Personal Information is information or an opinion that identifies an individual, or from which an individual’s identity can be reasonably ascertained (irrespective of whether the information or opinion is true or not, and regardless of whatever form it is recorded in). Examples of your Personal Information that we collect include: names, your occupation, job title and place of business, bank account, financial details and tax information, addresses, email addresses, phone and facsimile numbers, incident reports, developmental records and summaries, custodial arrangements and child care subsidy information.

Sensitive information is defined in the Privacy Act to include information or an opinion about an individual’s racial or ethnic origin, biometrics, genetics, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a trade union, professional or trade association or other professional body, sexual orientation or practices, criminal record or health.

We collect your Personal Information in a number of ways including: directly from you, in person, by telephone and facsimile, by email, via our website and from third parties to whom you make payments in connection with our products or services, or to whom you provide personal details in connection with the receipt of marketing materials. This includes third parties who you authorise to provide us with your Personal Information.

There are also a limited number of situations in which the Privacy Act permits the collection of your and your child’s sensitive information (collectively referred to as ‘your sensitive information’ in this policy), without your consent. An example of this is where the collection of health information about an individual is necessary to provide a health service to that individual and the information is required or authorised by or under an Australian law (other than the Privacy Act). Other than circumstances permitted by law, we will not collect or retain your sensitive information unless you consent to the collection and the information is reasonably necessary for our business activities.

You may refuse to provide your Personal Information to us. However, if you exercise this right of refusal, it may affect our ability to meet our obligations to you or to a third party agency.

You may also deal with us anonymously or by using a pseudonym. However, if you do so, we may be prevented from providing you with accurate or useful information, and you may not be able to access our full range of products or services.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. We will only solicit and collect your Personal Information if it is reasonably necessary in order for us to provide our products and services and conduct our functions and activities or we are permitted to do so by law.

We collect, hold and use your Personal Information:

• to provide information in relation to our products and services;
• to better understand our clients and to improve our services;
• to assess any application for employment, during the recruitment process;
• to administer and manage processes which are key to our operations;
• to answer any queries, provide information you may have request and generally conduct dealings with you;
• to effect the collection of money that you owe to us;
• any purpose authorised by you;
• for other purposes for which it was initially obtained and for purposes related to the purpose for which it was initially obtained; or
• to comply with legislative or other legal requirements.

Your Personal Information may be disclosed by us for a number of reasons, including the following:

• to identify you and verify your identity and financial information;
• to provide our services to you and your child or children;
• to improve our website and the products and services that we provide;
• to communicate with you; and
• for other purposes which are related, or directly related (in the case of sensitive information), to the purpose for which your information was initially collected.

We may disclose your personal information to:

• our related parties;
• other companies or individuals that assist us to provide our products or services, or to administer our internal operations. This includes:
• government authorities or other agencies where the disclosure is required or authorised by law;
• anyone else to whom you authorise us to disclose your personal information;
• prospective purchasers of all or substantially all of our assets, in the event of a merger, re-organisation or acquisition of our business;
• information technology/cloud service providers, such as persons who develop any of the software used by our business; and
• external business advisors, such as auditors and lawyers.

Sensitive information will be used or disclosed by us:

• for the purpose for which it was initially obtained;
• for a purpose that is directly related to the purpose for which your Personal information was initially collected;
• with your consent; or
• where required or authorised by law.

There are also a limited number of situations in which the Privacy Act permits the use or disclosure of your Personal Information and your sensitive information, without your consent. An example of this is where the use or disclosure is necessary to prevent a serious and imminent threat to any person’s life, health or safety or a serious threat to public health or safety.

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party, and why it was necessary and reasonable in the circumstances.

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. To help protect the privacy of data and Personal Information collected and held, we maintain physical, technical and administrative safeguards. Security technology is updated and tested on an ongoing basis, however, you must be aware that no data transmission over the internet can be guaranteed as totally secure. Our employees sign confidentiality agreements on commencement of their employment. Access to your Personal Information is restricted to employees who need it to provide services to individuals or to conduct our business. To the extent permitted by law, we accept no responsibility for unauthorised access of any Personal Information held by us. However, in the event of any such unauthorised access and/or disclosure, we comply with our obligations under the Privacy Act in dealing with any such unauthorised access and/or disclosure, including any obligations in respect of eligible data breaches within the meaning of the Privacy Act.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

You may request, and we will provide you with, access to your Personal Information or access to update and/or correct your Personal Information, subject to certain exceptions, such as if granting access would have an unreasonable impact on the privacy of others, where the request is frivolous or vexatious, we are unable to verify your identity, we are entitled to reject access to your Personal Information pursuant to any law or if access would be unlawful. If you wish to access your Personal Information, you may do so on any online account that you maintain with us or by contacting us in writing.

Ladybird Manor will not charge any fee for your access request or correcting your Personal Information but we may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you. Prior to correcting or updating your Personal Information, we may request further details from you to verify your identity. We reserve the right not to grant your request for correction or updating if we cannot verify your identity to our reasonable satisfaction.

This policy may change from time to time and is available on our website.

If you believe that we have breached this policy, please contact management using the details provided below. We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your compliant to be frivolous, vexatious or without legal or factual merit. If you are not satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner.

If you have any queries or require further information, please contact us at:

info@ladybirdmanor.com.au
121-139 Grote Street, Adelaide SA 5000
08 8212 1350