Privacy Policy

1. Introduction

Equal Path Co. Pty Ltd (ABN 71 699 405 153), referred to as "Equal Path Co.", "we", "our", "us" in this document, is committed to protecting your privacy and handling your personal information in accordance with our legal obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and the secrecy provisions in the National Disability Insurance Scheme Act 2013 (Cth) (NDIS Act).

This Privacy Policy describes how Equal Path Co. collects, handles, uses and discloses your personal information as a registered-ready provider of NDIS supports across Australia.

We may update this Privacy Policy from time to time, including when our information-handling practices change. Updated versions take effect when published on our website.

Information about how we handle personal information relating to our employees and contractors is addressed in our separate Information Collection, Sharing and Privacy Policy.

2. What we collect

We may collect personal information about you when it is reasonably necessary for, or directly related to, delivering NDIS supports. We may collect sensitive information about you where you consent, where the collection is authorised or required by law, or where it is otherwise allowed under the Privacy Act.

The kinds of personal information we collect may include:

• identity information such as name, date of birth, gender and signature
• contact details and address
• NDIS participant number and plan information
• bank account or plan-manager details for invoicing
• communication preferences, including interpreter requirements
• records of communications and interactions with us
• information about family, nominees, guardians or authorised representatives
• background and circumstances relevant to your supports (e.g. living situation, employment, education)

The kinds of sensitive information we may collect include:

• health information such as disability or functional impairment, goals in your NDIS plan, support requirements, medical treatment and treating practitioners
• cultural or linguistic background
• criminal history (where relevant for safeguarding)

3. Why we collect personal information

We collect, hold, use and disclose your personal information to:

• assess your eligibility for and deliver NDIS supports that meet your goals
• match you with suitable support workers and coordinate rosters
• develop, review and update your support plan
• communicate with you, your nominees and other approved providers
• invoice the NDIA, plan managers or self-managed participants
• meet our legal, regulatory, NDIS Practice Standards and Quality and Safeguards obligations
• conduct internal operations including recruitment, worker screening, training, audits, complaints handling and quality improvement

4. How we collect information

We collect personal information when you provide it to us, for example when you:

• enquire about or request our services
• book a free consultation through our website, phone or email
• complete intake, consent or risk-assessment documents
• provide feedback or make a complaint
• participate in a survey or subscribe to communications

With your consent, we may also collect personal information from third parties such as your support coordinator, plan manager, the NDIA, disability support providers, treating professionals, family members or nominees, and our contracted service providers.

5. Online and digital interactions

When you visit our website we may collect technical information such as your server address, top-level domain name, the date and time of your visit, pages accessed, the previous site visited, your browser type, your email address (if you provide it), and any cookies your browser presents to our server. This information is used to improve our website and services, and to maintain the security and integrity of our systems.

Our website may contain links to third-party sites. The privacy practices of those sites are outside our control and are not covered by this Privacy Policy.

6. Use and disclosure of personal information

In addition to the Privacy Act and APPs, the NDIS Act contains secrecy provisions which restrict the purposes for which certain "protected information" may be used or disclosed. Unauthorised use or disclosure of protected information is an offence under section 62 of the NDIS Act.

We generally only use or disclose your personal information for the primary purpose for which it was collected, or for a related secondary purpose you would reasonably expect. We may disclose information to:

• your support workers and other Equal Path Co. staff involved in your care
• the NDIA and the NDIS Quality and Safeguards Commission
• your plan manager, support coordinator or nominee
• treating professionals and other providers involved in your supports
• our contracted service providers (e.g. IT, payroll, professional advisors), under arrangements that require them to protect your personal information

We may also use your personal information to seek feedback regarding your satisfaction with our services. You can opt out of marketing communications at any time by using the unsubscribe mechanism in the message or by contacting us.

Where possible, we will de-identify information before providing it to any third party outside Equal Path Co.

7. Storage and security

We store personal information in a range of hard-copy and electronic forms. All hard-copy records are held in Australia. Digital records are held in secure cloud storage on servers located in Australia, and Equal Path Co. retains effective control over any personal information held on those servers.

We take all reasonable and appropriate steps to protect personal information from misuse, loss, and unauthorised access, modification or disclosure, including through access controls, staff training, confidentiality obligations, and secure destruction of records once they are no longer required.

8. Accessing and correcting your personal information

You may request access to, or correction of, the personal information we hold about you. We may need to verify your identity before processing your request. We will respond to requests within 30 days. If a request is refused, we will provide you with reasons for the decision and information about how to complain.

9. Privacy complaints

If you have a concern about how we have handled your personal information, please contact us first so we can try to resolve it. We comply with the Privacy Act in handling privacy breaches and will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) of serious data breaches where appropriate.

If you are not satisfied with our response, you can contact the OAIC at oaic.gov.au.

10. Contact us

For general enquiries, requests to access or correct your personal information, or to make a privacy complaint, please contact:

Britt Rener — Founder & Managing Director, Equal Path Co.
Phone: 0434 406 011
Email: britt@equalpathco.com.au

If you need assistance contacting us through the National Relay Service (a service provided by the Australian Government to assist people who are Deaf or have a hearing or speech impairment), call 1800 555 677 then ask for our number above.