1. Who we are
Willow Franklin Supports Pty Ltd (ABN 91 701 373 051) provides disability and community support services across Perth, Western Australia. We are committed to protecting the privacy and dignity of every person who engages with us, including participants, families, carers, referrers and our team members.
2. Our commitment under the Australian Privacy Principles
This policy describes how we manage personal information in accordance with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs). Where we handle information about participants of the National Disability Insurance Scheme (NDIS), we also have regard to our obligations under the NDIS Practice Standards and the NDIS Code of Conduct.
3. The kinds of information we collect
Depending on your dealings with us, we may collect and hold:
- your name, date of birth and contact details;
- information about your support needs, goals and preferences;
- health, disability and other sensitive information relevant to delivering safe supports;
- details of your NDIS plan or funding arrangements, where applicable;
- emergency contact and next-of-kin details;
- records of the supports we deliver, including progress notes and incident reports;
- billing, invoicing and payment information; and
- enquiries, complaints and feedback you provide to us.
4. How we collect personal information
We collect personal information in a number of ways, including:
- directly from you, when you contact us by email, complete a form on our website, or speak with us in person;
- through referral information provided by you, a family member, carer, support coordinator or plan manager;
- during service delivery, when our support workers record progress notes; and
- from third parties where you have consented, or where otherwise permitted by law.
Where it is reasonable and practicable, we collect personal information directly from you. If we receive information about you from another source, we will take reasonable steps to let you know, consistent with APP 5.
5. Why we collect, hold, use and disclose personal information
We collect, hold, use and disclose personal information so that we can:
- assess whether our services are suitable for you and respond to enquiries;
- plan and deliver safe, person-centred supports;
- communicate with you, your nominated contacts and your support network;
- manage funding, billing and invoicing arrangements;
- meet legal, regulatory, quality and safety obligations, including reporting to the NDIS Commission where required;
- handle complaints, feedback and incidents; and
- improve our services through internal review and staff training.
6. Sensitive information
Some of the information we hold, such as health and disability information, is classified as sensitive information under the Privacy Act. We will only collect sensitive information with your consent, or where the collection is required or authorised by law. We recognise the extra care required when handling sensitive information and apply strict internal controls accordingly.
7. Disclosure of personal information
We do not sell or rent personal information. We may disclose personal information to:
- your nominated family members, carers or support coordinators, with your consent;
- health professionals and allied health providers involved in your care, with your consent;
- the National Disability Insurance Agency (NDIA) and the NDIS Commission, where required for plan, funding or regulatory purposes;
- our professional advisers, such as accountants and insurers, where necessary; and
- law enforcement or other agencies, where we are required or authorised by law.
8. Cross-border disclosure
We take reasonable steps to keep personal information within Australia. If we ever need to disclose personal information to an overseas recipient, we will do so only with your consent or in circumstances permitted by APP 8, and we will take reasonable steps to ensure the recipient handles the information consistently with the APPs.
9. Data quality and security
We take reasonable steps to ensure the personal information we hold is accurate, complete and up to date. We also take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. These steps include secure storage systems, restricted access on a need-to-know basis, staff confidentiality obligations and secure destruction or de-identification of records when they are no longer required and retention periods have ended.
10. Access to and correction of your personal information
You may request access to the personal information we hold about you, and you may ask us to correct information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond to access and correction requests within a reasonable time. There is no charge for making a request. In limited circumstances, we may decline a request where permitted by the APPs, and we will explain our reasons in writing.
11. Anonymity
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, we generally need identifying information to deliver supports, manage funding arrangements and meet our regulatory obligations.
12. Our website and cookies
Our website may use cookies and similar technologies to improve your browsing experience and understand how the site is used. You can adjust your browser settings to refuse cookies, although some parts of the site may not function correctly as a result. We do not use website analytics to identify individual users.
13. Complaints and privacy enquiries
If you have a question about this policy, wish to access your information, or believe your privacy has been breached, please contact us:
- Email: ceo@willowfranklinsupports.site
- Post: Privacy Officer, Willow Franklin Supports Pty Ltd, Perth WA
We will acknowledge your complaint promptly and aim to resolve it within 30 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
14. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version will always be published on this page, along with the date of the most recent update.