1. About this policy
Aligned Beginnings Pty Ltd (ABN 93 701 353 620) (“Aligned Beginnings”, “we”, “us” or “our”) is committed to protecting the privacy and dignity of every person who engages with our services, visits our website or otherwise provides us with their personal information. This policy explains how we handle personal information in accordance with the Privacy Act 1988 (Cth) (“the Privacy Act”) and the thirteen Australian Privacy Principles (APPs) contained within it.
This policy applies to all clients, participants, families, carers, guardians, referrers, contractors, employees, volunteers and visitors to our website at https://alignedbeginnings.site.
2. Who we are
Aligned Beginnings Pty Ltd is a disability and community support services provider based in Perth, Western Australia. We deliver supports designed to help people live independently, participate in their communities and pursue their personal goals. Where we handle personal information of National Disability Insurance Scheme (NDIS) participants, we also comply with our obligations under the National Disability Insurance Scheme and relevant Western Australian legislation.
3. The Australian Privacy Principles
The APPs govern how Australian organisations may collect, use, disclose, store and transfer personal information. Broadly, the APPs require that we:
- collect personal information only where it is reasonably necessary for our functions and activities, and by lawful and fair means;
- take reasonable steps to notify individuals of the purposes of collection and their rights;
- only use and disclose personal information for the primary purpose of collection, or for a related purpose an individual would reasonably expect;
- obtain consent before collecting sensitive information, such as health or disability-related information;
- take reasonable steps to ensure the personal information we hold is accurate, complete, up to date and protected from misuse, interference, loss and unauthorised access;
- allow individuals to access and correct the personal information we hold about them; and
- have processes in place for handling privacy complaints and queries.
4. What information we collect
The types of personal information we may collect include:
- Identity and contact details — your name, date of birth, residential address, email address and preferred method of contact;
- Support and care information — details of your support needs, goals, plans, routines, preferences and any reasonable adjustments required to deliver services safely;
- Health and disability-related information — diagnoses, medical conditions, medication requirements, behavioural support needs and allied health reports, where relevant to the supports we provide;
- Funding and plan information — NDIS participant numbers, plan details, plan manager or support coordinator details, and information required for invoicing and service agreements;
- Emergency and nominee contacts — details of family members, carers, guardians, nominees or other authorised representatives;
- Employment and contractor information — for team members and contractors, including qualifications, clearances, working rights and references;
- Website and enquiry information — the details you provide through our enquiry and quote forms, and general, non-identifying usage data such as pages visited.
We will only collect sensitive information (such as health, disability or cultural information) where you have consented, where it is reasonably necessary for our service delivery functions, or where another exception under the Privacy Act applies.
5. How we collect information
We collect personal information in a number of ways, including:
- directly from you, when you complete a form on our website, send us an email, or speak with us in person or online;
- from your authorised representative, such as a family member, carer, guardian, plan nominee or support coordinator;
- from referrers, allied health professionals and other providers involved in your care, with your consent;
- from funding bodies or government agencies where relevant to the delivery of your supports; and
- through our website, including through cookies and similar technologies described in section 11.
Wherever practicable, we collect personal information directly from you. If we receive personal information about you from a third party, we will take reasonable steps to let you know and to handle it in accordance with this policy.
6. Why we collect and use your information
We collect, use and disclose personal information so that we can:
- respond to enquiries and provide quotes for our services;
- assess your eligibility and suitability for the supports we offer;
- enter into and manage service agreements with you or your plan nominee;
- plan, deliver, monitor and review safe, high-quality supports tailored to your goals;
- coordinate with other providers, allied health professionals and your support network, with your consent;
- manage invoicing, payments and claims with plan managers or the National Disability Insurance Agency (NDIA);
- meet our legal, regulatory, funding, insurance and quality and safeguards obligations;
- maintain accurate business records and manage complaints, incidents and feedback; and
- recruit, train and manage our workforce and contractors.
We will not use or disclose your personal information for a secondary purpose unless you would reasonably expect us to do so, you have consented, or the use is permitted or required by law.
7. Disclosure of your information
We may disclose your personal information to:
- you, and any person you authorise, including nominees, guardians and carers;
- the NDIA, your plan manager and your support coordinator, where necessary for the funding and delivery of your supports;
- other service providers, therapists or medical practitioners involved in your care, with your consent;
- our professional advisers, such as accountants, insurers and legal advisers, where reasonably required;
- our software and hosting providers who store information on our behalf, subject to strict confidentiality obligations;
- the NDIS Quality and Safeguards Commission, government agencies and regulators, where we are required or authorised by law to do so, including for the reporting of reportable incidents; and
- emergency services, where there is a serious and imminent threat to someone's life, health or safety.
