Privacy Policy
1. Lead Consulting Services Pty Ltd ABN 33 6334 70587 (Lead Consulting) is a registered NDIS Service Provider, providing plan management and support co-ordination services.
2. We are committed to protecting your privacy and handling your personal information in accordance with our obligations under the Privacy Act (Cth)and the Australian Privacy Principles (APP). As a NDIS Service Provider, we also have to comply with secrecy provisions of the National Disability Insurance Scheme Act 2013(Cth) (NDIS Act).
3. This Privacy Policy explains how Lead Consulting manages and handles the personal information it collects, holds, uses and discloses. This Policy also explains the rights that individuals have to access their personal information that is held by Lead Consulting and seek correction of their personal information.
4. Information about how Lead Consulting manages and handles personal information relating to its employees and contractors is in a separate “Lead Consulting – Employee and Contractor Privacy Policy”. Lead Consulting may also issue privacy statements relating to specific services or activities.
5. This policy does not cover non-personal information management related to business records, data retention practices and cybersecurity measures.
6. A copy of this Privacy Policy is accessible on Lead Consulting’s website located at https://leadconsultinggroup.net.au. You can also request a copy of Lead Consulting’s Privacy Policy from our Privacy Officer.
7. This Privacy Policy may be updated and changed from time to time to reflect changes in how we manage personal information and/or changes in privacy laws. Lead Consulting will publish an updated privacy policy on our website.
Information We Collect and Hold
8. The personal information Lead Consulting collects and holds is reasonably necessary for or directly related to Lead Consulting’s functions or activities as a NDIS Service Provider, and when required to do so by law. We collect personal information:
a. When a NDIS participant or their representative, nominee or legally appointed decision maker is referred to, contacts or visits Lead Consulting regarding the provision of NDIS plan management and/or NDIS support co-ordination services and entering into a Services Agreement with Lead Consulting.
b. While a NDIS participant is receiving NDIS plan management services and support co-ordination services from Lead Consulting under our Services Agreement.
c. When a NDIS participant and/or their representative, nominee or legally appointed decision maker provides consent for the collection of personal information and sensitive information.
d. When personal information and sensitive information concerning the NDIS participant and/or their representative, nominee or legally appointed decision maker is shared with Lead Consulting by National Disability Insurance Agency (NDIA), NDIS Quality and Safeguard Commission, other government agencies, government departments, external support providers, carers, medical and health service providers and hospitals.
e. When managing funding for supports in a NDIS participant’s plan and connecting with third party NDIS service providers.
f. When we coordinate supports and connect NDIS participants to service providers and when we find transitional supports.
g. When we make referrals to service providers including occupational therapy, physiotherapy, nursing, speech therapy and other therapeutic and allied health services.
h. When receiving, assessing and investigating a complaint.
i. When undertaking recruitment and assessment processes in respect of employees, contractors or other service providers.
j. When undertaking assessment processes of NDIS service providers and/or their employees for the purpose of referral of or engagement to provide supports and other services to Lead Consulting’s clients.
k. During investigations and compliance activities by a regulatory body.
9. Personal information is information or an opinion about an identified individual or an individual that is reasonably identifiable1. The type of personal information Lead Consulting collects and holds varies depending on the functions and activities we have to perform, and requirements imposed by law and may include the following:
a. Identification information – full name, date of birth, signature and copies of identification documents.
b. Contact details – address, email and telephone numbers.
c. Photographic images, video recordings and audio recordings.
d. Information about your background and personal circumstances such as – education, employment history, occupation, marital status, residency or visa status, preferred language, requirements for interpreter, court orders (such as parenting orders or personal protection intervention orders), compensation claims and determinations.
e. Financial information such as – bank details, payment details and information about business and financial interests.
f. Government identifiers such as – Centrelink customer reference numbers, Medicare numbers, Tax file number and NDIS participant numbers.
g. Information about your family and other related persons such as – any partners, children, dependents, nominees or authorised representatives including name and contact details.
h. Information about persons involved in your care such as carers, medical and allied health professionals including name and contact details.
i. Information related feedbacks and complaints.
10. Lead Consulting may collect sensitive information2 about you if:
a. you have consented to the collection of the information, and the collection is reasonably necessary for, or directly related to, one or more of Lead Consulting’s functions or activities; or
b. the collection is authorized by or required by law;
c. the collection is otherwise allowed under the Privacy Act.
11. The sensitive information that Lead Consulting may collect includes:
a. Gender identity and sexuality and preferred pronouns
b. Cultural background, including your country of birth and languages spoken, nationality and whether you identify as Aboriginal or Torres Strait Islander. Information about your cultural needs.
c. Religious beliefs or affiliations and information about your religious needs.
d. Health and disability information including medical treatment and medical reports.
e. Information about your NDIS support requirements.
f. Information about your current NDIS Plan and history of receiving NDIS supports and services under the NDIS.
g. Criminal history.
