Overview

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We take your privacy seriously.

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Circle SC will respect the privacy, confidentiality, and dignity of all individuals that interact with. We understand that this is of key importance in establishing a trusting and transparent working relationship.

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Circle SC is bound by the Australian privacy principles under the Privacy Act (1988) and other relevant legislation relating to how National Disability Insurance Scheme (NDIS) service providers handle personal information. Circle SC collects and holds information to provide a safe working environment, deliver high-quality support and to meet obligations contained in funding and service agreements. Personal information may be used for quality improvement and accreditation purposes.

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What personal information do we collect?

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This policy outlines our commitment to complying with all applicable privacy laws which govern how we collect, use, store and disclose personal information (personal data) administered for the purposes of providing a safe working environment and a high standard of service delivery. Circle SC handles personal information in accordance with relevant legislation and disposal guidelines.

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The personal information we collect about you depends on the nature of your dealings with us or what you choose to share with us. The personal information we collect about you may include your:

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• Name.
• Date of birth.
• Address.
• Contact details.
• NDIS participant reference number.
• NDIS plan dates.
• NDIS supports.
• NDIS progress notes following each F2F support.
• Assessments, reports and other sensitive health information.  

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If we collect sensitive information, we will do so only with your consent, if it is necessary to prevent a serious and imminent threat to life or health, or as otherwise required or authorised by law, and we take appropriate measures to protect the security of this information.

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‍How do we collect your personal information?

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‍We collect your personal information directly from you when you:

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• Talk with us on the phone.
• Talk with us in person.
• Send an enquiry to us online.
• Participate in surveys or questionnaires.
• Attend a Circle Specialist Coordination event.
• Subscribe to our mailing list.
• Apply for a position with us as an employee, contractor or volunteer.
• If you or your providers complete forms with us or send us documents.

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The ‘Circle SC Privacy, Dignity and Consent Form’ stipulates who Circle SC may contact and for what purpose. Both you and us (Circle SC) sign this form, and it is uploaded to the Circle SC practice management database.

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Collecting personal information from third parties

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Circle SC follows the Privacy Act 1988: Australian Privacy Principle 1 - open and transparent management of personal information.

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Personal information may be used for quality improvement and accreditation purposes however this will be discussed prior to use to obtain consent.

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Circle SC will not collect personal information unless the information is necessary for service provision. We may also collect your personal information from third parties or through publicly available sources, for example from your other NDIS service providers. We collect your personal information from these third parties so that we can coordinate your supports effectively.

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How do we use your personal information?

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‍Circle SC will only use or disclose information to provide a safe working environment, improve service delivery, meet legal obligations or for quality improvement purposes. 

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We use personal information for many purposes in connection with our functions and activities, including the following purposes:

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• Provide you with information or services that you request from us.
• Deliver to you a more personalised experience and service offering.
• Improve the quality of the services we offer.
• Internal administrative purposes.
• Marketing and research purposes.
• Provide evidence to the National Disability Insurance Agency (NDIA) to support your NDIS plan reassessments.  

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Disclosure of personal information to third parties

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‍Circle SC will only ever release personal information if required by law or requested by the participant, their family/nominee/Guardian in relation to their own personal information. If the participant is 16 years of age or over, information will only be released with their consent including to family and support providers.

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Personal information may be shared with other agencies, services or health providers if the participant provides consent (written or verbal) that is voluntary and informed. When personal information is shared, it is shared securely. Personal information may be disclosed in connection with the performance of a duty or the exercise of a power or function in accordance with relevant legislation (such as emergency and disaster management as described in the NDIS Practice Standards). 

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We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:

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• Third party service providers (for example, your core, capacity building or capital providers).
• Our marketing providers.
• Our professional services advisors.  

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Transfer of personal information overseas

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‍Some of the third-party service providers we disclose personal information to may be based in or have servers located outside ofAustralia, including in New Zealand (Xero) and the United States of America (Microsoft, Zoom etc.).

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Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:

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• You have given us your consent to disclose personal information to that third party; or
• We reasonably believe that:
• The overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs ;and      
• The law or binding scheme can be enforced; or
• The disclosure is required or authorised by an Australian law or court / tribunal order. 

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How do we protect your personal information?

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Circle Specialist Coordination will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:

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• having robust cyber security of our databases / records.
• taking measures to restrict access to only personnel who need that personal information to effectively provide services to you.
• having technological security measures in place (for example, password protection and two factor-authentication).  

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Online Activity

Cookies

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The Circle Specialist Coordination website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website before, so we can distinguish you from other users of the website. This improves your experience and the Circle Specialist Coordination website.

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We do not use cookies to identify you, just to improve your experience on our website. If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and the functionality of our website may be affected.

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‍Website analytics

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Our website uses analytics services to help us better understand visitor traffic, so we can improve our services. Although this details mostly anonymous, it is possible that under certain circumstances, we may connect it to you.

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Direct marketing

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We may send you direct marketing communications and information about our services, opportunities, or events that we consider maybe of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth).

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You may opt-out of receiving marketing communications from us at any time by clicking ‘unsubscribe’ or by contacting us using the enquiry and referral forms on our website www.circlesc.com.au

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With your consent, we may also use your personal information or disclose your personal information to third parties for the purposes of advertising; including online behavioural advertising, website personalisation, and to provide targeted or retargeted advertising content to you (including through third party websites).

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Retention of personal information

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‍Personal information will be retained and disposed of in accordance with appropriate record keeping and disposal guidelines. 

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All reasonable steps are taken to ensure that information is complete, current, and accurate. Circle SC takes reasonable steps to ensure that information is protected from misuse, loss and unauthorised access.  

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We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example for record-keeping obligations.

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How to access and correct your personal information

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Circle Specialist Coordination will endeavour to keep your personal information accurate, complete and up to date.

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If you wish to make a request to access or correct the personal information we hold about you, you should make a request by contacting us and we will attempt to respond within 7 days. We will deal with such a request by following the procedure outlined below:

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• Exporting and downloading your individual NDIS participant information from our practice management software and sharing this with you.
• Making any necessary changes to ensure information is current and correct.   

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Links to third party sites

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Circle Specialist Coordination website may contain links to websites operated by third parties. If you access a third party website through our website, personal information may be collected by that third party website.We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website.

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Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies. For complaints about how Circle Specialist Coordination handles, processes or manages your personal information, please contact us at support@circlesc.com.au.

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We may require proof of your identity and full details of your request before we can process your complaint. Please allow up to 7 days for Circle Specialist Coordination to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with our response to a complaint, you have the right to contact the Office of the Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint.

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How to contact us

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‍Access to the full policy is available on request. If you have any questions about this policy or about how we use your personal data please contact us via support@circlesc.com.au.

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Participants and their authorised representatives have the right to request access to their personal records. All persons aged 18 years and above are assumed to have the capacity to provide informed consent unless evidenced otherwise.