Privacy Policy and Procedure

Policy Overview

 

By providing us with your personal information, including through Simplified Plan Management (SPM) Platforms (e.g., Client Portal), you are giving your consent to the collection, use, and disclosure of that personal information in accordance with this Privacy Policy and any other relevant agreements between us, such as the Platform Terms.

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We may update our Privacy Policy periodically by publishing changes on our website. We encourage you to check our website regularly to stay informed about the most up-to-date version of the Privacy Policy.

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This Privacy Policy should be read together with any specific collection notice or consent that we provide to you.

 

Collection of Personal Information

 

Personal information refers to information or an opinion about an individual that can reasonably identify them. In this Privacy Policy, unless stated otherwise, references to personal information also include sensitive information.

The types of personal information we may collect from you include:
 

• Name, date of birth, and contact details, such as address, phone number, and email address.

• Information about your preferred modes of communication.

• Your NDIS plan details, including government identifiers like your participant NDIS number (NDIS), if applicable.

• Information related to your consent to obtain and release information.

• Any information or documents you provide or upload to an SPM platform regarding the services and supports provided.

• Information about your interactions with SPM or SPM services, platforms, or websites, including engagement with others while using SPM platforms (e.g., feedback, "likes," comments, choices, preferences, messages).

• Details about the services or products we have provided to you or that you have inquired about, including any additional information necessary for delivering those services and products and responding to your inquiries.

• Information related to bank accounts if you choose "reimbursements" as a payment option for Plan Management Services.

• Audio recordings and any other relevant information required by SPM to fulfill the roles and responsibilities of a Plan Manager.

 

Collection of Sensitive Information

 

If you are an NDIS Participant, due to the nature of our business and service platforms, we may also collect 'sensitive information' about you, as defined in the Privacy Act. This includes information or opinions about your health and/or disability, your wishes regarding future service provision (including goals and aspirations in your NDIS Plan, if disclosed), and information about services provided or to be provided to you through our service platforms.

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While we generally collect such sensitive information directly from you (during registration or your interactions with SPM and/or SPM platforms), we may also collect it from third parties in cases where it is unreasonable or impracticable to collect it directly from you. This may include information provided by your Primary Decision Maker or Primary Account Manager (for SPM platforms), service providers, or members of your chosen community of support when they upload information such as appointment reminders.

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Unless specified otherwise, all references to 'personal information' in this privacy policy should be understood to include sensitive information.

 

Collection and Storage of Personal Information

 

At Simplified Plan Management (SPM), we collect personal information from various sources. This information is obtained directly from you, your nominated decision maker, the National Disability Insurance Agency (NDIA), or other third parties involved in our services. The following are the methods through which we collect your personal information:

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1. Service Sign-Up: When you sign up or register for any of our services.
    

2. Website and Platform Interaction: When you visit our websites or platforms, such as our client portal.
    

3. Communication Channels: When you communicate or interact with us through methods like telephone, email, post, website, SPM platforms, or in-person meetings.
    

4. Invoice Processing: When you authorize us to process invoices on your behalf.
    

5. Plan Management and Capacity Building: When we contact you for activities related to our roles and responsibilities, such as budget discussions, seeking approvals, individual capacity building and coaching, social and community engagement using SPM platforms, etc.
    

6. Representation to NDIA: When we represent a matter to the NDIA on your behalf, with your consent as applicable.
    

7. Other Notified Circumstances: When we collect information as explicitly notified to you from time to time.

 

Furthermore, we may also collect information from third parties, including nominated service providers, support coordinators, and individuals approved by you to participate in SPM platforms. For instance, we may gather information when you or others post content on our platforms.

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Regarding audio recordings, we will seek your consent before recording your voice during telephone conversations with SPM. If a supervisor or staff member is to monitor a call for training or support purposes, we will inform you beforehand.

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Your personal information is collected and stored securely. We have implemented appropriate measures to protect it from misuse, loss, unauthorized access, modification, or disclosure.

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Please note that all the information provided above is applicable and relevant as of the time of communication.

 

Use of Your Personal Information

 

At Simplified Plan Management (SPM), we handle your personal information in accordance with our role and responsibilities as outlined in the Simplified Plan Management Service Agreement and the services and supports you have purchased. This includes the following activities:
 

1. Providing Information: We may use your personal information to provide you with information about the services and products we offer.
    

2. Opt-Out and Suspension: We may use your personal information to offer you the option to opt out or temporarily suspend access to our services and products.
    

3. Notifications: We may send you SMS or email notifications related to our services and products.
    

4. Responding to Inquiries: We use your personal information to respond to your questions and suggestions.
    

5. Improving Quality: We may utilize your personal information to enhance the quality of our products, services, website, and community platform.
    

6. Platform Usage: We use your personal information to provide you with access to our platform, manage our relationship with you (including account setup and identity verification), and optimize the platform's operation, protection, and moderation. This may involve sharing personal information with SPM or third parties performing moderation or related activities on our behalf.
    

