Canine Essentials Policies | Work Health & Safety: Version – Open Access
Preamble
It is the intention of Canine Essentials to provide a safe working environment for Employees, Contractors, Sub-Contractors, Clients and Visitors. Herein contains policies and procedures designed to assist compliance with the Work Health and Safety Act (2012), the Fair Work Act (2009), the Workers Rehabilitation and Compensation Act 1986, Australian Standards governing Nursing, and Codes and Guidelines from the Nursing and Midwifery Board of Australia, Childrens Protection Act (1993), the National Health and Medical Research Council, the Australian Health Practitioner Regulation Agency, Dog and Cat Management Act (1995), Dog and Cat Management Regulations (2017), RSPCA animal welfare legislation and Prevention of Cruelty to Animals Regulations (2008).
Legal Obligation
The information contained here is general in nature. As such the statements made and associated documents referred to are not to be taken as a statement of law and must not be construed to waive or modify any legal obligation. Although every effort is made to identify the relevant Codes and Regulations, it is the responsibility of Canine Essentials to ensure compliance with all legislative responsibilities and standards, codes and guidelines established by all legislative bodies as referred to herein.
All Employees have obligations
As stated here, this is not inclusive of all possible situations and persons in charge of a business or undertaking, officers and employees should be mindful of their legal responsibilities toward each other for maintaining a safe and healthy work environment. Any employee becoming aware of health and safety matters not addressed here should advise the Director accordingly.
Regular Review
All policies and procedures are reviewed six months – 12 months at a minimum. However, the policies should be viewed as working documents which can be reviewed and changed as the needs and requirements of the business change. Specifically:
- When new legislation is proclaimed;
- When amendments are made to legislation;
- As a result of reviews of hazard reports or site inspections; or
- Following receipt of advice which would improve the relevance of the documents.
Glossary
Assistance Dog | Assistance Dog in Training (ADiT)
A dog that is deemed suitable to be trained by Canine Essentials Pty. Ltd. that has undergone a thorough vetting process (and will also include the Handler) that meets a set criterion as suitable to then sit an Australian Government Public Access Test. Canine Essentials does not perform this test, nor is Canine Essentials a Government approved organisation. Canine Essentials Pty. Ltd. provides the training to enable the dog to potentially sit a Public Access Test (refer DDA, 1992 Section 9. 2. a) by having appropriately qualified and experienced Canine Behaviourist’s to conduct such training – although acknowledge there are no guarantees of passing such tests. The Assistance Dog and Assistance Dog in Training will be trained to alleviate the symptoms of the Handler (subject to T&C’s) by skilled Canine Behaviourists who hold healthcare qualifications in addition. The Assistance Dog in Training will be expected to perform (and pass) a Public Standards Assessment in preparation for the Government accreditation – however the onus is on the handler to complete this aspect thereafter (or work with the company that Canine Essentials has been Sub-Contracted to that is a Government accredited Organisation on the completion of the training program).
Codes
Codes are guidelines written to assist industry to comply with safe work at the office of Canine Essentials.
Controls
A Control is an action taken to reduce the likelihood of someone being injured by being exposed to a hazard. There are 5 levels of control ranging from eliminating the hazard completely, through to using Protective Equipment. Many hazards require a range of controls to be place.
Employees
(See workers)
Hazard
A hazard is something that could cause injury.
Legislation
The Legislation which applies most directly to these Policies and Procedures is:
- The Fair Work Act (2009);
- The Work Health and Safety Act (2012);
- The Workers Rehabilitation and Compensation Act (1986);
- Equal Opportunity Act (1984);
- Racial Vilification Act (1996);
- Racial Discrimination Act (1975);
- Sex Discrimination Act (1984);
- Disability Discrimination Act (1992);
- Human Rights and Equal Opportunity Commission Act (1986);
- Age Discrimination Act (2004);
- Equal Opportunity for Women in the Workplace Act (1999);
- Environment Protection Act (1993);
- Children’s Protection Act (1993);
- Defamation Act (2005);
- Dog and Cat Management Act (1995);
- Dog and Cat Management Regulations (2017);
- Prevention of Cruelty to Animals Regulations (2008);
- Scope of Practice for Registered Nurses and Midwives;
- ICN Code of Ethics for Nurses;
- Registered Nurse Standards for Practice
- Copyright Act (1968); and
- Privacy Act (1988).
Management
Anyone in a supervisory position. It includes the Director, Managers and Supervisors at Canine Essentials.
Mandated Notification
There are 2 situations when Mandated Notification is required. They are:
- On suspicion of the abuse of a child by a parent or caregiver; or
- When a Canine Behaviourist/Trainer/Employee of Canine Essentials has formed a reasonable belief that the behaviour of a colleague may place a member of the public at risk of harm.
Notifiable Incident
Under the Work Health and Safety Act (2012), a Notifiable Incident includes fatalities, serious injuries and illnesses, and dangerous incidents.
Officers
In the Work Health and Safety Act (2012), Officers have a specific role. An Officer is a person who is responsible for ensuring that the system that the Person in Charge of a business or Undertaking (PCBU) has put in place is actually used. At Canine Essentials this is the Director. They must show “due diligence” and ensure the employees are working safely, completing hazard or injury forms as required etc.
Owner Trained Assistance Dog Program
A program designed specifically for people that meet the criterion under the Disability Discrimination Act (1992) as referred to by the Human Rights Commission who seek to prepare their dog for Assistance Dog accreditation with State or Territory Governments. As each State or Territory Government varies in their Public Access Test the program will not only be uniquely designed to fit those requirements, but also individualised to suit the individual needs of the individual and their unique requirements of their dis-ability.
This program is led and developed by Dr. Geller, a Canine Behaviourist who has completed nationally recognised (RTO) modules including Work Health & Safety, Assistance Dog Training, Scent Detection and Complex Skills Training. Her main specialty is training Assistance Dogs (with a client base that focuses on mental health animal assisted treatment modalities). She is also a Dr. in Nursing (completing a PhD in Psychiatric Risk Assessment and Management), a Registered Nurse, has completed an Honors degree and is a Sociologist with a focus on Risk Theory.
This program also has a Consumer driven focus (based off of the “Recovery Framework”), with a significant amount of Consumer input from those who have utilised Assistance Dogs in their day-to-day life to further improve the program.
This program has been utilised in a number of companies that are government accredited whereby Canine Essentials has acted in either a Sub-Contractor capacity or Mentor capacity. From this it has been necessary to implement a variety of Assistance Dog policies due to the crossover of companies and to provide a variety of vulnerable Handlers firm but fair direction.
Person in Charge of a Business or Undertaking (PCBU)
The PCBU at Canine Essentials is the Director.
Reasonably Practicable
The term is described in detail in the Work Health and Safety Act (2012). Determining what is reasonably practicable includes taking the following into account:
- Severity of the hazard or risk;
- What is known about this hazard and how others have controlled the risk;
- What information other professionals, industry associations, unions or government bodies can provide;
- Availability and suitability of proposed controls; and/or
- The cost of removing or minimising the hazard.
Risk
A risk is the result of being exposed to a hazard and refers to the risk of being injured. Risks are categorised as Low, Medium and High.
Safe Work Procedures
This is a document which describes the way a particular job must be done in order to ensure that the job can be done safely. Most sessions undertaken by employees of Canine Essentials are guided by professional standards outlined by the Nursing and Midwifery Board of Australia and the Australian Health Practitioner Regulation Agency (AHPRA).
Safe Work Method Statement
This is a Safe Work Procedure that is developed for High Risk jobs. It includes a Risk Assessment and has the same purpose as a Safe Work Procedure but is more comprehensive. The most likely situation for a Safe Work Method Statement to be required would be when a tradesperson is undertaking work at the Office of Canine Essentials where there is a high level of risk involved (e.g. fall from 3 metres).
Workers
The definition of workers in the Work Health and Safety Act (2012) includes subcontractors and their employees, volunteers, and apprentices and students on work placement. At Canine Essentials, all staff members are referred to as employees, but for the purposes of the Act, they are workers.
Worksite
A worksite includes the office and any other place where work is likely to be carried out. It includes vehicles used as part of work, and a Client’s home.
Legal Matters
LM.A Disclaimer
Assistance Dogs International (ADI) has not reviewed this material and does not endorse or recommend these materials. Any views or opinions presented in these materials are solely those of the author. These materials and/or class do not qualify for ADI Assistance Dog Certification.
Please be aware that Canine Essentials Pty Ltd is a “for profit” organisation and as such is ineligible to apply to be a member of Assistance Dogs International.
LM.B Defamation
Canine Essentials will take legal action to any and all persons or groups who make defamatory comments and incorrect statements against Canine Essentials as a company or, discriminate or harass our clients and/or staff. This includes statements on social media being of an untruthful or inaccurate nature. This also includes (but is not limited to) for example closed/secret FaceBook Groups.
As such, it is an expectation that Canine Essentials is not to be “blocked” by clients (or former clients) from any “publically” available social media feeds/posts that include but is not limited to Instagram, Facebook, Pinterest, SnapChat etc.
LM.C Wrongful Interference
Canine Essentials will take legal action to any and all persons or groups who cause loss or interfere with negotiations by unlawful means. * False statements will also be included in this action.
Causing loss by unlawful means: acts against a third party counted as unlawful means only if they were actionable by that third party if he had suffered loss; and which was intended to cause loss to the claimant, but did not include acts which might be unlawful against a third party but which did not affect his freedom to deal with the claimant.
Typical examples include:
- Tortious interference of business- When false claims and accusations are made against a business or an individual’s reputation in order to drive business away.
- Tortious interference of contract- When an individual uses “tort” (a wrongful act) to come between two parties’ mutual contract.
Elements:
- The existence of a contractual relationship or beneficial business relationship between two parties.
- Knowledge of that relationship by a third party.
- Intent of the third party to induce a party to the relationship to breach the relationship.
- Lack of any privilege on the part of the third party to induce such a breach.
- The contractual relationship is breached.
- Damage to the party against whom the breach occurs.
LM.D Copyright
The Australian Copyright Act (1968) is applied throughout Australia and protects artistic works – in Canine Essentials case, this would be considered the Canine Essentials logo. In other situations this would be Canine Essentials work output (i.e. Training Manuals and other forms that have been exclusively created / designed for Canine Essentials use) (Australian Copyright Council 2017). “Copyright protection is free and automatic from the time a work is first written down or recorded in some way” (Australian Copyright Council 2017, p.1). Contrary to popular belief, a copyright symbol or notice is not necessary.
Infringement of copyright:
“Using copyright material in one of the ways exclusively reserved to the copyright owner without permission. Unless a special exception applies, people who use copyright material in any of the ways exclusively controlled by the copyright owner without permission infringes copyright. Using part of a work without permission may also infringe copyright if that part is an important part – the part doesn’t need to be a large part. In this context, the issue is not whether you have changed or added something to the copyright material, but whether the part you have used is an important, essential or distinctive part of the original material”. (Australian Copyright Council 2017, p.7)
Other ways in which copyright can be infringed:
“People may also infringe copyright if they:
- authorise infringement (that is, endorse or sanction someone else’s infringement – for example, by asking or encouraging them to infringe copyright, or by providing them with the means to do so);
- import certain types of items containing copyright material; or
- sell infringing articles or certain types of items containing copyright material which were imported without permission.”
(Australian Copyright Council 2017, p.1)
In “plain language” Canine Essentials takes infringements against copyright towards our branding and work output seriously. This means if our logo is created as a badge (for example) and placed on a dog’s vest which then misrepresents a dog to be associated with Canine Essentials immediate legal action will be taken both against the person who placed the logo on the dog and the person who created the unauthorised badge. CE Badges (i.e. Logo’s) may only be issued by the Director or staff of CE. If created/issued without the express permission by the Director of Canine Essentials in writing, legal action will be taken against the person who created/issued the badge with the CE Logo. Likewise if any copyrighted Canine Essentials written work is used by a business or dog trainer without prior written authorisation, legal action will be taken.
As such Canine Essentials will ensure that if Training Manuals are issued, they must be returned prior to the next level being issued excluding postage costs (this must be at the cost of the owner). Copying is strictly forbidden, as is distribution/sharing. Similarly, while Canine Essentials logo badges are expected to be purchased in certain instances, once client’s cease to be a Canine Essentials client, these logo badges will be expected to be returned to Canine Essentials and the client will be refunded 75% of the cost of each badge excluding postage costs (this must be at the cost of the owner). Clients will be expected to sign an agreement to that effect.
LM.E Compliance
In certain instances, a non-compliance fee may be issued by Canine Essentials Pty. Ltd. This is reserved for a small amount of cases at the discretion of the Director. Generally this is for instances such as:
- Failure to return Training Manuals despite written requests.
- Failure to return Canine Essentials Logo Badges despite written requests.
- Failure to return Canine Essentials Membership cards despite written requests.
- Continuing to work a dog as a Canine Essentials dog and misrepresenting the Company despite written requests to cease and desist.
- Breach of Copyright issues.
- Use of banned equipment on a dog despite written warnings.
1 COMMITMENT, ETHICS & RESPONSIBILITIES
1.1 COMMITMENT TO CLIENTS
Canine Essentials Pty. Ltd. (herein knowns as Canine Essentials) is dedicated in its commitment to each client in furnishing them with up to date, accurate information and services. We are committed to ad continually work towards informing the wider community of our services.
Canine Essentials is dedicated in its commitment in providing excellence in customer service. This is fulfilled by a team of educated professionals whose knowledge and expertise in their chosen industry will assist each client in meeting their requirements in a courteous respectful manner.
The following elements apply:
- Each client´s needs will be treated with equal importance and we at Canine Essentials will strive for flexibility in our communications with our clients in order to meet their needs.
- Skilled Canine Essentials staff will make every effort to fulfil a client´s requests using their knowledge of Canine Essentials resources to fulfil requests in a favourable time frame. When appropriate an alternative course may be suggested.
- If anyone has a question about why Canine Essentials has a policy or if the purpose of a policy is not understood, an explanation will either be provided at the time or referred on to a supervisor or the Director of Canine Essentials
- It is the ultimate goal of Canine Essentials to meet clients’ needs and expectations whilst abiding by Canine Essentials Mission, Philosophy, Code of Practice, Code of Ethics and associated Policies and Procedures. Any comments are welcome regarding how well those expectations are being met.
1.2 QUALITY
Policy
It is the policy of this Office of Canine Essentials to operate our business in a manner that consistently meets or exceeds the quality standards set by our industry and required by Clients. To achieve this, we are committed to continuous improvement of our business and the services provided by our company.
Procedure
To achieve this goal, we recognise that the quality of our services is determined by our Client’s needs and expectations. Our objectives are to:
- Identify the changing needs and expectations of our Clients;
- Develop and maintain processes and procedures that ensure that these changes are accommodated;
- Achieve efficiency in our operations, attention to detail, and responsiveness to Clients’ priorities;
- Provide quality services on time, and ethically costed;
- Provide an employment environment where continuous improvement is encouraged;
- Seek to constantly improve the quality of our work by complying with new Codes of Canine Essentials and/or Quality Standards as appropriate and if possible to exceed those standards;
- In all instances, seek to implement best solutions for health and safety concerns; and
- Remain committed to ensuring compliance with all relevant and current legislation.
Canine Essentials will:
- Identify areas where improvement can be achieved;
- Remove inefficient steps and wasted time in our processes where feasible;
- Strive to ensure that Client satisfaction is achieved at all times and in all things; and
- Support the adoption of appropriate quality systems and management principles in order that all stakeholders benefit from our commitment to quality.
Employees are expected to:
- Assist and cooperate in ensuring that this policy is followed; and
- Actively participate in helping Canine Essentials to achieve the goals and objectives of this policy.
Canine Essentials will seek to comply with the relevant Legislation and Codes of Canine Essentials and Standards which guide and govern the industry. This includes but is not limited to:
- Work Health and Safety Act (2012) and Regulations;
- Fair Work Act (2009);
- Preventing Workplace Bullying -A Practical Guide for Employers -SafeWork SA;
- First Aid in the Workplace;
- Hazardous Manual Tasks;
- Managing the Risk of Falls in the Workplace;
- Managing Electrical Risks in the Workplace;
- AS/NZS 3760 -Testing and Tagging of Electrical Equipment;
- AS1319 -Signage;
- AS/NZS 4031 or AS/NZS 4261 -Sharps Disposal;
- Code of Conduct -Nursing and Midwifery Board of Australia;
- Australian Guidelines for the Prevention and Control of Infection in Healthcare -National Health and Medical Research Council;
- Guidelines for Supervision of Clinicians -Nursing and Midwifery Board of Australia;
- Guidelines for Mandatory Notifications -Australian Health Practitioner Regulation Agency;
- Guidelines for Mandated Notifiers -Child Safe Environments -Department of Communities and Social Inclusion; and
- Information Sharing Guidelines -Department of Communities and Social Inclusion.
Canine Essentials will endeavour, through the regular review of its systems, to strive for continuous improvement to bring about an ongoing improvement of work health and safety performance, with the aim of eliminating all unwanted work-related hazards and work-related injuries.
Appropriate References
| Australian Health Practitioner Regulation Agency
National Health and Medical Research Council Nursing and Midwifery Board of Australia Work Health and Safety Act (2012) Work Health and Safety Regulations (2012) |
1.3 ETHICAL BUSINESS STRUCTURE
Canine Essentials values its reputation, and at times are approached by clients to work in tandem with other Canine Behaviourist’s / Trainer’s either in South Australia or in other states.
Canine Essentials sees this as a valuable opportunity to network and share ideas. More often than not this is in the training of Assistance / Service Dogs.
Once the client has submitted an Expression of Interest form in the Canine Essentials Owner Trained Assistance Dog Program that is approved, the Canine Behaviourist / Trainer the client is working with will be contacted by the Director of Canine Essentials to ensure there is no conflict of interest and to assure the Canine Behaviourist / Trainer there is a non-compete in place.
Canine Essentials will reserve the right to terminate the services of the client if the original Canine Behaviourist / Trainer of the client chooses not work in a symbiotic manner with Canine Essentials as this would be against the Value System and Ethics of Canine Essentials and be seen to be “poaching” business away from other Canine Behaviourist’s / Trainer’s. This is clearly not our intent.
1.4 ETHICAL CONSIDERATION OF CLIENTS
- All Canine Essentials clients will be accorded equal consideration for their requests.
- Canine Essentials staff and will seek to carry out the mission of the Canine Essentials in a way that provides optimum service to all.
- Canine Essentials staff and recognise the confidentiality rights of clients and as such will not reveal the identity of people using Canine Essentials resources, or services to a third party.
- All requests for information will be considered confidential requests and will never be discussed with a third party, except for the purposes of answering a question posed by the client if necessary.
- For those enquiring about Canine Essentials Clients in an OFFICIAL capacity, Canine Essentials advises that telephone enquiries will no longer be accepted.
- Please send an email to info@canineessentials.com.au, so your credentials may be verified (i.e. the person is from a governmental department etc.).
- Credentials WILL BE SCREENED prior to contact. Note if the credentials stated turn out to be false/fake/misrepresented, you will be reported to the relevant governing body.
- If the general public have any concerns about Canine Essentials dogs (most likely those in the Assistance Dog Program), click here to download the form, complete and email the form to info@canineessentials.com.au for further investigation.
- Canine Essentials policies reflect our desire to promote the professional pet industry, and encourage responsible pet ownership. Policy statements are under constant review and are posted on our website.
1.5 CLIENTS RIGHTS AND RESPONSIBILITIES
Policy
It is the policy of Canine Essentials to ensure that Clients are fully informed about their services received and this includes being aware of the rights and responsibilities in the relationship continuum.
Employees
All Employees must be committed to the following:
- Respect our Clients’ rights and dignity;
- Deliver respectful service;
- Not discriminate against age, gender, ethnicity, beliefs, sexual preference or health status;
- Respect a Client’s individuality and be courteous at all times;
- Demonstrate extra respect for a particularly vulnerable Client or minor;
- Respect Client’s rights to have a third party during consultations;
- Inform Clients of the qualifications of the Behaviourist/Trainer;
- Respect a Client’s decision to accept or decline a particular type of session;
- Respect a Client’s decision to transfer to another Behaviourist/Trainer;
- Respect a Client’s request for a second opinion, to provide feedback or make a complaint;
- Provide the general information along with diagrams for exercises, if applicable and brochures or information material regarding what has been explained by your Behaviourist/Trainer.
Clients’ responsibilities
- Provide current and relative information regarding your progress in training during the week along with any information that may affect the outcome of your sessions;
- Provide updated information regarding changes to yours or your dog’s health etc., as soon as possible;
- Observe Canine Essentials policies including fee schedules and time tables;
- Treat Canine Essentials staff and other Clients with respect;
- Do not take your dog into a (non-dog friendly) public access area without the presence of a Canine Essentials qualified Canine Behaviourist or without the express permission of the Director of Canine Essentials (if applicable);
- Communicate in a timely manner, any concerns, needs or expectations.
Behaviourist/Trainers Rights
- Behaviourist/Trainers have the right to refuse provision of service where there are reasonable reasons to do so;
- Behaviourist/Trainer’s may discontinue service where a Client has behaved in a violent, irrational, threatening, un-cooperative or disrespectful manner, or by any reason that causes a significant breakdown of the Client relationship;
- Behaviourist/Trainers have the right to protect their professional reputation and to take reasonable steps to avoid further professional consequences that may seem negative.
Complimentary Feedback or Complaints
Canine Essentials welcome any feedback, either complimentary or critical, as this enables us to improve our services and Clients’ needs. Please see Canine Essentials Complaint & Feedback Policy for further information.
1.6 DISCONTINUATION OF CLIENT SERVICES
Policy
Canine Essentials is committed to ensuring correct procedures are in place for discontinuation of Client services for reasons other than Behaviourist/Trainer leave, retirement or relocation.
Procedure
In all instances, the Behaviourist/Trainer must have a transparent and bona fide reasoning for ending the relationship of the Client. The Client should be advised at the appropriate time and all communications must be clearly documented on the clients file and a Warning Note pop up should be added so that Employees who may, in the line of their work, go into the Client file will be immediately aware of the situation.
These circumstances may be due to miscommunication, trust or respect breakdowns, or other unresolvable issues. The decision should always be communicated in person but if this may further inflame the situation, written communication may be warranted, as per the available template. A copy must be kept as an attachment to the Client’s file.
Behaviourist/Trainer handing the Client over to another Behaviourist/Trainer within Canine Essentials for ongoing sessions, must ensure a referral has been written for handover.
If the issue in unresolvable at Canine Essentials, Canine Essentials ensures assistance is given by referring the Client to another Behaviourist/Trainer at an alternate location, with Client approval. Also advise the Client that you will make available their sessions records if and when requested.
If discontinuation is warranted due to violent, irrational, threatening, un-cooperative or disrespectful behaviour, this must be communicated to the Client as soon as appropriate, this may be by phone after the altercation. At the time of the episode, if possible, direct the Client to a quiet room or the kitchen area away from other Clients, offer a drink of water, tissues or whatever may seem appropriate at the time (or this may have been building up after some time). It would be appropriate to make sure the Client is safe to drive if that is how they arrived at the office, and to escort them to their vehicle. As with all other circumstances, this must be accompanied by a written letter, as per the available template, a copy of this letter attached to the Client’s file and a Warning Note pop up also added to the Client’s file.
The Behaviourist/Trainer should notify all appropriate staff that they are no longer providing services for the Client. If no Behaviourist/Trainer is available to take over training, then the client will cease to remain a client of Canine Essentials and no refunds will be issues.
1.7 RESPONSIBILITY TO THE COMMUNITY
Canine Essentials is committed to acting responsibly and morally towards the community at large.
Child Welfare
Dr. Geller, the Director of Canine Essentials is a mandated reported and is held to a higher standard than members of the general public. In most situations this is applied under the Child Protection Act (1993). However this does not exhaust her duty of care towards the child and their family thereafter.
- A mandated notifier is required by law to notify the Department for Child Protection if they suspect on reasonable grounds that a child has been or is being abused or neglected.
- This obligation arises when a mandated notifier forms this suspicion in the course of their work (whether paid or voluntary) or in carrying out official duties.
- A mandated notifier must make the notification as soon as practicable after the suspicion is formed.
- If a mandated notifier forms a suspicion outside of their work (whether paid or voluntary) that a child has been or is being abused or neglected, they may make a notification to the Department for Child Protection voluntarily.
Canine Welfare
Similarly, the dog’s welfare is of paramount concern. As such, Dr. Geller has a duty of care towards the dog’s welfare which is based on the “Five Freedoms” of dog welfare:
- Freedom from hunger and thirst: by ready access to fresh water and a diet to maintain full health and vigour.