We do not sell, rent or trade personal information. We take reasonable steps to ensure that any third party we engage handles personal information in a manner consistent with the APPs. We do not routinely disclose personal information to recipients overseas; if this ever becomes necessary, we will take reasonable steps to ensure the recipient is subject to comparable privacy obligations.
8. Data quality
We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete, up to date and relevant to the purposes for which it is held. We encourage you to contact us if any of the information we hold about you changes, so that we can update our records.
9. Data security and retention
We hold personal information in electronic records protected by appropriate technical and organisational safeguards, including access controls, password protection and secure cloud storage. Physical records, where kept, are stored securely and access is limited to authorised personnel.
Access to personal information is restricted to team members, contractors and agents who need it to perform their duties, and all personnel are bound by confidentiality obligations.
We retain personal information for only as long as is reasonably necessary to fulfil the purposes described in this policy, to comply with our legal and record-keeping obligations (including those applying to disability service providers), and to resolve disputes. When information is no longer required, we take reasonable steps to destroy it or de-identify it.
10. Access to and correction of your information
You have a right under the APPs to request access to the personal information we hold about you, and to request corrections if you believe it is inaccurate, incomplete, out of date, irrelevant or misleading.
To make a request, please email us at ceo@alignedbeginnings.site with details of the information you would like to access or correct. We will respond within a reasonable period, generally within thirty (30) days. There is no charge for making a request, although we may charge a reasonable fee for providing a copy of a large volume of material.
In limited circumstances, we may refuse access where permitted by the Privacy Act — for example, where granting access would pose a serious threat to the safety of any person or would unreasonably interfere with another person's privacy. If we refuse access, we will provide you with our written reasons and information about how you can complain about the decision.
11. Cookies and website analytics
Our website may use cookies and similar technologies to improve your browsing experience and to understand, in aggregate, how visitors use our site. Cookies are small files stored on your device. Most browsers allow you to refuse cookies or to be alerted when cookies are used; declining cookies may affect some features of the website. Analytics data collected through our website is used in a de-identified or aggregated form wherever practicable, and is not used to identify individual visitors.
12. Anonymity and pseudonymity
Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym — for example, when making a general enquiry about our services. However, in order to deliver personal supports, manage service agreements and meet our regulatory obligations, we will generally need to collect identifying information from clients and participants.
13. Direct marketing
We will only send you marketing communications where you have consented or where you would reasonably expect to receive them and you have a reasonable opportunity to opt out. Every marketing communication we send will include a simple way for you to unsubscribe or ask us to stop. You may opt out of direct marketing at any time by emailing ceo@alignedbeginnings.site. Even if you opt out of marketing, we will still send you service-related communications necessary for the delivery of your supports.
14. Complaints and feedback
If you believe we have breached the APPs or mishandled your personal information, we encourage you to raise it with us so we can resolve the matter promptly:
- By email: ceo@alignedbeginnings.site (attention: Privacy Officer)
- By post: Privacy Officer, Aligned Beginnings Pty Ltd, Perth WA, Australia
Please include details of your concern so we can investigate. We will acknowledge your complaint and aim to provide a written response within thirty (30) days. We will treat all privacy complaints seriously and handle them respectfully, promptly and in accordance with our internal complaint handling procedures.
If you are not satisfied with our response, or if you prefer not to raise the matter with us first, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au. If your concern relates to NDIS services, you may also contact the NDIS Quality and Safeguards Commission.
15. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, technology or legal obligations. The current version will always be published on our website at alignedbeginnings.site/privacy.html, together with the date of the most recent update. We encourage you to review this policy periodically. Continued use of our website or services after an update constitutes acceptance of the revised policy.
16. How to contact us
For any questions about this policy, or about how Aligned Beginnings Pty Ltd handles your personal information, please contact:
Privacy Officer
Aligned Beginnings Pty Ltd
ABN 93 701 353 620
Perth, WA, Australia
Email: ceo@alignedbeginnings.site
Website: https://alignedbeginnings.site
You may also wish to review our Terms & Conditions or contact us about any other matter.