NDIS
Privacy Policy

SpotOnCare Pty Ltd is committed to protecting the privacy of an individual’s personal information. The following sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us, and the way we collect, use and disclose your personal information.

In handling your personal information, we will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the thirteen Australian Privacy Principles in the Privacy Act.

We have policies and procedures in place to ensure that:

• personal information is managed in an open and transparent way
• the privacy of personal information of participants and staff are protected
• we collect and handle personal information fairly
• personal information we collect is used and disclosed for legally permitted purposes only
• we regulate access to and correction of personal information
• we maintain the confidentiality of personal information through appropriate storage and security.

The kinds of information we collect

Consumer personal information is collected to provide care and services. Personal information we collect could include your:

• name, address, telephone number and email address
• date of birth
• gender
• advocate or emergency contact’s telephone number and email
• health information
• diversity status (ethnicity, lifestyle preferences).

How we collect personal information

Participant personal information may be collected from:

• you, the participant
• your family members or significant others
• your advocate
• your doctor or other service providers or facilities.

We will collect personal information directly from you unless:

• we have your consent to collect the information from someone else
• we are required or authorised by law to collect the information from someone else
• it is unreasonable or impractical to do so.

You can withdraw your consent at any time by contacting us; although you should be advised that this may impact on our capacity to provide services.

Purpose of collecting personal information

Personal information is collected for the purposes of providing care and services. The information may be used to:

• provide support services
• enable service providers and medical practitioners to provide care and services

Disclosure of personal information

We may disclose your personal and health information, for the purpose of your care and services, to:

• service providers who assist us in providing care and services, medical practitioners, external health agencies such as the ambulance service, hospitals, the National Disability Insurance Scheme, and other relevant government organisations
• a person you have nominated as being your advocate, e.g. parent, child or sibling, spouse, a relative, a member of your household, a guardian, an enduring power of attorney, or a person you have nominated to be contacted in case of emergency, provided they are at least 18 years of age.

We may not use or disclose personal information for a purpose other than providing care and services, unless:

• you have consented
• the purpose is related to providing care and services, and you would reasonably expect disclosure of the information for that purpose.
• we believe on reasonable grounds that the disclosure is necessary to prevent or lessen a serious and imminent threat to your life, health or safety or a serious threat to public health or public safety
• we have reason to suspect unlawful activity and disclosure is required or authorised by law.

We will not disclose your personal information to an overseas recipient.

Security of personal information

We take all reasonable steps to ensure that the personal information we hold is protected against misuse, loss, unauthorised access, modification or disclosure. We hold personal information in both hard copy and electronic forms in secure databases on secure premises and on secure, cloud-based technology, accessible only by our authorised staff.

Accessing the personal information that we hold about you

Under the Privacy Act, you have a right to access your personal information that is collected and held by us. If at any time you would like to access or change the personal information that we hold about you, or you would like more information on our approach to privacy, please contact us.

To obtain access to your personal information, you will have to provide us with proof of identity. We will take all reasonable steps to provide access to your personal information within seven (7) days from your request.

Employee information

Records of current and past employees which are related to the employment relationship are managed in accordance with workplace laws. Privacy laws may apply to employee personal information if the information is used for something that is not related to the employment relationship between our organisation and the employee.

Volunteer records

Personal information collected and held by us in relation to our volunteers will be managed in accordance with the Privacy Act.

Privacy data breaches

In the event that your personal information is lost, stolen or subject to unauthorised access or disclosure, we will implement our Management of Data Breach Policy and Procedure.

Privacy complaints

All complaints regarding privacy can be lodged via our complaint handling process.

At all times, privacy complaints will:

• be treated seriously
• be dealt with as promptly as possible
• be dealt with in a confidential manner
• not affect your existing obligations or affect the commercial arrangements between you and us.

You will be informed of the outcome of your complaint following completion of the investigation.

1. 1. Background

       

      1. SpotOnCare’s policy is to respect and protect the privacy of all people connected with the National Disability Insurance Scheme (NDIS) inclusive of participants, providers, employees and contractors. In dealing with personal information, SpotOnCare abides by the obligations imposed under federal law, inclusive of the Privacy Act 1988 (Cth) and the National Disability Insurance Scheme Act 2013 (Cth).

      2. The Privacy Act 1988 (Cth) authorises the collection of personal information where this is required to facilitate access to services provided under the NDIS and perform the other functions required for service provision. The National Disability Insurance Scheme Act 2013 (Cth) sets the provisions for confidentiality and secrecy which limit how SpotOnCare collect and use personal information and when and to whom this information can be disclosed.

       
       

      Information collected and stored

      1. 1. SpotOnCare will collect information which is considered reasonably necessary to carry out our role as service providers. The kinds of information we collect and store includes, but is not limited to, personal information (as defined under the Privacy Act 1988 (Cth)) about the participants and other users of our services, and about our employees, contractors and providers.

