Privacy Policy
1. Introduction
Lifeskills Plus Inc (“ LSP”) value your privacy. We take reasonable steps to protect your personal information. We abide by the requirements of the Privacy Act 1988 (Cth) (“Act”) in relation to the collection, use and disclosure of your personal information and comply with other applicable laws protecting privacy including State and Territory health information legislation.
By accessing the LSP website, engaging our services or providing personal information to us, you consent to our collection, use and disclosure of that information on the terms of this privacy policy (Privacy Policy) and any other contractual or other arrangements (if any) that may apply between us.
2. Scope of this Privacy Policy
This Privacy Policy describes how your privacy is respected and protected in accordance with the Australian Privacy Principles. It applies to all information we collect about you through the use of our services. This includes personal information collected in person, in forms completed by you or on your behalf, by telephone, through our website, via other service providers and by other electronic communication channels (e.g. desktop, laptop, mobile phone or other consumer electronic device) to access our services.
3. Agreeing to these terms (use of website constitutes acceptance)
Your continued use of our website and/or our service indicates that you accept the conditions of this Privacy Policy, consent to the collection and use by us of any personal information you provide while using our services or our website.
4. What is personal information?
Personal information is any information that can be used to identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you or you are reasonably identifiable from it, the information will be considered personal information.
5. Why do we collect personal information?
We collect personal information that is necessary for us to undertake and provide our services and activities. Due to the nature of our services, this may include sensitive information, including health information.
We also collect personal information so that we can improve and perform our business activities and functions, to provide you with any products or services you may request, or to respond to any query or complaint that you may have.
De-identified information may also be used for reporting, benchmarking and academic or industry research
6. When do we collect personal information?
Examples of personal information we may collect, and when we may collect it, include (but is not limited to) the following:
- Conducting our general business activities: we collect personal information about individuals for our general business operations. From time to time, we may collect, use and disclose personal information for quality assurance, risk management, billing and administrative purposes.
- Sensitive Information: we may collect sensitive information if it is relevant to the provision of our services to you. That information will be treated in accordance with requirements of the Privacy Act and any state and territory health information legislation.
How do we collect your personal information?
In addition to the means of collection set out above, we may also collect personal information:
- When information is provided through our website.
- From publicly available sources of information.
- From third parties, where it is reasonably necessary or normal business practice, so that we can continue to provide you with our services.
We also collect limited information about all visitors to our online resources which is used only to identify generic behavioural patterns. We may use cookies, Google Analytics or other technology to track visits to our website to monitor its effectiveness, maintain our server and improve our services. Types of data collected include:
- The date and time of the visit to the site;
- The pages accessed and documents downloaded;
- If the individual has visited our site before; and
- These statistics will not identify you as an individual.
7. How do we use your personal information?
We use and disclose personal information we collect:
- To provide and improve our services to our clients and others, including to Identify and provide services required including those offered by third parties.
- Assess the adequacy of, and our members’ level of satisfaction with, our services.
- To verify the identity of whom we interact with.
- To communicate with members and others, conducting events and raising awareness about our services.
- To undertake our general business activities, including interacting with contractors, government agencies and administration.
- To administer and manage our services including charging and billing for products (as applicable);
- To conduct appropriate financial checks.
- To update our records and keep contact details up to date.
- Maintain and develop our business systems and infrastructure, including testing and upgrading of these systems; and/or
- For other purposes with your consent or as permitted by law.
8. When will we disclose your personal information?
We will not share any personal information with third parties without consent except in accordance with this Policy and:
- If we are required by law or we believe in good faith that such action is necessary in order to comply with law, cooperate with law enforcement or other government agencies, or comply with a legal process served on the company (including insurers) or court order.
- If the disclosure of the information will prevent or lessen a serious and imminent threat to somebody’s life or health.
- To our contractors only to the extent necessary for them to perform their duties to us.
- To our professional advisers, including our accountants, auditors, and lawyers.
