Participant Rights Policy

Participant Rights Policy

Upholding the rights, dignity, and voice of every person we support

1. Purpose

This policy sets out how Together Two Limited upholds and protects the rights of every participant who receives supports and services from our organisation. It establishes the standards, practices, and safeguards that ensure each person we support is treated with dignity, respect, and fairness.

This policy is grounded in our mission, “We connect to empower”, and is informed by the Keys to Citizenship framework, which embeds the principles of freedom, direction, money, home, assistance, life, and relationships into everything we do. It reflects our commitment to community-led, person-centred service delivery as set out in Our Future: Community-Led Plan 2026–2029.

→ Our Future: Community-Led Plan 2026–2029: Pillar 1 (Community-Led Governance and Co-Design) and Guiding Frameworks (Keys to Citizenship).

2. Scope

This policy applies at all times and across all settings where Together Two provides supports and services, including Supported Independent Living (SIL) dwellings, ZigZag Day Program, in-home supports, community-based supports, School Leaver Employment Supports (SLES), support coordination, and all sites operated by or on behalf of Together Two across metropolitan Sydney.

It applies to all representatives of Together Two including the Board of Directors, Senior Leadership Team, permanent and casual workers, contractors, volunteers (including Good in the Hood volunteers), and students on placement.

This policy applies to all participants regardless of age, gender, cultural background, disability, communication ability, or any other characteristic.

3. Legislative and Regulatory Framework

This policy is informed by and supports compliance with the following legislation, standards, and frameworks:

National Disability Insurance Scheme Act 2013 (Cth)

NDIS (Provider Registration and Practice Standards) Rules 2018, Core Module: Rights and Responsibilities

NDIS (Code of Conduct) Rules 2018

NDIS (Complaints Management and Resolution) Rules 2018

NDIS (Incident Management and Reportable Incidents) Rules 2018

NDIS (Restrictive Practices and Behaviour Support) Rules 2018

United Nations Convention on the Rights of Persons with Disabilities (UNCRPD)

Disability Discrimination Act 1992 (Cth)

Privacy Act 1988 (Cth) and Australian Privacy Principles

Children’s Guardian Act 2019 (NSW)

NSW Anti-Discrimination Act 1977

National Principles for Child Safe Organisations

→ Business and Operational Plan 2025–2028: Section 9 (Legislative and Regulatory Framework) maintains the full Compliance Register (Form 17).

4. Our Commitment to Participant Rights

Together Two exists to empower connections and wellbeing within our community. We recognise that every person we support has inherent human rights that exist independently of any service or funding arrangement. Our role is to uphold, protect, and actively promote those rights, not merely to avoid breaching them.

We are committed to ensuring that:

Every participant is at the centre of their supports, not the service provider, not the system, and not administrative convenience.

Every participant has a voice, even when they cannot verbally express it. For participants with complex communication needs, their Circle of Support, the people who know them best, helps ensure their will, preferences, and interests are heard and acted upon.

Every participant can take risks, make choices, and live with the consequences of those choices, consistent with dignity of risk, because an overprotected life is not a good life.

No participant is defined by their disability, their funding, or their support needs. Every person has strengths, preferences, relationships, and aspirations that matter.

Our organisational values, beliefs, or resource constraints never override a participant’s right to choice and control.

→ Circles of Support Engagement Framework: “When a participant cannot tell us that something is wrong, their circle can. When a participant cannot express what a good life looks like for them, their circle holds that vision.”

5. Rights and Responsibilities Outcomes

The NDIS Practice Standards establish five participant-focused outcomes for rights and responsibilities. Together Two is committed to achieving each of these outcomes in practice, not merely in policy.

5.1 Person-Centred Supports

Outcome: Each participant accesses support that promote, uphold, and respect their legal and human rights. Each participant is enabled to exercise informed choice and control. Supports promote, uphold, and respect individual rights to freedom of expression, self-determination, and decision-making.

At Together Two, person-centred practice means:

Support plans are developed with the participant and their Circle of Support, not for them. Plans reflect what matters to the person, including their goals, preferences, routines, cultural needs, and the relationships that give their life meaning.

We use the Keys to Citizenship framework to ensure supports address all seven domains of a good life: freedom, direction, money, home, assistance, life, and relationships.

Workers are trained to understand each participant’s specific communication methods, preferences, and how to interpret and respond to non-verbal cues, informed by the participant’s circle.

For SIL participants with complex behavioural and psychosocial needs, person-centred practice includes understanding the function of behaviour, supporting quality of life, and never reducing a person to a set of risk factors or incident reports.

The ZigZag Day Program and Good in the Hood partnership provide integrated, non-segregated community participation where participants work alongside approximately 80 community volunteers, building genuine relationships in the Circle of Participation.

→ Person-Centred Practice Policy; Circles of Support Engagement Framework; Positive Behaviour Support Policy.

