1 About this Policy
1.1 What this Policy is about
My Care Provider is committed to respecting and protecting the privacy of the information provided by you when you engage with My Care Provider, including when you access and use the Platform. Hireup is bound by and complies with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) and other relevant privacy laws.
This Policy applies to My Care Provider and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)). This Policy describes how we collect, use, store and disclose your information, including personal information, in connection with your interaction and engagement with My Care Provider and your access to our resources and services.
1.2 Your agreement to this Policy
By accessing our resources and services you confirm that you have read and agree to the terms of this Policy and consent to your personal information (including, your sensitive information) being collected, stored, used and disclosed in accordance with this Policy. Please read this Policy carefully to understand our practices regarding your personal information.
1.3 Changes to this Policy
We reserve the right to modify this Policy at any time in accordance with this provision. If we make changes to this Policy, we will upload the revised Policy to the Website. Changes to this Policy will come into effect immediately upon such changes being uploaded on the Website. Your continued use of the Website following such upload will constitute your acceptance of any changes.
1.4 Employee records exemption
Where applicable, My Care Provider will rely on the "employee records exemption" in the Privacy Act and any other applicable exemptions in the Privacy Act or other relevant legislation. The employee records exemption means that in many cases, My Care Provider is not bound by the requirements of the Privacy Act in relation to personal information it holds about its current or former employees (relating to their employment).
2 Kinds of information we collect
2.1 Your engagement with My Care Provider
There are many ways that you can engage with My Care Provider, its Representatives or the Website including (but not limited to) as an Unregistered, Registered or Approved User or via telephone, email, post or in person.
Depending on how you engage with My Care Provider and its Representatives and use the Website, we may ask you to share, or may collect your ‘personal information’.
2.2 Personal information
Under the Privacy Act, ‘personal information’ includes any information or opinion that identifies or can be used to identify, contact or locate you. Common examples include your name, address, telephone number or date of birth. Whether you choose to share your personal information (including your sensitive information) is completely up to you, but you may not be able to access some areas of the Platform or effectively use the services offered through the Platform without providing My Care Provider with certain personal information.
2.3 Types of personal information
The types of information that we collect from you depend on your dealings with My Care Provider. For example, the information that we collect from Unregistered Users and Approved Users will vary. Below is a non-exhaustive list of the four general categories of information we collect.
2.3.1 Information you give us
We generally collect the following personal information from you through the Platform, or via telephone, email, post or in person.
2.3.1.a Account Information: We may ask for and collect your:
date of birth;
residential and postal address;
academic qualifications and certifications (if any);
expertise and experience;
living arrangements, including information about the individuals you live with and receive care and support from (as appropriate);
background information about you including your criminal record and any geographical or other limitations or preferences; and
lifestyle or biography details.
2.3.1.b Identity verification information: We may ask for and collect identity verification information (such as, your NDIS number, copies of your government issued ID, passport, or drivers licence) or other authentication information to verify your identity.
2.3.1.c Financial Information: We may require you to provide certain financial information, such as your bank account details, insurance status, superannuation fund details, your National Disability Insurance Scheme (NDIS) number, NDIS plan details or credit card information.
2.3.1.d Communications with My Care Provider and other Users: When you communicate with My Care Provider or use the Platform to communicate with other Users, we monitor, record and store those communications and any information you choose to provide to My Care Provider and other Users.
2.3.1.e Information received from an Account Manager: An Account Manager may manage an Account on behalf of a Participant in certain circumstances. If an Account Manager intends to provide My Care Provider with personal information (including sensitive information) about any other person they must obtain the relevant person’s consent before providing us with that information.
2.3.2 Information we automatically collect from you
When you use the Website, we automatically collect certain information from you, including personal information.
2.3.2.a Usage information: We collect information about your interactions with the website such as the pages or content you view, your searches, your Bookings and other actions you take on the website.
2.3.2.b Engagement records: If you contact My Care Provider on the Platform, by telephone, email, post or in person we automatically record any information, including personal information that you provide to us. If you become an active particpant, this information will be linked with your Account.
2.3.2.c Log Data and Device Information: We automatically collect log data and device information when you access and use the Platform, even if you are an Unregistered User. That information includes, among other things, a recording showing how you used the Platform, your clicks, scrolls and activities on the Platform, your IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Platform. We use this type of information to administer the Platform and to analyse trends.
2.3.2.d Cookies: We may collect some anonymous information about how you use the Platform by setting and accessing cookies on your computer. A cookie is a small text file that allows our system to identify and interact more effectively with your computer or device. These cookies track information such as how often you visit the website, what pages you view, and where you go after you leave the website. The cookies track your computer, not you. You can configure your web browser to restrict or disable cookies, however, this may cause some parts of the website not to have full functionality.
2.3.2.e Payment Transaction Information: We may collect information related to your payment transactions through the website, including the payment instrument used, payment dates and times, payment amounts, your billing postcode, address and other related transaction details. This information is necessary for the adequate performance of the agreement between you and My Care Provider.