- Freedom from discomfort: by providing an appropriate environment including shelter and a comfortable resting area.
- Freedom from pain, injury or disease: by prevention through rapid diagnosis and treatment.
- Freedom to express normal behaviour: by providing sufficient space, proper facilities and company of the animal’s own kind.
- Freedom from fear and distress: by ensuring conditions and treatment which avoid mental suffering.
Canine Essentials abides by the Prevention of Cruelty to Animal Regulations (2008) [Click Here to Download the Regulations] and as such Dr. Geller, the Director of Canine Essentials remains is contact with the RSPCA should she have any concerns regarding the dog’s welfare.
Should any Client/Behaviourist/Trainer/Employee use any equipment or treat a dog in an inhumane way that contravenes the above regulations (including the use of banned equipment per above and as outlined in Canine Essentials Policy 5.6), Canine Essentials will immediately cease ties with the associated party. This is outlined below:
- For Employees this will mean instant dismissal;
- Clients, termination of contract (no refund will be issued); and,
- Contractor/Sub-Contractor instant termination of contract – with the applicable fine imposed per contract terms.
The person/s will then be reported to the appropriate authorities
Public Welfare
Canine Essentials believes that the community at large should be protected from dogs that have the potential or have attacked, harassed or chased a person. As such, Canine Essentials will not hesitate to notify the relevant council of the dog in question.
When the dog in question is an Assistance/Service Dog, Canine Essentials refers to industry standards which stipulate that: the “dog shows no aggression towards people or other animals” [NO EXCEPTIONS].
In our experience, it has proved pointless to approach the organisation that certified/accredited the Assistance/Service Dog due to conflicts of interest and attempts by other organisations to minimise the serious nature of the event. As such, the community at large can rest assured that the relevant council will be notified and be reminded of the higher standard that this dog must be held to. Canine Essentials will then ask the council to contact the relevant training organisation to prevent conflict between organisations.
1.8 ENVIRONMENT
Policy
The Work Health and Safety Act (2012) and the Environment Protection Act (1993) require that we take steps to minimise our impact on the environment.
Canine Essentials is committed to ensuring that we minimise our impact and reduce risk of harm on the natural environment and the local community.
Procedure
We will adopt procedures that:
- Reduce waste by recycling;
- Minimise environmental impacts by reduction (where possible) of polluting substances produced by our operations, activities, products or services;
- Minimise the impact of our operations on the neighbouring community; and
- Increase the use of environmentally acceptable materials, equipment and technology in place of those which are considered harmful.
Appropriate References
| Work Health and Safety Act (2012)
S19 — Primary Duty of Care
Environment Protection Act (1993) S10 — Objects of Act (…)
|
1.9 ETHICS FOR CLIENTS WITH ASSISTANCE DOGS TRAINED BY CANINE ESSENTIALS
Canine Essentials is committed to assisting people with disabling conditions to be able to achieve a higher level of independence and to improve their quality of living. The following ethical criterion determines Canine Essentials commitment towards achieving this:
- Canine Essentials Applicants and Clients have a right apply for the owner-trained Assistance Dog program regardless of their sex, religion or race.
- Clients will be treated at all times with respect and dignity when dealing with Canine Essentials representatives.
- Clients will receive an appropriately designed training program that is based on current evidence and this program must be designed so that Clients can effectively utilise their Assistance Dog at home and/or in the public sphere.
- Note: to enter the Assistance Dog Owner Trained Program, the dog must have a Canine Essentials prepared Veterinarian Certification at the Veterinarian service of your choice. Without this, your application will be denied – no exceptions.
- Should your first Canine Essentials prepared Veterinarian Certification assessment be unsuccessful, you will be offered the option to seek a second opinion from a second Veterinarian of your choosing. If this is also unsuccessful your application will again be denied and you will cease to become a Canine Essentials Assistance Dog client.
- Should (b) occur, you can however choose to remain and commence “Pet-Dog” Good Manners Training, but this will mean your dog is unsuited to be an Assistance Dog in the Canine Essentials program.
- The Client will be appropriately educated on their role as an Assistance Dog handler when out in the public sphere:
- It is important to note that at this point in time, that any Dog in the AD Owner Trained Program may enter a non-pet friendly venue until Level 3, and at this point, must be in the presence of a Canine Essentials Canine Behaviourist to monitor the Dog’s behaviour to mitigate liability and risk to the general public and Canine Essentials Pty. Ltd.
- All Handlers in the Owner Trained Assistance Dog Program must abide by Federal Law (Disability Discrimination Act 1992) and ensure your dog meets standards of hygiene and behaviour that are appropriate for an animal in a public place:
- This means you must have the functional capacity to clean up the Dog’s waste immediately and at all times.
- This means you may not work a dog during a training session (or any other time) if suspected of having an infectious disease.
- The Client will receive follow-up support and have regular contact with Canine Essentials Behaviourists’.
- The Client has the right to request further information and/or assistance when:
- the Client’s functional level has changed and the Assistance Dog requires additional training;
- if a behavioural change in the Assistance Dog occurs;
- a major health issue (Veterinarian problem) in the Assistance Dog occurs, and;
- if legal issues arise surrounding the use and access of their Assistance Dog in the public sphere.
- in these instances, Canine Essentials reserves the right to charge for these services.
- Canine Essentials ensures that the Client’s personal files will remain private and confidential and will not be disclosed unless the Client has provided Canine Essentials with written permission.
- Canine Essentials will act as an Advocate for the Client should the need arise.
- the Client must provide written permission before this occurs.
- Canine Essentials is committed to the community and will ensure:
- that the community is appropriately educated about Assistance Dogs;
- their benefits as an alternative treatment modality for a person with a disabling condition, and;
- includes educating the community on the Client’s legal rights and obligations as well as the community’s legal rights and obligations.
1.10 ETHICS FOR ASSISTANCE DOGS
Canine Essentials Ethics for Assistance Dogs are developed using industry standards. However these standards apply to all dogs that Canine Essentials train. As such, Canine Essentials encourages all clients to follow these ethics as a guide to ensure the humane treatment of their dog is assured. These are as follows:
- A dog has a right to a quality of life.
- A Veterinarian of the owners choice is an important factor to ensure:
- The dog has a sound temperament:
- this is a non-negotiable to qualify for an Assistance Dog.
- during the Expression of Interest phase (Stage 1) a Vet will be required to screen to potential Assistance Dog applicant.
- The dog must be fit for confirmed to be physically fit:
- Any dog trained by Canine Essentials must be physically fit to enter into any training program.
- The Dog (if to be utilised as an Assistance Dog) must NOT be a Prescribed Breed nor a “wild” or “native” breed such as a Dingo or Fox despite claims of domestication or permit issue by government bodies.
- The dog must be trained by a Behaviourist qualified to train Assistance Dog;
- Humane training methods must be used. These are:
- Using, Positive Reinforcement (administering a reward) and,
- Negative Punishment (withholding a reward)
- The training methods must be adjusted accordingly to protect the emotional and physical safety of the dog.
- The dog must be allowed to learn at its own pace.
- The dog must be emotionally and physically sound, mature to be able to work in the public sphere.
- Any dogs that display aggressive behaviour will be removed from the training program:
- however, barking as a trained behaviour is authorised (and this must be in writing) IF it is appropriate for the situation. This must be discussed with the Trainer before beginning training the behaviour.
1.11 MORAL EXPECTATIONS FOR ASSISTANCE DOG HANDLERS IN THE WORKPLACE
Canine Essentials Expectations for Assistance Dog Handlers are developed using industry standards. The minimum expectations Canine Essentials adopts are as follows:
- Produce Canine Essentials Membership Card (stating that a Canine Behaviourist has confirmed that the dog has passed Public Standards Training).
- Remember that the public are allowed to ask you if you have a disability but NOT THE NATURE OF YOUR DISABILITY.
- This is the ONLY question the public are allowed to ask.
- Ensure your dog wears approved Canine Essentials Pty. Ltd. Assistance Dog Logo and approved Canine Essentials wear/gear that visually identifies the dog as an Assistance Dog.
- To protect your dog’s feet from hot grounds, travelators/escalators (please avoid these if possible), dog footwear must be worn at all times.
- It is highly recommended that you purchase a “Medical Emergency Information” card from Canine Essentials so your workplace can assist you in an emergency situation and have the necessary information.
- Abide by Canine Essentials policy General Expectations for Assistance Dog Handlers in Public contained in this Policy Manual.
- Ensure your Assistance dog is under control at all times, or if you are incapacitated, arrange to have an alternate handler to assume care and control of your dog in your office space.
- Abide by Federal Law (Disability Discrimination Act 1992) and ensure your dog meets standards of hygiene and behaviour that are appropriate for an animal in a public place.
- Remember that you are solely liable for any damage to persons, premises, or facilities including places of public accommodation, public conveyances or transportation services, common carrier of passengers, places of housing accommodations, and places of employment caused by your Assistance Dog.
- Prepare extra provision to keep in your office / work space. Some suggestions include:
- Canine Essentials Membership Card;
- Assistance Dog Vest;
- Dog Boots;
- Dog Mat (freshly laundered);
- Portable food and water bowls;
- Food (ideally packed in sealed bags in meal portions);
- Medications for your dog (if required):
- This may also include if they are due for worming and de-flea spot on treatment;
- Leash, collar, Halti, waist harness;
- Brush, Zoom Groom, Furminator (for example);
- Poop bags;
- Hand wipes, sanitary hand cleaner;
- Garbage bags;
- Environmental enrichment toys that do not make any noises.
- Dogs are not to be on your office seat or desk;
- Must be unobtrusive at all times;
- The dog must be kept out of the way of office/cleaning staff at all times;
- To ensure hygiene is ensured consider keeping a “dustbuster” in your office space:
- Have the dustbuster electrically tagged and tested prior to use;
- If working late, notify staff that your dog may need to toilet in the evening and to ensure your safety ask for a security escort out to an appropriate place within the premises;
- Be aware that you are a representative of Canine Essentials. As such ensure that your dog behaves impeccably and is an ambassador to our company and our training.
In the interests of transparency, recommendations you can make to your workplace
- Advise your workplace that your dog is trained to alleviate the effects of your disability and this all you are obliged to divulge.
- Educate your workplace in a non-confrontational way on the rights of Disability Discrimination Act (1992) and the only places an Assistance Dog cannot enter is:
- The food preparation area.
- Ask if there are any members of staff who are scared and/or allergic to dogs and see if you can meet via teleconference to arrange some “work arounds”.
- Ask where the workplace would like you to toilet the dog around the surrounding building site.
- It would be advisable to have a sign outside the front of your office door (or pod) stating “Assistance Dog inside” to pre-warn staff entering.
- Educate your workplace that it is illegal that the Assistance Dog be left alone in any circumstances. If this is the case, contact Canine Essentials immediately so Dr. Geller can contact the Equal Opportunity Manager of the workplace to diffuse the situation.
- The workplace must instruct staff not to ask the handler why they have the Assistance Dog. This can be upsetting to the handler, is upsetting and can perpetuate stigma.
- Advise the workplace that staff may NOT:
- Approach the dog;
- Make eye contact with the dog;
- Touch the dog, or;
- Speak to the dog.
- This distracts the dog and can prove (at times fatal to the owner).
- The workplace should expect from your Assistance Dog:
- Being quiet;
- NO whining, growling or barking;
- The exception is whining if the Assistance Dog is indicating a need to go to the toilet or doing a trained alert bark or whine. Growling however is strictly prohibited;
- The dog should meets standards of hygiene and behaviour that are appropriate for an animal in a public place;
- Should never toilet inside the facility;
- Should sit quietly and unobtrusively on the floor (unless required to provide deep pressure therapy to relieve anxiety);
- The Assistance Dog may not sit on the furniture;
- The Assistance Dog must always be visibly identifiable as an Assistance Dog in coat/harness and leashed.
1.12 MORAL EXPECTATIONS FOR ASSISTANCE DOG HANDLERS IN HOSPITAL
Canine Essentials Expectations for Assistance Dog Handlers are developed using industry standards. The minimum expectations Canine Essentials adopts are as follows:
- Produce Canine Essentials Membership Card (stating that a Canine Behaviourist has confirmed that the dog has passed Public Standards Training).
- Remember that the public are allowed to ask you if you have a disability but NOT THE NATURE OF YOUR DISABILITY.
- This is the ONLY question the public are allowed to ask.
- Ensure your dog wears approved Canine Essentials Pty. Ltd. Assistance Dog Logo and approved Canine Essentials wear/gear that visually identifies the dog as an Assistance Dog.
- To protect your dog’s feet from hot grounds, travelators/escalators (please avoid these if possible), dog footwear must be worn at all times.
- It is highly recommended that you purchase a “Medical Emergency Information” card from Canine Essentials so medical staff can treat you appropriately and have the necessary information.
- Abide by Canine Essentials policy General Expectations for Assistance Dog Handlers in Public in addition to the below.
- Ensure your Assistance dog is under control at all times, or if you are incapacitated, arrange to have an alternate handler to assume care and control of your dog in your hospital/care facility room.
- Abide by Federal Law (Disability Discrimination Act 1992) and ensure your dog meets standards of hygiene and behaviour that are appropriate for an animal in a public place.
- Remember that you are solely liable for any damage to persons, premises, or facilities including places of public accommodation, public conveyances or transportation services, common carrier of passengers, places of housing accommodations, and places of employment caused by your Assistance Dog.
- Understandably in an emergency this may prove prohibitive, however try and be prepared prior to admission and ensure you pack for your Assistance Dog as well. Suggestions include:
- Canine Essentials Membership Card;
- Assistance Dog Vest;
- Dog Boots;
- Dog Mat (freshly laundered) – preferably x 2;
- Portable food and water bowls;
- Food (ideally packed in sealed bags in meal portions);
- Medications for your dog (if required):
- This may also include if they are due for worming and de-flea spot on treatment;
- Leash, collar, Halti, waist harness;
- Brush, Zoom Groom, Furminator (for example);
- Poop bags;
- Hand wipes, sanitary hand cleaner;
- Garbage bags;
- Environmental enrichment toys that do not make any noises.
- Dogs are not to be on your lap during treatment or procedures;
- Barring deep pressure therapy for anxiety, it is advisable that the dog is not to be on the bed and be tethered to the bed on the floor:
- Must be unobtrusive at all times;
- The dog must be kept out of the way of healthcare staff at all times;
- To ensure infection control and hygiene is ensured ask for a dustpan and ask for your support person (or yourself if well enough) to clean up any dog hair to keep the room hair free;
- Notify staff that your dog may need to toilet through the night and to ensure your safety ask for a security escort out to an appropriate place within the premises;
- Remember that Federal Law precludes your dog entry from the Operating Theatre and the Morgue.
- Be aware that you are a representative of Canine Essentials. As such ensure that your dog behaves impeccably and is an ambassador to our company and our training.
- If you are a visitor to a hospital the elements of the above still applies.
In the interests of transparency, recommendations you can make to the healthcare facility to help make you stay a little easier
- Advise the healthcare facility that your dog is trained to alleviate the effects of your disability and this all you are obliged to divulge.
- Educate the facility in a non-confrontational way about the Disability Discrimination Act (1992) and the only places an Assistance Dog cannot enter is:
- The food preparation area;
- Operating Theatre, and;
- Morgue.
- Ask if there are any members of staff who are scared and/or allergic to dogs and see if there can be some changes with the rostering system.
- Ask if a staff member would be willing to volunteer to assist in caring for the dog if you become incapacitated and unable to care for the dog and you are unable to contact your other carer.
- Ask where they would like you to toilet the dog within their facility.
- Ask if they would like a sign outside your door stating “Assistance Dog inside” to pre-warn staff entering.
- Ask if a dustpan could be in the room for the duration of your stay so you can ensure the room is kept as hygienic as possible.
- Educate the facility that it is illegal that the Assistance Dog be left alone in any circumstances. If this is the case, the facility must contact the Canine Essentials so Canine Essentials can organise a representative to sit with the dog in the facility. This will be at the owners cost.
- The facility must instruct staff not to ask the handler why they have the Assistance Dog. This can be upsetting to the handler, is upsetting and can perpetuate stigma.
- Advise the facility that staff may NOT:
- Approach the dog;
- Make eye contact with the dog;
- Touch the dog, or;
- Speak to the dog.
- This distracts the dog and can prove (at times fatal to the owner).
- The facility should expect from your Assistance Dog:
- Be quiet;
- NO whining, growling or barking;
- The exception is whining if the Assistance Dog is indicating a need to go to the toilet or doing a trained alert bark or whine. Growling however is strictly prohibited;
- The dog should meets standards of hygiene and behaviour that are appropriate for an animal in a public place;
- Should never toilet inside the facility;
- Should sit quietly and unobtrusively on the floor (unless required to provide deep pressure therapy to relieve anxiety);
- The Assistance Dog may not sit on the furniture;
- The Assistance Dog must always be visibly identifiable as an Assistance Dog in coat/harness and leashed.
1.13 MORAL EXPECTATIONS FOR ASSISTANCE DOG HANDLERS NEEDING PARAMEDIC ASSISTANCE
Canine Essentials Expectations for Assistance Dog Handlers are developed using industry standards. The minimum expectations Canine Essentials adopts are as follows:
- Produce Canine Essentials Membership Card (stating that a Canine Behaviourist has confirmed that the dog has passed Public Standards Training).
- Remember that the public are allowed to ask you if you have a disability but NOT THE NATURE OF YOUR DISABILITY.
- This is the ONLY question the public are allowed to ask.
- Ensure your dog wears approved Canine Essentials Pty. Ltd. Assistance Dog Logo and approved Canine Essentials wear/gear that visually identifies the dog as an Assistance Dog.
- It is highly recommended that you purchase a “Medical Emergency Information” card from Canine Essentials so medical staff can treat you appropriately and have the necessary information.
- It is your responsibility to prepare your dog for this situation.
- This can be achieved by simulating emergency situations such as pretending to be in pain, fainting, or seizing.
- Gauge the reaction of your Assistance Dog and the arrange with Canine Essentials extra training sessions of you think there are areas that needs to worked on.
- Note that it is acceptable for your dog to react by sniffing, whining and licking. Harness this reaction as an attempt for your dog to seek assistance from passer-by’s and/or neighbours. Barking should also be encouraged.
- Abide by Canine Essentials policy General Expectations for Assistance Dog Handlers in Public in addition to the below.
- In public
- Once the Paramedic (First Responders) have arrived:
- Ensure the Assistance Dog can see the handler at all times.
- Ensure the Assistance Dog is on lead.
- All South Australian Ambulances have tether points for Assistance Dogs – so refusal of transport of an Assistance Dog with the handler is unacceptable.
- Have the person holding the Assistance Dog reassure the dog in a quiet and calming way – preferably encouraging the dog to sit or drop which will aid in relaxing the dog.
- Do not make eye contact with the Assistance Dog as it is intended that the dog should maintain visual contact with the handler.
- Inside a person’s house
- Once the Paramedic (First Responders) have arrived:
- Here the situation is slightly different as the dog is out of coat and more “domesticated” and will unlikely to be on lead.
- Paramedics should follow the golden rules of “no look, no touch, no eye contact” with the dog.
- Ignore the dog.
- Gently reassure the dog with a soft voice.
- If needed place a lead on the dog before tending to the handler.
- Ensure the Assistance Dog can see the handler at all times.
- If possible, allow the Assistance Dog to be vested and have a small amount of supplies for the Assistance Dog to be gathered before transport.
- All South Australian Ambulances have tether points for Assistance Dogs – so refusal of transport of an Assistance Dog with the handler is unacceptable.
- Once the Paramedic (First Responders) have arrived:
- Once the Paramedic (First Responders) have arrived:
1.14 MORAL EXPECTATIONS FOR ASSISTANCE DOG HANDLERS WHILE TRAVELLING AND STAYING IN HOTELS & ACCOMMODATION ETC.
Canine Essentials Expectations for Assistance Dog Handlers are developed using industry standards. The minimum expectations Canine Essentials adopts are as follows:
- Whist not necessary, Canine Essentials believes it is a moral obligation and polite to notify the hotel or place of accommodation that you will be bringing an Assistance Dog with you. Be sure to advise them that dog is not considered a pet, rather a piece of medical equipment. This allows time for the Director of Canine Essentials to contact the hotel (for example) to advocate on your behalf if required.
- On arrival, produce Canine Essentials Membership Card (stating that a Canine Behaviourist has confirmed that the dog has passed Public Standards Training).
- Remember that the public are allowed to ask you if you have a disability but NOT THE NATURE OF YOUR DISABILITY.
- This is the ONLY question the public are allowed to ask.
- Ensure your dog wears approved Canine Essentials Pty. Ltd. Assistance Dog Logo and approved Canine Essentials wear/gear that visually identifies the dog as an Assistance Dog.
- To protect your dog’s feet from hot grounds, travelators/escalators (please avoid these if possible), dog footwear must be worn at all times.
- It is highly recommended that you purchase a “Medical Emergency Information” card from Canine Essentials so while travelling, in an emergency, medical staff can treat you appropriately and have the necessary information.
- Abide by Canine Essentials policy General Expectations for Assistance Dog Handlers in Public in addition to the below.
- Ensure your Assistance dog is under control at all times, or if you are incapacitated, arrange to have an alternate handler to assume care and control of your dog in your place of accommodation.
- Abide by Federal Law (Disability Discrimination Act 1992) and ensure your dog meets standards of hygiene and behaviour that are appropriate for an animal in a public place.
- Remember that you are solely liable for any damage to persons, premises, or facilities including places of public accommodation, public conveyances or transportation services, common carrier of passengers, places of housing accommodations, and places of employment caused by your Assistance Dog.
- Be prepared prior to travelling and ensure you pack for your Assistance Dog as well. Suggestions include:
- Canine Essentials Membership Card;
- Assistance Dog Vest;
- Dog Boots;
- Dog coat to prevent unnecessary shedding;
- Dog Mat (freshly laundered) – preferably x 2;
- Portable food and water bowls;
- Food (ideally packed in sealed bags in meal portions);
- Medications for your dog (if required):
- This may also include if they are due for worming and de-flea spot on treatment;
- Leash, collar, Halti, waist harness;
- Brush, Zoom Groom, Furminator (for example);
- Poop bags;
- Hand wipes, sanitary hand cleaner;
- Garbage bags;
- Environmental enrichment toys that do not make any noises;
- Crate (if crate trained);
- Clean sheets to protect the carpet, furniture and bed from any pet hair.
- It is advisable that the dog is not to be on the bed and if possible a crate would be useful in this instance:
- Must be unobtrusive at all times;
- The dog must be kept out of the way of staff at all times;
- Notify staff that your dog may need to toilet through the night and if they have security staff, ask that they be notified as well that your dog is an Assistance dog not a pet;
- Be aware that you are a representative of Canine Essentials. As such ensure that your dog behaves impeccably and is an ambassador to our company and our training.
- If you are a visitor the elements of the above still applies.
On Arrival & Departure
- Canine Essentials recommends that on arrival to your room, you record on your phone opening your door so that the room number is clearly visible and record all areas of the room to document the state and cleanliness of the room.
- On departure (check-out), it is recommended after packing and all luggage is packed in car or outside of your room, record all areas of the room to document the state and cleanliness of the room. Then, download the form “Accommodation Checkout” available at canineessentials/company/policies
- Take this form to the checkout counter and ask for a room inspection and the staff member to sign stating that the room was left in a clean and acceptable state.
- This may prevent problems arising in the future regarding “pet hair” and “odor” and provides you with documentation stating otherwise. In addition, you know have video evidence proving otherwise.
As Canine Essentials prides itself on being "Disability Friendly" and accessible in every way, should you require a copy printed and posted, or, a form fill version emailed so this can be typed on should one experience hand writing difficulties (for example), please contact Canine Essentials, or call 0426975364.
In the interests of transparency, recommendations you can make to the hotel &/etc. to help make you stay a little easier
- Advise the place of accommodation that your dog is trained to alleviate the effects of your disability and this all you are obliged to divulge.
- Educate the facility in a non-confrontational way about the Disability Discrimination Act (1992) and the only places an Assistance Dog cannot enter is:
- The food preparation area.
- Ask if there are any members of staff who are scared and/or allergic to dogs and see if there can be some changes with the rostering system.
- Ask if a staff member would be willing to volunteer to assist in caring for the dog if you become incapacitated and unable to care for the dog and you are unable to contact your other carer.
- Ask where they would like you to toilet the dog during your stay.
- Ask if they would like a sign outside your door stating “Assistance Dog inside” to pre-warn staff entering.
- Ask if a dustpan/vacuum could be in the room for the duration of your stay so you can ensure the room is kept as hygienic as possible.
