Caringbuddy Pty Ltd prioritise the protection of your personal information. Your privacy holds significant importance to us and is central to our operations for maintaining patient trust and complying with regulations. For details regarding our practices in collecting, managing, sharing, and safeguarding your information while utilizing our website, services, and products, please refer to the comprehensive outline available on our privacy page.

1. Introduction

 

Caring Buddy’s policy is to respect and protect the privacy of all people connected with the National Disability Insurance Scheme (NDIS) inclusive of participants, providers, employees and contractors. In dealing with personal information, Caring Buddy abides by the obligations imposed under federal law, inclusive of the Privacy Act 1988 (Cth) and the National Disability Insurance Scheme Act 2013 (Cth).

This Privacy Policy relates to the personal information we gather and maintain about individuals who:

• • visit our website (https://www.caringbuddy.com.au/),
  • utilize any services provided by Caringbuddy,
  • apply for employment opportunities with Caringbuddy, with such information potentially submitted through the associated Caringbuddy careers portal,
  • are collected by or on behalf of a law enforcement agency, in accordance with applicable legislative requirements.

We encourage you to read this Privacy Policy thoroughly, along with any additional privacy notices we may provide during specific instances of collecting or processing your personal data. This will ensure you are aware of how and why we collect, store, use, and share your personal information. Furthermore, this Privacy Policy outlines your rights concerning your personal information and provides guidance on how to reach us or relevant supervisory authorities should you wish to file a complaint.

This Privacy Policy is issued on behalf of Caringbuddy Pty Ltd; therefore, when we refer to “Caringbuddy,” “us,” “we,” or “our” within this document, we are referring to the division of Caringbuddy responsible for processing your personal data. The specific Caringbuddy division handling your personal information will be the one that initially collects data from or about you, which may be detailed in separate privacy notices provided at the time of collection.

In instances where the collection and use of personal information are not covered by this Privacy Policy, the privacy notice provided at the time of data collection will take precedence.

2. Principles of Data Protection

When we refer to “personal data” or “personal information” in this Privacy Policy, we are indicating information (including opinions) that pertains to you and can be used to identify you, either on its own or in conjunction with other information that we may possess.

To enhance your understanding of our management of your personal information, we present a summary of the data protection principles that govern our use of your personal information. These principles stipulate that personal data must be:

1. 1. Utilised in a lawful, fair, and transparent manner;
   2. Collected solely for legitimate purposes that we have explicitly communicated to you, and not employed in any manner that contradicts those purposes;
   3. Secured appropriately.
   4. Relevant to the stated purposes and restricted to those purposes only;
   5. Accurate and regularly updated;
   6. Retained only for the duration necessary to fulfill the purposes we have outlined; and

Our website may contain links to third-party websites. Caringbuddy disclaims any responsibility for the actions of non-Caringbuddy entities linked to our site, and we encourage you to review the privacy notices of these third parties regarding their handling of your personal information.

3. Kinds of information we collect

• Types of personal data collected

The following outlines the categories of personal data that we gather on our website:

• • Personal Information: title, full name, date of birth, age, gender, address, telephone numbers, email address, visa and immigration status, nationality, spoken language and dialect, preferences, subscriptions, and hobbies.

• • Visual and Audio Material: your photograph, video footage, and audio recordings that may include your voice.

• • Family and Friends Information: names and contact information of family members, dependents, and emergency contacts.

• • Employment History: business activities, work experience, job roles, references, work address, work telephone number, previous and current names and contact details of employees, and work-related social media profiles.

• • Educational Background: institutions attended, qualifications earned, and additional training received.

• • Consents: permissions or preferences you have indicated, such as your willingness to receive direct marketing by subscribing to Caringbuddy news and media alerts, Caringbuddy regulatory news alerts, Caringbuddy job alerts, or your agreement to the terms and conditions for submitting an employment application.

• • Interview Information: responses provided during interviews and feedback from interviewers.