5.2 Individual Values and Beliefs

Outcome: Each participant accesses support that respect their culture, diversity, values, and beliefs. Each participant’s autonomy is respected, including their right to intimacy and sexual expression.

At Together Two, we recognise and respect the diverse identities of the people we support:

Support plans document each participant’s cultural, spiritual, dietary, and personal preferences. These are communicated to all workers providing support and reviewed at least annually with the participant and their circle.

We actively support participants from culturally and linguistically diverse (CALD) backgrounds, including arranging interpreting and translation services through TIS National or other reputable services.

We support and affirm participants who identify as LGBTQI+, using inclusive language, respecting chosen names and pronouns, and maintaining confidentiality about gender identity and sexual orientation.

We adopt a neuro-affirming approach that recognises neurodivergence (including autism) as a natural part of human diversity, not a deficit to be corrected.

We respect each participant’s autonomy, including their right to intimacy and sexual expression, and support workers to navigate these conversations with sensitivity and professionalism.

→ Diversity and Inclusion Policy; Circles of Support Engagement Framework.

5.3 Privacy and Dignity

Outcome: Each participant accesses support that respect and protect their dignity and right to privacy.

Together Two protects participant privacy and dignity through:

Personal information is collected, stored, used, and disclosed in accordance with the Privacy Act 1988 (Cth) and Australian Privacy Principles. Participant consent is obtained for the collection and sharing of information, and participants are informed how to access, correct, or withdraw consent.

Personal care and high-intensity supports are delivered in a way that preserves dignity, with attention to participant preferences for timing, positioning, gender of worker, and the presence or absence of others. This is especially important in SIL settings where 24/7 support creates proximity that must be managed respectfully.

Participant information is shared with workers on a need-to-know basis. Case discussions, handovers, and clinical reviews are conducted in private settings.

The Support Circuits AI portal provides families with appropriate visibility of their loved one’s supports while maintaining the participant’s privacy boundaries as documented in their consent and service agreement.

→ Privacy and Confidentiality Policy; Information Security Policy; Data Breaches Policy.

5.4 Independence and Informed Choice

Outcome: Each participant is supported to make informed choices, exercise control, and maximise their independence in relation to the supports provided.

Together Two actively supports participant independence and choice:

We presume capacity. Every participant is assumed to have the capacity to make their own decisions unless there is clear evidence otherwise. We do not assume a person lacks capacity because of their age, disability, behaviour, or communication method.

Where a participant needs support to make decisions, we use supported decision-making approaches, helping the person understand their options, consider consequences, and communicate their choice. The Circles of Support model provides trusted people who can assist with this process.

Where a participant has a legally appointed guardian or substitute decision-maker, we work collaboratively with them while continuing to seek and respect the participant’s own expressed will and preferences wherever possible.

We support dignity of risk, recognising the right of every person to take calculated risks and learn from experience. Workers are trained to balance their duty of care with the participant’s right to live an autonomous and self-determining life.

Advice to participants about support options is transparent and promotes genuine choice and control, including information about services we do not provide directly.

SLES and employment support programs create genuine pathways to economic participation and independence, grounded in community connection through the Wellbeing Hub model.

→ Decision Making and Consent Policy; Duty of Care and Dignity of Risk Policy; Circles of Support Engagement Framework.

5.5 Freedom from Violence, Abuse, Neglect, Exploitation, and Discrimination

Outcome: Each participant accesses support free from violence, abuse, neglect, exploitation, and discrimination.

Together Two maintains robust safeguarding systems to prevent and respond to harm:

All workers complete pre-employment screening including NDIS Worker Screening Checks, Working with Children Checks (where applicable), reference checks, and verification of qualifications. Workers who fail or cannot renew screening are immediately removed from participant-facing roles.

All workers are trained during induction and through ongoing professional development in recognising, preventing, and responding to abuse, neglect, exploitation, and discrimination. This includes understanding the specific vulnerabilities of participants with complex communication needs, cognitive disability, and psychosocial disability.

Circles of Support act as a safeguarding mechanism. Trusted people around a participant notice changes in behaviour, mood, or wellbeing that may indicate harm, and can raise concerns when the participant cannot.

All allegations of abuse, neglect, or exploitation are treated as incidents, reported to the NDIS Quality and Safeguards Commission (for reportable incidents within 24 hours), and investigated in accordance with our Incident Management Policy. Where criminal conduct is alleged, the matter is reported to NSW Police.

We do not tolerate discrimination on any ground. Our supports are provided in environments free from bullying, harassment, and discrimination for both participants and workers.

Participants are informed of their right to make complaints to Together Two, to the NDIS Commission, or to an independent advocate, without fear of retribution or impact on their services.

→ Abuse, Neglect and Exploitation Policy; Incident Management Policy; Worker Screening Policy; Child Safe Policy; Complaint Management Policy.

