We respect your privacy and are committed to protecting personal information entrusted to us. This Privacy Policy explains how Compassion Circle Care (“we”, “us”, “our”) collects, uses, discloses and safeguards personal information relating to our participants, families, nominees, plan managers, support coordinators, staff, contractors and website users.

1. What We Collect

We collect personal information that is reasonably necessary to provide services and operate our business. This may include your name, contact details, date of birth, NDIS number, plan details, billing information, emergency contacts, preferred language and communication needs.
Because we provide disability supports, we may also collect sensitive information with your consent or as otherwise permitted by law, such as health information, behavioural risks, cultural considerations, mobility and medication details, and information about support needs, goals and routines.

2. How We Collect Information

We collect information directly from you (in person, by phone, email, forms and our website), from your authorised representative (parent, nominee or guardian), and from involved third parties such as support coordinators, plan managers, health professionals, or the NDIA where relevant and authorised. We may also generate service notes and assessment information as we deliver supports.

3. Why We Collect and Use Information

We use personal information to:
• assess eligibility and plan appropriate supports;
• deliver and coordinate services safely and effectively;
• manage rosters, travel and staffing;
• communicate with you, your representatives and providers involved in your supports;
• process claims, invoices and payments;
• respond to feedback, incidents and complaints;
• meet our legal, regulatory and quality-assurance obligations; and
• improve our services, website and user experience.

We will not use your information for unrelated purposes without your consent unless required or authorised by law.

4. Consent and Your Choices

Where practicable, we will seek your consent before collecting or sharing sensitive information. You may withdraw consent at any time; however, this may affect our ability to deliver certain supports safely. You may also opt out of non-essential communications (such as newsletters) by following the unsubscribe instructions or contacting us.

5. Disclosure of Information

We disclose personal information to:
• you and your authorised representatives;
• our staff and contractors who need the information to perform their work;
• other service providers involved in your supports (for example, support coordinators, plan managers, allied health providers, transport providers), with your consent or as otherwise permitted by law;
• government agencies or regulators where legally required;
• our professional advisers, insurers and IT providers under confidentiality obligations.

We do not routinely disclose personal information overseas. If an overseas disclosure becomes necessary (for example, through a cloud service located overseas), we will take reasonable steps to ensure appropriate privacy safeguards and will inform you where required.

6. Data Security

We take reasonable steps to protect personal information against loss, misuse, unauthorised access, modification or disclosure. Measures may include secure physical storage, access controls, staff training, encryption in transit where appropriate, and contractual confidentiality obligations with third-party providers. Despite our efforts, no method of storage or transmission is completely secure; we cannot guarantee absolute security.

7. Data Quality and Retention

We take reasonable steps to ensure information is accurate, complete and up-to-date. Please notify us if your details change. We retain records for as long as necessary to provide services and meet legal or insurance requirements, after which we take reasonable steps to securely destroy or de-identify information.

8. Access and Correction

You may request access to the personal information we hold about you and request corrections if it is inaccurate, out-of-date, incomplete or misleading. We will respond within a reasonable time and may require identification to protect privacy. In limited circumstances we may refuse access (for example, where disclosure would unreasonably impact the privacy of others or is unlawful); if so, we will provide reasons.

9. Website, Cookies and Analytics

When you visit our website, we may collect usage information such as your IP address, pages viewed, browser type and the date/time of your visit. We may use cookies or similar technologies to remember preferences and improve site performance. You can modify your browser settings to refuse cookies, but some features may not function properly. We may use aggregated, de-identified analytics to understand how visitors use our site and to improve content.

10. Communications, Social Media and Marketing

If you submit an enquiry form or contact us through social media, we will use the details you provide to respond. We may send updates or information about our services where permitted. You can opt out at any time. Public posts or messages on third-party platforms are subject to those platforms’ privacy policies; we encourage you to review them.

11. Children and Vulnerable Persons

Where participants are children or otherwise require decision-making support, we will work with parents, guardians or nominees as authorised. We take extra care when handling information relating to children and vulnerable persons and seek consent from appropriate representatives where required.

12. Complaints and Concerns

If you have a privacy concern or wish to make a complaint, please contact us using the details below. We will acknowledge your complaint, investigate it and respond within a reasonable timeframe. If you are not satisfied with our response, you may seek external review through relevant oversight bodies. We will provide up-to-date contact pathways on request.

13. Changes to this Policy

We may update this Privacy Policy from time to time to reflect operational or legal changes. The current version will be published on our website. Significant changes will be communicated where appropriate.

14. Contact Us

For privacy enquiries, access/correction requests or complaints, please contact:
Compassion Circle Care – Privacy Officer
Email: [insert email] | Phone: [insert phone] | Postal Address: [insert address]