Privacy Policy

TYPES OF INFORMATION

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.

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Sensitive information: is a subcategory 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.

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THE INFORMATION WE COLLECT

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

• your name;

• your contact details, including email address, mailing address, street address and/or telephone number;

• your age and/or date of birth;

• your credit card or payment details (through our third party payment processor);

• your preferences and/or opinions;

• information you provide to us through customer surveys;

• your occupation and employment details;

• your sensitive information as set out below;

• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  technical and usage data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of internet cookies or analytics) and communications with our website;

• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, 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.

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Sensitive information: The types of sensitive information we may collect about you include:

• drivers licence number;

• Medicare details;

• support needs;

• behaviour support information;

• health;

• disability;

• criminal history;

• safeguarding matters;

• ImmiCard; or

• Australian Passport.

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

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HOW WE COLLECT PERSONAL INFORMATION

We generally collect personal information directly from the client organisation, including through forms, email, telephone, video meetings, our website, client portals, file-sharing platforms, surveys, training sessions and in-person interactions.

We may also receive information from authorised representatives, employers, NDIS providers, auditors, professional advisers, contractors, public registers, government bodies or other third parties. If we receive unsolicited personal information, we will determine whether we could lawfully have collected it. If not, we will destroy or de-identify it where lawful and reasonable.

If you provide information about another person, you must have authority to do so and, where appropriate, tell that person about this policy. If you deal with us anonymously or using a pseudonym, we will accommodate this where lawful and practicable, although it may limit the Services we can provide.

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Passive collection

We may passively collect personal information, including where you interact with the content on our website, as well as information on your device or computer (such as cookies).

The sole purpose of passively collecting your information is to improve your experience when using our website and web services.

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Through a tracking code embedded on our website, the information collected includes:

Device-specific data

The following information may be collected through your device and browser:

• your device’s IP address (collected and stored in an anonymized format);
  device screen size;

• device type (unique device identifiers) and browser information;

• geographic location (country only); and

• preferred language used to display the webpage.

Log data

Our tracking software automatically record information which is created upon using our website. Data includes:

• referring domain;

• pages visited;

• geographic location (country only);

• preferred language used to display the webpage; and

• date and time when website pages were accessed.

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COLLECTION AND USE OF PERSONAL INFORMATION

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

• to provide our Services to you, including consulting services in relation to the NDIS registration and accreditation support and advice;

• to enable you to access and use our associated applications;

• to contact and communicate with you about our Services;

• for internal record keeping, administrative, invoicing and billing purposes;

• for analytics, market research and business development, including to operate and improve our Services, associated applications;

• for advertising and marketing, including to send you promotional information about our products and services and 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, when you have requested us to assist with NDIS registration and online portal set up;

• 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 another person and it is impracticable for us to obtain your consent; and

• if otherwise required or authorised by law.

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DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

Personal Information: We will only disclose personal information (excluding sensitive information) to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law. This means that we may disclose personal information (excluding sensitive information) to:

• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;

• other community members as part of our community platform;

• our employees, contractors and/or related entities;

• professional advisors, bankers, auditors, our insurers and insurance brokers;

• payment systems operators or processors;

• our existing or potential agents or business partners;

• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;

• 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 analytics providers and cookies; and

• any other third parties as required or permitted by law, such as where we receive a subpoena.

Sensitive Information: We will only disclose sensitive information with your consent or where permitted by law. This means that we may disclose sensitive information to:

• our employees, contractors and/or related entities;

• IT service providers, data storage, web-hosting and server providers; if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;

• 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 analytics providers and cookies;

• any other third parties as permitted by law, such as where we receive a subpoena.

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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 may contact the Office of the Australian Information Commissioner.

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CONSENT AND CAPACITY

Where consent is required, we seek consent that is informed, current, voluntary and specific to the relevant handling of information. Consent may be withdrawn, but withdrawal does not affect handling that has already occurred lawfully and may limit our ability to provide Services.

We recognise that some people may use a nominee, guardian, attorney, advocate, interpreter or other authorised representative. We will take reasonable steps to verify the representative’s authority and, wherever practicable, involve the individual and respect their communication preferences, decision-making ability and dignity.

 

ARTIFICAL INTELLIEGNCE (AI) AND AUTOMATED TOOLS

We may use approved technology-assisted tools to support drafting, summarisation, analysis, transcription or administration. We apply human oversight and do not rely solely on automated processing to make decisions that have a significant effect on an individual. We will not enter identifiable participant information, health information, government identifiers, portal credentials or other sensitive client material into a generative artificial-intelligence service unless the use is authorised, reasonably necessary, appropriately secured and consistent with the relevant contract, consent and law.

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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, 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.

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OVERSEAS DISCLOSURE

We store your personal information in Australia. Where we disclose your personal information to third parties, those third parties may store, transfer or access personal information outside of Australia, including but not limited to, Brunei, the Philippines and Pakistan. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

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DATA BREACHES

We maintain processes to identify, contain, assess and respond to suspected data breaches. Where the Notifiable Data Breaches scheme applies and an eligible data breach is likely to result in serious harm that cannot be prevented through remedial action, we will notify affected individuals and the Office of the Australian Information Commissioner as required. We may also notify clients, insurers, law-enforcement bodies, the NDIS Commission or other parties where required or appropriate.

Please report a suspected privacy or security incident immediately to hello@towellconsultancy.com or 0412 554 626.

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COOKIES

Our website may use essential, preference, analytics and marketing cookies or similar technologies. These tools may collect device, usage and interaction information. You can manage cookies through your browser and, where available, our cookie controls, although disabling essential cookies may affect website functions. Our website may link to third-party sites. Their privacy practices are governed by their own policies, not this policy.

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DIRECT MARKETING

We may use contact details to send information about our Services where permitted by law. You may opt out at any time using the unsubscribe facility in a message or by contacting us at hello@towellconsultancy.com. We will action opt-out requests within the period required by law. Service, security and account communications are not marketing and may still be sent where necessary.

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LINKS TO OTHER WEBSITES

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

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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.