• • Sensitive Personal Data: health and medical information, political beliefs or affiliations, trade union membership, ethnicity, religion, and sexual orientation.

• • Criminal Record Information: details regarding criminal convictions and offenses, including civil barring information.

• • Website Access Information: your computer’s unique identifier (e.g., IP Address), the date and time of your website access, and passwords for accessing alert preferences.

• Correspondence: responses, comments, views, and opinions shared when you communicate with us, such as during a complaint or while participating in a video interview.

• Information we automatically collect from you

1. 1. We may gather personal data regarding you under the following circumstances:

• • When you provide personal data directly (for instance, during your application for a position and registration with us, as well as through subsequent communications via email, telephone, or Skype);
  • When personal data is obtained in the usual course of our interactions with you (such as during interviews or while delivering services);
  • When personal data is recorded during a video assessment as part of a Caringbuddy recruitment initiative;
  • When personal data is sourced from your designated referees or representatives;
  • When you publicly share personal data (for example, by reaching out to Caringbuddy through a social media platform regarding potential career opportunities);
  • When we receive personal data from third parties, including for the purpose of verifying the information you have provided (such as recruitment agencies, previous employers, law enforcement agencies, and disclosure and barring service checks);
  • When personal data is collected during your visits to our website or while utilizing any features or resources available on or through the website (including the careers portal and marketing subscriptions), some of which may include personal data; or
  • When we generate personal data, such as records of your communications with us or reports from your job interviews and service provisions;
  • Demographic details;
  • Financial information, including payment and credit histories;
  • Sensitive personal information such as information about your health or disability, doctors or other health professionals you have seen or health services you have received and biometric data;
  • When you provide personal information about others, such as authorized representatives.

1. Cookies

Cookies serve the purpose of facilitating communication with a user during a website session. A cookie is a small file provided by Caringbuddy, which is saved by your web browser on your computer upon accessing the Caringbuddy website. These cookies enable Caringbuddy to identify individual web users as they navigate through the site. Importantly, they do not retain any personal information. Users have the option to disable cookies by modifying their web browser settings; however, doing so may limit their ability to utilize the full range of features available on the Caringbuddy website.

4. Purpose and use of personal Data

Caringbuddy will utilize or disclose personal information, including health information, solely under the following conditions, in accordance with Caringbuddy’s Information Systems Policy and Procedure:

• • For the primary purpose for which the information was originally collected, or
  • For a directly related secondary purpose that falls within the reasonable expectations of the individual concerned, or with the individual’s consent, or
  • To process a NCCHC application via NPCS, the Australian Criminal Intelligence Commission (ACIC), Australian Police Agencies, and associated entities, and to obtain results pertaining to the NCCHC application, or
  • For research or statistical analysis related to public health or public safety, in compliance with applicable legislative requirements, or
  • To mitigate or prevent specific threats to individual or public health and safety, in accordance with relevant legislative requirements, or
  • For investigations into suspected or confirmed unlawful activities, subject to the relevant legislative requirements, or
  • For uses or disclosures that are permitted or mandated by law, or
  • For activities associated with law enforcement bodies, in compliance with relevant legislative requirements (noting that a record must be maintained of such use or disclosure), or
  • To communicate with the individual responsible for the patient when the patient is unable to provide or communicate their consent, in accordance with relevant legislative requirements, or
  • For the funding, management, planning, monitoring, improvement, or evaluation of health services, or for the training of employees or individuals working with Caringbuddy, subject to relevant legislative requirements, or
  • For internal auditing, quality control, system updates, and other internal procedures mandated by Caringbuddy, or
  • For any other use as permitted or required by law, including applicable privacy laws and any future regulations or guidelines.

Personal employee information collected by Caringbuddy during the use of ACIC for criminal history verification will be retained for a period of three years in accordance with the stipulations of the Aged Care Act 1997. In instances where a third party requests information, personal details, including contact and health information, will not be shared unless explicit consent is obtained from the individual concerned or Caringbuddy is legally required to provide such information. Furthermore, Caringbuddy’s intellectual property, regardless of its commercial sensitivity, shall not be disclosed without the explicit permission of a member of the Caringbuddy Executive team.