2.3.3. Information we collect from third parties
My Care Provider may collect personal information about you, including sensitive information, from third parties. We do not control, supervise and are not responsible for how those third parties process your personal information. Any information request regarding the disclosure of your personal information by a third party to us should be directed to such third parties.
2.3.3.a Third Party Services: If you link, connect, or login to the website or your Account through a third party service (e.g. Google, Facebook) the third party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings with that service. The use of these technologies allows those third party services to evaluate your use of the website and other websites, deliver customised advertising content, measure the effectiveness of their advertising, and provide other services relating to website activity and internet usage.
2.3.3.b Information from the NDIS participant portal: If you have a NDIS plan, we may use your NDIS number and DOB and name to access your information through the NDIS participant portal. We may access information such as the start and end date of your NDIS plan, your NDIS funding categories and any other information that you choose to share through the NDIS participant portal.
2.3.3.c Advertising Services: If you click on an online My Care Provider advertisement (e.g. ads on Google) the third party service hosting that advertisement will collect certain information and will provide that information to us to allow us to measure the effectiveness of our advertising.
2.3.3.d Information from other Users: We may receive information, including personal information, about you from other Users. For example, an Approved User is required to report any incidents that occur during a Booking to My Care Provider; this report may include information about other Approved Users.
2.3.3.e Information from organisations and service providers you engage with: We may receive information, including personal information, about you from plan managers, the NDIA, support coordinators and other disability support service providers that you engage with.
2.3.3.f Your References: If someone has provided My Care Provider with a reference about you, it will be held and stored by My Care Provider.
2.3.3.g Background Information: As required and permitted by applicable laws, My Care Provider may obtain police, background and other checks on you. We may use your personal information, including your full name and date of birth, to obtain such reports.
2.3.4 Sensitive information
‘Sensitive information’ is a type of personal information and includes:
racial or ethnic origins;
membership of a political association, professional or trade association or trade union;
religious or philosophical beliefs or affiliations;
sexual orientation or practices;
criminal record; and
My Care Provider will only collect sensitive information that is necessary to allow you to use or receive My Care Provider services. Depending on how you engage with My Care Provider or use the Platform, we may ask you to share some or all of the above sensitive information with us. By way of example, to be an Approved User, we may ask you to provide information regarding your disability or impairment, current medications, support needs and support history. Once you are an Approved User, this information may be published on your Profile in accordance with paragraph 5.2 below.
My Care Provider will not collect your sensitive information unless:
it is required or authorised by law; or
you consent to the collection of the information; and
it is necessary for the adequate performance of your agreement with My Care Provider.
3 How we hold and store your personal information
We may hold and store your personal information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by infrastructure and storage service providers, including those that are located overseas, such as in the United States.
My Care Provider and our third party infrastructure and storage providers have implemented a range of measures to protect the security of your personal information including:
ensuring encrypted secure transmission of your personal information (as necessary);
controls regulating which staff and contractors can access particular information;
using enterprise firewalls to protect servers that host your personal information; and
only allowing certain components of your personal information to be accessed by other Approved Users (refer to paragraph 5.2 of this Policy).
4. How we use your personal information
Information about how we use your personal information is below. This list is not intended to be exhaustive and there may be other third parties to which we give your personal information (for example, professional advisors or insurers) where required or permitted by law.
4.1 Use of your personal information for the Business Growth
We may use your personal information to build, operate and improve the service and as necessary for the adequate performance of our agreement with you. Below is a non- exhaustive list of the purposes for which we may use your personal information.
Verify or authenticate information provided by you and your identity;
Conduct necessary background, reference and other checks and verify the information you have provided as part of the Registration Process;
Enable you to access and use the website;
Maintain and update our records;
Enable you to communicate and connect with appropriate My Care Provider representatives
Operate, protect, improve, and optimise the website
Operate, improve, and optimise related services, such as by performing analytics and conducting research;
Assist us to provide effective customer service to our Users;
Process, manage and administer account payments, billing issues and payroll transactions; and
Send you support messages, updates and account notifications.
4.2 Use of your personal information for the My Care Provider community
We may use your information to protect our community and the website, to create and maintain a safe environment for all of our Users and to comply with applicable laws. Below is a non-exhaustive list of the purposes for which we may use your personal information.
Verify or authenticate information provided by Users and the identity of other Users;
Detect and prevent fraud, spam, abuse, exploitation, neglect, security incidents, and other harmful activity;
Conduct security investigations and risk assessments;
Contact your referees and send requests for and collect references about you;
Conduct checks on Users (as required) against databases and other information sources, including background, working with children and vulnerable people checks or police checks;
Resolve any disputes or issues with any of our Users and enforce our agreements with third parties;
Comply with our legal obligations and protect our lawful interests.
4.3 Use of your personal information for marketing and advertising purposes
We may use your personal information to undertake and direct advertising and marketing activities to you. Below is a non-exhaustive list of the purposes for which we may use your personal information.