- Educate the manager of hotel &/etc. that it is illegal that the Assistance Dog be left alone in any circumstances. If this is the case, the hotel must contact the Canine Essentials so Canine Essentials can organise a representative to sit with the dog in the hotel. This will be at the owners cost.
- Preferably, ask the manager if he/she could instruct staff not to ask the handler why they have the Assistance Dog. This can be upsetting to the handler, is upsetting and can perpetuate stigma.
- Advise the manager that staff may NOT:
- Approach the dog;
- Make eye contact with the dog;
- Touch the dog, or;
- Speak to the dog.
- This distracts the dog and can prove (at times fatal to the owner).
- The place of accommodation should expect from your Assistance Dog:
- Be quiet;
- NO whining, growling or barking;
- The exception is whining if the Assistance Dog is indicating a need to go to the toilet or doing a trained alert bark or whine. Growling however is strictly prohibited;
- The dog should meets standards of hygiene and behaviour that are appropriate for an animal in a public place;
- Should never toilet inside the place of accommodation;
- Should sit quietly and unobtrusively on the floor (unless required to provide deep pressure therapy to relieve anxiety), and preferably the carpets should be protected by sheets;
- The Assistance Dog may not sit on the furniture;
- The Assistance Dog must always be visibly identifiable as an Assistance Dog in coat/harness and leashed.
1.15 STANDARDS AND EXPECTATIONS FOR ASSISTANCE DOG HANDLERS WHILE TRAVELLING IN AIRCRAFT
Canine Essentials Assistance Dogs have been afforded the privilege on a case by case basis to travel by Tiger Air and Canine Essentials Pty. Ltd. are currently applying to other airlines (however make no guarantees). Regardless, it is necessary and vital that strict standards apply for all Canine Essentials Assistance Dog Handlers to ensure Canine Essentials name and reputation continues to be held in good standing.
Canine Standards and Expectations for Assistance Dog Handlers are developed using industry standards. The minimum standards and expectations Canine Essentials adopts are as follows:
- Prepare well in advance. At least two months before departure, notify the airline of your choice that you will be travelling with an Assistance Dog. This will provide you enough time to gather documentation required by the airline (which may include medical certification from your medical practitioner and Canine Essentials Pty. Ltd.).
- Some airlines do have height, size and weight restrictions of Assistance Dogs – so please ensure that you have thoroughly researched this first!
- Wash/Bath your dog the day before you travel.
- Brush your dog thoroughly the morning of your flight and use a light deodorising spray designed for dogs to ensure your dog meets public hygiene standards.
- Try to plan your trip with toileting “stops” (4-5 hours) maximum as you “traverse” Australia or go overseas. This may prove more costly, but is the more humane way of travelling for your Assistance Dog and provides a way for your Assistance Dog to toilet every few hours before the next connecting flight.
- Withhold food and water a few hours before flying.
- Toilet before entering the airport.
- On arrival, produce Canine Essentials Membership Card (stating that a Canine Behaviourist has confirmed that the dog has passed Public Standards Training).
- Remember that the public are allowed to ask you if you have a disability but NOT THE NATURE OF YOUR DISABILITY.
- This is the ONLY question the public are allowed to ask.
- Ensure your dog wears approved Canine Essentials Pty. Ltd. Assistance Dog Logo and approved Canine Essentials wear/gear that visually identifies the dog as an Assistance Dog. Ensure the Canine Essentials membership card is also attached to the Assistance Dogs vest in a well-protected and robust card holder.
- Please bring a copy of your signed Canine Essentials Pty. Ltd. Public Standards Assessment approved and signed by Dr. Geller, Director, Canine Behaviourist and Certified Professional Dog Trainer.
- Please bring Form 3A: Disability Certification from your General Practitioner – however you are not obliged to produce this. This is a backup measure. If you are asked to produce this, please ring the Director of Canine Essentials FIRST so she may discuss this with the airline supervisor.
- Bring current Vaccination Certificate and De-sexing/Spaying Certification.
- To protect your dog’s feet from hot grounds, travelators/escalators (please avoid these if possible); dog footwear must be worn at all times.
- Consider placing the Assistance Dog in a “Doggy Diaper” and purchasing an absorbent mat for seating (may be provided by airline).
- It is highly recommended that you purchase a “Medical Emergency Information” card from Canine Essentials so while travelling, in an emergency, medical staff can treat you appropriately and have the necessary information.
- Abide by Canine Essentials policy General Expectations for Assistance Dog Handlers in Public in addition to the below.
- Ensure your Assistance dog is under control at all times, or if you are incapacitated, arrange with airline staff what needs to be done in an emergency situation.
- Abide by Federal Law (Disability Discrimination Act 1992) and ensure your dog meets standards of hygiene and behaviour that are appropriate for an animal in a public place.
- Remember that you are solely liable for any damage to persons, premises, or facilities including places of public accommodation, public conveyances or transportation services, common carrier of passengers, places of housing accommodations, and places of employment caused by your Assistance Dog.
- Be prepared prior to travelling and ensure you pack for your Assistance Dog as well. Suggestions include:
- Canine Essentials Membership Card;
- Assistance Dog Vest;
- Dog Boots;
- Dog coat to prevent unnecessary shedding;
- Dog Mat (freshly laundered) – preferably x 2;
- Portable food and water bowls;
- Food (ideally packed in sealed bags in meal portions);
- Medications for your dog (if required):
- This may also include if they are due for worming and de-flea spot on treatment;
- Leash, collar, Halti, waist harness;
- Brush, Zoom Groom, Furminator (for example);
- Poop bags;
- Hand wipes, sanitary hand cleaner;
- Garbage bags;
- Doggy Diapers;
- Absorbent Mat (may be provided by airline);
- Environmental enrichment toys that do not make any noises.
- Remember that the dog must not block aisles at any times. This becomes a safety and tripping hazard. Further, the DDA (1992) applies whereby:
- Must be unobtrusive at all times;
- The dog must be kept out of the way of staff at all times.
- Be aware that you are a representative of Canine Essentials. As such ensure that your dog behaves impeccably and is an ambassador to our company and our training.
In the interests of transparency, recommendations you can make to the airline staff to help make you stay a little easier
- Advise airline staff that your dog is trained to alleviate the effects of your disability and this all you are obliged to divulge. Please be amenable however, as this should have all been organised months ago when the booking had been made.
- Educate the staff in a non-confrontational way about the Disability Discrimination Act (1992) and the only places an Assistance Dog cannot enter is:
- The food preparation area.
- Ask if there are any members of staff/passengers who are scared and/or allergic to dogs and see if there can be some changes with the rostering system/seating arrangements.
- Ask if a staff member would be willing to volunteer to assist in caring for the dog if you become incapacitated and unable to care for the dog.
- Educate airline staff that it is illegal that the Assistance Dog be left alone in any circumstances.
- Preferably, ask the supervisor if he/she could instruct staff not to ask the handler why they have the Assistance Dog. This can be upsetting to the handler, is upsetting and can perpetuate stigma.
- Advise the supervisor that staff may NOT:
- Approach the dog;
- Make eye contact with the dog;
- Touch the dog, or;
- Speak to the dog.
- This distracts the dog and can prove (at times fatal to the owner).
- The airline should expect from your Assistance Dog:
- Be quiet;
- NO whining, growling or barking;
- The exception is whining if the Assistance Dog is indicating a need to go to the toilet (in this situation the dog is trained to toilet on command and will be able to hold until disembarking) or doing a trained alert bark or whine. Growling however is strictly prohibited;
- The dog should meets standards of hygiene and behaviour that are appropriate for an animal in a public place;
- Should never toilet inside the aircraft;
- Should sit quietly and unobtrusively on the floor (unless required to provide deep pressure therapy to relieve anxiety), and preferably the foot well (on a mat) or if placed on the seat beside the handler (if allowed by airline staff) should be protected by some form of covering;
- The Assistance Dog must always be visibly identifiable as an Assistance Dog in coat/harness with Canine Essentials membership card attached, clearly visible and leashed.
2 EQUITY
2.1 HUMAN RIGHTS AND EQUAL OPPORTUNITY
Policy
Canine Essentials promotes a culture of respect, tolerance and diversity and is also responsible for ensuring that all Employees are aware of their rights and obligations as outlined in this Equal Opportunity Policy.
Treating people fairly has a positive impact on Clients, Visitors and Employees, enhances the reputation of Canine Essentials as an employer of choice and delivers advantages to the business and workplace. Accordingly, Canine Essentials is committed to ensuring that all Employees and those persons seeking employment are treated fairly and equitably and are not subjected to any form of unlawful discrimination, harassment, bullying or victimisation in the workplace.
All levels of management and all Employees are responsible and accountable for ensuring that the provisions of this Equal Opportunity Policy are understood and adhered to and that the principles of Equal Opportunity are upheld in the decision making process, the performance of their respective duties and whilst acting as a representative of Canine Essentials.
Definition
“Unlawful Discrimination” in employment means treating a person less favourably than others because of their particular personal characteristics or because they belong to a certain group, such as a gender or culture, and this is unrelated to the performance requirements of the position. Discrimination can be direct or indirect. Indirect discrimination is sessions which appears to be equal but is unfair on certain people. To be unlawful, it must also be unreasonable. Mutual attraction or friendship with consent is not sexual harassment.
Procedure
It is unlawful to discriminate in employment under a range of both Federal and State legislation. Canine Essentials will not tolerate any form of discrimination based on any of the following grounds:
- Gender;
- Sexuality;
- Race, colour, nationality, descent and culture;
- Physical or intellectual disability;
- Family responsibilities;
- Age;
- Religion;
- Trade union membership or non-membership;
- Medical record;
- Pregnancy or potential pregnancy; or
- Marital status.
Client rights
Clients at Canine Essentials have the right to know the qualification of their Behaviourist/Trainer and the right to see the Behaviourist/Trainer of their choice, refuse intervention or seek a further opinion. Canine Essentials records such information in the client’s training records record including an explanation of the action taken. Clients are encouraged to provide feedback or make a complaint.
Discontinuing client’s relationship
At times, a Behaviourist/Trainer may not be able to effectively train a dog due to a variety of reasons due to such factors as a breakdown in the therapeutic relationship (e.g. the Client is behaving in a threatening or violent manner), cultural reasons, conflict of interest or range of professional scope.
In these cases, the Behaviourist/Trainer is not required to continue with services of the Client but refer them to another Behaviourist/Trainer that would better suit the Client’s needs. This ensures appropriate services are provided to the Client and also to prevent potential litigation.
Costs of intervention
Canine Essentials obtains informed financial consent when clients book training sessions with Clients.
Clients are given advanced information about consultation costs and billing systems including acceptable methods of payment, discounts that may apply and the costs incurred for late cancellations or failure to attend appointments.
Standard information such as this is provided:
- When booking the appointment;
- On our website; and
- In our Services Training Contract.
In addition, clients are given an estimated number of consultations for the proposed training:
- Whether the client needs to pay up-front, or;
- At the end of the session.
Culturally appropriate
- At Canine Essentials all staff avoid making general assumptions about a client’s individual needs when dealing with clients from different cultural backgrounds; and
- Employees at Canine Essentials are educated about culturally appropriate care and are aware of cultural groups likely to have higher incidence of post-traumatic stress so that Employees are well-placed to identify individual clients who may require a special approach to their training needs.
Interpreters
Canine Essentials will use an interpreter at the request of a client or if a Behaviourist/Trainer has concerns about the client’s capacity to comprehend information communicated in English;
- Where possible, Canine Essentials will provide an independent and formally accredited interpreter and will communicate any fee involved in advance;
- A family member or child may be used as an interpreter is circumstances where no other feasible option is available. In such situations, the health professional takes all reasonable care to cross-check that information is being communicated accurately; and
- If a client refuses language services against the advice of the Behaviourist/Trainer, this is documented in the client’s training records.
If any Employee feels that they have been discriminated against, they may make a complaint by following the procedure outlined in the Complaints and Disputes in the Workplace (Employees) Policy. (See also Workplace Bullying and Harassment Policy – available in the Closed Version of this Manual).
If any Employee is unsatisfied with the way their complaint has been handled by Canine Essentials they have the right to refer the matter to an appropriate statutory authority, such as the Equal Opportunity Commission.
Applicable Links
| o www.legislation.sa.gov.au/
o This site has links to SA legislation.
o For links to Commonwealth legislation.
o Links to the Fair Work Ombudsman. |
Appropriate References
| Equal Opportunity Act (1984) Racial Vilification Act (1996)Racial Discrimination Act (1975) Sex Discrimination Act (1984) Disability Discrimination Act (1992) Human Rights and Equal Opportunity Commission Act (1986) Age Discrimination Act (2004) Equal Opportunity for Women in the Workplace Act (1999) |
2.2 CULTURALLY APPROPRIATE
Policy
Canine Essentials operates in an area where there is considerable cultural diversity. We will ensure that we are responsive to the needs of Clients from diverse cultures.
Procedure
The following principles shape Canine Essentials response to our Clients who come from culturally and linguistically diverse backgrounds.
Access
Our services are available to all and free from any form of discrimination related to a person’s country of birth, language, culture, race or religion.
Equity
We will ensure that we offer fair sessions for all potential Clients.
Communication
We will ensure that all Clients from culturally and linguistically diverse backgrounds receive full information about our service, informed consent, information about sessions options and likely outcomes and fees. Where the Client is not familiar with any of the languages spoken in this office of Canine Essentials we will provide information in a language they understand.
Our office of Canine Essentials will engage interpreters if a common language is not able to be found between the Client and the Clinician.
Responsiveness
We will be sensitive to the needs and requirements of Clients from diverse linguistic and cultural backgrounds and responsive as far as practicable to the particular circumstances of individuals.
Culturally appropriate care
We will ensure that we do not make assumptions about people on the basis of their cultural origins. In addition we will strive to provide culturally appropriate options to Clients who have specific needs based on cultural experiences and beliefs.
Accountability
We are accountable for our actions and behaviour with Clients and will ensure that we are open to feedback about any areas where we need to improve.
2.3 CHILDREN AND YOUNG PEOPLE
Policy
Canine Essentials is committed to ensuring that children and young people receive a high quality service which is sensitive to their unique needs.
This policy reflects our commitment to provide a safe environment where every person has the right to be safe, treated with respect and protected from harm.
The Work Health and Safety Act (2012) requires all Employees to act safely at all times. In addition to that requirement, Canine Essentials is committed to complying with the Children’s Protection Act (1993) including:
- Section 8B-8(d) -Child safe environments and criminal history assessment for people working with children; and
- Section 11-Mandatory Reporting.
Procedure Children’s and young people’s participation The Nursing and Midwifery Board of Australia Code of Conduct provides the following guidelines for the management of children and young people that all Employees must follow:
- Placing the interests and wellbeing of the child or young person first;
- Ensuring that, when communicating with a child or young person, Behaviourist/Trainer:
- treat the child or young person with respect and listen to their views;
- encourage questions and answer those questions to the best of the Behaviourist/Trainer’s ability;
- provide information in a way the child or young person can understand;
- remain alert to children and young people who may be at risk and notify appropriate child protection authorities as required by law; and
- Ensuring all Council by-laws are adhered too when handling the dog (namely age requirements).
Recruitment
Canine Essentials takes all reasonable steps to ensure that it engages the most suitable and appropriate people to work with children and young people. To this end, we:
- Interview and conduct referee checks on all applications for positions; and
- Require current criminal history checks documentation on applicants.
Ongoing
Canine Essentials will take the following steps to ensure that Employees comply with their mandated requirements relating to children’s safety:
- Require Employees to advise the Director if their legal status changes;
- Require an update of all Police checks every 3 years for each Employee;
- Require all Employees to comply with Canine Essentials’ Code of Conduct and the Nursing and Midwifery Board’s Code of Conduct;
- Require any Employee who suspects abuse of a child by a parent or guardian to notify appropriate child protection authorities as required by law. In SA this involves making a Mandated Report to the Child Abuse Report Line (13 14 78);
- Require any Employee who suspects abuse of a child by a colleague or other Employee to make a Mandated Notification to AHPRA (1300419495); and
- Ensure that there is ongoing support available to the person who made the Mandated Notification, particularly where an ongoing service is provided to the child, young person and/or their family.
Employees who are considered to have jeopardised the safety or wellbeing of children or young people will be subject to disciplinary procedures which could include termination of employment.
Applicable Links
|
Appropriate References
| AHPRA – Guidelines for Mandatory Notifications
*** Canine Essentials seeks to have Canine Behaviourists that are also Healthcare Professionals. As such, the below applies: S3 — Notifiable Conduct Section 140 of the National Law defines “notifiable conduct” as when a practitioner has: (…)
Children’s Protection Act (1993) S6 — Interpretation
|
2.4 DISABILITY, DISCRIMINATION & EQUITY POLICY
Canine Essentials operates using the legal framework being:
- Australian Human Rights Commission (AHRC) Act (1992)
- Commonwealth Disability Discrimination Act (DDA) (1992)
- South Australian Equal Opportunity Act (1984)
Disability & Discrimination
Canine Essentials defines “Disability” and “Discrimination” as follows:
Disability: The definition of disability adopted by Canine Essentials is that which appears in Section 4 of the DDA (1992).
- Disability, in relation to a person, means:
-
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total or partial loss of the person’s bodily or mental functions; or
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total or partial loss of a part of the body; or
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the presence in the body of organisms causing disease or illness; or
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the presence in the body of organisms capable of causing disease or illness; or
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the malfunction, malformation or disfigurement of a part of the person’s body; or
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a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or
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a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour; and includes a disability that:
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presently exists; or
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previously existed but no longer exists; or
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may exist in the future (including because of a genetic predisposition to that disability); or
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is imputed to a person.
- To avoid doubt, a disability that is otherwise covered by this definition includes behaviour that is a symptom or manifestation of the disability.disability aid has the meaning given by subsection 9(3).
- disability standards has the meaning given by subsection 31(1).
- discriminate has the meaning given by sections 5 and 6.
- Note: Section 7 (associates) and section 8 (carers, assistants, assistance animals and disability aids) extend the concept of discrimination.
-
-
Discrimination: The definition of discrimination adopted by Canine Essentials is that which appears in Sections 5 and 6 of the DDA.
-
5 Direct disability discrimination
- For the purposes of this Act, a person (the discriminator) discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if, because of the disability, the discriminator treats, or proposes to treat, the aggrieved person less favourably than the discriminator would treat a person without the disability in circumstances that are not materially different.
- For the purposes of this Act, a person (the discriminator) also discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator does not make, or proposes not to make, reasonable adjustments for the person; and
- the failure to make the reasonable adjustments has, or would have, the effect that the aggrieved person is, because of the disability, treated less favourably than a person without the disability would be treated in circumstances that are not materially different.
- For the purposes of this section, circumstances are not materially different because of the fact that, because of the disability, the aggrieved person requires adjustments.
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6 Indirect disability discrimination
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For the purposes of this Act, a person (the discriminator) discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator requires, or proposes to require, the aggrieved person to comply with a requirement or condition; and
- because of the disability, the aggrieved person does not or would not comply, or is not able or would not be able to comply, with the requirement or condition; and
- the requirement or condition has, or is likely to have, the effect of disadvantaging persons with the disability.
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For the purposes of this Act, a person (the discriminator) also discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator requires, or proposes to require, the aggrieved person to comply with a requirement or condition; and
- because of the disability, the aggrieved person would comply, or would be able to comply, with the requirement or condition only if the discriminator made reasonable adjustments for the person, but the discriminator does not do so or proposes not to do so; and
- the failure to make reasonable adjustments has, or is likely to have, the effect of disadvantaging persons with the disability.
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Subsection (1) or (2) does not apply if the requirement or condition is reasonable, having regard to the circumstances of the case.
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For the purposes of subsection (3), the burden of proving that the requirement or condition is reasonable, having regard to the circumstances of the case, lies on the person who requires, or proposes to require, the person with the disability to comply with the requirement or condition.
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Principle of Access and Equity
Clients
Canine Essentials is committed to providing access and equity for clients with disabilities to enable them to participate fully and independently, to the greatest extent possible, in their academic, cultural and social life. In particular, Canine Essentials has the following objectives:
- to provide opportunities for clients with disabilities to realise their individual capabilities for intellectual, social, emotional and physical development through a high level of participation in Canine Essentials;
- to ensure that people with disabilities are not discriminated against in admission to any course or service offered by Canine Essentials;
- Canine Essentials will consider applications to vary the standard entry requirements for people with disabilities;
- to provide equipment and support services that prevent, minimise or overcome barriers to fuller participation in courses, education and other activities within Canine Essentials;
- to respect the rights of people with disabilities to privacy and confidentiality and to ensure the delivery of services to clients with disabilities in a manner that respects and promotes their dignity, rights and opportunities;
- to foster and encourage, among staff, clients and the community, positive, informed and unprejudiced attitudes towards people with disabilities;
- to encourage clients (particularly those undergoing Assistance Dog Training) to maintain memberships with other dog training organisations. It is Canine Essentials opinion that independent accreditation or training of dogs by multiple organisations benefits both the client and dog in a positive and beneficial manner;
- to cooperate with organisations, universities, TAFE, schools, government and community organisations to maximise use of resources available to the State for clients with disabilities;
Staff
Canine Essentials is committed to providing access and equity for staff with disabilities to enable them to participate fully and independently as employees of Canine Essentials in all aspects associated with work, career development and employee relations at Canine Essentials.
2.5 EQUAL OPPORTUNITY & FREEDOM OF ASSOCIATION
Canine Essentials abides by the Australian Equal Opportunity Act (1984); whereby “Equal opportunity is a stipulation that all people should be treated similarly, unhampered by artificial barriers or prejudices or preferences” (Government of South Australia 1984). This is interpreted to be that clients of Canine Essentials are encouraged to be members or consumers of other canine services and will not be disadvantaged in any way by Canine Essentials.
Likewise, the Australian Charter of Human Rights (Victorian Equal Opportunity & Equal Rights Commission 2017) allows Australians the right to have “freedom of association”. As such, it our clients’ right to be a member of whichever organisation they choose and also, be a member of many organisations in the same field should they choose to be.
Note: In this current climate, Canine Essentials believes that clients that utilise Assistance Dogs in their day-to-day life should consider (if they are financially able to do so), be a member of at least two organisations. In this way, clients can have multiple advocates if they require, get the benefit of two Public Standard Assessments - independently assessed by two trained professionals, and, be able to receive different forms of education and advice that they can utilise when training their dog.
Should you believe that there has been a breach in this policy, you are strongly encouraged to contact the Director of Canine Essentials who will treat this matter as strictly confidential, and in no way will you be disadvantaged if you make a complaint.
3 Contract
3.1 SERVICES CONTRACT AND WAIVER
|
Contract Terms & Conditions [Click Here] |
Complete Training Contract [HERE] |
Canine Essentials require a Training (Services) Contract to be signed prior to any service being provided. This Training Contract offers important information and you, the client are required to acknowledge that you have read, understood and will abide by the conditions as set out in this contract. Prior to engaging Canine Essentials, please read this contract carefully to ensure that you are in full agreement with the conditions outlined.
Canine Essentials is committed to ensuring all clients have the opportunity to participate in safe and appropriate ways. In addition, Canine Essentials considers the welfare of the dogs under our care must be paramount. As such, prior to any training or behaviour modification commencing, and at the time of purchasing any service, the client will be required to complete and sign a Service Contract. This contract requires the Values, Ethics and Policies document in addition to the terms and conditions of our services provided. Canine Essentials will undertake to explain any of the conditions stated within the contract and are happy to discuss any concerns you may have. You are also invited to take this contract away to be reviewed by other independent parties. However, prior to training this contract must be signed with no exceptions. Please see the Training Contract (for training dogs) or Services Contract (for presentations or other such business activities) for relevant Terms of Service, Waivers, Agreements and undertakings required of the client and Canine Essentials.
As Canine Essentials prides itself on being "Disability Friendly" and accessible in every way, should you require a copy printed and posted, or, a form fill version emailed so this can be typed on should one experience hand writing difficulties (for example), please contact Canine Essentials, or call 0426975364.
4 Complaints
4.1 COMPLAINTS POLICY
As Canine Essentials prides itself on being "Disability Friendly" and accessible in every way, should you require a copy printed and posted, or, a form fill version emailed so this can be typed on should one experience hand writing difficulties (for example), please contact Canine Essentials, or call 0426975364.
Introduction
Purpose
This policy is intended to ensure that we handle complaints fairly, efficiently and effectively.
Our complaint management system is intended to:
- enable us to respond to issues raised by people making complaints in a timely and cost-effective way
- boost public confidence in our administrative process, and
- provide information that can be used by us to deliver quality improvements in our products, services, staff and complaint handling.