5. Information about Criminal Convictions

if you apply for a specific position that necessitates vetting, we may be obligated to conduct such checks. This process may entail the collection and utilization of sensitive information derived from criminal records checks, including details of offenses or alleged offenses, as well as any current or past criminal proceedings. We perform criminal records checks for the following reasons:

• • To fulfill our legal obligation to verify an individual’s eligibility to work in Australia; and
  • To serve our legitimate interests or those of a third party, as necessary, in exercising our rights as an employer to conduct pre-employment screening, which may include a comprehensive background and criminal records check, depending on the position:
    1. to determine whether an applicant has engaged in unlawful activities or has a history of dishonesty, malpractice, or other serious misconduct; or
    2. to meet government and registration requirements.

We have established appropriate policy documents and safeguards that we are legally required to uphold when processing such data.

6. Disclosing your personal information

• Sharing your personal information with others

We will disclose personal information to third parties only under very specific circumstances or when legally permitted. The third parties to whom we may share your personal data include:

• • Entities within the Caringbuddy Group of companies, where such sharing is essential for delivering our services or managing our operations (for instance, for recruitment purposes).
  • Clients when necessary for particular business objectives, such as additional vetting processes.
  • Financial institutions and payment processors to authorize and finalize transactions.
  • Credit reference agencies and organizations dedicated to preventing fraud in financial services.
  • Caringbuddy’s external service providers, including IT suppliers, infrastructure support services, legal firms, and other partner organizations.
  • Service providers that assist in drafting and distributing requested news and job alerts.
  • Third parties responsible for conducting pre-employment checks, including relevant vetting services.
  • Professional advisors, such as legal consultants, insurance firms, and auditors.
  • Governmental, regulatory, and law enforcement agencies when required to:
  • Fulfill our legal obligations;
  • Assert our legal rights (for example, to pursue or defend a claim); and
  • Aid in the prevention, detection, and investigation of criminal activities.

We may transfer your personal information to third parties in the context of a reorganization, restructuring, merger, acquisition, sale, or asset transfer, provided that the receiving entity agrees to handle your personal information in accordance with this Privacy Policy.

Caringbuddy will share your personal information exclusively with our contracted service providers after confirming that they possess adequate and effective data protection and security measures. Additionally, we impose contractual obligations on these third parties to ensure that they utilize your data solely for the services provided to Caringbuddy as outlined above. These third parties are prohibited from disclosing your information to any other entities unless directed to do so by Caringbuddy.

7. How we hold and store your personal information

• Security of your personal information

Caringbuddy implements a range of precautions, encompassing administrative, technical, and physical measures, to protect your personal information from loss, theft, and misuse, as well as from unauthorized access, modification, disclosure, alteration, and destruction. We hold personal information in both hard copy and electronic forms in secure databases on secure premises and on secure, cloud-based technology, accessible only by our authorised staff. The destruction or permanent anonymization of personal information when it is no longer necessary for the purposes for which it was collected.

• How long do we keep your personal information?

Caringbuddy will retain your personal information only for the duration necessary to achieve the objectives specified in this Privacy Policy, as well as to comply with relevant legal obligations and internal company regulations. When your personal information is no longer required, we will ensure its secure disposal.

In certain situations, we may retain your personal information for extended periods if mandated by legal or regulatory obligations, or to maintain an accurate record of your interactions with us in case of any complaints or disputes. Additionally, if we have reasonable grounds to anticipate potential litigation concerning your personal information or interactions, we may also retain it for that purpose.

8. Accessing your personal information

• Your legal rights

8.1.1 You possess legal rights concerning your personal information. Under specific conditions, you are entitled by law to:

• • Request access to your personal information. This allows you to obtain a copy of the personal information we maintain about you and to verify that we are processing it lawfully.

• • Request correction of the personal information we hold about you. This grants you the ability to rectify any incomplete or inaccurate information in our records.