6. How We Uphold Rights in Practice

Policies alone do not protect rights. Together Two embeds rights into practice through the following mechanisms:

6.1 Induction and Training

All workers complete the NDIS Worker Orientation Module (‘Quality, Safety and You’) and the Supporting Effective Communication e-learning module as part of induction.

Induction includes training on the NDIS Code of Conduct, participant rights, abuse recognition and reporting, complaints handling, and cultural responsiveness.

Ongoing training addresses person-centred practice, supported decision-making, dignity of risk, restrictive practices awareness, and participant-specific communication methods.

Training records are maintained in the Skill and Competency Matrix and Microsoft Dynamics 365.

→ Human Resources Policy; Business and Operational Plan 2025–2028: Section 10 (Workforce Plan).

6.2 Supervision and Performance

Workers receive regular supervision where rights-based practice is discussed, modelled, and reinforced.

Performance management includes assessment of the worker’s ability to deliver person-centred, rights-respecting supports.

Workers who breach participant rights, the NDIS Code of Conduct, or Together Two policies are subject to disciplinary action up to and including termination of employment.

6.3 Participant and Family Engagement

The Circles of Support Engagement Framework provides multiple pathways for participants and families to have a voice: individual circles, the Family and Supporter Committee (bi-monthly), co-design sessions, the Support Circuits AI portal, annual satisfaction surveys, support plan reviews, and informal feedback.

Feedback from all mechanisms is documented, analysed for themes, and actioned through the Continuous Improvement Register. Participants and families are informed of actions taken, closing the loop.

→ Circles of Support Engagement Framework; Continuous Improvement Policy; Internal Audit Schedule and CI Register.

6.4 Advocacy Access

Participants are informed during onboarding (and on an ongoing basis) of their right to access independent advocacy at no cost.

Information about advocacy services is provided in accessible formats and includes Disability Advocacy Network Australia (DANA), People with Disability Australia, Family Advocacy (NSW), and the NDIS Commission complaint mechanism.

Together Two will never obstruct, discourage, or penalise a participant or family member for accessing independent advocacy or making an external complaint.

→ Advocacy Policy; Circles of Support Engagement Framework: Access to Advocacy section.

6.5 Complaints and Incident Reporting

Participants, families, workers, and any member of the public can make a complaint about any aspect of Together Two’s services. Complaints can be made in person, by phone (02 9556 9500), by email (hello@together2.org.au), or in writing.

Complaints can also be made directly to the NDIS Quality and Safeguards Commission by calling 1800 035 544, using the National Relay Service, or completing the online Complaint Contact Form at ndiscommission.gov.au.

All incidents, including near misses, are reported, recorded, investigated, and reviewed in accordance with the Incident Management Policy. Reportable incidents are notified to the NDIS Commission within 24 hours.

→ Complaint Management Policy; Incident Management Policy.

7. Communicating Rights to Participants

Rights that participants do not know about are not meaningful rights. Together Two communicates participant rights through:

Service agreements, which include a plain-language summary of participant rights, how to make a complaint, and how to access advocacy.

Easy Read materials, including the Circles of Support Easy Read document, which explains in accessible language how participants can have a voice, give feedback, and raise concerns.

Interpreting and translation services, arranged through TIS National or other reputable services for participants from CALD backgrounds. The cost of face-to-face interpreting for NDIS meetings can be billed to the NDIA.

Visual and augmentative communication supports for participants who use communication devices, picture boards, or alternative communication methods.

The Support Circuits AI portal, which provides family members and authorised circle members with ongoing visibility of their loved one’s supports, goals, and avenues for raising concerns.

Posters and information displayed at service delivery sites, including NDIS Commission contact details and advocacy service information.

8. NDIS Quality Indicators, Audit Reference

This policy addresses the following NDIS Practice Standards outcomes and quality indicators. This table is provided as a reference for internal audit and external audit preparation.

9. Related Documents

See the Related Documents register in the Policy Map. Key companions: Our Future: Community-Led Plan 2026–2029; Business and Operational Plan 2025–2028; Circles of Support Engagement Framework; Person-Centred Practice Policy; Decision Making and Consent Policy; Advocacy Policy; Abuse, Neglect and Exploitation Policy; Diversity and Inclusion Policy; NDIS Code of Conduct Policy; Child Safe Policy; Complaint Management Policy; Incident Management Policy; Privacy and Confidentiality Policy; Risk Register (Form 01); Skill and Competency Matrix; Circles of Support Easy Read.

10. Reporting Concerns About Participant Rights

If a participant, family member, worker, or any other person has a concern about the rights of a participant being breached or at risk, they should report it immediately. Concerns can be raised through any of the following pathways:

No person will ever face retribution, penalty, or reduction in services for raising a concern or making a complaint. This is a fundamental principle of Together Two’s commitment to participant rights.

11. Document Control