This policy provides guidance to our staff and people who wish to make a complaint on the key principles and concepts of our complaint management system.
Scope
This policy applies to all staff receiving or managing complaints from the public made to or about us, regarding our products, services, staff and complaint handling.
Staff grievances, code of conduct complaints (for local councils) and public interest disclosures are dealt with through separate mechanisms.
Organisational commitment
This organisation expects staff at all levels to be committed to fair, effective and efficient complaint handling. The following table outlines the nature of the commitment expected from staff and the way that commitment should be implemented.
| Who | Commitment | How |
| Director of Canine Essentials Pty. Ltd. | Promote a culture that values complaints and their effective resolution | Report publicly on Canine Essentials Pty. Ltd.’s complaint handling.
Provide adequate support and direction to key staff responsible for handling complaints. Regularly review reports about complaint trends and issues arising from complaints. Encourage all staff to be alert to complaints and assist those responsible for handling complaints resolve them promptly. Encourage staff to make recommendations for system improvements. Recognise and reward good complaint handling by staff. Support recommendations for product, service, staff and complaint handling improvements arising from the analysis of complaint data. |
| Manager responsible for complaint handling (Director of Canine Essentials Pty. Ltd.) or assigned substitute. | Establish and manage our complaint management system. | Provide regular reports to Director of Canine Essentials Pty. Ltd. on issues arising from complaint handling work.
Ensure recommendations arising out of complaint data analysis are canvassed with the Director of Canine Essentials Pty. Ltd. Recruit, train and empower staff to resolve complaints promptly and in accordance with Canine Essential Pty. Ltd.’s policies and procedures. Encourage staff managing complaints to provide suggestions on ways to improve the organisation’s complaint management system. Encourage all staff to be alert to complaints and assist those responsible for handling complaints resolve them promptly. Recognise and reward good complaint handling by staff. |
| Staff whose duties include complaint handling | Demonstrate exemplary complaint handling practices | Treat all people with respect, including people who make complaints.
Assist people make a complaint, if needed. Comply with this policy and its associated procedures. Keep informed about best practice in complaint handling. Provide feedback to management on issues arising Provide suggestions to management on ways to improve the organisation’s complaints management system. Implement changes arising from individual complaints and from the analysis of complaint data as directed by management. |
| All staff | Understand and comply with Canine Essentials Pty. Ltd.’s complaint handling practices. | Treat all people with respect, including people who make complaints.
Be aware of Canine Essentials Pty. Ltd.’s complaint handling policies and procedures. Assist people who wish to make complaints access the Canine Essentials Pty. Ltd.’s complaints process. Be alert to complaints and assist staff handling complaints resolve matters promptly. Provide feedback to management on issues arising from complaints. Implement changes arising from individual complaints and from the analysis and evaluation of complaint data as directed by management. |
Terms and Definitions
Complaint
Expression of dissatisfaction made to or about us, our products, services, staff
or the handling of a complaint where a response or resolution is explicitly or implicitly expected or legally required.
A complaint covered by this Policy can be distinguished from:
- staff grievances [see our grievance policy – internal policy]
- public interest disclosures made by our staff [see our internal reporting policy]
- code of conduct complaints [see our Standards for Trainers]
- responses to requests for feedback about the standard of our service provision [see the definition of ‘feedback’ below]
- reports of problems or wrongdoing merely intended to bring a problem to our notice with no expectation of a response [see definition of ‘feedback]
- service requests [ see definition of ‘service request’ below], and
- requests for information [see our privacy policy].
Complaint management system
All policies, procedures, practices, staff, hardware and software used by us in the management of complaints.
Dispute
An unresolved complaint escalated either within or outside of our organisation.
Feedback
Opinions, comments and expressions of interest or concern, made directly or indirectly, explicitly or implicitly, to or about us, about our products, services or complaint handling where a response is not explicitly or implicitly expected or legally required.
Service request
- requests for approval
- requests for action
- routine inquiries about the organisation’s business
- requests for the provision of services and assistance
- reports of failure to comply with laws regulated by the organisation
- requests for explanation of policies, procedures and decisions.
Grievance
A clear, formal written statement by an individual staff member about another staff member or a work related problem. [Handled internally].
Policy
A statement of instruction that sets out how we should fulfil our vision, mission and goals.
Procedure
A statement or instruction that sets out how our policies will be implemented and by whom.
Guiding principles
Facilitate complaints
People focus
We are committed to seeking and receiving feedback and complaints about our services, systems, practices, procedures, products and complaint handling. Any concerns raised in feedback or complaints will be dealt with within a reasonable time frame.
People making complaints will be:
- provided with information about our complaint handling process
- provided with multiples and accessible ways to make complaints
- listened to, treated with respect by staff and actively involved in the complaint process where possible and appropriate, and
- provided with reasons for our decision/s and any options for redress or review.
No detriment to people making complaints
We will take all reasonable steps to ensure that people making complaints are not adversely affected because a complaint has been made by them or on their behalf.
Anonymous complaints
We accept anonymous complaints and will carry out an investigation of the issues raised where there is enough information provided.
Accessibility
We will ensure that information about how and where complaints may be made to or about us is well publicised. We will ensure that our systems to manage complaints are easily understood and accessible to everyone, particularly people who may require assistance.
If a person prefers or needs another person or organisation to assist or represent them in the making and/ or resolution of their complaint, we will communicate with them through their representative if this is their wish. Anyone may represent a person wishing to make a complaint with their consent (e.g. advocate, family member, legal or community representative, member of Parliament, another organisation).
No charge
Complaining to us is free.
Respond to complaints
Early resolution
Where possible, complaints will be resolved at first contact with Canine Essentials Pty. Ltd.
Responsiveness
We will promptly acknowledge receipt of complaints.
We will assess and prioritise complaints in accordance with the urgency and/or seriousness of the issues raised. If a matter concerns an immediate risk to safety or security the response will be immediate and will be escalated appropriately.
We are committed to managing people’s expectations, and will inform them as soon as possible, of the following:
- the complaints process
- the expected time frames for our actions
- the progress of the complaint and reasons for any delay
- their likely involvement in the process, and
- the possible or likely outcome of their complaint.
We will advise people as soon as possible when we are unable to deal with any part of their complaint and provide advice about where such issues and/or complaints may be directed (if known and appropriate).
We will also advise people as soon as possible when we are unable to meet our time frames for responding to their complaint and the reason for our delay.
Objectivity and fairness
We will address each complaint with integrity and in an equitable, objective and unbiased manner.
We will ensure that the person handling a complaint is different from any staff member whose conduct or service is being complained about.
Conflicts of interests, whether actual or perceived, will be managed responsibly. In particular, internal reviews of how a complaint was managed will be conducted by a person other than the original decision maker.
Responding flexibly
Our staff are empowered to resolve complaints promptly and with as little formality as possible.
We will adopt flexible approaches to service delivery and problem solving to enhance accessibility for people making complaints and/or their representatives.
We will assess each complaint on its merits and involve people making complaints and/or their representative in the process as far as possible.
Confidentiality
We will protect the identity of people making complaints where this is practical and appropriate.
Personal information that identifies individuals will only be disclosed or used by Canine Essentials Pty. Ltd. as permitted under the relevant privacy laws, secrecy provisions and any relevant confidentiality obligations.
Manage the parties to a complaint
Complaints involving multiple agencies
Where a complaint involves multiple organisations, we will work with the other organisation/s where possible, to ensure that communication with the person making a complaint and/or their representative is clear and coordinated.
Subject to privacy and confidentiality considerations, communication and information sharing between the parties will also be organised to facilitate a timely response to the complaint.
Where a complaint involves multiple areas within our organisation, responsibility for communicating with the person making the complaint and/or their representative will also be coordinated.
Where our services are contracted out, we expect contracted service providers to have an accessible and comprehensive complaint management system. We take complaints not only about the actions of our staff but also the actions of service providers.
Complaints involving multiple parties
When similar complaints are made by related parties we will try to arrange to communicate with a single representative of the group.
Empowerment of staff
All staff managing complaints are empowered to implement our complaint management system as relevant to their role and responsibilities.
Staff are encouraged to provide feedback on the effectiveness and efficiency of all aspects of our complaint management system.
Managing unreasonable conduct by people making complaints
We are committed to being accessible and responsive to all people who approach us with feedback or complaints. At the same time our success depends on:
- our ability to do our work and perform our functions in the most effective and efficient way possible
- the health, safety and security of our staff, and
- our ability to allocate our resources fairly across all the complaints we receive.
When people behave unreasonably in their dealings with us, their conduct can significantly affect the progress and efficiency of our work. As a result, we will take proactive and decisive action to manage any conduct that negatively and unreasonably affects us and will support our staff to do the same in accordance with this policy.
Complaint Management System
Introduction
When responding to complaints, staff should act in accordance with our complaint handling procedures as well as any other internal documents providing guidance on the management of complaints.
Staff should also consider any relevant legislation and/or regulations when responding to complaints and feedback.
The five key stages in our complaint management system are set out below.
Receipt of complaints
Unless the complaint has been resolved at the outset, we will record the complaint and its supporting information. We will also assign a unique identifier to the complaint file.
The record of the complaint will document:
- the contact information of the person making a complaint
- issues raised by the person making a complaint and the outcome/s they want
- any other relevant and
- any additional support the person making a complaint requires.
Acknowledgement of complaints
We will acknowledge receipt of each complaint promptly, and preferably within 4 working days.
Consideration will be given to the most appropriate medium (e.g. email, letter) for communicating with the person making a complaint.
Initial assessment and addressing of complaints
Initial assessment
After acknowledging receipt of the complaint, we will confirm whether the issue/s raised in the
complaint is/are within our control. We will also consider the outcome/s sought by the person making a complaint and, where there is more than one issue raised, determine whether each issue needs to be separately addressed.
When determining how a complaint will be managed, we will consider:
- How serious, complicated or urgent the complaint is
- Whether the complaint raises concerns about people’s health and safety
- How the person making the complaint is being affected
- The risks involved if resolution of the complaint is delayed, and
- Whether a resolution requires the involvement of other organisations.
Addressing complaints
After assessing the complaint, we will consider how to manage it. To manage a complaint we may:
- Give the person making a complaint information or an explanation
- Gather information from the product, person or area that the complaint is about, or
- Investigate the claims made in the complaint.
We will keep the person making the complaint up to date on our progress, particularly if there are any delays. We will also communicate the outcome of the complaint using the most appropriate medium. Which actions we decide to take will be tailored to each case and take into account any statutory requirements.
Providing reasons for decisions
Following consideration of the complaint and any investigation into the issues raised, we will contact the person making the complaint and advise them:
- the outcome of the complaint and any action we took
- the reason/s for our decision
- the remedy or resolution/s that we have proposed or put in place, and
- any options for review that may be available to the complainant, such as an internal review, external review or appeal.
If in the course of investigation, we make any adverse findings about a particular individual, we will consider any applicable privacy obligations under the Privacy and Personal Information Protection Act 1998 and any applicable exemptions in or made pursuant to that Act, before sharing our findings with the person making the complaint.
Closing the complaint, record keeping, redress and review
We will keep comprehensive records about:
- How we managed the complaint
- The outcome/s of the complaint (including whether it or any aspect of it was substantiated, any recommendations made to address problems identified and any decisions made on those recommendations, and
- Any outstanding actions that need to be followed up.
We will ensure that outcomes are properly implemented, monitored and reported to the complaint handling manager and/or senior management.
Alternative avenues for dealing with complaints
We will inform people who make complaints to or about us about any internal or external review options available to them (including any relevant Ombudsman or oversight bodies).
The three levels of complaint handling
We aim to resolve complaints at the first level, the frontline. Wherever possible staff will be adequately equipped to respond to complaints, including being given appropriate authority, training and supervision.
Where this is not possible, we may decide to escalate the complaint to a more senior officer within Canine Essentials Pty. Ltd.. This second level of complaint handling will provide for the following internal mechanisms:
- assessment and possible investigation of the complaint and decision/s already made, and/or
- facilitated resolution (where a person not connected with the complaint reviews the matter and attempts to find an outcome acceptable to the relevant parties).
Where a person making a complaint is dissatisfied with the outcome of [organisation’s name] review of their complaint, they may seek an external review of our decision (by the Ombudsman for example).
Accountability and learning
Analysis and evaluation of complaints
We will ensure that complaints are recorded in a systematic way so that information can be easily retrieved for reporting and analysis.
Regular reports will be run on:
- the number of complaints received
- the outcome of complaints, including matters resolved at the frontline
- issues arising from complaints
- systemic issues identified, and
- the number of requests we receive for internal and/or external review of our complaint handling.
Regular analysis of these reports will be undertaken to monitor trends, measure the quality of our customer service and make improvements.
Both reports and their analysis will be provided to Canine Essentials Pty. Ltd.’s Director and senior management for review.
Monitoring of the complaint management system
We will continually monitor our complaint management system to:
- ensure its effectiveness in responding to and resolving complaints, and
- identify and correct deficiencies in the operation of the system.
Monitoring may include the use of audits, complaint satisfaction surveys and online listening tools and alerts.
Continuous improvement
We are committed to improving the effectiveness and efficiency of our complaint management system. To this end, we will:
- support the making and appropriate resolution of complaints
- implement best practices in complaint handling
- recognise and reward exemplary complaint handling by staff
- regularly review the complaints management system and complaint data, and
- implement appropriate system changes arising out of our analysis of complaints data and continual monitoring of the system.
5 Training and Standards
5.1 CANINE GENERAL POLICY
Canine Essentials considers the welfare of dogs in our charge and under our care to be paramount. Owning a dog is a life-long commitment, and as such, are must honour that commitment by being responsible for having our companion´s needs met. Canine Essentials promotes the responsible handling of dogs and in addition uses dog-friendly techniques in line with the Association of Pet Dog Trainers Incorporated (2017) core values. As such all our Behaviourists and Trainers use as the first option positive reinforcement e.g. administering a reward for a desired behaviour and negative punishment e.g. not administering the reward when undesirable behaviour is displayed.
Because each dog and its owner is unique, we are committed to a thorough and careful assessment before deciding on one of the many training methods we are able to employ. Following that, we will create an individualised training plan that suits both you and your dog. We consider that building a bond with your companion is critical, but must be accompanied by respect (for the dog and for the human) in addition to leadership. We do this by being fair to your dog and are committed to set them up for success in each and every training session.
Canine Essentials policies reflect our desire to promote professionalism within the industry, and encourage responsible and ethical handling of dogs. Policy statements are under constant review and are posted on our website.
Canine Essentials has a robust policy development mechanism which includes consultation with members, provision of external expertise where appropriate and a review process based on changes within the industry and externally.
5.2 FORCE FREE POLICY
Canine Essentials considers the welfare of dogs under our care must be of primary importance and the safe and ethical training of dogs be paramount. Dr. Geller, as the Director of Canine Essentials, is a proud member of the Pet Professional Guild Australia “The Association for Force-Free Pet Professionals”, and all training policies comply with their Guiding Principles.
Definition of Force-Free
In line with the Pet Professional Guild Australia, Canine Essentials “understands force-free to mean that methods involving shock, pain, choking, fear, and/or physical compulsion are never used to manage, care for or train pets.”
Non-Negotiable Banned Equipment
In line with the Pet Professional Guild Australia (and as per Canine Essentials Policy 5.5), Canine Essentials deems the following equipment banned per the Pet Professional Guild Australia’s Guiding Principles and as per our own policies. Devices used to choke; prong, and/or shock pets constitute that which is considered to be banned. For further banned devices, please refer to Policy 5.5 in this manual.
5.3 CANINE TRAINING
Canine Essentials considers the welfare of dogs under our care must be of primary importance and the safe and ethical training of dogs be paramount. We consider that the behaviour of a pet dog is determined by a combination of genetics life experiences – including training and socialisation with other dogs and humans– and their environment.
Reward-based positive reinforcement training is the most humane and effective dog training method. It sets the dog up to succeed and it is proven to be enjoyable and rewarding for both dog and handler resulting in an enhanced relationship between them. Canine Essentials ensures that our training methods are humane and will not cause pain, injury, distress or suffering to the dog by using, Positive Reinforcement (administering a reward) and Negative Punishment (withholding a reward). As such, Canine Essentials training programs are designed to facilitate the development and maintenance of acceptable behaviours using reward-based positive reinforcement.
Canine Essentials will not develop or utilise any training programs based on aversive stimuli, dominance, force or punishment.* These programs are inhumane and can cause long-term behavioural problems.
Canine Essentials position is that the notion of dominance is an obsolete and aversive method of interacting with dogs. It is founded in incorrect and misinterpreted data, often resulting in damage to the dog-human relationship and behavioural problems in the dog. Canine Essentials view is that dog handlers should be educated by organisations and associations on dominance theory and the numerous problems arising from such thinking. Our position is consistent with leading dog behaviourists. Canine Essentials agree with ethologists who claim that dominance theory is frequently applied to dog training in a way that promotes adversarial relationships between dogs and humans. Dominance theory is a counterproductive construct that distracts from the functional relationship between behaviour, and the environment, which actually causes and explains behaviours. It is the position of Canine Essentials that all training be conducted in a manner which encourages dogs and focuses on the use of behaviourism. Canine Essentials Trainers and Behaviourists use functional analysis to identify and resolve problem behaviours. Canine Essentials actively abstains from the use of the term “dominance” and all training methods employing dominance theory.
* Punishment is defined as applying something aversive (painful or unpleasant) to the dog when a certain behaviour is displayed.
5.4 RESPONSIBILITIES FOR THE DIRECTOR
The Director of Canine Essentials is solely responsible for providing for all care and welfare needs of dogs, staff and facilities under the control and ownership of the business, including but not limited to:
- Ensuring compliance with all relevant Codes and Regulations
- Protection of dogs from over handling, particularly by children.
- Protection of dogs from disease, distress, stress or injury.
- Setting in place arrangements with a veterinary surgeon to ensure prompt attention as required.
- Ensuring maintenance of clean, tidy and hygienic conditions in the business environment
- Ensuring that all products/items for sale conform to state and federal requirements and that these do not endanger the safety of dogs or users.
- Ensuring all staff are appropriately skilled, experienced &/or qualified to undertake the tasks to which they are assigned when required to handle/manage dogs demonstrate a compassionate attitude to dogs as well as technical skills.
- Ensuring that at all times adequately qualified and experienced staff are available to provide appropriate services to the public and the dogs in their care. This includes adequate product knowledge to avoid inappropriate sales.
- Undertaking all reasonable measures to ensure staff health and safety, and to manage all relevant workplace risks, including the risk of contracting zoonotic disease by those in direct contact with dogs.
- Ensuring that certain staff members are properly trained to meet particular State and Territory requirements e.g. Certified First Aid staff, Fire Wardens etc.
- Providing adequate ongoing training to ensure optimal dog and staff health and welfare. This includes induction training and ongoing staff and Director training.
- Ensuring staff (including the Director) are protected from bullying, aggressive, violent, un-cooperative or disrespectful behaviour from clients and the public.
- Ensuring adequate systems and processes, written procedures and record keeping are in place to demonstrate the above without ambiguity.
5.5 STANDARDS FOR TRAINERS
The minimum standards Canine Essentials adopts are as follows:
- Canine Essentials Trainers and Behaviourist’s must understand and adhere to all policies and standards as described in this manual.
- Canine Essentials Trainers and Behaviourist’s must be able to produce effective training results for both Assistance Dog and Pet-Dog training programs.
- They are appropriately trained and/or experienced to undertake all tasks they are required to undertake, particularly for roles including handling and management of dogs
- They bring to the attention of their manager or the Director any deficiencies in their knowledge or skills in relation to their roles, particularly for roles including the handling and management of dogs and including species specific knowledge and skills.
- They are aware of their obligations under this Code, including the Code of Ethics.
- They can adequately provide members of the public with detailed and accurate information about the care and management of the species of dogs in their care and/or the products that they recommend.
- They are knowledgeable and trained in the use of medications to treat ill dogs under their control and empowered to seek professional veterinary advice when appropriate.
- Regardless of the circumstances, they maintain a professional and compassionate attitude toward the public, the dogs in their care and the other staff with whom they work.
- They can recognise stress in the dogs under their care, including breathing, feeding, postural, and behavioural signs.
- Any deviations from this Code are immediately reported to the manager or Director.
- Canine Essentials Trainers and Behaviourist’s must have up-to-date knowledge on the following:
- canine behaviour;
- canine learning theory;
- canine care and safety;
- appropriate training techniques and methods, and;
- appropriate and humane equipment use.
- Canine Essentials Trainers and Behaviourist’s must demonstrate effective:
- communication and dispute resolution skills;
- educational instruction at both an individual and group level;
- problem solving skills;
- assessment skills, and;
- reflective skills (self-assessment) to enhance their personal performance.
- Canine Essentials Trainers and Behaviourist’s must be able to determine when training programs should be altered or discontinued.
- Canine Essentials staff Dogs must wear approved Canine Essentials gear (see approved wear). They must also carry their Canine Essentials Staff Card on their person.
- Canine Essentials Trainers and Behaviourist’s must demonstrate a responsibility to the wider community. They must have
- a knowledge of all laws relevant to the training program being undertaken;
- the ability to build a rapport not only with Clients of Canine Essentials, but also, their co-workers and the community, and;
- the ability and be able to display appropriate and professional behaviour when working with Clients either in their home or in the public sphere. This includes
- being polite;
- showing respect;
- consideration of property;
- maintaining appropriate personal hygiene;
- educating and maintaining appropriate canine hygiene, and;
- be more than willing to educate the community about Assistance Dogs, their rights and the laws surrounding Assistance Dogs in Australia.
5.6 CANINE TRAINING EQUIPMENT
Canine Essentials considers the welfare of the dogs under our care to be of primary importance and the safe and ethical training of dogs be paramount. Accordingly, Canine Essentials requires equipment to be humane and not cause injury, pain, suffering or distress to the dog. Therefore any device used to modify the behaviour of a companion dog must also not cause injury, pain, suffering or distress. Canine Essentials will not develop or utilise any training programs based on aversive stimuli, dominance, force or punishment*. This includes any equipment used in the training of dogs.
* Punishment is defined as applying something painful or unpleasant to dogs when a certain behaviour is carried out.
Approved Dog Training Equipment:
Canine Essentials will only use humane training equipment when working with dogs.
- The use of collars and leads intended to apply constriction, pressure, pain or force – such as choke chains and prong collars – are strictly not allowed.
- Canine Essentials actively promotes the use of safe equipment such as: flat buckle collars, head halters, harnesses and other types of control equipment.
- Collars:
- Buckle Collars, Flat Collars, Front Clip Harnesses, Gentle Leader Head Halters, Halti´s, Regular Harnesses–that attach from the top, are all suitable.
- Leashes:
- Leashes must not exceed 2 metres in length (or as stipulated by council leash laws)
- Leather, nylon, or cotton leashes are suitable
- Quality leather leashes are recommended for dogs past the chewing stage.
- For dogs (or Toy to Small Breed Puppies/Dogs) that pull on the lead &/or for handlers with physical limitations:
- Positive anti-pull devices are recommended.
- Collars:
Note: Veterinarians often recommend that collars not be used when walking puppies or toy/small breeds in order to avoid damage to their necks/trachea. Choose a regular harness or positive anti-pull device while walking or in training.
For public safety, dogs are required to be on leash and attached to handlers at all times; whether inside the Training Facility, an outside venue, or a Private Lesson or in public with Canine Essentials’ representatives.
Long Lines may be used– in line with the South Australian Leash Laws– in outside settings – while working with long distance recalls and stays; although restricted breed laws apply in certain instances.
Handlers not following these safety requirements will be excused from lessons.
Banned Equipment:
- No Choke Chains
- No Prong Collars
- No Shock Collars
- No Slip Collars
- No Chain Martingale Collars
- No Muzzles (except in certain instances with permission from Canine Essentials Behaviourist or Trainer)
- No Flexi-Leashes (Retractable Leashes)
- No Chain Type Leashes (as can break a dog´s teeth and are hard on owner´s hands)
- No Citronella Barking Collars in Class
- No wrapping leashes around dogs waist in a quick fix for pulling. There are waist devices available that enable a safe release if required, and as such, is considered a safer option.
Rationale
Canine Essentials is opposed to the use of any device that are inhumane and abusive – this is defined to be devices that inflict pain and as such, denote punishment. These include:
- Electric shock devices
- Collars delivering aversive sound or scent
- Pronged/pinch collars
- Choke chain collars
- Muzzles:
- should not be used as a routine management procedure, and;
- for the majority of dogs they serve no constructive objective.
