What is personal information?
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
What personal information do we collect?
We may collect the following types of personal information:
- your name, date of birth, mailing or street address, email address, personal or work telephone number, and other contact details;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- your financial information and payment details;
- any information that you provide to us when making an enquiry through our website;
- any information that you provide to us when requesting an appointment in person, by telephone or via our website;
- details of the services we have provided to you or that you have enquired about, including any additional information necessary to deliver those services and respond to your enquiries;
- any additional information relating to you that you provide to us directly or indirectly in person, by telephone or via our website;
- personal information which is sensitive information including: your racial or ethnic origin; religious beliefs or affiliations; philosophical beliefs; sexual orientation or practices; and health information including genetic information (including the health information contained in your plans prepared from time to time pursuant to the National Disability Insurance Scheme (NDIS)); and/or
- any other personal information that may be required in order to facilitate your dealings with us.
How do we collect your personal information?
We may collect these types of personal information directly from you when you:
- use our website;
- enquire about or receive services or supports from us;
- communicate with us in person, by telephone, by correspondence (e.g. letters, email, facsimile), via social networking sites (e.g. Facebook), or via our website;
- when you share information with us from other social applications, services or websites; or
- interact with our sites, services, content, advertising, and marketing campaigns.
We may also receive your personal information indirectly from the following sources:
- your family members, guardians or other legally authorised representatives;
- our contracted service providers;
- your carer, attorney or guardian or other persons responsible for your healthcare decisions;
- your GP and other medical and healthcare professionals involved in your care;
- the NDIS and any other government agencies which administer subsidies and benefits relevant to our services;
- your NDIS support coordinator; and
- any person who makes an enquiry or referral through our website on your behalf.
Why do we collect, hold, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to provide supports and services to you;
- to provide appropriate information and opinions about your care needs and our supports and services to you;
- to operate, protect, improve and optimise our website, services and user-experience – such as to perform research and analytics;
- for advertising and marketing purposes;
- to send you marketing and promotional messages, and other information that may be of interest to you;
- to provide information to our professional advisors, contractors, service providers and other personnel for the purpose of us providing our services to you;
- to provide information to overseas entities in order to provide our services and for administrative, data storage or other business management purposes;
- to provide information to a hospital or aged care facility if you are referred for respite or higher levels of care;
- to provide information to a third party support provider in circumstances where you decide to engage a different organisation or NDIS provider unrelated to us;
- to provide information credit reporting agencies and courts, tribunals and regulatory authorities if you fail to pay for the services and supports we have provided;
- to provide information to courts, tribunals, regulatory authorities, and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- to comply with our legal obligations (including under the National Disability Insurance Scheme Act 2013 (Cth) and its associated Rules);
- to resolve any disputes with or in relation to you; and
- to enforce our agreements with third parties.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
When no longer required by us, unless required by law to retain it, we will take reasonable steps to destroy or de-identify your personal information securely.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about us and our services. This may take the form of emails, SMS, mail or other forms of communication. You may opt-out of receiving marketing communications and information from us by contacting us at email@example.com or by using the opt-out facilities provided (eg an unsubscribe link).
To whom do we disclose your personal information?
- your family members;
- your carer, guardian, legally authorised representative or other persons responsible for your healthcare decisions;
- your GP and other medical and healthcare professionals involved in your care;
- the NDIS and any other government agencies responsible for administering entitlements and benefits relevant to our services;
- your NDIS support coordinator;
- if you receive services and/or supports from third parties – those third parties to the extent reasonably required to coordinate service delivery or as otherwise required at law;
- if you transition to another service provider – that third party service provider to facilitate their provision of your services and supports;
- third party suppliers, including cloud-based storage solution service providers and other service providers that we rely on to operate our website and otherwise provide our services;
- third party payment service providers that we rely on to process your payments to us;
- our employees, contractors, and other personnel;
- our professional advisers;
- our existing or potential agents, business partners or partners;
- anyone to whom our assets or business (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us – e.g. your GP and other medical and healthcare professionals; and/or other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure and transfer of personal information outside Australia
We may disclose personal information outside of Australia to third party suppliers of cloud-based storage located in the USA with head offices located in the USA and which may have server locations in other overseas locations. We may also disclose personal information to overseas companies which provide us with administration services with offices located in India, Malaysia, Europe, the Philippines and the USA. We may also disclose personal information to our contractors located in the USA. We may disclose your personal information to entities who may store or process your data overseas.
These countries may not provide the same level of protection as the privacy laws of Australia. When you provide your personal information to us, you consent to the disclosure and/or transfer of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act. We take reasonable steps to ensure that overseas recipients deal with your personal information in a way that is consistent with the Privacy Act (including the Australian Privacy Principles). Third parties located overseas are not permitted to access or use your personal information except for these limited purposes and we only choose reputable service providers.
Using our website and cookies
We may collect personal information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’; or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies, but our website may not work as intended for you if you do so.
We may also use the Google Ads service to enable remarketing services, and Google UserID, demographic and interest reports. Information about you regarding your web usage behaviour is held by Google. Information from Google’s UserID service may be connected to other data that we hold about you.
We may also use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms which can be viewed here: https://www.facebook.com/customaudiences/app/tos/?ref=u2u.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and accidental loss, as well as unauthorised access, use, destruction, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. In particular:
- personal information is backed up to a secure cloud based server;
- our secure server is protected by anti-malware software;
- access to our information systems is controlled through identity and access management, including password protection on our company laptops; and
- we require contractors that might have access to your personal information to enter into a binding legal contract requiring them to keep that information confidential.
However, we cannot guarantee the security of your personal information.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the below contact information. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We reserve the right to charge a reasonable fee for searching for, and providing access to, your information on a per-request basis. We may also need to verify your identity when you request your personal information.
If you think that any of the personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the below contact information and we will take reasonable steps to ensure that it is corrected.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us about your complaint using the below contact information. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, please let us know and we will provide you with information about the further steps you can take.
By mail: Privacy Officer
Innvue Consulting Pty Ltd t/as Upscale Care
By email: firstname.lastname@example.org
Effective date: [15 March 2021].