Privacy policy
How we collect, use and look after your personal information.
Draft, please have this reviewed
Last updated: TODO date
About this policy
This policy explains how Being Human Care Service Pty Ltd, trading as Espoir Care (formerly Being Human Care), handles personal information. In this policy "we", "us" and "our" mean Espoir Care.
We follow the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Because we provide health services, the Privacy Act applies to us whatever the size of our business. We also follow the NDIS Code of Conduct, the NDIS Practice Standards and our obligations to the Department of Veterans' Affairs (DVA).
Health information is sensitive information
Information about your health, disability or support needs is "sensitive information" under the Privacy Act. We only collect it when we need it to reply to you or to provide your support. We only collect it with your consent or where the law allows. We hold it to a higher standard of care than other information.
What we collect
Through our website forms
| Form | What we ask for |
|---|---|
| Enquiry form | First and last name, phone, email, preferred contact method, suburb, services you are interested in, your message, main language and whether you need an interpreter (both optional). People needing support and families are asked how the support is funded. Family members are asked their relationship to the person. Coordinators and health professionals are asked for their organisation, and health professionals for their role. Veterans are asked for their DVA card type and whether they have a referral. |
| General question | Name, phone, email, your question and main language (optional). |
| Referral form | The referrer's name, organisation (optional), role or relationship, phone and email. The participant's name, phone or best contact, suburb, date of birth, main language and interpreter needs (optional), funding type, NDIS number (optional), DVA file number (optional), the services requested, a preferred start date, a short description of the support needed and any risks for staff (optional). We also record that the participant or their guardian has agreed to the referral. |
| Careers form | Name, phone, email, suburb, the role you are interested in, your availability and your message. We also ask whether you have an NDIS Worker Screening Check and whether you have a driver's licence and car. Resumes are sent to us by email. |
Our enquiry forms do not ask for NDIS numbers, dates of birth or diagnoses. Please do not include detailed medical information in a message box. We will ask for what we need when we talk with you.
When you become a client
To provide support safely we collect more information directly from you, or from people you have authorised, such as your care needs, health information, medication, emergency contacts, NDIS plan details or DVA details. We explain what we need and why at the time. [TODO list your client record system and the forms used at intake]
When you use our website
If you choose "Accept analytics", Google Analytics collects information about how you use the site, such as the pages you visit, your device and your general location. If you choose "Decline" or make no choice, Google Analytics does not load. Read our cookie policy for details.
Why we collect it
- To reply to your enquiry, question or referral
- To work out whether we can help and which services suit you
- To plan and provide your support safely
- To claim payment from the NDIS, a plan manager, DVA or you
- To meet our legal, NDIS and DVA obligations
- To consider you for a job, if you apply to work with us
- To improve our website, only if you accept analytics
We do not sell your information. We do not use it for marketing unless you ask us to.
How our website forms send your details
When you send a form, the details are passed to a service called Web3Forms, which emails them to our inbox at info@beinghumancare.com.au. Web3Forms may process this information on servers outside Australia. [TODO check Web3Forms' current privacy terms, where it processes data and whether it keeps a copy of submissions, then update this paragraph]
Our email is hosted by [TODO name your email provider, for example Google Workspace or Microsoft 365].
Who sees your information
Only people who need it to do their job. That can include:
- Our staff who are arranging or providing your support
- With your consent, your support coordinator, plan manager, GP, hospital team or other providers
- The NDIA, the NDIS Quality and Safeguards Commission or DVA, when we need to for funding, reporting or compliance
- Companies that provide services to us, such as email, Web3Forms and, if you accept analytics, Google
- Anyone else when the law requires it, or to lessen a serious threat to someone's life, health or safety
Some of these services may store or process information overseas. When that happens we take reasonable steps to make sure the information is protected in line with the Australian Privacy Principles.
How we store and protect it
We take reasonable steps to protect your information from misuse, loss and unauthorised access. This includes password protected systems and limiting access to staff who need it. [TODO describe your main systems and security measures]
We keep records for as long as we need them and for as long as the law, the NDIS rules and DVA require. After that we securely destroy or de-identify them. [TODO confirm retention periods, for example how long you keep client records, enquiries that do not go ahead and job applications]
Using a pseudonym
You can ask a general question without giving your real name. To provide support, or to reply to an enquiry, we will need your real contact details.
Accessing or correcting your information
You can ask to see the information we hold about you, or ask us to correct it. Call us on 0412 632 913 or email info@beinghumancare.com.au. We will respond within a reasonable time, usually 30 days. There is no charge to make a request. If we cannot give you access, we will tell you why in writing.
Data breaches
If a data breach is likely to cause you serious harm, we will tell you and the Office of the Australian Information Commissioner (OAIC), as the Notifiable Data Breaches scheme requires.
Making a privacy complaint
If you are worried about how we have handled your information, please contact us first so we can try to fix it. See our complaints and feedback page for how we handle complaints.
If you are not happy with our response within 30 days, you can complain to the OAIC:
- Phone: 1300 363 992
- Website: oaic.gov.au
Contact us about privacy
Privacy officer: [TODO name or role]
Phone: 0412 632 913
Email: info@beinghumancare.com.au
Changes to this policy
We may update this policy from time to time. The latest version will always be on this page.