- When muzzling devices are used, they must:
- be worn for short periods only and where the dog is under constant supervision;
- be properly fitted avoiding risk of injury, pain or distress; allow the dog to undertake normal activities such as panting and drinking and;
- the only exception is when muzzles are used for Veterinary clinical examinations.
- When muzzling devices are used, they must:
5.7 DIFFICULTIES EXPERIENCED
Canine Essentials considers that the welfare of the dogs under our supervision be paramount. Therefore it is critical our training methods be safe and honourable. If a handler is anxious because the dog is not focusing enough to be able to work properly –perhaps too excited, too barky or too shy, please bring it to the Instructor´s attention right away – if the instructor happens to miss it for any reason. There are things that can be done to help get and maintain the dog´s focus and or build its confidence.
In the event that the handler/owner experiences ´technical difficulties´ away from class, please do not wait until session time to discuss them. Many problems have simple solutions. The whole purpose of these sessions is to offer support to the dog owner. So please bring any concerns to our attention sooner than later. We work hard to promote good relations between clients and Canine Essentials.
Please call or email beforehand. Remember, we want to know so we can assist you to succeed!
5.8 SPECIAL REQUIREMENTS
Canine Essentials is committed to ensuring all clients have the opportunity to participate despite physical or other limitations. Therefore if you have hearing difficulties or other special physical needs (example: you have a bad back and should avoid bending over) we should be advised of, please let us know in advance.
Handlers with limitations are welcome to have a friend, family member, or assistant help you during the session, with your dog, and training exercises.
5.9 PHOTOS AND VIDEOS
Videotaping, recording, or photographing of the class, of students, of the Behaviourist / Trainer, or Dogs will not be allowed. Please protect the privacy of all. If under special circumstances approval of videoing and photographing is granted, this approval will be conditional on viewing be limited to within the home and as such videos and photos must not show up on social networking sites. For example (but not limited to) Face Book, You Tube, etc.
Canine Essentials occasionally will take videos/photos of dogs working. These photos may be used for advertising purposes (example: our Newsletter or Website). If you are not interested in being a part of our advertising please let us know, so we may exclude you.
5.10 CHILDREN
Canine Essentials is committed to ensuring all clients have the opportunity to participate in safe and appropriate ways. Therefore:
Attendance
- Children accompanied and supervised by a responsible adult (over the age of 18) are welcome at our sessions.
- Minors are unable to attend without adult supervision.
- To ensure the dog gets the maximum training/bonding time with its family as well as meeting the child´s individual needs it may be necessary to have two adults present. It is imperative that children must be well- behaved and not disruptive in the consultation for their safety, and that of dogs, clients and trainers. Children unable to comply will not be allowed to attend sessions. The Behaviourist/Trainer´s decision is final.
- If a child is no longer able to attend due to disrupting the session, parents/guardians will be notified in writing via e-mail. It is the parent´s/guardian´s sole responsibility to make arrangements for child care in order for training to continue. In this instance, if suitable child care cannot be arranged, then then please refer to services refund policy for a suitable remedy.
- Please understand Canine Essentials is engaged to train dogs and also equip the handler with the tools necessary to use outside the consultation. The handler needs to fully concentrate on the instructions being given.
Handling
- Children are permitted to handle the dog over the age of 16 years of age by themselves provided a responsible adult over the age of 18 years old is in the immediate vicinity;
- This is however determined as to their capabilities and other factors (such as physical and intellectual capabilities, in addition to the breed, strength and disposition of the dog);
- If unsure, please consult with the Director of Canine Essentials who will make a determination.
5.11 VACCINATION
Canine Essentials considers the welfare of dogs under our care to be of primary importance. Canine Essentials have consulted with leading experts in the field including experienced Veterinarian’s, Canine Essentials Pty. Ltd. preferred Veterinarian Clinic and Canine Essentials Pty. Ltd. leading outside consultant who holds a PhD in Animal Behaviour and is also qualified in Veterinarian Care. The final outcome is that all consider dogs should receive an annual C5 vaccination.
As such, dogs registered for any service with Canine Essentials must have a current C5 vaccination certificate, and be vaccinated annually. The rationale provided by industry experts and Canine Essentials is that Canine Essentials implements this policy in order to meet ethical obligations to the community to prevent the spread of communicable diseases and, to ensure the dog in training with Canine Essentials remains as healthy as possible in relation to what the C5 vaccination offers. This policy is non-negotiable.
A current C5 Vaccination Certificate must be sighted by a Canine Behaviourist or Dog Trainer of Canine Essentials prior to training beginning and Canine Essentials will undertake to send SMS reminders to all current clients when C5 vaccinations are due.
The C5 Vaccination contains the following:
- Canine parvovirus,
- Canine distemper
- Canine adenovirus (hepatitis)
- Parainfluenza virus and,
- Bordetella bronchiseptica (kennel or canine cough).
Heart worm vaccination is also an area that Canine Essentials considers of vital importance. As such, Canine Essentials encourages owners to have a yearly injection, or, at a minimum, be able to state to Canine Essentials that each dog is administered monthly heart worm preventative tablets/chewables.
Disease Prevention Information
(Source: https://www.rspcapetinsurance.org.au/pet-care/new-pet/about-pet-vaccinations)
Canine parvovirus – this deadly virus is one of the most common viruses in the world, and is extremely hard to eradicate given that each species has a different version of it. Because maternal antibodies can interfere with the vaccine, it is important for your Vet to determine an appropriate age at which your dog should receive the vaccines.
Canine distemper – this fatal disease attacks a dog’s nervous system and can lead to severe damage, including paralysis. Puppies and young dogs are more susceptible to this virus. Thanks to increased vaccination, the disease is not as common as it once was. However, outbreaks can still occur in areas where vaccination rates are low, so ensure your dog gets their vaccines!
Canine adenovirus (hepatitis) – this disease affects the liver, and subsequently the eyes and kidneys. It cannot be transmitted to humans, but is a very serious illness for dogs.
Parainfluenza virus – this mild respiratory infection is usually transmitted by nasal secretion and is highly contagious. It is not fatal, but being vaccinated against this disease can help prevent your dog from getting other related infections.
Bordetella bronchiseptica (kennel or canine cough) – this virus causes a harsh cough and is highly contagious. If your dog is in contact with other dogs, is very young or very old, it will be more at risk of infection. It is usually recommend that the vaccine for kennel cough is given annually.
Heartworm in Dogs
(Source: https://www.heartwormsociety.org/heartworms-in-dogs)
The dog is a natural host for heartworms, which means that heartworms that live inside the dog mature into adults, mate and produce offspring. If untreated, their numbers can increase, and dogs have been known to harbor several hundred worms in their bodies. Heartworm disease causes lasting damage to the heart, lungs and arteries, and can affect the dog’s health and quality of life long after the parasites are gone. For this reason, prevention is by far the best option, and treatment—when needed—should be administered as early in the course of the disease as possible.
Transmission
The mosquito plays an essential role in the heartworm life cycle. Adult female heartworms living in an infected dog or fox produce microscopic baby worms called microfilaria that circulate in the bloodstream. When a mosquito bites and takes a blood meal from an infected animal, it picks up these baby worms, which develop and mature into “infective stage” larvae over a period of 10 to 14 days. Then, when the infected mosquito bites another dog, cat, or susceptible wild animal, the infective larvae are deposited onto the surface of the animal’s skin and enter the new host through the mosquito’s bite wound. Once inside a new host, it takes approximately 6 months for the larvae to mature into adult heartworms. Once mature, heartworms can live for 5 to 7 years in dogs and up to 2 or 3 years in cats. Because of the longevity of these worms, each mosquito season can lead to an increasing number of worms in an infected pet.
Signs
In the early stages of the disease, many dogs show few symptoms or no symptoms at all. The longer the infection persists, the more likely symptoms will develop. Active dogs, dogs heavily infected with heartworms, or those with other health problems often show pronounced clinical signs.
Signs of heartworm disease may include a mild persistent cough, reluctance to exercise, fatigue after moderate activity, decreased appetite, and weight loss. As heartworm disease progresses, pets may develop heart failure and the appearance of a swollen belly due to excess fluid in the abdomen. Dogs with large numbers of heartworms can develop a sudden blockage of blood flow within the heart leading to a life-threatening form of cardiovascular collapse. This is called caval syndrome, and is marked by a sudden onset of laboured breathing, pale gums, and dark bloody or coffee-coloured urine. Without prompt surgical removal of the heartworm blockage, few dogs survive.
Significance
Many factors must be considered, even if heartworms do not seem to be a problem in your local area. Your community may have a greater incidence of heartworm disease than you realise—or you may unknowingly travel with your pet to an area where heartworms are more common. Heartworm disease is also spreading to new regions of the country each year. Stray and neglected dogs and certain wildlife such as foxes can be carriers of heartworms. Mosquitoes blown great distances by the wind and the relocation of infected pets to previously uninfected areas also contribute to the spread of heartworm disease.
5.12 FIT FOR TRAINING
Canine Essentials deems the safe and ethical training of dogs is of primary importance. Therefore to ensure the dog´s physical or emotional welfare is not compromised, a Pre-Training form must be completed for each dog prior to any training being commenced.
5.13 HOT WEATHER
Canine Essentials recognises that hot weather can lead to heatstroke in dogs and will then require emergency veterinary care. Outdoor training sessions will be cancelled if the forecasted temperature is 30 degrees or over. Canine Essentials may continue training indoors if there is effective air-conditioning available, and only if the dog is not showing any signs of distress. During the training session, water must be freely available. If these requirements cannot be met, another training session will be scheduled at no further cost to you.
5.14 TREAT ADMINISTRATION
A major part of Canine Essentials training techniques is the administration of food as a reward. Therefore Canine Essentials requires that all clients advise Canine Essentials staff of any food allergies their dog has acquired. Clients are advised here that the primary ´treat´ that Canine Essentials uses is ´Fritz´ or Chicken/Beef Jerky. However if their dog is experiencing unwanted weight gain it may be best to use boiled chicken breast. The client must supply this instead. Clients are required to provide permission for Canine Essentials to administer treats as per the Training Contract.
Clients need to be aware that food allergies, though not very common in dogs, may be extremely dangerous and even fatal. It is important to know which substance a dog is allergic to. Correct diet plays a crucial role in preventing dog allergies. So regular monitoring of his/her diet is equally important. Added to that, a dog´s overall health, wellbeing and longevity benefit greatly from a correct diet.
Please be aware that food allergies, also referred to as food hypersensitivities or adverse food reactions, are abnormal immune responses to something in the diet. Common causes of food allergies in dogs are dairy products, grains, potatoes, eggs, soy and some dietary supplements. When the immune system senses that something is foreign, it remembers that substance and activates every time the substance is present. Symptoms of food allergies in dogs vary, but generally they scratch a lot, have raised skin bumps and then often lose their hair. Some can vomit and develop diarrhoea. Food allergies typically show up in young dogs less than one year of age. Management of dog allergies requires plenty of time, money, dedication and patience. It is the client´s responsibility to inform staff of Canine Essentials if their dog has any allergies.
5.15 FEEDING AND TOILETING
Canine Essentials considers the welfare of the dogs under our care to be of primary importance and the safe and ethical training of dogs be paramount. Therefore:
- Ample exercise and playtime before class is vital so that your dog is relaxed and focused for their lesson. This is especially beneficial when working with high energy dogs.
- Unless advised otherwise by your Veterinarian it may be beneficial to feed him/her 4-6 hours prior to class start time. This will allow a good amount of ´down time´ and therefore avoid sleepiness and lethargy during ´work time´. This may also help in preventing Bloat, which is a life- threatening condition.
- Please advise us of any health concerns
- Be aware that most dogs are excited in a new environment, and can find it difficult to focus at the start of class.
- Make sure your dog has a chance to relieve themselves prior to the training session start time.
- It is a handler´s responsibility to thoroughly clean up all bathroom accidents–as soon as possible after the accident.
- Please ask us if you need assistance, as we understand it can be difficult to clean up and control dogs together.
- Please pick up all, diarrhoea, or vomit waste.
- Please do not let dogs urinate or defecate on footpaths, sides of buildings, cars, man-made surfaces, etc.
- Recommended cleaning:
- Urine accidents need to be cleaned by mopping until urine has been thoroughly removed.
- Bowel excretion &/or vomit accidents need to first be picked up with a bag, then cleaned with paper towels. Spray and sanitise if runny/smears are present with sanitising wipes. Then mop thoroughly.
5.16 CARE AND WELFARE OF CANINES’
Canine Essentials considers the welfare of the dogs in our charge and under our care to be paramount. We endeavour at all times to allow clients the opportunity of participating in safe and appropriate ways. In order to do this:
- Dogs must be protected from distress or injury from other dogs, particularly larger or predatory species or from excessive handling or interference from adult customers and children.
- Dogs in high traffic areas require additional attention to avoid stress and procedures must in place to manage this issue
- All equipment used with dogs must be designed and maintained to minimise the risk of stress, illness or injury.
- The client is responsible for following the Supervisor´s instructions in keeping their dog under control. For example, the Instructor will demand distance between dogs as a critical component of group sessions. It is the client´s responsibility to keep their dog´s attention from straying and not allow interaction with other dogs without permission.
- Covered shoes with a non-slip tread are required, (no sandals). Although not required we recommend long sleeve shirts and pants.
- The client is responsible for cleaning up after their dog; inside the training room as well as outside the facility and on public excursions.
- No excessive barking, jumping on, biting, peeing on, or humping other dogs/people or aggression of any kind will be tolerated. Canine Essentials Behaviourists and Trainers will handle any issue that arises. Clients are never to intervene in a dog fight. Canine Essentials Behaviourists and Trainers instructions must be followed immediately. If a dog is a danger to other people or dogs it will be necessary for that dog to be removed from that session until the issue is resolved.
- Children are welcome at sessions, but must be accompanied by a responsible adult and never left unattended during session. Please be aware that not all dogs are child friendly. Please see Canine Essentials specific policy on Children attending sessions.
- Doors Close 5 minutes after session starts. There will not be any consumption of alcohol or drugs, intoxication or smoking in any session!
- Dogs must be vaccinated. We require a current vaccination of C5 and proof of same to be brought along to the first session or email a copy.
- Please do not train sick dogs as they can be highly contagious to other dogs, and do not feel well!
- Signs of a sick dog (but not limited to): not eating, not drinking, vomiting, blood in vomit, diarrhoea, blood in diarrhoea, lethargic, coughing/hacking (sounds like a barking seal), sneezing, grumbly and sensitive to the touch, to name a few. Kennel Cough, Giardia, Coccidia are all highly contagious.
- Dogs cannot train again until Canine Essentials receives written and signed verification from your Veterinarian, that dog is safe/no longer contagious and may return to session.
- We take the health of our dog students and our own dogs very seriously.
- Safety in our sessions is our number one priority. Students MUST follow instructions promptly at all times or you will be asked to leave that session. If training is conducted in home – then the Behaviourist/Trainer will leave as the session will become ineffective for handler, dog and Behaviourist. Alternative options will be provided.
- Please ask permission before you attempt to greet a dog.
- Mobile phones are extremely disruptive in a session and must be turned completely OFF during all Group Training Sessions and Private Training Sessions.
- Please give your dog 100% of your attention.
- If you have a special need which requires your phone to be on VIBRATE/ please let us know prior to session beginning.
- If you receive a call that requires you to leave the session we will e-mail your homework to you so you may stay up with to date.
5.17 DOG COMFORT ZONE
Canine Essentials considers the welfare of the dogs under our care to be of primary importance and the safe and ethical training of dogs be paramount.
Therefore:
- We at all times need to be familiar and attentive to our dog needs and responses in various circumstances. This awareness should extend to that of other dogs in the vicinity and their reaction toward our canine.
- At all times – sessions and elsewhere – always be willing to remove your dog from situations you are uncomfortable with. If your dog is fearful or unsure both during session time as well as play time, please pay attention to this. Be supportive and encouraging.
- If you have an excited &/or rambunctious dog please refrain from allowing it to impolitely invade the space of another dog.
- Similarly do not allow your dog into the space of a dog that is chewing on a Chew Toy or Stuffed Toy. They may wish to guard it and protect what is theirs.
- Please respect other dogs comfort zones at all times.
- The goal is always about positive interactions and enjoyable experiences. We need our companion to focus on their handler, therefore encouraging calm behaviour. Please discourage impolite and out of control greetings. Instead, keep it safe for all with nice dog-dog greetings.
- We want to take the opportunity to practice nice behaviour, and when we see this, capture it, and reward.
5.18 ROUGH HANDLING
Canine Essentials considers the welfare of the dogs in our charge and under our care be paramount. As such the safe and ethical training of dogs is critical. Therefore:
- Rough handling of dogs will not be tolerated. This includes teenagers, children and adults
- Examples of rough handling are (but not limited to) – alpha rolls, scruff shakes/holds, harsh jerking corrections on the collar or leash, or, slapping/hitting.
- This is a zero tolerance policy – the focus of the training is positive reinforcement NOT positive punishment (!):
- Handlers will be immediately reminded in a polite manner by the Behaviourist / Trainer to handle their dog in a positive, enjoyable and respectful way.
- If rough handling continues, the Behaviourist or Trainer will cease the session immediately and handlers and dogs will not be allowed to continue in the present or any remaining classes. Homework will be e-mailed to the client for any remaining classes. Refunds will not apply. This policy is non-negotiable.
- If you are feeling frustrated with your dog, please address the issue with the Behaviourist or Trainer before it accelerates. There are always other training options to be explored.
- We understand dogs, (quite like small children and teenagers) can be frustrating. We are here to fulfill our mission to enrich the dog-human bond which will assist you and your dog to enjoy a quality lifelong relationship. Therefore all of our courses are structured to create and promote a positive, fun, and quality learning experience for dogs and handlers / their human families. Rough handling simply does not have a place in this context.
6 Assistance Dogs
6.1 TRAINING & PROGRAM STANDARDS FOR THE OWNER TRAINED ASSISTANCE DOG PROGRAM: BEHAVIOURISTS, CLIENTS & DOGS
Canine Essentials Training Standards are developed using industry standards. These are as follows:
Age of Dog
- Only those who currently own a dog (aged between 5 months – 4 years) may apply to enter the Canine Essentials Owner Trained Assistance Dog Program.
Training Options
- Canine Essentials Pty. Ltd. advises that the Owner Trained Assistance Dog Program is aimed for those Handlers seeking to prepare for Assistance Dog accreditation with State or Territory Governments.
- Canine Essentials Pty. Ltd. advises Handlers that across Australia, public access rights for Assistance Dogs are protected by the Disability Discrimination Act (1992), Section 9, Part 2: For the purposes of this Act, an assistance animal is a dog or other animal:
- accredited under a law of a State or Territory that provides for the accreditation of animals trained to assist a persons with a disability to alleviate the effect of the disability; or
- accredited by an animal training organisation prescribed by the regulations for the purposes of this paragraph; or
- trained:
- to assist a person with a disability to alleviate the effect of the disability; and
- to meet standards of hygiene and behaviour that are appropriate for an animal in a public place.
- Canine Essentials Pty. Ltd. will support Handlers who choose to remain under Federal law (Disability Discrimination Act 1992, Section 9, 2, c) noting the following South Australian Legislation, being the Dog and Cat Management Act 1985, Section 81 – Assistance Dogs, Part 2: A person must not claim that a dog is an assistance dog unless the dog –
- is accredited as an assistance dog under section 21A; or
- is an assistance animal (within the meaning of the Disability Discrimination Act 1992 of the Commonwealth.
- Maximum penalty: $1 250.
- Expiation fee: $210.
- Please advise Canine Essential Behaviourists at the commencement of training so the course outline can be individualised to your requirements. Training for both will include basic alleviation of symptoms task training in Level 3 (Manners 101) and Level 4 (Public Standards Training).
Vaccination/Sterilisation Standards and Outcomes
- The dog must have a current C5 vaccination and be de-sexed (by the age of 6 months):
- The Handler/Owner must submit a Certificate of Sterilisation prior to beginning Level 3 of Training.
- Failure to comply with this condition will mean immediate expulsion from the program and c.ii will be invoked as per below.
- The Handler/Owner must supply Canine Essentials with an up-to-date current C5 vaccination no later than 4 weeks past the vaccination due date.
- This means the onus is on the Handler/Owner to submit the vaccination certificate to Canine Essentials Pty. Ltd.
- Once past 4 weeks overdue without receipt of an up-to-date C5 vaccination certificate will mean immediate expulsion from the program.
- That is, failure to comply with these conditions (emailing to info@canineessentials.com.au a current c5 vaccination certificate within 4 weeks past vaccination due date) will mean immediate expulsion from the program, and the following will apply:
- No refunds will be issued in this case.
- All Training Manuals must be posted back to Canine Essentials Pty. Ltd. at the Handler’s cost.
- Once client’s cease to be a Canine Essentials client, any Logo badges will be expected to be returned to Canine Essentials and the client will be refunded 75% of the cost of each badge excluding postage costs (this must be at the cost of the owner).
- Should the Training Manuals and Logos be returned without postage (which Canine Essentials Pty. Ltd. is forced to pay), then the Handler will be invoiced for the following:
- The applicable postage costs supported by the receipt from Australia Post or equivalent Company.
- Travel Costs per Travel Fee Schedule to the Post Office Box of Canine Essentials Pty. Ltd.
- Time of staff at the Post Office collecting the parcel.
- Administrative Costs processing parcel.
- Less 75% of the cost of each badge returned.
- This means the onus is on the Handler/Owner to submit the vaccination certificate to Canine Essentials Pty. Ltd.
Forms
- Prior to assessment, all forms must have been submitted and approved. In addition, all fees must have been paid in full.
- Expression of Interest;
- Confidentiality Agreement;
- Application Form;
- Form 1: Self-Assessment of Dog;
- Form 2: Veterinarian Declaration;
- Form 3 A & B: Disability Declaration by Healthcare Professionals’’;
- Form 4: Pet Dog & Assistance Dog: Branch Training Contract;
- Form 5: Training Logs are now available via the CE phone Training APP and are completed during the training program. Please read the section about Training Logs in depth.
Recognised Prior Learning
- The dog can be assessed for Recognised Prior Learning for Level’s 1 and 2, however must complete Level’s 3 and 4 with Canine Essentials in order to complete a Public Standards Assessment with Canine Essentials.
Copyright – Training Manuals
- Clients of Canine Essentials Pty. Ltd. are not permitted to share or distribute Training Manuals, Recognised Prior Learning (RPL) Assessments/Tests and Training Logs to anyone under any circumstances (regardless if they are a Canine Essentials client or not). Should this happen the following measures can occur:
- If this person (a) applies for Canine Essentials training programs, the person that the material was shared with, will now become ineligible for any form of Recognised Prior Learning for any level of training and must pay for the entire level of training (Leve’s 1 & 2).
- Should the person (a) subsequently withdraw from the program and refuse to pay for Level’s 1 and 2 in their entirety, then client/s (b) who shared these materials with person (a) are now liable for these fees – both Level’s 1 and 2. Payment plans are no longer offered at Canine Essentials.
- Should client/s (b) be unwilling to pay for these fees, then at the Director’s discretion, client/s (b) may be removed from any Canine Essentials Training Program/s immediately.
- To prevent 6.1(c) occurring, all training manuals will now be posted out to clients. A new training manual will not be issued until the previous level training manual has been returned to Canine Essentials.
Commitment to Training Sessions
- Upon passing Level 3 and entry into Level 4 Public Standards Training is granted, it is expected that the Handler commit to weekly training sessions with Canine Essentials Pty. Ltd. until passing Level 4.
- Note that there are no guarantees (for any Level as to how long each Level may take to gain a successful pass as it is vital that the dog be trained “at it’s own pace”).
- Should weekly sessions be missed by the Handler and Dog for a variety of reasons – and the gap is greater than two (2) weeks the following shall be deemed appropriate and invoked:
- A shared Google Drive Folder will be set up and two videos must be submitted each week during the Handler’s absence.
- This means the Handler commits to submitting two training videos per week of them and their ADiT working in a public venue such a shopping mall or a similarly busy public setting.
- The Handler commits to this being undertaken – excuses such as being unable to get to a venue such as this are not acceptable for the following reasons:
- The Handler has been able to attend training sessions at Goodwood Community Centre for a period of no less than 12 weeks.
- For a period of no less than 6 weeks the Handler has been to public settings away from their home setting.
- The only acceptable reason for a gap in training to occur with no training videos and training logs being submitted will be extenuating medical reasons. These must be supported by a letter from their Medical Specialist and include a time frame of when they will return back to training or, if the ADiT is unwell and will then require a letter from their Veterinarian and include a time frame of when they will return back to training.