How we collect and hold Personal Information
How we collect your Personal Information
12. Lead Consulting collects information through various means including over telephone discussions, Zoom or MS Teams video meetings, face to face meetings or visits, paper and electronic forms, online portals and document management systems, written correspondence and communication, cameras and video and audio recording devices and when you visit and engage with us through Lead Consulting’s website.
13. When you engage Lead Consulting to provide services, we will require you to provide us with your consent to collect, hold, use and disclose your personal information as required for us to provide you with the services and to comply with our reporting requirements and other obligations under the NDIS Act. If you do not provide us with your consent for the collection, holding, use and disclosure of your personal information, we will not to be able to provide you with any of our services.
14. Lead Consulting collects your personal information directly from you or your authorised representatives, where it is reasonable and practical to do so, such as when:
a. you contact us and make an enquiry or provide feedback to us including through Lead Consulting’s website.
b. you apply to use our services or have engaged us to provide services including support coordination and plan management services to you or a NDIS participant that you represent.
c. providing services to you and coordinating your supports and managing your plan and making referrals to NDIS service
providers or other service providers to provide supports and services to our clients.
d. assisting you with making any changes to your NDIS plan or the services that we provide you.
e. you apply to be or become a NDIS service provider for supports or other services to our clients.
f. you provide feedback or make a complaint in relation to a provider of your NDIS supports or Lead Consulting.
15. Lead Consulting also collects your personal information indirectly:
a. from third parties, including:
i. your authorised representative, child representative such as parents
or legal guardians
ii. the NDIA and NDIS Commission
iii. your prior plan manager and support coordinator
iv. NDIS service providers engaged to provide supports to you.
v. disability support providers and carers
vi. health and allied health service providers
b. from third parties who own or operate the security surveillance system located on the ground floor of the building where our offices are located, if we require access to video footage collected by the third parties via the security surveillance system to perform our functions as a NDIS service provider. c. When you interact with us on-line via Lead Consulting’s website.
Lead Consulting website and Cookies
16. When you visit Lead Consulting’s website, we use cookies to collect information about how our website is used. Cookies are small data files which are transferred onto computers or devices by websites for – authentication (keeping you logged in), recording your preferences, analytics tracking usage and browsing behaviour and to enhance the functionality of websites. Most browsers allow you to choose whether to accept or reject some or all cookies. Please check your browser preferences on your computer or device in respect of cookies and set them according to your own preferences. If you do not wish to have cookies placed on your computer or device, please set your browser preferences to reject all cookies.
17. Lead Consulting website uses the following cookies:
a. Analytics cookies (Google Analytics) – to track website usage and performance.
b. Security cookies – to protect the site from malicious traffic and bots.
c. Functional cookies – required for basic website functionality.
18. Lead Consulting uses the cookies on its website to:
a. Monitor website traffic and user behaviour (e.g. pages visited, time on site).
b. Improve website performance and user experience.
c. Protect the website from spam, bots, and security threats.
d. Ensure the website functions correctly.
19. The cookies we use on our website collect the following kinds of information:
a. IP address (anonymised via Google Analytics where applicable)
b. Browser and device information
c. Pages visited and time spent on the site.
d. General location data (e.g. city-level)
How we hold and store your Personal Information
20. Lead Consulting holds and stores personal information that we collect in formats including
a. on computers, laptops and mobiles issued by Lead Consulting,
b. on cloud -based databases and client management systems,
c. on cloud storage facilities on servers located in Australia and owned and operated by third party cloud service providers.
d. paper based files in respect of personal information collected prior to Lead Consulting having transitioned to all information and data being stored and collected in electronic format.
21. Lead Consulting retains control over personal information that is stored on cloud-based databases and client management systems and on cloud storage facilities on servers located in Australia.
22. Lead Consulting takes reasonable steps to protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification and disclosure. These include:
a. we engage third party technology service providers to manage and
maintain the security of our IT systems in compliance with appropriate
industry standards.
b. Storing paper-based records in secure storage.
c. limiting access to personal information to a need-to-know basis by authorised personnel using authenticated credentials.
d. ensuring that access to our office is secure.
23. Subject to requirements under Australian law or court/tribunal orders to retain personal information, documents and business records, Lead Consulting will take reasonable steps to destroy, delete or de-identify personal information that is no longer required for business purposes and does not have to be retained under Australian law or court/tribunal orders.