- To any governmental or semi-governmental organisation who requests it (including but not limited to as part of any application for a grant or other benefit under the NDIS);
- If you are not able to provide us with consent, we may use and disclose your personal information with the consent of a person responsible (as defined under the Privacy Act)
- As otherwise permitted by law.
If we retain any sensitive information, that information will not be used, shared or disclosed without express or implied consent that is current, voluntarily given and obtained in accordance with the Privacy Principles. If the individual is unable to give consent then we may use and disclose personal and sensitive information with the consent of a person responsible (as defined under the Privacy Act).
9. Security of your personal information
We regard the security of personal information as a priority and implement a number of reasonable physical and electronic measures to protect it. Staff who may have access to personal information are required to sign a confidentiality agreement and if contract service providers are used, they will be bound by our Privacy Policy and Data Sharing Agreement.
It should be noted, however, that the internet is not a secure environment and although all care is taken, we cannot guarantee the security of information provided to us via electronic means.
10. Data quality
We take all reasonable steps to ensure that the personal information we collect is accurate, up to date, concise and complete. This includes maintaining and updating personal information when we are advised it has changed and at other times as necessary.
11. Cross border data transfer
We will not provide your information to parties any other parties without your prior consent. We do from time to time, however, use web-based programs for particular activities such as email broadcast which may be hosted offshore, or cloud service providers but only when the supplier agrees with us to be bound by privacy laws or where the jurisdiction in which the data is located has laws that are equal to or better than Australian privacy laws.
12. What if there is a data breach?
We take all reasonable steps to prevent data breaches. However, if we suspect that a data breach has occurred, we will undertake a reasonable and expeditious assessment to determine if the data breach is likely to result in serious harm to any individual affected. If so, we will:
- Take all reasonable steps to contain the breach.
- Where possible, taking action to remediate any risk of harm.
- Notify individuals and the Commissioner where an individual is likely to suffer serious harm (or if otherwise required by law); and
- Review the incident and consider what actions can be taken to prevent future breaches.
13. Accessing and correcting your information
As a member of LSP, you are entitled to view the information we hold about you and reasonable requests for access and correction will be responded to as quickly as possible.
If you wish to view the information we hold about you, please contact the LSP CEO using the contact detailed set out below. If we refuse to give you access to your personal information or to correct your personal information, we will give a reason for this decision. Generally, if requested, we will amend any personal information which you demonstrate is inaccurate, incomplete or not current, and will remove any information that is not relevant. If we disagree with your view on these matters we will keep a note on the file setting out your view of the information held.
14. Security measures for online payments
If Payments are made online through our website, these are processed in real-time using a secure payment gateway. Payments are processed in Australia in Australian Dollars. Our website has security measures designed to protect against the loss, misuse and/or alteration to your personal information under our control.
15. Links to other websites
Our websites may contain links to third party websites, and third-party websites may also have links to our websites. We do not endorse any of those Websites or links. This Privacy Policy does not apply to external links or other websites who may also collect your personal information. We encourage you to read the privacy policies of any website you link to from our website.
16. Effective date and updates
This is our current Privacy Policy. We may at any time vary this Privacy Policy by publishing an updated version on our website. You accept that by using the website or continuing to use our services, provided you with sufficient notice of the variation.
17. Changes to this Privacy Policy
We reserve the right, as it may be necessary, to review, revise or make changes to our Privacy Policy and will notify you of those changes by posting those changes on our website.
18. Complaints
If you wish to make a complaint about a possible breach of privacy, please provide full details of your complaint in writing, and send it to the LSP CEO (see contact details below).
If your complaint relates to our failure to provide access to or to correct any personal information that we hold about you, you may lodge a complaint directly with the Office of the Australian Information Commissioner (for more information, please see the Office of the Australian Information Commissioner website).
If your complaint does not relate to these matters, you must first lodge a complaint with us in writing and provide us with details of the incident so that we can investigate. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the relevant privacy legislation, if applicable).
Individuals enquiring about their rights and remedies for breaches of privacy, can access detailed information at the Office of the Australian Information Commissioner.
Contact Details:
Lifeskills Plus CEO – Owen Rogers
Phone: (02) 6372 6440
Email: [email protected]