- Fit to Train Certificates will be required in both instances.
- Failure to comply with these conditions will mean immediate expulsion from the program.
- No refunds will be issued in this case.
- All Training Manuals must be posted back to Canine Essentials Pty. Ltd. at the Handler’s cost.
- Once client’s cease to be a Canine Essentials client, any Logo badges will be expected to be returned to Canine Essentials and the client will be refunded 75% of the cost of each badge excluding postage costs (this must be at the cost of the owner).
- Should the Training Manuals and Logos be returned without postage (which Canine Essentials Pty. Ltd. is forced to pay), then the Handler will be invoiced for the following:
- The applicable postage costs supported by the receipt from Australia Post or equivalent Company.
- Travel Costs per Travel Fee Schedule to the Post Office Box of Canine Essentials Pty. Ltd.
- Time of staff at the Post Office collecting the parcel.
- Administrative Costs processing parcel.
- Less 75% of the cost of each badge returned.
Commitment to Completing Training Logs
- Training Logs are expected to be completed by Clients in Level’s 3 and 4 via the Canine Essentials APP. This is IN ADDITION to ONE completed by your assigned Canine Behaviourist during your weekly training session. However as a minimum of 6 months of Training Logs are expected to have been completed at the end of Level 4, Canine Essentials strongly advises all Clients to begin completing Training Logs from Level 1.
- For Clients in Level 3, it is expected that TWO Training Logs be completed per week (in addition to ONE completed by your assigned Canine Behaviourist during your weekly training session).
- For Clients in Level 4, it is now an expectation that TWO Training Logs be completed per week (in addition to ONE completed by your assigned Canine Behaviourist during your weekly training session).
- For Clients who have passed their Public Standards Assessment, it is now an expectation that ONE Training Log be completed per week.
- Failure to comply with these conditions will mean the following:
- Client’s in Level’s 3 and 4:
- If no Training Logs as per the above conditions have been submitted for a period of 2 weeks, a “First Warning” will be issued.
- If no Training Logs as per the above conditions have been submitted for a period of 4 weeks, a “Second Warning” will be issued.
- If no Training Logs as per the above conditions have been submitted for a period of 6-8 weeks, a “Final Warning” will be issued and immediate expulsion from the program will occur.
- If there are continual two weekly gaps for example, these will count as first, second and final warnings.
- In this situation – immediate expulsion from the program:
- No refunds will be issued in this case.
- All Training Manuals must be posted back to Canine Essentials Pty. Ltd. at the Handler’s cost.
- Once client’s cease to be a Canine Essentials client, any Logo badges will be expected to be returned to Canine Essentials and the client will be refunded 75% of the cost of each badge excluding postage costs (this must be at the cost of the owner).
- Should the Training Manuals and Logos be returned without postage (which Canine Essentials Pty. Ltd. is forced to pay), then the Handler will be invoiced for the following:
- The applicable postage costs supported by the receipt from Australia Post or equivalent Company.
- Travel Costs per Travel Fee Schedule to the Post Office Box of Canine Essentials Pty. Ltd.
- Time of staff at the Post Office collecting the parcel.
- Administrative Costs processing parcel.
- Less 75% of the cost of each badge returned.
- Client’s who have passed their Public Standard’s Assessment:
- Should Client’s not submit a weekly Training Log under any circumstances (see below rationale), Canine Essentials Pty. Ltd. will not make available any advocacy services under any circumstances for situations such as Public Access issues and the like.
- Whilst advocacy services remains a paid service (albeit heavily discounted), Canine Essentials Pty. Ltd. chooses to use the Disability Discrimination Act (1992) – Section 54 A in this decision making process on this matter.
- In this situation – immediate expulsion from the program:
- Client’s in Level’s 3 and 4:
- Failure to comply with these conditions will mean the following:
- Rationale for Training Log Commitment: Disability Discrimination Act (1992) Section 54A:
- This Part does not render it unlawful for a person to request the person with the disability to produce evidence that:
- the animal is an assistance animal; or
- the animal is trained to meet standards of hygiene and behaviour that are appropriate for an animal in a public place.
- This Part does not render it unlawful for a person (the discriminator) to discriminate against the person with the disability on the ground that the person with the disability has the assistance animal, if:
- the discriminator requests or requires the person with the disability to produce evidence referred to in subsection (5); and
- the person with the disability neither:
- produces evidence that the animal is an assistance animal; nor
- produces evidence that the animal is trained to meet standards of hygiene and behaviour that are appropriate for an animal in a public place.
Uniform Requirements
- Once passing Public Standards Assessment and being supported by Canine Essentials, the dog must be visually identifiable as an Assistance Dog when working in the public sphere. Canine Essentials Policy requires clients ensure that their Assistance dog:
- wear approved Canine Essentials wear/gear with a Canine Essentials Logo and badge clearly stating “Assistance Dog”. [Note: “similar piece of equipment or clothing” refers to pre-approved CE wear that is generally balance and/or mobility harnesses that are specifically designed for the handlers disability not vests/butterfly vests or saddle bag vests etc.];
- a Canine Essentials Membership Card (stating that a Canine Behaviourist has confirmed that the dog has passed Public Standards Training) on the handler’s person and on the Assistance Dog harness or vest, and;
- the Canine Essentials Assistance Dog “Approved Wear” catalogue will be issued to the handler during their training at Level 3 by their Trainer/Canine Behaviourist.
Handler Standards
- Handlers (Clients) of Canine Essentials must be able to demonstrate that:
- they have a knowledge and thorough understanding of humane training techniques.
- they must be able to have a working theoretical knowledge and be able to state the rationale of these to the Behaviourist of Trainer of Canine Essentials.
- they must be able to apply these 100% of the time to dog;
- they must be able to demonstrate an understanding of canine health and care and:
- ensure they apply this to their dog 100% of the time. Further,
- they need to demonstrate that they have the financial ability to pay for Veterinarian care should their dog require medical assistance.
- have a thorough knowledge of public access laws (both federally and at a state level).
Behaviourist Standards
- Canine Essentials Behaviourists’ must have a thorough and working knowledge of the Clients’ disabilities:
- Trainers and Behaviourists’ must be able to transfer this knowledge into individualised training plans that will benefit the client and the trainee Assistance Dog.
- Behaviourists’ and Trainers will also have training in the healthcare field.
- It is the Client’s (or in the case of a minor, the parent and/or guardian) to keep the Director of Canine Essentials fully informed of any changes in their health status and or diagnosis so that courses/interactions can be adapted to needs. This must also be supplied at the Director’s request and certified by the client’s treating medical healthcare professional.
Assistance Dog Expectations
- After passing Public Standards Training, the dog must show at least 90% of the time in the home in the public sphere basic good manners and trained tasks. These include (for example):
- no jumping;
- sitting on command;
- down/drop on command;
- no unnecessary barking/vocalisation;
- no unnecessary solicitation of attention.
- After passing Public Standards Training, the dog must respond to hand and/or voice signals (hand signals preferred). These include:
- controlled heel
- sit;
- down/drop
- come when signalled or called
- stay.
Client’s Commitment
- Client’s must commit to contacting Canine Essentials Pty. Ltd. every fortnight, for 6 months after assessment:
- the details of the contact must be documented in the Client’s file.
- the client’s details will be kept strictly confidential and no less than two back-ups will be kept to guard against unforeseen circumstances.
- Canine Essentials Pty. Ltd. will not charge a fee for this contact.
6.2 STANDARDS FOR ASSISTANCE DOGS IN PUBLIC
Canine Essentials Standards for Assistance Dogs in Public are developed using industry standards. Canine Essentials acknowledges that there is no control over handlers upon attaining Level 4 and conflicting legislation that is currently in play at a Federal and State level. As such, regardless of whether a client chooses to prepare their dog for accreditation with State or Territory Governments, or, those seeking independence under the Commonwealth Disability Discrimination Act (1992; Section 9.c), the minimum standards Canine Essentials adopts are as follows:
- The Assistance dog must be clean, well-groomed and odour free.
- The Assistance Dog must not:
- solicit attention from the public;
- disrupt the general and normal course of business;
- show aggression towards people and animals;
- steal food or items – NO EXCEPTIONS.
- Be appropriately trained:
- to be calm when working;
- to be able to toilet on command; and,
- it is recommended that the Assistance Dog be trained in 3 tasks to alleviate the symptoms of the handlers’ disability (this is despite it not being a legislative requirement in Australia).
- Safety standards must be adhered to. For example, the handler must:
- ensure the Assistance Dog be leashed and under control of the handler at all times, or, at least 60cm away from the handler and;
- ensure WHS standards are adhered to and be unobtrusive and not block doorways, aisles etc.
- to prevent the transimission of zoonotic diseases (see Section 9), under no circumstances may Assistance Dogs sit in Shopping Trolleys or Carts. This prevents such transfer regardless if they sit on a mat. Handlers must be mindful of the general public who have dog allergies – moreover, food hygiene. The rule must be Four Paws on the Floor.
6.3 GENERAL EXPECTATIONS FOR ASSISTANCE DOG HANDLERS
Canine Essentials Expectations for Assistance Dog Handlers are developed using industry standards. As Canine Essentials works for a number of organisations that are both Government accredited and operate under the Disability Discrimination Act Section 9. 2 (c) it is expected that the minimum expectations should be as follows:
- Produce a Canine Essentials Membership Card (if requested) that recognises your dog has passed Public Standards Training with Canine Essentials Pty. Ltd.
- Remember that the public are allowed to ask you if you have a disability but NOT THE NATURE OF YOUR DISABILITY.
- This is the ONLY question the public are allowed to ask.
- Ensure your dog wears approved Canine Essentials Pty. Ltd. Assistance Dog Logo and approved Canine Essentials Assistance Dog vest that visually identifies the dog as an Assistance Dog. Any additions or alterations to Canine Essentials wear/gear must be approved by the Canine Essentials Policy Committee in writing. Please submit your request with a photo example by email to info@canineessentials.com.au . This also includes the addition of badges/logos and saddles packs etc.
- To protect your dog’s feet from hot grounds, travelators/escalators (please avoid these if possible), dog footwear must be worn at all times.
- Continue to maintain high training standards of your Assistance Dog and undergo annual re-assessment with Canine Essential Pty. Ltd.
- Abide by Federal Law (Disability Discrimination Act 1992) and ensure your dog meets standards of hygiene and behaviour that are appropriate for an animal in a public place
- (this includes cleaning up dog excrement from your dog).
- Note: If you are not capable of cleaning up after your dog in certain situations then please consider whether you would be meeting legislative standards on that day!
- Remember that you are solely liable for any damage to persons, premises, or facilities including places of public accommodation, public conveyances or transportation services, common carrier of passengers, places of housing accommodations, and places of employment caused by your Assistance Dog.
- Your dog must be trained to:
- Sit, toilet, drop and heel on command.
- Your dog must not bark or be a public nuisance.
- Your dog must be de-sexed and have a current c5 vaccination.
- Your dog must be in impeccable health as certified by a Veterinarian.
- Your dog must not react to people approaching people, noises or other dogs.
- You are encouraged to firmly discourage people from engaging with your dog thus preventing your dog from doing its job and causing unnecessary attention to you. Please educate them in a kind but firm manner.
- In this situation, Canine Essentials authorises you to place your dog between you and the inquisitive person in a non-threatening manner to provide you with personal space.
In the interests of transparency, here is some information that you can provide to the public to help make your public outings a little easier
- An Assistance Dog as a dog trained to perform identifiable physical tasks or other perhaps seemingly invisible behaviours to assist a person with a disability to reduce the person’s need for support.
- There are many breeds that can be used as Assistance Dogs. The only limitations are those breeds that are “Prescribed Breeds”, “wild” or “native” breed such as a Dingo or Fox despite claims of domestication or permit issue by government bodies (note this is the policy of Canine Essentials Pty. Ltd. and many other Assistance Dog training organisations), or, dogs who have been declared as dangerous.
- Mobility requirements and physical ability will determine the most appropriate type of dog for each type of disability.
- All Assistance Dogs are required to display the approved badge on their coat or harness. If you are unsure about the legitimacy of a dog, you may ask the person with the dog if it is an Assistance Dog required because of a disability.
- Individuals who decide to utilise the Disability Discrimination Act (1992) and be supported by Canine Essentials will be issued with a Membership Card that will include a photo of them and their dog which will clearly state that you are an owner trained handler operating under Federal Law, but has met the criterion per a Canine Behaviourist.
- All people with a disability who are accompanied by an Assistance Dog are provided with the right of access under the Commonwealth Disability Discrimination Act (1992) which makes it unlawful to discriminate against a person on the grounds of that person’s disability.
- An Assistance Dog may be excluded from a public place if the dog’s behaviour poses a direct threat to the safety of others.
- Not all forms of disability are obvious. For example, the person may have a psychiatric disability, a sensory disorder or chronic diabetes. Their dog may be a ‘normal’ Assistance Dog or even a highly specialised seizure alert/response/signal dog.
- Assistance Dogs may not enter:
- Operating Theatres
- Morgue
- A part of a public place or public passenger vehicle where food is ordinarily prepared.
- In general, when you meet a person with an Assistance Dog, please remember that the dog is working. You should not do anything to interrupt the dog from performing its tasks. Keep in mind that even though it may appear to you that the team is not performing a task at that moment, the dog is always on call and must give its full attention to the handler – as well as being alert to possible dangers.
- Breaches include:
- Not allowing a person with an Assistance Dog or Trainee Dog to enter a public place, public passenger vehicle, private rental arrangement or holiday accommodation;
- Separating a person from their Assistance Dog;
- Not providing service to person with a dog or requiring the person to pay an extra charge because the dog is present;
- Staff of a public place, public transport service or place of accommodation not assisting with an investigation of an allegation or complaint of not allowing a person with a Assistance or Trainee support Dog access or withholding service to them;
- Direct or indirect discrimination;
- Disparaging comments;
- Stigma and stereotyping.
Direct disability discrimination (DDA 1992)
1) For the purposes of this Act, a person (the discriminator) discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if, because of the disability, the discriminator treats, or proposes to treat, the aggrieved person less favourably than the discriminator would treat a person without the disability in circumstances that are not materially different.
2) For the purposes of this Act, a person (the discriminator) also discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator does not make, or proposes not to make, reasonable adjustments for the person; and
- the failure to make the reasonable adjustments has, or would have, the effect that the aggrieved person is, because of the disability, treated less favourably than a person without the disability would be treated in circumstances that are not materially different.
3) For the purposes of this section, circumstances are not materially different because of the fact that, because of the disability, the aggrieved person requires adjustments.
6 Indirect disability discrimination (DDA 1992)
1) For the purposes of this Act, a person (the discriminator) discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator requires, or proposes to require, the aggrieved person to comply with a requirement or condition; and
- because of the disability, the aggrieved person does not or would not comply, or is not able or would not be able to comply, with the requirement or condition; and
- the requirement or condition has, or is likely to have, the effect of disadvantaging persons with the disability.
2) For the purposes of this Act, a person (the discriminator) also discriminates against another person (the aggrieved person) on the ground of a disability of the aggrieved person if:
- the discriminator requires, or proposes to require, the aggrieved person to comply with a requirement or condition; and
- because of the disability, the aggrieved person would comply, or would be able to comply, with the requirement or condition only if the discriminator made reasonable adjustments for the person, but the discriminator does not do so or proposes not to do so; and
- the failure to make reasonable adjustments has, or is likely to have, the effect of disadvantaging persons with the disability.
3) Subsection (1) or (2) does not apply if the requirement or condition is reasonable, having regard to the circumstances of the case.
4) For the purposes of subsection (3), the burden of proving that the requirement or condition is reasonable, having regard to the circumstances of the case, lies on the person who requires, or proposes to require, the person with the disability to comply with the requirement or condition.
Stereotyping: a set idea that people have about what someone or something is like… An Assistance Dog may not be excluded based on assumptions or stereotypes about the animal’s breed or how the animal might behave.
Stigma: Generally, stigma is a negative set of beliefs about people with specific characteristics. For people with disabilities, stigma can be a major barrier to participation. Stigmatising attitudes about disabilities can also affect relationships between patients and providers. However, health care providers can be allies with their patients and help reduce the impact of stigma. The general public can also play a crucial impact in reducing stigma.
6.4 ASSISTANCE DOGS SEEKING TO VISIT AUSTRALIA ZOO
Canine Essentials Pty. Ltd. has received approval to register with Australia Zoo (QLD) on 17/04/2019. Canine Essentials is authorised by Australia Zoo to provide the following information to Canine Essentials Assistance Dog Clients who wish to visit Australia Zoo:
“Australia Zoo provides the opportunity for guests with registered assistance dogs to visit their organisation. All visits are required to be confirmed with Australia Zoo as soon as possible with a minimum of 2 days notice prior to the planned visit. For further information about visiting Australia Zoo with a registered assistance dog (including access limitations) or to book a date for your visit, please contact Australia Zoo via:
Email: volunteers@australiazoo.com.au
Phone: 07 5436 2038″
Canine Essentials urges all Assistance Dog Clients to contact Australia Zoo directly as soon as you plan to visit the zoo which will help make the process a lot more streamlined and easier for Australia Zoo to process quickly – hopefully making your visit as beneficial possible.
Contact Details:
Australia Zoo
Steve Irwin Way, Beerwah, QLD 4519
P 07 5436 2038 | F 07 5439 9629 | E volunteers@australiazoo.com.au
6.5 ASSISTANCE DOGS SEEKING TO VISIT OTHER ZOOS
Canine Essentials Pty. Ltd. acknowledges that Assistance Dogs entering Zoos will have limitations at the best of times. If the particular zoo does grant entry, there may be limitations as to where you and your Assistance Dog may be granted access.
Please check well in advance prior to attendance as to what is required to ensure a seamless visit.
If required, Canine Essentials Pty. Ltd. may provide advocacy in certain instances. This is not a free service.
7 Services and Fees
7.1 PRICING OF SERVICES
Canine Essentials reserves the right to change prices without notice. We will however, honour all packages purchased prior to price change and not require payment of additional monies. If sessions have been purchased in advance, we will honour those sessions at the price quoted. Canine Essentials will honour any and all written quotes despite changes in price within a reasonable period being 3 months.
All prices referred are in Australian Dollars only.
Canine Essentials does not currently charge G.S.T for services.
Please see current Fees.
7.2 PRICING OF GOODS
Canine Essentials complies with ACCC (2017) standards when pricing goods for sale. Accordingly, if a product has two prices displayed, Canine Essentials will sell the product at the lowest displayed price or withdraw the goods from sale until the price is corrected.
The single price of the product will be the total of all measurable costs including any charges payable and GST (If applicable).
7.3 PROOF AND TRANSACTION AND ITEMISED BILLS
Canine Essentials complies with ACCC (2017) standards in relation to itemisation of accounts and providing the client with proof of their transaction with Canine Essentials.
Canine Essentials must provide proof of transaction to consumers for goods or services valued at $75 or more. A GST tax invoice is sufficient proof of transaction. ‘Proof of transaction’ for supply of goods or services to a consumer is a document that states the: supplier of the goods or services, Canine Essentials ABN, Canine Essentials CAN, date of the supply goods or services supplied to the consumer, and price of the goods or services. Canine Essentials must give proof of transaction when a consumer: buys goods or services worth $75 or more (excluding GST), as soon as possible after the transaction, or, asks for proof of transaction for goods and services costing less than $75, within seven days.
Consumers may request an itemised bill. A consumer can ask Canine Essentials for an itemised bill that shows: how the price was calculated, the number of labour hours and the hourly rate (if relevant), and a list of the materials used and the amount charged for them (if relevant). This request must be made within 30 days of whichever happens later: the services are supplied, or the consumer receives a bill or account from Canine Essentials for the supply of the services. Canine Essentials must give the consumer the itemised bill, without charge, within seven days of the request. It must be expressed in plain language, legible and clear.
7.4 CONSUMER GUARANTEES – WARRANTIES, REFUNDS AND REPAIRS
Canine Essentials abides by the requirements of the ACCC (2017) in relation to consumer guarantees. The consumer guarantees means that:
Products must be of acceptable quality, that is:
- safe, lasting, with no faults
- look acceptable
- do all the things someone would normally expect them to do.
- Acceptable quality takes into account what would normally be expected for the type of product and cost.
Products must also:
- match descriptions made by the salesperson, on packaging and labels, and in promotions or advertising
- match any demonstration model or sample you asked for
- be fit for the purpose the business told you it would be fit for and for any purpose that you made known to the business before purchasing
- come with full title and ownership
- not carry any hidden debts or extra charges
- come with undisturbed possession, so no one has a right to take the goods away or prevent you from using them
- meet any extra promises made about performance, condition and quality, such as life time guarantees and money back offers
- have spare parts and repair facilities available for a reasonable time after purchase unless you were told otherwise.
Services must:
- be provided with acceptable care and skill or technical knowledge and taking all necessary steps to avoid loss and damage
- be fit for the purpose or give the results that you and the business had agreed to
- be delivered within a reasonable time when there is no agreed end date.
Consumer guarantees on products and services also apply to:
- bundled products and services
- gifts with proof of purchase
- sale items
- online products and services bought from Australian businesses
- second-hand products from businesses, taking into account age and condition.
7.5 REFUNDS AND REMEDIES – SERVICES
Canine Essentials has specific terms and conditions related to refunds. We allow 3 business days from date of purchase and prior to the starting date when granting a refund for cancellations. Once lessons have commenced, all fees shall be due and payable.
There will be no refund for clients who do not show up for training sessions without prior notice and any monies paid to date will be forfeited. Uncompleted sessions cannot be transferred to other future Canine Essentials services without authorisation by the Director of Canine Essentials. Canine Essentials will consider it a completed lesson if clients arrive later than 15 minutes after starting time and will be charged accordingly.
Canine Essentials also complies with ACCC (2017) requirements. Canine Essentials is not required to provide a refund if you change your mind about the services you asked for. But you can choose to cancel your contract, and receive a refund for unconsumed services, if the service has a major problem. This is when the service:
- has a problem that would have stopped someone from purchasing the service if they had known about it
- is substantially unfit for its common purpose, and can’t be easily fixed within a reasonable time
- does not meet the specific purpose you asked for and cannot be easily rectified within a reasonable time
- creates an unsafe situation.
If you choose to continue with the contract, you can ask us to compensate you for any difference in the value of the services we provided and what you paid.
If the problem is not major, we will fix it within a reasonable time. If it is not fixed within this time, you can choose to have someone else fix the problem and recover all reasonable costs from us. If the problem cannot be fixed, we view it as a major problem.
Please keep proof of your agreement—e.g. your invoice or quote.
However, Canine Essentials abides by the Prevention of Cruelty to Animal Regulations (2008) [Click Here to Download the Regulations] and as such Dr. Geller, the Director of Canine Essentials remains is contact with the RSPCA should she have any concerns regarding the dog’s welfare.
Should any Client/Behaviourist/Trainer/Employee use any equipment or treat a dog in an inhumane way that contravenes the above regulations (including the use of banned equipment per above and as outlined in Canine Essentials Policy 5.6), Canine Essentials will immediately cease ties with the associated party. This is outlined below:
- For Employees this will mean instant dismissal;
- Clients, termination of contract (no refund will be issued); and,
- Contractor/Sub-Contractor instant termination of contract – with the applicable fine imposed per contract terms.
The person/s will then be reported to the appropriate authorities. In plain language, a refund cannot be issued should a client choose to use banned equipment that is in breach of Australian legislation. One such example would be the use of “Prong Collars” in certain states. Canine Essentials cannot issue refunds when a client chooses to breach the law, it is that simple. However, we will work with you to choose alternative corrective devices that are within our policy guidelines.
Please note. It is unreasonable to expect a guarantee of success in your dog’s behaviour and/or training, and Canine Essentials urges consumers to be wary of such claims, because in reality, training takes place throughout a dog’s and handlers lifetime. Without consistent training and proper reinforcement by the handler/owner, the dog will most likely not continue with the desired behaviour.
7.6 REFUNDS AND RETURNS – GOODS
Canine Essentials complies with ACCC (2017) requirements. Canine Essentials is not required to provide a refund or replacement if you change your mind. But you can choose a refund or exchange if an item has a major problem. This is when the item:
- has a problem that would have stopped someone from buying the item if they had known about it
- is unsafe
- is significantly different from the sample or description
- doesn’t do what we said it would, or what you asked for and can’t be easily fixed.
Alternatively, you can choose to keep the item and we will compensate you for any drop in value. If the problem is not major, we will repair the item within a reasonable time. If it is not repaired in a reasonable time you can choose a refund or replacement.
Please keep your proof of purchase— e.g. your receipt.