7. Service and Support: We may send you service, support, and administrative messages, reminders, technical notices, updates, security alerts, and the information you have requested. We also address your queries and fulfil your requests.
    

8. Platform Content: We may present you, your parent, guardian, or decision maker with platform content, including specific discussion topics or posts, information about other platform users, or details about other services and products both on and off the platform that may be of interest to you or relevant parties.
    

9. Compliance and Dispute Resolution: We use your personal information to comply with our legal and industry obligations, including the NDIS Code of Conduct. Additionally, we resolve any disputes that may arise between users and enforce our agreements with third parties.
    

Please note that the above uses of your personal information align with our obligations and commitments, and they contribute to delivering effective services and improving your overall experience with SPM.

 

Sharing Your Personal Information

 

At Simplified Plan Management (SPM), we may disclose your personal information to third-party contractors, such as information technology suppliers, communication suppliers, and our business partners. These contractors assist us in conducting our business and meeting our obligations under applicable laws, including the NDIS Act and Rules, as well as policy requirements of the National Disability Insurance Agency. It is important to note that these third-party contractors are located in Australia.
 

When sharing information with these third parties, we take reasonable steps to ensure that they maintain the confidentiality of your information and refrain from using or disclosing it beyond what is necessary to assist us. We have strict controls in place to safeguard the privacy of your personal information.
 

Except for third-party contractors, Simplified Plan Management will obtain written consent from you before disclosing your information to external parties. For instance, we may require your consent to communicate with other support providers on your behalf. This consent is typically documented in our "Consent to Obtain and Release" form.
 

If the "Consent to Obtain and Release Information" form is not completed, Simplified Plan Management may request that the individuals seeking information liaise directly with you or your nominated person.
 

We respect your right to withhold consent. In such cases, Simplified Plan Management will inform you of any known impacts this may have on service delivery and our ability to provide services effectively.
 

In situations where clients are unable to provide informed consent, such as in the case of service agreements, Simplified Plan Management will collaborate with nominated representatives or guardians. These representatives or guardians are responsible for considering the needs and goals identified by the person with a disability, making decisions regarding privacy and dignity, and maximizing the client's well-being in all aspects of their life. Simplified Plan Management will work closely with the nominee as necessary to achieve these objectives.

 

Storing Your Personal Information

 

At Simplified Plan Management (SPM), we take the security and protection of your personal information seriously. We store the personal information we collect in electronic format, ensuring it is securely protected. We employ appropriate security measures to prevent misuse, interference, loss, unauthorized access, modification, or disclosure of your personal information.
 

To safeguard your privacy, we utilize technologies, security software, network firewalls, and physical security measures. These measures are in place to maintain the confidentiality of your personal information and ensure its integrity.
 

Your personal information will be stored by us for the duration of our service provision to you unless otherwise mandated by law. Following this period, we will retain your personal information in our archives to the extent required by applicable laws that govern our business, which may change over time.
 

It is important to note that while we store your data in Australia, certain features of third-party applications may require these third parties to access information as overseas recipients. This access is necessary for them to provide their functionalities for use on our platform. We ensure that these third parties comply with appropriate privacy and data protection standards.
 

Rest assured that we are committed to maintaining the security and confidentiality of your personal information throughout its storage and use in compliance with applicable laws and industry best practices.

 

Access to Your Personal Information

 

At Simplified Plan Management (SPM), we strive to ensure the accuracy, completeness, and currency of your personal information. We take reasonable steps to achieve this whenever we collect or utilize your information. As a client, you have the right to access your personal information at any time. If you believe any of the information to be inaccurate or incomplete, you have the right to request changes to it. In such cases, we will add an amendment note to the relevant file, acknowledging your disagreement and specifying how you would like the information to be presented.
 

We respect your autonomy and acknowledge that you have the right to refuse to provide personal information to Simplified Plan Management. If you choose not to disclose certain requested information, we will endeavour to inform you of the potential impact on service delivery. We will discuss whether it will still be possible to provide services and support without the required information.

 

Links

 

Our platforms or website may contain links to third-party websites. These links are provided for convenience and may not always be current or maintained. Please note that we are not responsible for the privacy practices or content of these linked websites, and we do not exercise control over them. The privacy policies governing these external websites may differ significantly from our Privacy Policy. We encourage individuals to review the privacy policies of these websites before using them.

 

Feedback and Complaints

 

Clients are welcome to provide feedback or raise concerns regarding privacy matters. To do so, please refer to the Simplified Plan Management Complaints and Feedback Policy, available on the SPM website, and submit any complaints to info@simplifiedpm.com.au. Rest assured that we treat all complaints with confidentiality and address them promptly.
 

Please note that making a complaint or providing feedback does not restrict your right to lodge a complaint about how Simplified Plan Management has handled your personal information with the Office of the Australian Information Commissioner. You can contact them at any time by calling 1300 363 992.
 

We value your privacy and are committed to ensuring that your personal information is handled in accordance with applicable laws and regulations.