Background

EduLinked Pty Ltd'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, EduLinked Pty Ltd abides by the obligations imposed under federal law, inclusive of the Privacy Act 1988 (Cth) and the National Disability Insurance Scheme Act 2013 (Cth).

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 EduLinked Pty Ltd collect and use personal information and when and to whom this information can be disclosed.

Information collected and stored

EduLinked Pty Ltd 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.

We may collect the following types of personal information:

• Identity information, such as your full name and date of birth
• Contact details, such as your email and phone number
• Government identifiers, such as your participant number under the National Disability Insurance Scheme (NDIS) if applicable
• The relevant NDIS Plan information when provided
• Any information or documents which you upload to the EduLinked Pty Ltd platform
• Information about your interactions with us on or via the EduLinked Pty Ltd platform
• Information you provide via free text inputs on or via the EduLinked Pty Ltd platform
• Your occupation
• Your preferences
• Your relationship to other users of EduLinked Pty Ltd
• 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
• Other personal information that may be required in order to facilitate your dealings with us
• Financial information, such as your bank account details or credit card information, when necessary for processing payments or reimbursements

Health information

EduLinked Pty Ltd 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.

Health information will be collected only with your explicit consent for identified purposes directly related to service delivery, stored securely separate from general personal information, and subject to restrictions on secondary use. We will comply with mandatory reporting obligations under disability services legislation and will notify you of any such reports where legally permissible, respecting your right to access and control your health information in accordance with NDIS Quality and Safeguards Commission standards.

Sensitive information

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".

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.

Purposes of information collection and storage

Where an individual has provided consent, EduLinked Pty Ltd will use and disclose the personal information we collect to:

• Provide and improve our services to our clients and their family members
• Process donations and communicate with our donors and supporters, including sending them information (which may be by phone, email or other electronic means)
• Communicate 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
• Conduct 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
• Obtain, document and manage consent for each purpose category through separate opt-in mechanisms, maintain audit trails of consent decisions, and process consent withdrawal requests promptly, ensuring that refusal or withdrawal of consent for marketing or fundraising activities does not affect service delivery under the NDIS Act 2013 (Cth)

Sharing of information

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

• 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
• The disclosure of the information will prevent or lessen a serious and imminent threat to somebody's life or health
• To our contractors, service providers and volunteers only to the extent necessary for them to perform their duties to us, and where we have entered into written data processing agreements that impose equivalent confidentiality obligations, specify permitted uses of personal information, require compliance with applicable privacy and data security standards, and include breach notification requirements
• In the event of a merger, acquisition, or sale of all or a portion of our assets, in which case personal information held by us about our customers will be among the assets transferred to the new owner

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.

Website data and analytics

Like many websites, EduLinked may collect anonymous data about how visitors use the site. This information helps improve the website and user experience.

Security and data protection

EduLinked Pty Ltd 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:

• Paper-based records which are held securely
• Access to personal information is on a need-to-know basis, by authorised personnel
• Storage and data systems are regularly updated and audited
• Use of encryption technologies to protect personal information during transmission and storage
• Multi-factor authentication and role-based access controls are implemented for all systems containing personal information

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

Data retention

Personal information retention schedules specify that:

• NDIS plan information is retained for the duration of the plan plus 7 years
• Health information is retained in accordance with disability services standards
• Financial records are retained per taxation law requirements
• All records are destroyed using secure deletion methods or certified destruction processes, with destruction certificates maintained for audit purposes

Accessing and correcting your personal information

EduLinked Pty Ltd 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 EduLinked Pty Ltd holds about them is inaccurate, outdated, incomplete, irrelevant or misleading, that person can contact EduLinked Pty Ltd so that the information can be updated accordingly.

Where a person requests EduLinked Pty Ltd 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 to.

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.

We will respond to your request to access or correct your personal information within 30 days of receiving your request. If we require more time to respond, we will notify you and explain the reasons for the delay.

Links to third party websites

Our website www.edulinked.com.au 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). EduLinked Pty Ltd 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.

Making a complaint

You may make a complaint about our handling of your personal information, including if you think we have breached the Privacy Act, by contacting EduLinked Pty Ltd in writing, by email, mail or fax using the contact information set out below.

EduLinked Pty Ltd will aim to resolve your complaint within twenty-one (21) 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.

If you are not satisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling 1300 363 992.

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.

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 www.oaic.gov.au.