7.7 PAYMENT
Canine Essentials has specific terms and conditions related to payments. As such the client is advised that:
- Full payment for all services (including packages) must be made at the time of the first session. An invoice and receipt will be issued at the end of the session.
- Payment plans are no longer offered unless there are extenuating circumstances and approved by the Canine Essentials Board of Directors.
- Payment methods are either by Direct Deposit, PayPal, EFTPOS, Master Card, Visa Card or Cash.
- A receipt will be provided upon payment.
- No credits for services or products and all accounts must be paid for IN FULL.
- This means that all products must be paid for at time of issue.
- This means all services must be paid for upon the commencement of the beginning of classes.
- There are No Exceptions.
- For non-payment of fees, Canine Essentials reserves the right to cancel any future sessions booked. In addition Canine Essentials will actively seek non-payment of fees via debt collectors and/or the Australian legal system. Should this occur, the client agrees to reimburse Canine Essentials for any and all expenses incurred to recover the monies owed by the client.
7.8 CANCELLATIONS
Canine Essentials has specific terms and conditions related to cancellations. Cancellations will be automatically charged if cancelled no less than 48 hours’ notice provided – the session will be charged in full. Subject to trainer availability, it is recommended that the session be rescheduled within the same week. If this session is rescheduled within that week and subject to trainer availability (and had been cancelled with less than 48 hours’ notice cancellation given), then Canine Essentials is prepared to offer a $20.00 surcharge to that week’s lesson to ensure continuity of training in the dog’s best interests. It is vital your dog complete the training schedule within the recommended time frame. If trainers are not available, Canine Essentials highly recommend that the original scheduled session times be adhered to.
Exceptions to this will be when a dog is unwell and unable to attend the session. A veterinarian certificate will be required.
Canine Essentials, reserves the right to cancel or reschedule any training class or course. Clients will be notified via telephone or email. Please check your messages prior to commencement of session.
Canine Essentials reserve the right to terminate lessons and refund monies owing if we believe the circumstances are not going to be beneficial to either the dog or its owner/carer.
Canine Essentials , reserves the right to temporarily suspend lessons if a dog is sick, injured, infested, unfit, or needs grooming. The situation must be remedied before the lessons are re-started. We require a vet´s written certification and evidence.
Our priorities remain: personal and dog safety before training results.
7.9 DISCOUNTS – SERVICES
Canine Essentials offers a discount to clients for Assistance Dog clients at our discretion. No further discounts apply in these instances. Please ask if you are eligible.
7.10 DISCOUNTS – SHOP
Canine Essentials currently showcases its products online. At this time, all products can be ordered directly from Canine Essentials (by phone or email) and will receive free home delivery of the products ordered. Please note that free delivery only applies to the Adelaide metropolitan area.
Clients may qualify for discounted products. At this stage discounts are limited to Assistance Dog clients and are clearly identified on the web page. Clients that qualify for a discount will receive the discounted prices as long as they continue with Canine Essentials as a client.
8 Privacy
Canine Essentials is committed to protecting your personal information. As such Canine Essentials handles all information according to the Privacy Principles as described in the Australian Commonwealth Privacy Act (1988). Please note that this Policy is also available here for your convenience.
The client is advised that:
Collection of personal information
We will only collect personal information necessary for our business functions or activities. This includes:
- providing you with our services;
- providing you with information you may have requested and answering your enquiries;
- providing you with the information we consider of interest to you – but please remember that we will always ask for your permission first.
In general, the information collected from you will be your name, address and contact details (including telephone number and e-mail address) and details that are applicable to your dog.
We will collect personal information by way of written forms, and other correspondence. This means letters and e-mails, by telephone, in person, by our representative and via our Website. We will collect personal information directly from you, unless there are extenuating circumstances.
Fair and lawful means for collecting your personal information will always be used. At the time of collecting personal information, we will inform you generally about the purpose of collection and to whom we will disclose the information. We will inform you of any law that requires us to collect the information and the relevant consequences if you do not provide all information requested. Be aware that if not all the information we require is not forthcoming we may be unable to provide you with the services you are seeking. We will enable you to interact pseudonymously or anonymously, whenever practicable and lawful.
Use and disclosure of personal information
We may use and disclose your personal information for the primary purpose for which we have collected it, and for other related purposes you would reasonably expect. This would generally include providing you with information about our services, marketing information or offers regarding other services of Canine Essentials or upcoming events, and obtaining your feedback on our products and services. If you have received communications, from us but do not wish to do so in the future, please let us know via e-mail or call 0426 975 364.
We will not pass on, sell or swap your personal information with any third party.
Apart from the above uses, we will otherwise only use and disclose personal information with your consent (unless such uses and disclosures are required or permitted by law, including without limitation those prescribed by the APPs).
Storage and security
We take all reasonable steps to securely store your personal information to ensure it is protected from loss, misuse, interference, or unauthorised access, modification or disclosure. We safeguard your information through our written privacy policy and by using physical, electronic and procedural protection. The information collected is destroyed or permanently de-identified when it is no longer needed for any purpose.
However, be aware that if you provide us with your personal information via the website, we cannot guarantee the privacy or security of that information during that transmission. But once we receive it, we will take reasonable steps to securely store your personal information to ensure it is protected from loss, misuse, disclosure, interference, unauthorised access, or modification.
Canine Essentials’ Website
Whenever you use our website, or any other website, the computer on which the web pages are stored needs to know the network address of your computer so that it can send the requested web pages to your Internet browser. The unique network address of your computer is called its ‘IP address’, and is sent automatically each time you access any Internet site. From a computer´s IP address, it is possible to determine the general geographic location of that computer, but otherwise it is anonymous.
We do not keep a record of the IP addresses from which users access our website except when it is specifically provided to. Our website may contain links to other websites. We are not responsible for the privacy practices or the use and protection of your personal information on those sites.
Access and correction
You may seek access to any of the personal information we hold about you by contacting the Director of Canine Essentials. If Canine Essentials is required or authorised by law to do so, we may refuse to provide you with access to this information. If this is the case, then we will provide a written reason/s for the refusal and how you may complain about our decision.
If access us granted, we may require identification documents to accompany a request and may also charge a fee for providing access. This fee will be limited to the amount of our reasonable expenses incurred. The expenses one could generally expect to pay includes photocopying and administration. We do not charge a fee for lodging a request for access.
We may provide access to personal information in any of a number of ways. These include a paper hard copy, or by allowing viewing our records. If any personal information we hold is incomplete, inaccurate, irrelevant, misleading or out-of-date, we will amend that information and thus, our records, accordingly. Be advised that the onus is on you to let us know if any of your personal details change.
Complaints, concerns or further information
If a client believes we have breached our obligations under the Privacy Act (including the APPs), or has queries or concerns regarding their privacy and the way in which we handle their personal information, we ask they contact the Director of Canine Essentials. As appropriate, we will endeavour to provide further information, or in the case of a complaint we will investigate the complaint and provide a response within 14 days.
Cameras and recording devices in the workplace and during home visits
Policy
The purpose of cameras and recording devices in the workplace in the workplace is to assist the Director to provide quality services to the Client.
Cameras and recording devices may only be used with the permission of the Client and in the context of provision of services. However, it is acknowledged that some Clients may not be comfortable with this.
Canine Essentials acknowledges the right of Clients, Visitors and Employees to privacy and will ensure that no person is photographed or recorded without their specific permission. Where the person is unable to give informed consent i.e. children, then the parent or guardian will be responsible for consent.
Definition
The definition of “camera” or “recording device” includes, but is not limited to:
- Devices designed to record and/or store a still or moving image, with or without sound;
- Mobile phones containing cameras;
- Any device used to record voices including phones and laptops; and
- Any other device that can be used as a camera or recording device.
For the purposes of this policy, “covert surveillance” refers to surveillance of an individual without their knowledge or consent and to surveillance of Canine Essentials property without the Director’s consent or authorisation.
Procedure
The use of any equipment to conduct covert surveillance without the Director’s express consent is forbidden in the Office of Canine Essentials.
The use of cameras or recording devices by an Employee of Canine Essentials to photograph a Client, Visitor or an Employee, or record an interview or consultation without that individual’s knowledge and specific consent, is strictly prohibited. Media consent is obtained in the Services Contract and will be expressly asked prior to photographs or videotaping being obtained.
Any Employee who is found to have compromised the confidentiality or safety of any individual or of Canine Essentials through the inappropriate use of a camera or recording device, will have the images confiscated and will be disciplined. In serious cases, an Employee’s employment contract will be terminated and where appropriate, the matter will be reported to the SA Police.
Clients and any other Visitors may not take photographs or use recording devices within the Office of Canine Essentials, or of the Director of Canine Essentials, Clients, their Dogs etc. (whether inside the office or outside the office) without the express approval of the Director of Canine Essentials.
Any Employee who observes the inappropriate use of a recording device, or becomes aware of another Employee who has been the perpetrator or victim of inappropriate use of a recording device, must report such use to the Director as soon as possible. If the Director is of the opinion that confidentiality or the Privacy Act has been breached then they may consider taking legal action.
Clients and Visitors must be advised of the requirements in relation to the carrying and/or use of cameras and recording devices on the premises, especially those contained in mobile phones.
Opt in:
“Section 6EA of the Privacy Act allows small businesses/not-for-profits, who would otherwise not be covered by the Privacy Act, to choose to be treated as an organisation for the purposes of the Privacy Act and therefore subject to the Australian Privacy Principles and any relevant APP code” (Office of the Australian Commission, Australian Government, 2018). Canine Essentials Pty. Ltd. has decided to “opt in” and be subject to the Australian Privacy Principles and any relevant APP code.
Data Breach and the Australian Privacy Act
Information sourced directly from: Data breach preparation and response — A guide to managing data breaches in accordance with the Privacy Act 1988 (Cth) “Office of the Australian Commission – Australian Government”: https://www.oaic.gov.au/agencies-and-organisations/guides/data-breach-preparation-and-response
Key points
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A data breach is an unauthorised access or disclosure of personal information, or loss of personal information.
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Data breaches can have serious consequences, so it is important that entities have robust systems and procedures in place to identify and respond effectively.
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Entities that are regulated by the Privacy Act should be familiar with the requirements of the NDB scheme, which are an extension of their information governance and security obligations.
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A data breach incident may also trigger reporting obligations outside of the Privacy Act.
What is a data breach?
A data breach occurs when personal information that an entity holds is subject to unauthorised access or disclosure, or is lost.
Personal information is information about an identified individual, or an individual who is reasonably identifiable.[1] Entities should be aware that information that is not about an individual on its own can become personal information when it is combined with other information, if this combination results in an individual becoming ‘reasonably identifiable’ as a result.
A data breach may be caused by malicious action (by an external or insider party), human error, or a failure in information handling or security systems.
Examples of data breaches include:
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loss or theft of physical devices (such as laptops and storage devices) or paper records that contain personal information
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unauthorised access to personal information by an employee
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inadvertent disclosure of personal information due to ‘human error’, for example an email sent to the wrong person
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disclosure of an individual’s personal information to a scammer, as a result of inadequate identity verification procedures.
Consequences of a data breach
Data breaches can cause significant harm in multiple ways.
Individuals whose personal information is involved in a data breach may be at risk of serious harm, whether that is harm to their physical or mental well-being, financial loss, or damage to their reputation.
Examples of harm include:
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financial fraud including unauthorised credit card transactions or credit fraud
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identity theft causing financial loss or emotional and psychological harm
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family violence
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physical harm or intimidation.
A data breach can also negatively impact an entity’s reputation for privacy protection, and as a result undercut an entity’s commercial interests. As shown in the OAIC’s long-running national community attitudes to privacy survey, privacy protection contributes to an individual’s trust in an entity.[2] If an entity is perceived to be handling personal information contrary to community expectations, individuals may seek out alternative products and services.
An entity can reduce the reputational impact of a data breach by effectively minimising the risk of harm to affected individuals, and by demonstrating accountability in their data breach response. This involves being transparent when a data breach, which is likely to cause serious harm to affected individuals, occurs. Transparency enables individuals to take steps to reduce their risk of harm. It also demonstrates that an entity takes their responsibility to protect personal information seriously, which is integral to building and maintaining trust in an entity’s personal information handling capability.
The Australian Privacy Principles
The Privacy Act contains 13 Australian Privacy Principles (APPs) that set out entities’ obligations for the management of personal information. The APPs are principles-based and technologically neutral; they outline principles for how personal information is handled and these principles may be applied across different technologies and uses of personal information over time.
Compliance with the APPs as a whole will reduce the risk of a data breach occurring. This is because the APPs ensure that privacy risks are reduced or removed at each stage of personal information handling, including collection, storage, use, disclosure, and destruction of personal information. For example, APP 3 restricts the collection of personal information. APPs 4.3 and 11.2 outline requirements to destroy or de-identify information if it is unsolicited or no longer needed by the entity. Compliance with these requirements reduces the amount of data that may be exposed as a result of a breach.
Compliance with the requirement to secure personal information in APP 11 is key to minimising the risk of a data breach.[3] APP 11 requires entities to take reasonable steps to protect the personal information they hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. The type of steps that are reasonable to protect information will depend on the circumstances of the entity and the risks associated with personal information handled by the entity.[4]
In addition, APP 1 requires entities to take reasonable steps to establish and maintain practices, procedures, and systems to ensure compliance with the APPs.[5]
The OAIC has published various resources to assist entities to meet their obligations under APP 1.2[6] and APP 11.[7]
The Notifiable Data Breaches (NDB) scheme
The NDB scheme in Part IIIC of the Privacy Act requires entities to notify affected individuals and the Commissioner of certain data breaches.
The NDB scheme requires entities to notify individuals and the Commissioner about ‘eligible data breaches’. An eligible data breach occurs when the following criteria are met:
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There is unauthorised access to or disclosure of personal information held by an entity (or information is lost in circumstances where unauthorised access or disclosure is likely to occur).
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This is likely to result in serious harm to any of the individuals to whom the information relates.
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The entity has been unable to prevent the likely risk of serious harm with remedial action.
Entities must also conduct an assessment if it is not clear if a suspected data breach meets these criteria. The assessment will determine whether the breach is an ‘eligible data breach’ that triggers notification obligations.
The primary purpose of the NDB scheme is to ensure individuals are notified if their personal information is involved in a data breach that is likely to result in serious harm. This has a practical function: once notified about a data breach, individuals can take steps to reduce their risk of harm. For example, an individual can change passwords to compromised online accounts, and be alert to identity fraud or scams.
The NDB scheme also serves the broader purpose of enhancing entities’ accountability for privacy protection. By demonstrating that entities are accountable for privacy, and that breaches of privacy are taken seriously, the NDB scheme works to build trust in personal information handling across industries.
Part 4 of this guide provides detailed information to assist entities to meet their obligations under Part IIIC of the Privacy Act when responding to an eligible data breach or a suspected eligible data breach.
Other obligations
Entities may have other obligations outside of those contained in the Privacy Act that relate to personal information protection and responding to a data breach. These may include other data protection obligations under state-based or international data protection laws. Australian businesses may need to comply with the European Union’s (EU’s) General Data Protection Regulation (GDPR)[8] if they have an establishment in the EU, if they offer goods and services in the EU, or if they monitor the behaviour of individuals in the EU.
For data breaches affecting certain categories of information, other mandatory or voluntary reporting schemes may exist. For example, entities might consider reporting certain breaches to:
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the entity’s financial services provider
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police or law enforcement bodies
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the Australian Securities & Investments Commission (ASIC)
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the Australian Prudential Regulation Authority (APRA)
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the Australian Taxation Office (ATO)
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the Australian Transaction Reports and Analysis Centre (AUSTRAC)
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the Australian Cyber Security Centre (ACSC)
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the Australian Digital Health Agency (ADHA)
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the Department of Health
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State or Territory Privacy and Information Commissioners
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professional associations and regulatory bodies
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insurance providers.
Some entities may have additional obligations to report to the Commissioner under the National Cancer Screening Register Act 2016 (NCSR Act)or have different reporting obligations under the My Health Records Act 2012 (My Health Records Act).
Under the NCSR Act, current and former contracted service providers of the National Cancer Screening Register must notify the Secretary of the Department of Health (the Secretary) and the Commissioner if they become aware of unauthorised recording, use or disclosure of personal information included in the Register. The Secretary must also notify the Commissioner of certain data breaches, including potential breaches, in connection with the National Cancer Screening Register. The Secretary must also consult the Information Commissioner about notifying individuals who may be affected. Separately, entities with NCSR Act obligations must consider whether the incident also requires notification under the NDB scheme, as the two schemes operate concurrently. Where the test for both schemes have been met, the entity may make a joint notification to the Commissioner.
Certain participants in the My Health Record system (such as the System Operator, a registered healthcare provider organisation, a registered repository operator, a registered portal operator or a registered contracted service provider), are required to report data breaches that occur in relation to the My Health Record system to the either the System Operator or the Commissioner, or both, depending on the entity reporting the data breach (s 75 of the My Health Records Act). More information about obligations under the My Health Records Act and how these obligations interact with the NDB scheme is available in Part 4.
| Information to be included | Yes/No | Comments |
| What a data breach is and how staff can identify one | ||
| Clear escalation procedures and reporting lines for suspected data breaches | ||
| Members of the data breach response team, including roles, reporting lines and responsibilities | ||
| Details of any external expertise that should be engaged in particular circumstances | ||
| How the plan will apply to various types of data breaches and varying risk profiles with consideration of possible remedial actions | ||
| An approach for conducting assessments | ||
| Processes that outline when and how individuals are notified | ||
| Circumstances in which law enforcement, regulators (such as the OAIC), or other entities may need to be contacted | ||
| Processes for responding to incidents that involve another entity | ||
| A record-keeping policy to ensure that breaches are documented | ||
| Requirements under agreements with third parties such as insurance policies or service agreements | ||
| A strategy identifying and addressing any weaknesses in data handling that contributed to the breach | ||
| Regular reviewing and testing of the plan | ||
| A system for a post-breach review and assessment of the data breach response and the effectiveness of the data breach response plan |
Canine Essentials Pty. Ltd. is committed to a clear and immediate communications strategy that allows for the prompt notification of affected individuals and other relevant entities. In particular:
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who is responsible for implementing the communications strategy;
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determining when affected individuals must be notified (refer to Identifying eligible data breaches for further information about mandatory data breach notification requirements under the NDB scheme);
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how affected individuals will be contacted and managed;
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criteria for determining which external stakeholders should be contacted (for example, law enforcement and cyber security agencies, regulators such as the OAIC, and the media).
Strategies
Canine Essentials will address the following questions to help identify strategies to contain a data breach:
- How did the data breach occur?
- Is the personal information still being shared, disclosed, or lost without authorisation?
- Who has access to the personal information?
- What can be done to secure the information, or stop the unauthorised access or disclosure, and reduce the risk of harm to affected individuals?
At this point, an entity may suspect an eligible data breach under the NDB scheme has occurred, which would trigger assessment obligations. Or, the entity may believe the data breach is an eligible data breach, which requires them to notify individuals as soon as practicable.
During this preliminary stage, be careful not to destroy evidence that may be valuable in identifying the cause of the breach, or that would enable the entity to address all risks posed to affected individuals or the entity.
Assess
An assessment of the data breach can help an entity understand the risks posed by a data breach and how these risks can be addressed. It should be conducted as expeditiously as possible.
Gather and evaluate as much information about the data breach as possible. By creating a complete picture of the data breach, an entity can ensure they understand the risk of harm to affected individuals, and identify and take all appropriate steps to limit the impact of a data breach.
This assessment should also assist entities in deciding whether affected individuals must be notified.
In Canine Essentials, the assessment of a data breach will consider:
- the type or types of personal information involved in the data breach
- the circumstances of the data breach, including its cause and extent
- the nature of the harm to affected individuals, and if this harm can be removed through remedial action.
All entities should consider whether remedial action can be taken to reduce any potential harm to individuals. This might also take place during Step 1: Contain, such as by recovering lost information before it is accessed.
Entities subject to the NDB scheme are required to conduct an assessment of ‘suspected’ eligible data breaches and take reasonable steps to complete this assessment within 30 days (see Assessing a suspected data breach). Criteria for assessing a data breach, including the risk of harm and remedial action, is explored in Identifying eligible data breaches.
Notify
Notification can be an important mitigation strategy that has the potential to benefit both the entity and the individuals affected by a data breach. The challenge is to determine when notification is appropriate. Sometimes, notifying individuals can cause undue stress or harm. For example, notifying individuals about a data breach that poses very little or no risk of harm can cause unnecessary anxiety. It can also de-sensitise individuals so that they don’t take a notification seriously, even when there is a real risk of serious harm. Each incident needs to be considered on a case-by-case basis to determine whether breach notification is required.
Consider:
- the obligations of the entity under the NDB scheme. Entities are required to notify individuals and the Commissioner about data breaches that are likely to result in serious harm. Part 4 of this guide provides further detail about the NDB scheme’s requirements
- other circumstances in which individuals should be notified. For example, your entity may not have obligations under the NDB scheme, but have processes in place to notify affected individuals in certain circumstances
- how notification should occur, including:
- what information is provided in the notification
- how the notification will be provided to individuals
- who is responsible for notifying individuals and creating the notification.
- who else other than affected individuals (and the Commissioner if the notification obligations of the NDB scheme apply) should be notified
- where a law enforcement agency is investigating the breach, it may be appropriate to consult the investigating agency before making details of the breach public
- whether the incident triggers reporting obligations to other entities.
Effective data breach response is about reducing or removing harm to affected individuals, while protecting the interests of your organisation or agency. Notification has the practical benefit of providing individuals with the opportunity to take steps to protect their personal information following a data breach, such as by changing account passwords or being alert to possible scams resulting from the breach. It is important that staff are capable of engaging with individuals who have been affected by a data breach with sensitivity and compassion, in order not to exacerbate or cause further harm. Notification can also help build trust in an entity, by demonstrating that privacy protection is taken seriously.
Review
Once steps 1 to 3 have been completed, an entity should review and learn from the data breach incident to improve its personal information handling practices.
This might involve:
- a security review including a root cause analysis of the data breach
- a prevention plan to prevent similar incidents in future
- audits to ensure the prevention plan is implemented
- a review of policies and procedures and changes to reflect the lessons learned from the review
- changes to employee selection and training practices
- a review of service delivery partners that were involved in the breach.
In reviewing information management and data breach response, an entity can refer to the OAIC’s Guide to securing personal information.[10]
When reviewing a data breach incident, it is important to use the lessons learned to strengthen the entity’s personal information security and handling practices, and to reduce the chance of reoccurrence. A data breach should be considered alongside any similar breaches that have occurred in the past, which could indicate a systemic issue with policies or procedures.
If any updates are made following a review, staff should be trained in any changes to relevant policies and procedures to ensure a quick response to a data breach.
Notifiable Data Breach (NDB) Scheme
The Privacy Act requires certain entities to notify individuals and the Commissioner about data breaches that are likely to cause serious harm.
The requirements of the NDB scheme are contained in Part IIIC of the Privacy Act and apply to breaches that occur on or after 22 February 2018.
This part of the guide covers the following topics:
- Entities covered by the NDB scheme
- Data breaches involving more than one entity
- Identifying eligible data breaches
- Exceptions to the notification obligation
- Assessing a suspected data breach
- Notifying individuals about an eligible data breach
- What to include in an eligible data breach statement
- The Australian Information Commissioner’s role in the NDB scheme
Entities covered by the NDB scheme
Key points
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Entities that have existing obligations under the Privacy Act to secure personal information must comply with the NDB scheme.
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This includes Australian Government agencies, businesses and not-for profit organisations that have an annual turnover of more than AU$3 million, private sector health service providers, credit reporting bodies, credit providers, entities that trade in personal information and tax file number (TFN) recipients.
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Entities that have Privacy Act security obligations in relation to particular types of information only (for example, small businesses that are required to secure tax file number information) do not need to notify about data breaches that affect other types of information outside the scope of their obligations under the Privacy Act.
APP entities
The NDB scheme applies to entities that have an obligation under APP 11 of the Privacy Act to protect the personal information they hold (s 26WE(1)(a)). Collectively known as ‘APP entities’, these include Australian Government agencies and private sector and not-for-profit organisations with an annual turnover of more than $3 million. The definition of APP entity generally does not include small business operators, registered political parties, state or territory authorities, or a prescribed instrumentality of a state (s 6C). However, some businesses of any size are APP entities, including businesses that trade in personal information[12] and organisations that provide a health service to, and hold health information about, individuals (see Is my organisation a health service provider?).