Send promotional messages, marketing, advertising, and other information to you via telephone, email, online and other means;
Manage our relationships with you and our other Users;
From time to time, we may contact you by telephone or text message solely in connection with the services we provide and only if you have provided us with your phone number;
Conduct product and market research; and
Personalise, measure, and improve our advertising and marketing.
You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications. For more information about how to opt out of receiving marketing communications, please see paragraph 9 below entitled “Your choices”.
5. Disclosing your personal information
5.1 Disclosure with your consent
Where you have provided your express consent for specific parts of your personal information to be disclosed, we will only disclose and share your personal information that is held by us as at the time of receiving your consent. If a Participant has nominated an Account Manager, that Account Manager will have access to all of the Participant’s personal information (including sensitive information) unless and until we are advised otherwise.
5.3 Compliance with legal requirements and requests
We may disclose your personal information to courts, law enforcement, government authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary to:
comply with our legal obligations;
respond to claims asserted against My Care Provider;
respond to requests relating to criminal investigations or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our Users to legal liability;
comply with our mandatory obligations under relevant state legislation;
protect the rights, property or personal safety of My Care Provider, its Representatives, other Users, or members of the public.
We may disclose your personal information to:
calculate, deduct and remit to the Australian Tax Office all necessary taxation and compulsory superannuation contributions; and
provide, manage and administer My Care Provider’s insurance coverage.
If you fail to meet your payment obligations to My Care Provider, we may be entitled to disclose your personal information to credit reporting bodies in accordance with the Privacy Act. The credit reporting bodies to which we may disclose your personal information include Equifax Pty Ltd.
5.4 Sharing with My Care Provider Related Bodies Corporate, affiliates and partners
We may share your personal information with our Related Bodies Corporate. We may also share your personal information with any organisation or entity in connection with any acquisition or potential acquisition of shares or assets in My Care Provider or the My Care Provider business (or part thereof).
We may disclose your personal information to third party service providers, consultants and business partners that assist us with, or work with us, or may potentially work with us in relation to archiving, auditing, accounting, customer contact, legal matters, business or growth consulting, risk management, banking, payment processing, delivery, data storage, data processing, data analysis, information management, marketing, investigations, cyber-security, research, training and website or technology services.
5.5 Sharing with organisations and service providers that you engage with
We may share your personal information, including sensitive information, with plan managers, the NDIA, support coordinators and other disability support service providers that you engage with. We will obtain your consent before sharing any information with plan managers, support coordinators or other service providers.
5.6 Unidentified data sharing
We may also share information about our Users that has been aggregated or combined so that it no longer identifies an individual User and other anonymised information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
6. Age restrictions
6.1 The Platform is not intended for use by, and is not designed to attract any person under the age of 18.
6.2 In the case of Participants under the age of 18, we require those individuals to be represented by an appointed other (including a care giver or coordinator) at all times.
6.3 In the case of Home Care and Support Workers under the age of 18, we require those individuals to comply with the My Care Provider Standards and Procedures relating to Workers under the age of 18, before commencing their employment with My Care Provider.
7. Accessing your personal information
You may access and amend your personal information provided to My Care Provider by contacting us. Alternatively, you have a right to ask for access to the personal information we hold about you. Please contact our Privacy Officer at:
Postal address: 8 Blake Street, Wangaratta, Victoria 3677
Phone 1300 998 774
Your personal information will usually be available within 30 days of your request. If there is a fee for accessing your personal information, we will confirm the amount before providing the information. We may require evidence of your identity as part of the process of providing you with access to your personal information.
In some circumstances we may decline to grant you access to your personal information (for example, if the release of your personal information would have an unreasonable impact on the privacy of others). Please see the APPs for further information.
8. Updating and correcting your Personal Information
You may update or correct your personal information held by My Care Provider at any time by contacting us on 1300 998 774 or by email at firstname.lastname@example.org. It is your responsibility to ensure that your contact and personal information held by My Care Provider is kept up-to-date.
9. Your Choices
You may opt-out of receiving marketing communications or targeted advertising from us at any time, by using the link in promotional and marketing emails or by contacting us directly on 1300 998 774 or at email@example.com. Please note you cannot opt-out of receiving administrative and transaction-related emails from us unless you inform us that you no longer wish to be receiving My Care Provider services. These are emails that relate to your engagement of our services.
10. Contact Us
If you have a concern about how we have handled your personal information, please let us know so we can address the problem. Please contact us at firstname.lastname@example.org or 1300 998 774.
To lodge a formal complaint, please send details in writing. We will attempt to respond within a reasonable time, usually 30 business days. My Care Provider treats all privacy complaints seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need to investigate the complaint appropriately. If your complaint is not resolved by our Privacy Officer, you can refer it to the Office of the Australian Information Commissioner.
The contact details are:
Office of the Australian Information Commissioner
Postal address: GPO Box 2999, Canberra, ACT 2601
Phone: 1300 363 992
Fax: 02 9284 9666
If your concern relates to your health information you may also contact your State or Territory Privacy Commissioner.