Privacy Policy

1. Your privacy is important.

This document sets out how we protect your privacy and manage your personal information. It applies to all people who deal with us, other than our employees.

We may change or update our Privacy Policy from time to time. We encourage you to visit our website regularly so that you are familiar with the most recent version. Any updates or changes will apply from the time they are posted on our website at thrive365.com.au.

2. Some useful definitions

In this Privacy Policy:

Consent
Means your permission. Your consent can be express or implied. Express consent can be written (eg, when you sign a form) or verbal (eg, when you give us your permission over the phone or in a face to face conversation). Your consent will be implied where we can reasonably form a conclusion that you have given consent by taking action or deciding not to take action.

Person we support
Means a person who is currently receiving or has previously received services from us or has made inquiries to us about receiving services from us.

Personal Information
Means information about you, where your identity is clear or identifiable from the information (for example, your name, address, phone number, date of birth). It does not include de-identified information (for example, information about the number of people using a service that you use, where your identity is not disclosed or otherwise identifiable).

Sensitive Information
Is a category of personal information and includes your health or medical information.

We or us
Means Thrive365 Pty Ltd ABN 84622661723 and any related companies.

3 – Collection of your personal information

3.1 What kind of personal information do we collect and hold?

The amount and type of personal information we collect from you and hold about you will vary depending on how you deal with us.

If you are a person we support or are connected to a person we support (eg, family member, carer, advocate or nominated representative), the personal information that we hold about you may include:

your name, address, telephone and email contact details
your gender, date of birth and marital status
information about your disability and support needs (see section 3.2 below)
health and medical information (see section 3.2 below)
your Medicare number and other identifiers used by Government agencies or other organisations to identify you
financial information
records of our interactions with you such as system notes and records of conversations you have had with our employees
information about the services you are funded to receive, whether under the National Disability Insurance Scheme or otherwise
information about the services we provide to you including details of the outcomes or goals we are working with you to achieve, and other plans relating to the services you have asked for and the way in which we will deliver those to you
your billing details

If you are a job applicant or volunteer, the personal information we hold about you may include:

your name, address, telephone and email contact details
your gender, date of birth and marital status
your tax file number and other identifiers used by Government agencies or other organisations to identify you
information about your qualifications, training and work history
information from police checks, working with children checks (or similar), and information about your right to work in Australia
records relating to your volunteer work with us

If you are connected with us through our marketing or community access activities, the personal information we hold about you may include:

your name, address, telephone and email contact details
events and activities you have participated in
publications and services you have received from us

If you use our websites, the personal information we hold about you may include:

your name, address, telephone and email contact details
any details you provide to us through your use of the website – for example, if you register to be on our mailing list or use the website to send us messages or comments
any details you provide to us as part of a payment or donation process via the website

If you do not fall into one of these categories, we generally do not hold information about you.

3.2 Do you collect sensitive information?

We understand that protecting your privacy in relation to health and sensitive information is particularly important.

To provide our services or to respond to inquiries about our services, we may be required to collect and hold your sensitive information including health and medical information and information relating to your disability and support requirements.

We will limit the collection of sensitive information to the minimum amount required in the circumstances.

3.3 How do we collect personal information?

We may collect personal information from you in a range of ways including:

when you inquire about services or supports
when you apply to receive services or supports from us
when you contact us in person, by phone, via mail, email or online (or when we contact you through any means)
when you receive services and supports from us
through our direct marketing activities
through our contracted service providers

Where possible, we will collect your personal information directly from you or your nominated representatives. However, there may be circumstances in which we need to collect your information from other people or organisations. For example, if you are receiving funding for your Thrive365 supports, we may collect information about you from the funding agency.

If you have provided us with information about another person, then you need to tell that other person that you have done so, that they have a right to access their information and that they can refer to the Privacy Policy for information on how Thrive365 will handle their personal information.

3.4 If you do not provide us with your personal information

If you do not provide us with the personal information we reasonably request, we may be unable to provide you with the information, services or supports that you are requesting.

4 – Use of your personal information

4.1 How does Thrive365 use your personal information?

The purposes for which we use your information depends on how you deal with our organisation.

If you are a person we support or are connected to a person we support (eg, family member, advocate or nominated representative), we may use your information to:

Provide you with information about our services and supports
Administer our services and supports
Process payments
Answer your inquiries and deliver customer service to you
Conduct quality assurance activities
Carry out internal functions including administration, training, accounting, audit and information technology
Resolve complaints
Comply with laws and regulations and to report to funding and government agencies
Send you information about our organisation, services and supports
Send you information about our events, community activities, research, fundraising appeals and donor activities
Conduct surveys, research and analysis
Invite you to participate in research projects and activities
Encourage further involvement with Thrive365, to seek and process donations, and for direct marketing and telemarketing

Also, information collected about you that does not identify you may be used for research, evaluation of services, quality assurance activities, and education. If you do not wish for your de-identified data to be used this way, please contact us. Our contact details are at the end of this Privacy Policy.