For more information about APP entities, see Chapter B of the Australian Privacy Principle Guidelines (APP Guidelines).[14]
Exempt acts and practices, including employee records
The NDB scheme only applies to entities and personal information holdings that are already subject to security requirements under the Privacy Act. This means that acts and practices of APP entities that are exempt from the Privacy Act will also be exempt from the NDB scheme.
For example, in some circumstances, private sector employers do not have to comply with the APPs in relation to employee records associated with current and former employment relationships (s 7B(3)). If an exempt employee record is subject to unauthorised access, disclosure or loss, the private sector employer does not have to assess the breach or notify individuals and the Commissioner. This exemption does not apply to TFN information that is contained within an employee record. However, given community expectations around the handling of their personal information, it is recommended that employers notify affected individuals where a breach of an employee record is likely to result in serious harm. Doing so will enable affected individuals to take protective action against any potential harms, as well as illustrating to employees that the security of their records is taken seriously.
Further information about acts and practices that are exempt from the APPs and, by extension, the NDB scheme can be found in Privacy business resource 13: Application of the Australian Privacy Principles to the private sector.
Small business operators
A small business operator (SBO) is an individual (including a sole trader), body corporate, partnership, unincorporated association, or trust that has not had an annual turnover of more than $3 million in any financial year since 2001 (s 6D).
Generally, SBOs do not have obligations under the APPs unless an exception applies (s 6D(4)).
In certain circumstances an SBO must comply with the APPs, and therefore with the NDB scheme. That will be the case where the SBO
- holds health information and provides a health service
- is related to an APP entity
- trades in personal information. That is, the SBO discloses personal information about individuals to anyone else for a benefit, service or advantage; or provides a benefit, service or advantage through the collection of personal information about another individual from anyone else
- is a credit reporting bodies
- is an employee associations registered under the Fair Work (Registered Organisations) Act 2009
- has ‘opted-in’ to APP coverage under s 6EA of the Privacy Act.
If an SBO carries on certain activities it must comply with the APPs, and therefore must comply with the NDB scheme, but only in relation to personal information held by the entity for the purpose of, or in connection with, those activities. Those activities include:
- providing services to the Commonwealth under a contract
- operating a residential tenancy data base
- reporting under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006
- conducting a protected action ballot
- information retained under the mandatory data retention scheme, as per Part 5-1A of the Telecommunications (Interception and Access) Act 1979.
More information about how to determine whether a business or organisation is an APP entity or subject to the APPs for some of its activities is available at Privacy business resource 10: Does my small business need to comply with the Privacy Act?.[16]
Applicable Links
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Appropriate References
| The Privacy Act (1988) – 13 Australian Privacy Principles
Principle 1 – Open and transparent management of personal information
Principle 2 – Anonymity and pseudonymity
Principle 3 – Collection of personal information
Principle 4 – Dealing with unsolicited personal information
Principle 5 – Notification of the collection of personal information
Principle 6 – Use or disclosure of personal information
Principle 7 – Direct marketing
Principle 8 – Cross-border disclosure of personal information
Principle 9 – Adoptions, use or disclosure of government related identifiers
Principle 10 – Quality of personal information
Principle 11 – Security of personal information
Principle 12 – Access to personal information
Principle 13 – Correction of personal information
For more information on the National Privacy Principles, see the National Privacy Principles guidelines, issued by the Office of the Federal Privacy Commissioner. The full text of the NPPs can be found at the Federal Privacy Commissioner’s website: http://www.privacy.gov.au/ |
9 SAFETY
9.1 SECURITY
Canine Essentials adopts the following industry standards:
- Premises and dog enclosures must be secure against ingress of unwanted dogs, persons or pests.
- All external openings must prevent escape of dogs or easy removal of products or equipment without authorisation.
- Adequate security must be in place to ensure the safety of staff, the public and any dogs on the premises.
9.2 EMERGENCY
Canine Essentials adopts the following industry standards:
- A business risk assessment should be made to identify risks that may result in emergencies.
- An Emergency plan must be available for fire, threat, chemical spills and other emergencies as appropriate, and staff trained in its use.
- Formal procedures must be in place to ensure (where practical), the swift and safe evacuation of dogs from the premises in the case of fire or other emergencies.
- The Director should provide the local RSPCA/Police or other relevant authorities with up-to-date emergency contact details, including that of a nominated veterinarian.
- The Director must ensure that all products on site have been assessed for safety and Material Safety Data Sheets must be available as appropriate.
- Appropriate firefighting equipment must be readily available and staff trained and practiced in its use.
- WARNING: some fire retardants may be toxic to dogs and these should not be used except as a last resort.
9.3 PEST CONTROL
Canine Essentials adopts the following industry standards:
- Pests including fleas, flies, lice, mosquitoes, cockroaches and wild rodents are all a potential health hazard to staff and livestock and must be controlled.
- Specialist advice must be sought before pest control operations are conducted, in order to protect the health and safety of staff and dogs.
- Chemicals used for pest control must be approved by the relevant government authority and used in accordance with the manufacturer’s instructions. In some cases, MSDS’s and ongoing staff monitoring may also be required.
9.4 INFECTION CONTROL
Canine Essentials Pty. Ltd. will identify health risks and implement control measures to minimise the transmission risks associated with zoonotic diseases. Canine Essentials Pty. Ltd. does this primarily through Disease Prevention and Control. Persons responsible for dog care will be familiar with the signs of disease which are common to the type of dog being held. When signs of disease or injury are observed, prompt veterinary or other appropriate treatment should be obtained to protect the health of individual dogs and prevent the spread of disease.
The specific guidelines to be employed in aiding staff in infection control measures may be found below to enable Canine Essentials Pty. Ltd. to comply with both Federal and State legislature: “Infection Control Guidelines for Dog Contact”.
Zoonotic Infections
Zoonoses are infections that can be passed from dogs to humans. Sources of zoonoses reported in Australia include cattle, sheep, horses, goats, pigs, guinea pigs, ferrets, dogs, cats, poultry, birds, tropical fish, rodents, amphibians, reptiles (including turtles and tortoises), bats and other species of native wildlife.
Reports of human illness associated with dog contact through farms, shows, zoos, petting zoos and wildlife exhibitors are infrequent in Australia. However, where illness does occur, the disease can be serious, especially for:
- infants and young children
- pregnant women
- older adults
- people with compromised immune systems.
Providers of dog contact opportunities have a duty under the Work, Health and Safety Act (2012) to ensure the health and safety of themselves, staff and other persons, so far as is reasonably practicable. Dog care in relation to husbandry, health, facilities, safety and hygiene are regulated and subject to various codes of practice and minimum standards.
Infection Control Guidelines for Dog Contact
Canine Essentials adopts the following industry standards regarding special infection risks associated with dogs:
- The Director and staff must reduce the risk of transmission of dog diseases to humans (zoonoses).
- Adequate hand washing/cleansing facilities &/or gloves must be provided.
- Any person who routinely works with dogs should be immunised against tetanus.
- Any person who works with dogs should be made aware of the risk of zoonotic disease, including toxoplasmosis, psittacosis, and transmission of funguses and bacteria; and the measures that they should take to minimise the risk.
- The Director should work with staff and external agencies as appropriate to assess and manage these risks, and staff should be trained, informed and regularly assessed on their adherence to risk mitigation procedures.
Sick (or suspected sick) Dogs:
- Prompt and appropriate veterinary care must be provided for sick or injured dogs and the owner notified where appropriate.
- Any sick dog and all those in the same enclosure; and any injured dog must be isolated in an area away from contact with the public and other dogs until fully recovered or returned to the owner.
- Where treatment is impractical or unsuccessful, or the situation is an emergency with no reasonable prospect of recovery and not to act would constitute cruelty, or the owner cannot be located, or the owner has requested the action; then the dog should be humanely destroyed (euthanased). Euthanasia of dogs and cats must only performed by a veterinarian.
- Veterinary advice (and possible autopsy) should be obtained in the event of unexplained illness or death.
Hygiene around dogs:
- All cages and pens holding dogs must be cleaned on a regular basis and records of cleaning must be kept.
- All cages, pens and containers must be cleaned and/or disinfected according to the species as often as needed, but at least once every week and when an enclosure is vacated.
- Dog enclosures and equipment must be managed to minimise cross-infection risk.
- Cleaning and disinfection chemicals and materials must be chosen on the basis of their suitability (including suitability for species), safety and effectiveness and must only be used in accordance with the manufacturer’s instructions.
- Hygiene measures must minimise the risk of dog: dog transmission of disease including nose: nose contact, vaccination protocols, materials and equipment hygiene
Precautions
Operators should assume that all dogs are capable of carrying germs potentially harmful to humans and should take appropriate precautions to prevent the spread of disease, including:
Dog wellbeing
- Provide only healthy dogs for public display or contact:
- establish a close association with a veterinarian to ensure dogs are clinically healthy
- maintain a comprehensive parasite control program with the veterinarian
- exclude dogs which are unwell, for example with skin sores and diarrhoea
- vaccinate or screen dogs when appropriate (as per veterinary advice), for example Hendra virus vaccination for horses.
- Maintain dogs in an environment appropriate to maintaining their health, welfare and biosecurity.
- Do not use dogs with unsuitable temperaments as contact dogs.
- Alleviate any stress, over handling and overcrowding of dogs to reduce possibility of disease.
- The operator must take appropriate measures to manage any associated risk where contact between dogs and visitors is promoted, or where visitors are allowed unsupervised access to dogs. For example, in order to minimise the risk of visitors or staff being bitten, scratched or otherwise injured by the dogs, exhibitors should:
- monitor dog behaviour during the exhibit
- remove any dogs that exhibit signs of irritability or aggression
- not exhibit dogs that may have increased potential for aggressive behaviour associated with mating/breeding.
- Provide adequate barriers and signage to prevent visitors from touching dogs that are not available for touching or that should not be touched.
9.5 TRANSPORT OF DOGS
Canine Essentials adopts the following industry standards:
- Note: transportation distresses some dogs and should be minimised. People responsible for the transport of dogs have a duty of care to ensure that dogs are not assembled, loaded, transported or unloaded in a way that is likely to cause injury, suffering or distress.
- People responsible for the transport of dogs must be trained and competent in the tasks they are expected to perform.
- All dogs transported to or by a Canine Essentials should be boxed, caged or suitably restrained to ensure their security and protection whilst in transit. The size of containers and crates for the transport of dogs by air, road and rail is dictated by IATA regulations to which Australia is a signatory.
- Dogs selected for transport must be in good health and fit for the intended journey. The only exception to this requirement is when the transport is for emergency purposes to seek veterinary treatment. Transport cages must permit an dog to turn around, but otherwise should be of an appropriate size to avoid trauma during transport.
- Dogs must be protected from extremes of temperature during transport and all dog transport journeys must be planned to be as short as possible in terms of the time travelled.
- The consignor and consignee should confirm departure and arrival times of dogs with the carrier. In the event of delay or cancellation, the carrier must ensure the welfare of dogs in transit and attached documentation must specify and include this responsibility.
- Adequate and appropriate food and water must be provided, particularly during long periods of long-distance transport.
- Dog transport containers must provide adequate light and ventilation and must be strong enough to withstand handling and possible stacking.
- Containers in which dogs are transported must be clearly labelled. Consignor and consignee contact details including phone number(s) must be shown as well as date and time of departure.
- The dog must be suitably identified, where possible, with external identification, microchip, labelling of internal containers etc. to allow identification if the transport container is lost or damaged.
10 COMMITTEES
10.1 PREAMBLE
Canine Essentials prides itself on being proactive and ethical when conducting business. As such, there are a number of committees that are active to ensure that Canine Essentials remain committed to our core Mission Statement, Values and Ethics. To that end, Canine Essentials has a Board of Directors and a number of Committees that serves a number of specific functions. Overall, Canine Essentials Board of Directors pass a resolution to form a committee to deal with a number of specific tasks that are assigned for which the Board is responsible for, but which it does not necessarily have enough time and resources to manage. By delegating these tasks to the Committees, the Canine Essentials Board of Directors can spend their time more efficiently. All Committee members must sign a Confidentiality Agreement which will be kept on file and Committees will meet on an ad hoc basis as the need arises.
10.2 APPLICATION REVIEW COMMITTEE (ARC)
The purpose and rationale of the Application Review Committee is: Consultation and review about Applicants who pass Veterinarian Certification and submit an application to formally apply for the Owner Trained Assistance Dog Program. As such, it is vital that Applicants can be screened by people with different expertise and life experience to ensure the ethical treatment of dogs, give clients the best outcome and to protect Canine Essentials business interests and reputation. Therefore Consumer Representatives must be an integral part of this Committee (see: Section – 10.6).
10.3 ETHICS COMMITTEE
The purpose and rationale of the Ethics Committee is: Consultation and review about ethical issues that arise during the course of business. As such ethical issues and dilemmas that arise during the course of business can be looked at by all angles by people with different expertise and life experience to ensure the ethical treatment of dogs, give clients the best outcome and to protect Canine Essentials business interests and reputation. Therefore Consumer Representatives must be an integral part of this Committee (see: Section – 10.6).
10.4 POLICY REVIEW COMMITTEE
The purpose and rationale of the Policy Review Committee is: Consultation and review about policy changes and amendments that may arise due to changes in industry standards or legislative changes, or, to ensure compliance with industry standards and legislative requirements. Policy adherence is vital in an ever changing environment such as this and it is vital that this can be considered and researched by a number of people who can meet and discuss this. By doing so, policy changes and amendments can be looked at by all angles by people with different expertise and life experience to ensure the ethical treatment of dogs, give clients the best outcome and to protect Canine Essentials business interests and reputation. Therefore Consumer Representatives must be an integral part of this Committee (see: Section – 10.6).
10.5 TRAINING COMMITTEE
The purpose and rationale of the Policy Review Committee is: Consultation and review about Training in line with industry standards and clients (both potential, present and past) including their conduct and adherence to polices etc. Also inclusive of training memberships held by Canine Essentials. Canine Behaviour and Training must be founded on humane training methods and a force free methodology. As such the Committee is charged with considering the latest evidence available to date, ensuring client compliance and bring to the table a vast range of expertise and life experience to ensure the ethical treatment of dogs, give clients the best outcome and to protect Canine Essentials business interests and reputation. Therefore Consumer Representatives must be an integral part of this Committee (see: Section – 10.6).
10.6 CONSUMER REPRESENTATIVES
Canine Essentials supports consumers of our services to be an effective voice in their role as a consumer representative and or advisory group member. Consumer representatives can choose to remain confidential should they choose to be.
Who is a Consumer?
A consumer is a person who uses, or potentially uses a Canine Essentials services, including their family and carers. Consumers may participate as individuals, groups, organisations of consumers, consumer representatives or communities. It is most likely an Assistance Dog Service.
Being a Consumer Representative
Canine Essentials promotes and enables consumers of our services to have a voice in the planning, implementation and evaluation of policies, programs and services to achieve better outcomes for both themselves and their dogs.
What is the role of a Consumer Representative?
A consumer representative’s role is to provide feedback to Canine Essentials to influence our services, policy, systems and service reform from the consumer perspective.
The role of a consumer representative involves:
- Representing consumer, carer’s and their (perceived canine’s) views to the committee/group;
- Providing a consumer perspective which reflects their journey and the collective experience of consumers;
- Helping the committee to think about things from a consumer perspective by raising consumer concerns and views;
- Providing broader community feedback rather than focus on one’s own individual experiences to inform system and service level improvements;
- Being engaged with formal and informal consumer networks;
- Attending and participating in committee meetings as agreed with Canine Essentials;
- Maintaining confidentiality and disclosure of conflicts of interest, and;
- Providing feedback to own networks of consumers as required.
Although everyone is a consumer, not every committee member can represent consumers. Other committee members such as service providers, researchers or professionals are usually there to provide the perspective from that work area. (http://www.hcq.org.au/for-consumer-representatives/)
Broad Overview
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Related Acts, Polices and Documents |
o Disability Discrimination Act (1992).
o Equal Opportunity Act (1984). o Racial Vilification Act (1996). o Racial Discrimination Act (1975). o Sex Discrimination Act (1984). o Human Rights and Equal Opportunity Commission Act (1986). o Age Discrimination Act (2004). o Equal Opportunity for Women in the Workplace Act Act (1999). o Environment Protection Act (1999). o Defamation Act (2005). o Fair Work Act (2009). o Australian Competition and Consumer Commission. o Competition and Consumer Act (2010). o Work Health and Safety Act (2012). o Workers Rehabilitation Act and Compensation Act (1986). o National Law: Section 39 – Mandated Reporting. o Children and Young People Act 2008 (ACT), Children and Young Persons (Care and Protection) Act 1998 (NSW), Care and Protection of Children Act 2007 (NT), Child Protection Act 1999 (Qld), Children’s Protection Act 1993 (SA), Children, Young Persons and their Families Act 1997 (Tas.), Children, Youth and Families Act 2005 (Vic.). o Dog and Cat Management Act (1995). o Dog and Cat Management Regulations (2017). o RSPCA: State and Territory animal welfare legislation. o Prevention of Cruelty to Animals Regulations (2008). o Scope of Practice for Registered Nurses and Midwives. o ICN Code of Ethics for Nurses. o Registered Nurse Standards for Practice. o Privacy Act (1988). o Canine Essentials Privacy Policy. o Canine Essentials Policies.
NORTHERN TERRITORY OF AUSTRALIA COOMALIE (DOG MANAGEMENT) BY-LAWS (2002) (NT) Section 5: Interpretation – “owner”, in relation to a dog, means – (a) the registered owner of the dog or the person for the time being in control of the dog; (b) the occupier of premises or a part of premises where the dog is usually kept; or (c) if the owner has not attained the age of 17 years – a parent or guardian of the owner, but does not include a person controlling or keeping a dog that is seized or impounded under Part 4, Division 2. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – AS STATED HERE 17 YEARS WILL BE THE DESIGNATED AGE WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY. |
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| Companion Animals Act (1998) No 87 (NSW)
Section 13: must be under the effective control of some competent person – 2(b) over the age of 16 years old. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – 16 YEARS IS A REASONABLE AGE IN MOST STATES WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY.
Dog and Cat Management Act (1995 including amendments 2016) (SA) Section 6: a person is responsible for the control of a dog while in possession of the dog – (3) interpreted to mean over the age of 16 years old. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – 16 YEARS IS A REASONABLE AGE IN MOST STATES WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY.
Dog Act (1976) (WA) Section 30: every person liable for the control of the dog at that time commits an offence. Section 31: 1. A dog shall not be in a public place unless it is — (a) held by a person who is capable of controlling the dog. 2. A person is a competent person for the purposes of subsection (1) only if — (a) he is a person who is liable for the control of the dog; and (b) he is capable of controlling it; and (c) he is carrying and capable of attaching to the dog for the purpose of controlling it, a chain, cord, leash or harness of sufficient strength and not exceeding the prescribed length. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – 16 YEARS IS A REASONABLE AGE IN MOST STATES WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY.
Animal Management (Cats and Dogs) Act (2008) (QLD) Section 10: Who is a responsible person for a dog (1) A person is a responsible person for a dog if— (a) the person, or the person’s employee acting within the scope of the employment, has immediate control or custody of the dog; or (b) the person is the parent or guardian of a child who has immediate control or custody of the dog; or (c) the person occupies the place at which the dog is usually kept. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – 16 YEARS IS A REASONABLE AGE IN MOST STATES WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY.
Domestic Animals Act (1994) (VIC) Section 4: 4 Parent or guardian deemed to be owner Where the owner of a dog or cat is under the age of 18 years, for the purposes of this Act, the parent or guardian of that person is deemed to be the owner. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – 16 YEARS IS A REASONABLE AGE IN MOST STATES WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY.
Domestic Animals Act (2000) (ACT) Section 6: (1) An individual who is a keeper of a dog may apply to the registrar for registration of the dog. (2) If the applicant is less than 16 years old and resides with a parent or guardian, a written consent to the registration by the applicant’s parent or guardian must accompany the application. INTERPRETED TO MEAN THE NATIONAL AGE OF MAJORITY IS OVER THE AGE OF 18 YEARS – HOWEVER THIS WILL BE BASED ON THE ABILITY ON THE COMPETENCY AND ABILITY TO HANDLE THE DOG – 16 YEARS IS A REASONABLE AGE IN MOST STATES WITH AN ADULT 18+ IN THE IMMEDIATE VICINITY.
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| Policy Custodian | Dr. Geller | |
| Responsible Officer | Dr. Geller | |
| Endorsed By | Dr. Geller | |
| Reviewed By | Mr. Jolly | |
| Date |
Version |
Approved By |
| 30th December 2013 |
1 |
Dr. Geller |
| 19th January 2014 |
2 |
Dr. Geller |
| 10th July 2014 |
3 |
Dr. Geller |
| 10th October 2014 |
4 |
Dr. Geller |
| 1st February 2014 |
5 |
Dr. Geller |
| 30th June 2015 |
6 |
Dr. Geller |
| 6th October 2015 |
7 |
Dr. Geller |
| 21st December 2016 |
8 |
Dr. Geller |
| 2nd February 2016 |
9 |
Dr. Geller |
| 1st March 2016 |
10 |
Dr. Geller |
| 20th May 2016 |
11 |
Dr. Geller |
| 30th June 2016 |
12 |
Dr. Geller |
| 8th August 2016 |
13 |
Dr. Geller |
| 1st September 2016 |
14 |
Dr. Geller |
| 15th November 2016 |
15 |
Dr. Geller |
| 1st December 2016 |
16 |
Dr. Geller |
| 10th February 2017 |
17 |
Dr. Geller |
| 8th March 2017 |
18 |
Dr. Geller |
| 21st April 2017 |
19 |
Dr. Geller |
| 10th May 2017 |
20 |
Dr. Geller |
| 30th June 2017 |
21 |
Dr. Geller |
| 11th August 2017 |
22 |
Dr. Geller |
| 15th November 2017 |
23 |
Dr. Geller |
| 1st December 2017 |
24 |
Dr. Geller |
| 1st January 2018 |
25 |
Dr. Geller |
| 9th May 2018 – Open Acess
5th September 2018 – OA | 7th September – CA Complete 5th October 2018 – OA | CA 21st December 2018 – OA | CA 30th May 2019 – OA 5th July 2019 – OA 6th August 2019 – OA |
26
27 28 29 30 31 32 |
Dr. Geller (OA) | CA Incomplete
Dr. Geller OA | CA Dr. Geller OA | CA Dr. Geller OA | CA Dr. Geller OA | CA Dr. Geller OA | CA Dr. Geller OA | CA
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References
Association of Pet Dog Trainers Incorporated 2017, Home Page, Association of Pet Dog Trainers Incorporated, NSW, viewed 14 Feb 2014, <http://apdt.com.au/>.
Australian Competition and Consumer Commission 2017, Consumer Rights, Australian Competition and Consumer Commission, Adelaide, viewed 14 Feb 2017, <https://www.accc.gov.au/>.
Australian Copyright Council 2017, An Introduction to Copyright in Australia, Australian Copyright Council, NSW, viewed 1 Macrh 2017, <https://www.copyright.org.au/ACC_Prod/ACC/Information_Sheets/An_Introduction_to_Copyright_in_Australia.aspx?WebsiteKey=8a471e74-3f78-4994-9023-316f0ecef4ef>.
Commonwealth of Australia 1968, Copyright Act, Australian Federal Government, Canberra, viewed 14 Feb 2017, <http://www5.austlii.edu.au/au/legis/cth/consol_act/ca1968133/>.
Commonwealth of Australia 1992, Disability Discrimination Act, Australian Federal Government, Canberra, viewed 14 Feb 2017, <http://www.austlii.edu.au/au/legis/cth/consol_act/dda1992264/>.
Government of South Australia 1984, Equal Opportunity Act, Government of South Australia, Adelaide, viewed 14 Feb 2017, <https://www.legislation.sa.gov.au/LZ/C/A/Equal%20Opportunity%20Act%201984.aspx>.
Human Rights Commission 1992, Assistance animals and the Disability Discrimination Act 1992 (Cth), Human Rights Commission, Canberra, <https://www.humanrights.gov.au/our-work/disability-rights/projects/assistance-animals-and-disability-discrimination-act-1992-cth>.
Victorian Equal Opportunity & Equal Rights Commission 2017, Australian human rights framework, Victorian Equal Opportunity & Equal Rights Commission, Melbourne, viewed 14 Feb 2017, <http://www.humanrightscommission.vic.gov.au/the-charter/australian-human-rights-framework>.
Canine Essentials Pty. Ltd. reserves the right to review and/or amend our policies from time to time to reflect changes in the law, industry standards, our business practices or other relevant factors.
At a minimum, policies are reviewed every 6 months.



























