/html/inforce/current/act-2002-071 ↩︎
18. HCCC, About, viewed 8 October 2025, https://www.hccc.nsw.gov.au/ ↩︎
19. Australian Government Style Manual, Inclusive language, viewed 8 October 2025, https://www.stylemanual.gov.au/writing-and-editing/inclusive-language ↩︎
20. Australian Government Style Manual, Accessible content, viewed 8 October 2025, https://www.stylemanual.gov.au/accessibility-inclusivity ↩︎
21. Digital NSW, Inclusive content, viewed 8 October 2025, https://www.digital.nsw.gov.au/policy/digital-design-system/inclusive-content ↩︎
22. NSW Health, Interpreters PD2017_044, viewed 8 October 2025, https://www1.health.nsw.gov.au/pds/ActivePDSDocuments/PD2017_044.pdf ↩︎
23. NSW Health, Health Care Interpreting Services, viewed 8 October 2025, https://www.health.nsw.gov.au/multicultural/Pages/health-care-interpreting-services.aspx ↩︎
24. Multicultural Health Communication Service, Guidelines, viewed 8 October 2025, https://www.mhcs.health.nsw.gov.au/policies ↩︎
25. Multicultural Health Communication Service, Translation service, viewed 8 October 2025, https://www.mhcs.health.nsw.gov.au/services/translation ↩︎
26. OAIC, Privacy guidance for health service providers, viewed 8 October 2025, https://www.oaic.gov.au/privacy/privacy-for-organisations/health-service-providers ↩︎
27. IPC NSW, Health Privacy Principles, viewed 8 October 2025, https://www.ipc.nsw.gov.au/fact-sheet-hrip-health-privacy-principles ↩︎
28. AHPRA, Advertising guidelines, viewed 8 October 2025, https://www.ahpra.gov.au/Publications/Advertising-resources/Legislation-guidelines.aspx ↩︎
29. Medical Board of Australia, Social Media Guidance, viewed 8 October 2025, https://www.medicalboard.gov.au/Codes-Guidelines-Policies/Social-media-guidance.aspx ↩︎
30. NSW Health, Code of Conduct Notices, viewed 8 October 2025, https://www.health.nsw.gov.au/publichealth/Public-Health-Regulation-2022 ↩︎
31. NSW Government, Public Health Regulation 2022, viewed 8 October 2025, https://legislation.nsw.gov.au/view/html/inforce/current/sl-2022-0475 ↩︎
32. HCCC, Complaints process, viewed 8 October 2025, https://www.hccc.nsw.gov.au/Complaints/How-to-make-a-complaint ↩︎
33. HCCC, Responding to the Commission, viewed 8 October 2025, https://www.hccc.nsw.gov.au/Complaints/For-health-service-providers/Responding-to-the-Commission ↩︎
34. NSW Health, Respecting the Difference Cultural Training, viewed 8 October 2025, https://www.health.nsw.gov.au/policies/pd/2022/pdf/PD2022_028.pdf ↩︎
35. AHPRA, Cultural Safety and CPD, viewed 8 October 2025, https://www.ahpra.gov.au/Resources/Cultural-safety.aspx ↩︎