Privacy Policy

1. What Personal Information We Collect

We may collect the following kinds of information, depending on your relationship with us:

• Identity information — name, date of birth, address, contact details, emergency contact details
• Health information (a category of "sensitive information" under the Privacy Act) — medical history, diagnoses, medications, mobility and care needs, assessments from My Aged Care or health professionals
• Government-related information — Aged Care ID, Medicare number, Home Care Package or Support at Home details, Centrelink/Services Australia references (only where relevant and necessary)
• Financial information — income testing details relevant to aged care contributions, billing and payment details
• Representative information — details of family members, powers of attorney, guardians, or other authorised representatives acting on a participant's behalf
• Website and enquiry information — details submitted through contact forms, email, phone enquiries, or our website's AI assistant chat feature
• Employment information — for job applicants and staff, including qualifications, work history, and police/working-with-vulnerable-people checks

We only collect information that is reasonably necessary for our functions and activities as an aged care and in-home support provider.

2. How We Collect Personal Information

We generally collect personal information directly from you or your authorised representative, including:

• When you or your representative contact us by phone, email, our website, or in person
• When you use the AI chat assistant on our website
• When you complete a service agreement, intake form, or care assessment with us
• From My Aged Care, aged care assessors, or the Department of Health, Disability and Ageing, where you have been referred to us or where this is authorised under the Aged Care Act
• From your treating health professionals, with your consent, where relevant to your care
• From publicly available sources, only where appropriate and lawful

Where practical, we will collect sensitive information (such as health information) only with your express consent, or where another exception under the Privacy Act applies (for example, where collection is necessary to provide you with care and you are physically or legally unable to give consent).

Our website AI assistant. Our website features an AI-powered chat assistant that can answer general questions about our services and the Support at Home program. If you type personal information into this chat (for example, to request a callback), that information is:

• Used only to respond to your enquiry or connect you with our team
• Processed using third-party AI service providers, which may be located overseas (see Section 7 — Overseas Disclosure below)
• Not used to make any decisions about your care, eligibility, or funding — the assistant provides general information only, and all care-related decisions are made by our staff

Please avoid sharing sensitive health details through the chat assistant where possible; contact us directly by phone or email for anything involving your specific care needs.

3. Why We Collect, Hold, Use and Disclose Personal Information

We collect, hold, use, and disclose personal information for purposes including:

• Assessing your needs and providing aged care and in-home support services, including under the Support at Home program
• Complying with our obligations as a registered provider under the Aged Care Act 2024 and Aged Care Quality Standards
• Communicating with you, your representatives, and your other service providers about your care
• Billing, funding claims, and program administration with My Aged Care, Services Australia, and the Department of Health, Disability and Ageing
• Meeting our legal obligations, including reporting under the Serious Incident Response Scheme (SIRS) where applicable
• Responding to enquiries made through our website, phone, email, or AI chat assistant
• Staff recruitment and management
• Improving our services, including reviewing chatbot conversation logs to improve the accuracy of information we provide (with identifying details removed or restricted wherever possible)

We do not use or disclose personal information for any purpose other than the purpose for which it was collected, unless you would reasonably expect that use, the Privacy Act permits it, or you have consented.

4. Disclosure of Personal Information

We may disclose your personal information to:

• My Aged Care, the Aged Care Quality and Safety Commission, and the Department of Health, Disability and Ageing, as required or authorised under the Aged Care Act 2024
• Services Australia, where relevant to funding or income testing
• Your treating doctors, allied health professionals, or hospital, with your consent or where necessary for your care
• Subcontracted support workers or allied service providers engaged to deliver part of your care
• Your nominated emergency contacts or authorised representatives
• Our professional advisers, auditors, and insurers, where necessary
• Regulatory or law enforcement bodies, where required by law

We do not sell personal information, and we do not disclose personal information for direct marketing purposes by other organisations.

5. Direct Marketing

We may occasionally send you information about our services that may be relevant to you. You can opt out of receiving marketing communications from us at any time by contacting us using the details below, or by using the unsubscribe option in any email we send.

6. Data Quality

We take reasonable steps to ensure the personal information we collect, use, and disclose is accurate, up to date, and complete. You can help us by letting us know if your details change, and you may request a correction to your information at any time (see Section 9).

7. Overseas Disclosure

Some of the technology services we use to operate our website and AI chat assistant are provided by companies based overseas (including the United States). This means personal information submitted through our website or chat assistant may be processed on servers located outside Australia.

Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure that recipient does not breach the Australian Privacy Principles in relation to that information, including by relying on the service providers' own data protection commitments and contractual terms. We otherwise generally do not disclose personal information overseas except where required by law, authorised under the Aged Care Act 2024, or where you or your representative are located overseas and contacting us directly.

8. Data Security

We take reasonable steps to protect personal information we hold from misuse, interference, loss, and unauthorised access, modification, or disclosure. This includes:

• Restricting access to personal information to staff who need it to perform their role
• Using secure systems and access controls for client records and our website's knowledge base and chat tools
• Staff training on privacy and confidentiality obligations
• Secure destruction or de-identification of personal information no longer needed, subject to our record-keeping obligations under aged care legislation

If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act.

9. Access to and Correction of Your Personal Information

You, or your authorised representative, may request access to the personal information we hold about you, or request that it be corrected, by contacting us using the details below. We will respond within a reasonable period. In some circumstances, access may be limited or refused as permitted under the Privacy Act (for example, where it would unreasonably impact the privacy of others), and we will explain our reasons if this occurs.

There is generally no charge for making a request, though we may charge a reasonable fee for providing access in some circumstances.

10. Anonymity and Pseudonymity

Where lawful and practicable, you may interact with us anonymously or using a pseudonym — for example, when making a general enquiry through our website or chat assistant. However, we will generally need to verify your identity to provide aged care services, assess eligibility, or manage funding under the Support at Home program.

11. Government-Related Identifiers

We do not use government-related identifiers (such as Medicare numbers or Aged Care IDs) as our own identifiers for you, except as required or permitted by law.

12. Complaints

If you have concerns about how we have handled your personal information, please contact us first using the details below so we can attempt to resolve the matter directly.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner:

• Website: www.oaic.gov.au
• Phone: 1300 363 992

You may also raise concerns about your aged care services with the Aged Care Quality and Safety Commission:

• Phone: 1800 951 822

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The most current version will always be available on our website.