PRIVACY POLICY
For Disability Pathway Solutions
A. Disability Pathway Solution’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, Disability Pathway Solutions abides by the obligations imposed under federal law, inclusive of the Privacy Act 1988 (Cth) and the National Disability Insurance Scheme Act 2013 (Cth).
B. 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 Disability Pathway Solutions collect and use personal information and when and to whom this information can be disclosed.
1. Information collected and stored
a. Disability Pathway Solutions will collect information that is considered reasonably necessary to carry out our role as service providers. The kinds of information we collect and store include, but are 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.
b. We may collect the following types of personal information:
I. identity information, such as your full name and date of birth;
II. contact details, such as your email and phone number;
III. government identifiers, such as your participant number under the National Disability Insurance Scheme (NDIS) if applicable;
IV. the relevant NDIS Plan information when provided;
V. any information or documents that you upload to the Disability Pathway Solutions platform;
VI. information about your interactions with us on or via the Disability Pathway Solutions platform;
VII. information you provide via free text inputs on or via the Disability Pathway Solutions platform;
VIII. your occupation;
IX. your preferences;
X. your relationship to other users of Disability Pathway Solutions;
XI. information about you, which is held by third parties, where you have;
XII. Provide your separate consent to such collection, such as information that is or was held by the National Disability Insurance Agency; and
XIII. other personal information that may be required in order to facilitate your dealings with us.
2. Sensitive information
a. 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”.
b. Without your consent, we will not collect 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.
3. Purposes of information collection and storage
a. Where an individual has provided consent, Disability Pathway Solutions will use and disclose the personal information we collect to:
I. provide and improve our services to our clients and their family members;
II. process donations and communicate with our donors and supporters, including sending them information (which may be by phone, email, or other electronic means);
III. 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
IV. 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.
b. We will not share any of your personal information with third parties without your consent except:
(i) if we are required by law or 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;
(ii) the disclosure of the information will prevent or lessen a serious and imminent threat to somebody's life or health;
(iii) to our contractors, service providers and volunteers only to the extent necessary for them to perform their duties to us.
c. 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.
4. Processes for collecting and storing information
a. Disability Pathway Solutions 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:
I. paper-based records which are held securely;
II. access to personal information is on a need-to-know basis, by authorised personnel; and
III. storage and data systems are regularly updated and audited.
b. When no longer required, personal information is either archived or destroyed in accordance with federal law.
5. Accessing and correcting your personal information
a) Disability Pathway Solutions 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 Disability Pathway Solutions holds about them is inaccurate, outdated, incomplete, irrelevant, or misleading that person can contact Disability Pathway Solutions through the methods detailed in Section 7 so that the information can be updated accordingly.
b) Where a person requests Disability Pathway Solutions 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 to which we have previously disclosed the personal information.
c) 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.
6. Making a complaint
a) You may make a complaint about our handling of your personal information, including if you think we have breached the Privacy Act, by contacting Disability Pathway Solutions in writing via email. The contact information is set out at the end of this privacy policy.
b) Disability Pathway Solutions will aim to resolve your complaint within seven (7) 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.
7. Contact information
If you would like to leave feedback or complain about the service you have received from us or feel that we have breached your privacy obligations, please Contact Us.
If you want to obtain additional information on your privacy rights and how you can enforce them, please visit the website of the Office of the Australian Information Commissioner at:
Australian Government Office of the Australian Information Commissioner
