Freedom Social Skills Pty Ltd ABN 13 634 845 462 (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our individual and group behavioural support services online or in-person to your dependent (Services) or when otherwise interacting with you, in accordance with the requirements of the Privacy Act 1988 (Cth), including the Australian Privacy Principles.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• you and your dependent’s name;
• images of you or your dependant, where you have consented to these images being taken;
• the National Disability Insurance Scheme (NDIS) reference number of your dependent;
• your contact details, including email address, street address and/or telephone number;
• you or dependent’s date of birth;
• your payment details;
• information you provide to us, including through feedback, customer surveys or otherwise;
• you or your dependent’s sensitive information as set out below;
• details of services we have provided to you and/or that you have enquired about, and our response to you;
• support requests submitted to us and our response to you;
• where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience;
• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

The types of sensitive information we may collect about you or your dependent who is receiving the benefit of our Services include:

• the NDIS plans of your dependent (and any other support plan you provide us with);
• diagnoses of any disorders or illnesses; and
• any therapies, treatments or medications that they are currently receiving or have received.

Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register for our Services, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as from the NDIS, your doctors and other service providers, your family members or significant others, and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies. We may also receive information from third parties who you have consented to share your confidential information with us, such as health practitioners and schools or other education providers.

Why we collect, hold, use and disclose personal information

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

• to enable you and your dependent to access and use our Services;
• To safely provide our Services to you, including to ensure we are equipped appropriately to provide the Services;
• to contact and communicate with you about our Services, including in response to any support you request from us;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Services;
• for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have;
• if you have applied for employment with us; to consider your employment application; and
• if otherwise required or authorised by law.

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

• any purposes you consent to;
• the primary purpose for which it is collected, which is to ensure that we can safely provide the Services with the appropriate equipment and tools to keep each recipient of our Services safe;
• secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you;
• to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or your dependent and it is impracticable for us to obtain your consent; and
• if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We may disclose personal information to:

• the National Disability Insurance Agency (NDIA), for the purposes of billing, auditing, plan management and progress reporting;
• the NDIS Commission, if compelled as part of an investigation;
• a person you have nominated as an advocate (such as an NDIS Plan Manager) or nominated to be contacted in case of an emergency;
• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) our IT service providers, data storage, web-hosting and server providers, email marketing providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators. These currently include:
  • Xero
  • Active Campaign
  • Class Dojo
  • CareMaster
  • Rethink; and
  • Minecraft;
• our employees, contractors and/or related entities, including contractors and service providers who assist us to provide the Services;
• our existing or potential agents or business partners;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as Facebook Pixel or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia.

Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you.  An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, including written internal policies, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Freedom Social Skills Pty Ltd ABN 13 634 845 462

[email protected]

Last update: 29 November 2022

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