         2. We may collect the following types of personal information:

            1. identity information, such as your full name and date of birth;

            2. contact details, such as your email and phone number;

            3. government identifiers, such as your participant number under the National Disability Insurance Scheme (NDIS) if applicable;

            4. the relevant NDIS Plan information when provided;

            5. any information or documents which you upload to the SpotOnCare platform;

            6. information about your interactions with us on or via the SpotOnCare platform;

            7. information you provide via free text inputs on or via the SpotOnCare platform;

            8. your occupation;

            9. your preferences;

            10. your relationship to other users of SpotOnCare;

            11. information about you, which is held by third parties, where you have provided your separate consent to such collection, such as information that is or was held by the National Disability Insurance Agency; and

            12. other personal information that may be required in order to facilitate your dealings with us; and.

            13. Any information collected through the Participant Intake Form.

         3. SpotOnCare may also collect ‘health information’ as defined under the Privacy Act 1998 (Cth), such as information about your health or disability, doctors or other health professionals you have seen or health services you have received.

       

      Sensitive information

      1. 1. Sensitive information is defined under the Privacy Act 1988 (Cth) as “Information or an opinion about an individual’s: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record; or health information”.

         2. Without your consent, we will not collect information sensitive information. Sensitive information will only be collected if it is specifically required for operational purposes. This is subject to certain exceptions such as when collection is required by law, or when the information is necessary for the establishment, exercise or defense of a legal claim.

       

      1. Purposes of information collection and storage

         1. Where an individual has provided consent, SpotOnCare will use and disclose the personal information we collect to:

            1. provide and improve our services to our clients and their family members;

            2. process donations and communicate with our donors and supporters, including sending them information (which may be by phone, email or other electronic means);

            3. communicating with our clients and their family members, donors and supporters, and volunteers (including responding to queries and complaints) and distributing our publications, conducting events and raising awareness about our services; and

            4. our general business activities, including interacting with contractors and service providers, billing and administration including measuring and assessing the level of support we receive and the effectiveness of our fundraising activities and assessing applicants for positions with us.; and

         2. We will not share any of your personal information with third parties without your consent except:

            1. if we are required by law or we believe in good faith that such action is necessary in order to comply with law, cooperate with law enforcement or other government agencies, or comply with a legal process served on the company (including other service providers or insurers) or court order;

            2. the disclosure of the information will prevent or lessen a serious and imminent threat to somebody’s life or health;

            3. to our contractors, service providers and volunteers only to the extent necessary for them to perform their duties to us.

         3. We are obliged to report to the Australian government and other bodies on the services they fund us to provide. Reports cover demographic and service use information only.
            
            

      2. Processes for collecting and storing information

         1. SpotOnCare has systems and procedures in place to protect personal information from misuse and loss, as well as from unauthorised access, modification or disclosure. These steps include:

            1. paper-based records which are held securely;

            2. access to personal information is on a need-to-know basis, by authorised personnel; and

            3. storage and data systems are regularly updated and audited; and.

            4. Cloud-Enabled storage within the organisation. These data are held through a specified data centre which may be inside and outside of Australia..

         2. When no longer required, personal information is either archived or destroyed in accordance with federal law.
            
            

      3. Accessing and correcting your personal information

         1. SpotOnCare aims to ensure that all personal information held about a person is accurate, up to date, complete and relevant before acting on it. If a person learns that the personal information that SpotOnCare holds about them is inaccurate, outdated, incomplete, irrelevant or misleading that person can contact SpotOnCare through the methods detailed in Section 9Section 8Section 8Section 7 so that the information can be updated accordingly.

         2. Where a person requests SpotOnCare to correct the personal information we hold about them, we will action this request promptly. A person can request that we notify this change to any other agencies or organisations that we have previously disclosed the personal information too.

         3. If we do not agree to correct our records as requested, we will give written notice of the decision, setting out our reasons for refusing this request and how the person can lodge a complaint about our decision.
            
            

      4. Links to Third Party Websites

         Our website http://spotoncare.com.auu contains external links and widgets operated by certain third parties such as Facebook, Twitter, Instagram and Google. These third parties may not be subject to the Privacy Act 1988 (Cth). SpotOnCare is not responsible for the privacy practices of these third parties, or the accuracy, content and security of their websites. You should review the Privacy Policies of these individual websites and use your discretion regarding the use of their site.
         
         

      5. Making a complaint

         1. You may make a complaint about our handling of your personal information, including if you think we have breached the Privacy Act, by contacting SpotOnCare in writing, by email, mail or fax to the contact information set out at the end of this privacy policy.

         2. SpotOnCare will aim to resolve your complaint within 30 days from when your request was made. If we are not able to resolve your complaint, you may wish to contact the Office of the Australian Information Commissioner at the details set out below.
            
            

      6. Contact information

         If you would like to leave feedback or complain about the service you have received from us or you feel that we have breached your privacy obligations, please contact us through any of the following methods.
         
         

         Phone: +61473961701

         Email: info@spotoncare.com.au

         Postal Address: 7 Garden Grove, Seaholme, Victoria, 3018
         
         

         If you want to obtain additional information on your privacy rights and how you can enforce them, you can visit the website of the Office of the Australian Information Commissioner at: http://www.privacy.gov.au or http://www.oaic.gov.au/