If you are a job applicant or volunteer, we may use your information:

To process your job or volunteering application and to manage your activities with us
Carry out internal functions including administration, training, accounting, audit and information technology
Resolve complaints
Comply with laws and regulations and to report to funding and government agencies
Send you information about our organisation, services and supports
Send you information about other work or volunteering opportunities
Send you information about our events, community activities, research, fundraising appeals and donor activities
Conduct surveys, research and analysis
Invite you to participate in research projects and activities
Encourage further involvement with Thrive365, to seek and process donations, and for direct marketing and telemarketing

If you are connected with us through our marketing or community access activities we may use your information to:

Manage our relationship with you including (if applicable) to provide services to you
Answer your inquiries
Conduct quality assurance activities
Carry out internal functions including administration, training, accounting, audit and information technology
Resolve complaints
Comply with laws and regulations and to report to applicable government agencies
Send you information about our organisation, services and supports
Send you information about our events, community activities and research
Conduct surveys, research and analysis
Invite you to participate in research projects and activities
Encourage further involvement with Thrive365, to seek and process donations, and for direct marketing and telemarketing

If you use our websites we may use your information to:

Personalise your website visit or to enable remarketing website functionality
Answer your inquiries
Process donations and payments
Provide you with the goods and services you have asked us for
Resolve complaints
Conduct research, market research and analysis

We may use your personal information for the purposes we collect it for. We may also use it for purposes related to (or in the case of health or sensitive information, directly related to) the purpose of collection where you would reasonably expect us to.

4.2 Direct marketing, supporter communications, and invitations to participate in research

Where we use your personal information to send you marketing material, supporter communications, and invitations to participate in research by post, email or telephone, we will provide you with an opportunity to opt-out of receiving such information. By electing not to opt-out, we will assume we have your consent to receive similar information and communications in the future. We will always ensure that our opt-out notices are clear, conspicuous and easy to activate.

If you do not wish to receive direct marketing communications or research invitations from us, please contact us. Our contact details are at the end of this Privacy Policy.

4.3 Who does Thrive365 disclose your personal information to?

In order to operate an efficient and sustainable organisation and to enable us to carry out our activities and provide our services and supports, we may be required to disclose your personal information to third parties. This may include disclosure in the following circumstances:

Related and affiliated companies and organisations including joint venture partners and industry affiliate organisations.
People engaged by us or acting on our behalf in relation to our business, such as our service providers/suppliers. Suppliers are required to handle your personal information in accordance with this Privacy Policy.
Government and regulatory bodies, including the National Disability Insurance Agency, Medicare, the Department of Social Services, the Department of Health & Human Services, and the Australian Taxation Office.
People acting on your behalf including your nominated representatives, legal guardians, executors, trustees and legal representatives.
Lawyers, auditors, banks and other advisors appointed by us or acting on our behalf.
Where disclosure is required by law, including where required to the police, or to the Disability Services Commissioner, or to comply with compulsory notices from courts of law, tribunals or government agencies.

We take reasonable steps to make sure that these organisations will protect the privacy of your personal information, in accordance with this Privacy Policy.

We will not sell your personal information.

4.4 Will my personal information be transferred offshore?

Our technology infrastructure may make use of cloud infrastructure or servers located outside Australia. Apart from this, we do not typically transfer personal information offshore. By providing your personal information to us or using our services and supports, you are taken to have consented to this transfer.

If we transfer information offshore for other purposes, we will only do so with your consent or otherwise in accordance with Australian law. We will require that the recipient of the information complies with privacy obligations to maintain the security of the information.

4.5 How do we store personal information and for how long?

We take all reasonable steps to ensure that your personal information is securely stored and protected. These steps include password protection for accessing our electronic IT systems, securing paper files in locked cabinets and physical access restrictions to buildings where information is held. In addition, access to your personal information is restricted to those properly authorised to have access.

Unfortunately, there are inherent risks in the management of personal information and we cannot and do not guarantee that unauthorised access to your personal information will not occur.

We keep your personal information for as long as it is needed for the purposes for which it was collected and to comply with legal requirements.

When personal information we hold is no longer needed for any purpose, including legal purposes, and subject to our legal obligations (for example, under the Public Records Act), we will take reasonable steps to destroy or alter that information so that it no longer identifies you.

5 – Accessing and correcting your personal information

5.1 How do I keep my personal information up to date?

We depend largely on you to provide us with accurate personal information. If changes to your information are required, please let us know by contacting us.

5.2 Can I access my personal information?

You can ask us for access to the information that we hold about you at any time. Simply contact us (our contact details are listed below) to make your request. For security reasons, we may ask you to put your request in writing.

We will not typically charge you for access your personal information.

Generally (but subject to Australian law), we will give you full access to your personal information within a reasonable time and in the manner requested by you. However, there may be some circumstances when this is not possible, including where:

we no longer hold or use the information
providing access would have an unreasonable impact on the privacy of others
the request is frivolous or vexatious
providing access would be unlawful

If we do not provide you with access to all of your personal information, we will tell you the reason why we have not done so.

6 – Your privacy online

6.1 Online data collection and use

When you access a Thrive365 website, anonymous technical information may be collected about user activities on the website. This may include information such as the type of browser used to access the website and the pages visited.

This information is used by Thrive365 to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details.

6.2 Cookies

A cookie is a small text file placed on your computer by a web server when you access a website. Cookies in themselves do not identify the individual user, just the computer used. Like many websites, Thrive365’s websites may use cookies for various reasons, including to recognise a computer which has previously visited our websites and customise our websites according to previous preferences and site behaviour.

You can choose if and how a cookie will be accepted by configuring your preferences and options in your web browser. For example, you can set your browser to notify you when you receive a cookie or to reject cookies. However, if you decide not to accept cookies, then you make not be able to gain access to all the content and functionality of Thrive365’s websites.

6.3 How we handle email and ‘contact us’ messages

We may keep the content of any email, or “Contact us” or other electronic message or form, that we receive. The message content may be monitored by our service providers or staff for purposes including trouble shooting, compliance, auditing and maintenance, or where email abuse is suspected. Personal information will be handled in accordance with this Privacy Policy.

7 – Contact us

If you have any questions in relation to privacy, please contact us at info@Thrive365.org.au.

You can also seek further information and advice from the Office of the Australian Information Commissioner by calling 1300 363 992.