• • Request the deletion of your personal information. This permits you to ask us to eliminate or remove your personal information in certain limited situations, such as:

1. 1. 1. when it is no longer necessary for the purposes for which it was collected;
      2. if you have withdrawn your consent (in cases where processing was based on consent);
      3. following a successful objection;
      4. if it has been processed unlawfully; or
      5. to fulfill a legal obligation to which Caringbuddy is subject.

8.1.2 We are not obligated to fulfill your request for deletion of personal information if its processing is essential for various reasons, including:

1. 1. 1. compliance with a legal obligation; or
      2. the establishment, exercise, or defense of legal claims.

• • Object to processing: You may also object to the processing of your personal information by us or on our behalf when such processing is based on our legitimate interests, if you believe that your fundamental rights and freedoms outweigh those interests. Should you raise an objection, we will have the opportunity to demonstrate that our legitimate interests are compelling enough to override your rights and freedoms.

Additionally, you can object at any time to the processing of your personal information for direct marketing, profiling, or automated decision-making.

• • Request the restriction of processing of your personal information. This allows you to ask us to pause the processing of your personal information, but only in circumstances where:

1. 1. 1. its accuracy is disputed, enabling us to verify its correctness;
      2. the processing is unlawful, yet you do not wish for it to be deleted;
      3. if the information is no longer necessary for the purposes for which it was originally collected, but we require it to establish, exercise, or defend legal claims; or
      4. if you have invoked your right to object, and we are in the process of verifying any overriding grounds.

8.1.5 We may continue to process your personal information after a request for limitation in the following situations:

1. 1. 1. if we have obtained your consent;
      2. to establish, exercise, or defend legal claims; or
      3. to safeguard the rights of another individual or entity.

• • Request the transfer of your personal information. You may request that we provide your personal information to you in a structured, commonly used, machine-readable format, or you may ask for it to be transferred directly to another data controller, provided that:

1. 1. 1. the processing is based on your consent or the fulfillment of a contract with you; and
      2. the processing is conducted through automated means.

We retain the authority to impose a fee when legally permissible, such as in cases where your request is evidently unreasonable or disproportionate.

We may not be able to completely fulfill your request in all instances, particularly if it would compromise our obligation of confidentiality to third parties, or if we are legally obligated to handle the request in an alternative manner.

• Protection Contracts

You may access your personal information held by Caringbuddy Pty Ltd by logging into your Account and making changes at any time. Alternatively, you have a right to ask for access to the personal information we hold about you. A Privacy Officer has been designated to ensure adherence to this Privacy Policy. Should you have any inquiries regarding this Privacy Policy or our management of your personal information, please direct them to:

Privacy Officer,

Caringbuddy Pty Ltd

Postal address: PO Box 388 Auburn NSW 1835

You may also reach us via email at privacy@caringbuddy.com.au or by telephone.

• Changes to this Privacy Policy

This Privacy Policy may be revised periodically to ensure compliance with legal standards and to reflect our business practices. We encourage you to visit this page frequently to review the most current version of the Privacy Policy.

9. Contact Us

 9.1 Feedback

If you have any feedback or questions about this Privacy Policy or any of our privacy- related practices, please contact our Privacy Officer at privacy@caringbuddy.com.au or via telephone on 1300 001 615.

9.2 Complaints

At all times, privacy complaints will:

• • be treated seriously
  • be dealt with as promptly as possible
  • be dealt with in a confidential manner
  • not affect your existing obligations or affect the commercial arrangements between you and 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 our Privacy Officer at:

Privacy Officer,

Caringbuddy Pty Ltd

Postal address: PO Box 388 Auburn NSW 1835

You may also reach us via email at privacy@caringbuddy.com.au or by telephone.

To lodge a formal complaint, please send details to the Privacy Officer in writing. We will attempt to respond within a reasonable time, usually 30 business days. Caringbuddy treats all privacy complaints seriously and any complaint will be assessed by our Privacy Officer 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.