Purposes for collection, holding, use and disclosure of Personal Information. Purposes for collection and holding Personal information
24. Lead Consulting only collects and holds personal information that is reasonably necessary for and directly related to our functions and activities as a NDIS service provider and to perform our business functions and activities in, which include:
a. providing services to our clients including plan management and/or support coordination services.
b. responding to any enquiries in relation to our services.
c. assisting our clients or their authorised representatives in making any
changes to our clients’ NDIS plans or how Lead Consulting will provide its services.
d. undertaking assessments of third-party NDIS service providers and/or their employees/contractors for the purpose of referral of or engagement to provide supports and services to our clients.
e. making referrals to third party NDIS service providers or other service providers to provide supports and services to our clients.
f. arranging and co-ordinating the supports and services from third party NDIS service providers and other service providers.
g. monitoring the supports and services provided by third parties to our clients.
h. responding and dealing with any requests or complaints that our clients or authorised representatives may make about third party NDIS service providers, carers and supports or Lead Consulting.
i. complying with legal, regulatory, accounting, reporting, audit compliance and our obligations as a registered NDIS service provider under the NDIS Act.
25. If you do not agree to Lead Consulting collecting personal information, we will not be able to:
a. provide our services including NDIS plan management services and support coordination and act as a NDIS Plan Manager or NDIS Support Coordinator for NDIS participants and/or their authorised
representatives.
e. assist our clients and/or their authorised representatives in engaging third party NDIS service providers and other service providers to provide supports and services.
Purposes for use and disclosure of personal information.
26. Lead Consulting uses or discloses personal Information for the purpose for which it was collected (primary purpose). We may also use or disclose personal information for other purposes (secondary purposes) that are related to the primary purpose, where:
a. you have expressly or impliedly consented to the use or disclosure;
b. you would reasonably expect us to use or disclose the information for the secondary purpose;
c. we consider it necessary to ensure your health and safety or the health and safety of another NDIS Participant or an employee/contractor of a NDIS Service provider or another person;
d. the use or disclosure is required or authorised by or under an Australian law or a court/tribunal order or is permitted under Australian privacy laws.
Third party disclosures of Personal Information
27. Lead Consulting may also disclose personal information to third parties including:
a. NDIA in order to provide our services including plan management services and support coordination services to our clients, including reporting on plan usage and if necessary, assisting you to request a plan review;
b. The NDIS Commission, in order to respond to requests for information or assist the NDIS Commission in respect of complaints and
investigations;
c. Third party NDIS service providers and/or their employees/contractors who are providing direct support and care services to our clients.
d. Health and allied health services providers providing or who will be providing services to our clients.
e. Third party service providers who we engage to enable us to provide our services, such as technology service providers;
f. Our legal and professional advisors, auditors and consultants; and
g. Courts, tribunals, and other government departments or agencies where required under Australian Law.
28. Lead Consulting, in the process of referring and/or engaging third party NDIS service providers and other service providers on behalf of our clients, will disclose to our clients and/or their authorised representatives personal
information (namely contact details) of employees/contractors of the service
31. It is important that the personal information you have provided to us is up to-date, accurate and complete. You can make a request for us to
providers or other individuals who will be providing supports and care services to our clients.
Disclosure of Personal Information to overseas recipients.
29. We do not disclose any of your personal information that we collect to overseas recipients unless directed to do so by you.
How you can access your personal information and seek correction.
30. The Australian privacy laws give you a right to request access to or correction of the personal information that we hold about you in certain circumstances.
provide a copy of your personal information or correct any of your personal
information by emailing our Privacy Officer, whose contact details are in the “Our Contact Details” section of this policy, below.
32. If you make a request for us to provide a copy of your personal information or to correct any of your personal information we hold:
a. We will require you to verify your identity, using
appropriate means, before we act on your request;
b. We may refuse your request for access or correction of your personal information, where the relevant privacy laws allow us to do so. If we refuse your request, we will notify you in writing setting out the reasons for our decision as required by Australian privacy laws.
Privacy Breach Complaints
33. If you have any concerns about your privacy or seek to make a written complaint to us about how we have handled your personal information or that we have not complied with the privacy law, you may use the contact details provided in the “Our Contact Details” section of this policy below to submit a written complaint to our Privacy Officer.
34. Where you have submitted a written complaint we:
a. May request you to provide us with further information so that we can investigate the matter;
b. Will investigate the matter and provide you with a written
response to your complaint and how it will be dealt with; and
c. Will keep a record of your complaint, the information you provide us and the investigations undertaken by us in relation to your complaint.
35. If you are not satisfied with the way we have handled your complaint or our response to your complaint, you may also make a formal complaint to the privacy regulator, the Office of the Australian Information Commissioner. See the OAIC website for information regarding how to make a complaint to the OAIC.
Our Contact Details
If you would like to contact us to:
a. Make a request for, or to correct your Personal Information;
b. Make a privacy complaint; or
c. Make an enquiry in relation to anything in this Privacy Policy. Our contact
details are as follows:
Contact: Privacy Officer, Lead Consulting Services Pty Ltd ABN 33 6334 70587
Email: [email protected]
Address: Suite 4.13/89 Overton Road, Williams Landing Vic 3027