Privacy Policy

About this policy

The privacy of the personal information you provide to us is important to us. InPlace Living Pty Ltd (ABN 49 645 180 829) (we, us, our, or the Group - including our subsidiaries, employees, suppliers and contractors who assist you) provides Specialist Disability Accommodation (SDA) and disability supports, including to participants in the National Disability Insurance Scheme (NDIS). We are committed to protecting your privacy and handling your personal and health information with care, dignity and respect. This policy explains what information we collect, how we use and share it, how we keep it safe, and your rights. It applies to participants, residents, their families and representatives, prospective participants, staff, contractors and visitors.

The laws we follow

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the Health Records Act 2001 (Vic) and the Health Privacy Principles, and our obligations under the National Disability Insurance Scheme Act 2013 (Cth), the NDIS Code of Conduct and the NDIS Practice Standards.

1. The information we collect

The kinds of personal information we collect depend on our relationship with you and the supports we provide. They may include:

- Identity and contact details (name, date of birth, address, phone, email);

- NDIS number, plan details, goals and funding information (including SDA plan and funding status);

- Health and disability information relevant to your supports (diagnoses, medications, care and support needs, allied health and behaviour support information);

- Accommodation and tenancy information (SDA enrolment, residency and tenancy records, and information about your home and living needs)

- Assessments and reports (including occupational therapy, functional and behavioural assessments);

- Support and case notes, incident and complaint records, and restrictive practice records where relevant;

- Details of your family, carers, guardians, nominees or other representatives, and emergency contacts, and people authorised to act on your behalf;

- Financial and payment information needed to deliver and claim for supports;

- Feedback, enquiries, consent forms, and competition or promotion entries; and

- Records of your consents, communication and marketing preferences.

We only collect sensitive information (including health information) with your consent, or where otherwise permitted by law, and only where it is reasonably necessary for our functions.

2. How we collect it

We usually collect information directly from you - for example through our website, by email, over the phone, at property or open inspections, during interviews and assessments, and when you take part in enquiries, feedback, competitions or promotions. Where you are unable to provide it yourself, or where appropriate, we may collect it from your family, carers, guardian, nominee or authorised representative. We may also collect information from the National Disability Insurance Agency (NDIA), support coordinators, health and other service providers, and referrers - with your consent or as authorised by law.

3. Giving us information about others, and children

If you give us personal information about another person (for example a family member, emergency contact or someone you represent), you confirm that you are authorised to do so, that you have their consent for us to collect, use and disclose their information as set out in this policy, and that you will let them know they can access the information we hold about them.

If you are under 18 years of age, please obtain the approval of a parent or guardian before providing your personal information to us.

4. Why we collect and use your information

We collect, hold and use your information to:

- Provide and coordinate your accommodation, supports and services;

- Manage your tenancy and the safety, suitability and maintenance of your home;

- Plan, review and improve your supports, and keep you safe (including safeguarding and incident management);

- Respond to your enquiries, feedback and complaints;

- Communicate with you, your representatives and other providers involved in your care, and (where you have not opted out) send you marketing;

- Administer NDIS funding, service agreements, invoicing and claims;

- Carry out our internal administration, planning, service development and research;

- Meet our quality, compliance, record-keeping and reporting obligations; and

- Comply with the law and respond to complaints, audits and investigations.

We will only use your information for a purpose you would reasonably expect, that is directly related to why we collected it, or as you have consented to or the law requires.

5. Direct marketing

From time to time, we may send you information about our services, offers, promotions, news, events and updates. These communications may be sent by email, SMS, phone, post or social media, and by providing your contact details you consent to receiving them.

You can opt out of marketing communications at any time - by using the unsubscribe link in our emails or SMS messages, or by contacting us using the details in “Contact us”. Even if you opt out of marketing, we may still need to send you essential communications about your supports and our services.

6. Sharing your information

We treat your information as confidential and only share it where necessary. We may share your information with: Adenium Living – which is the South Australian arm of our business. Adenium Living is a separate but related disability services organisation we work with - through a shared, secure client system so that authorised staff across both organisations can coordinate and deliver your supports; your support network (such as your support coordinator or Supported Independent Living provider); the NDIA and the NDIS Quality and Safeguards Commission; health and other providers involved in your care; our contracted service providers (such as secure IT systems) under strict confidentiality obligations; and government agencies, regulators, or others, where required or authorised by law. We do not sell your information, and we do not trade or rent it to third parties for their own marketing.

Our arrangement with Adenium Living

InPlace Living and Adenium Living remain separate legal entities, each responsible for protecting your information. Our staff work under a single, aligned set of privacy and information-handling policies and a data sharing agreement, and access to your information is limited to those who need it to support you.

7. Our use of artificial intelligence (AI)

We use approved, business-grade artificial intelligence tools (such as Claude) to help our staff draft, summarise and organise information as part of delivering your supports - for example, helping to prepare notes or documents. When we do this:

- A suitably skilled staff member always reviews AI-assisted content, and we do not rely on AI alone to make decisions that significantly affect you;

- We only use approved tools, and staff are not permitted to enter your information into public or consumer AI tools;

- Our AI provider is contractually prevented from using your information to train or improve its models; and

- We apply data-minimisation, security and retention controls, and you can ask us not to use AI to process your information (see “Your choices” below).

8. Overseas disclosure

Where your information is processed

The approved AI tool we use (Claude) processes and stores information on servers located in the United States. This means that when your information is processed by that tool, it is disclosed to and handled overseas. We have assessed this arrangement and take reasonable steps to protect your information, including: a data processing agreement that requires the provider to protect your information and not use it to train its models; configuring the tool for minimal or zero data retention; confining processing to the United States; enabling enterprise security controls; applying data minimisation; and relying on the provider's independent security certifications.

Your choice

We tell you about this overseas processing so you can make an informed decision, and you can opt out of having your information processed by our AI tools at any time without affecting the supports you receive. If you would prefer that we do not use AI tools to process your information, please contact us.

9. How we keep your information safe

We take reasonable steps to protect your information from misuse, loss, and unauthorised access, modification or disclosure. These steps include secure systems with role-based access and unique user accounts, password protection, staff, contractor and supplier confidentiality obligations and training (our people sign a confidentiality deed before they are given access to your information), access logging, and a data breach response plan. Access to information held electronically is restricted to employees, contractors and suppliers whose role requires it. If a data breach occurs that is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner as required by law.

10. How long we keep your information

We keep your information only as long as needed for the purposes above and to meet our legal obligations. As an NDIS and health service provider, we are generally required to keep participant and health records for at least 7 years after our last service to you - and, for information collected while a person was under 18, until they turn 25. When information is no longer required, we securely destroy or de-identify it.

11. Accessing and correcting your information

You can ask us for access to the personal information we hold about you and for copies of it. We will endeavour to respond within 30 days. In some cases, a small administrative fee may apply to cover the reasonable cost of providing it, and in limited circumstances we may not be able to give full access, in which case we will explain why.

If you believe the information we hold is inaccurate, out of date or incomplete, you can ask us to correct it. We will consider your request; if we do not agree that a change is needed, we will add a note recording that you disagree. Please contact us to make an access or correction request.

12. Website, cookies and analytics

When you use our website, we may collect limited technical information to help the site work and improve it, such as the date and time of your visit, the pages you view and time spent, your device type and general location, and how you reached our site (for example a search engine or social media). We use cookies and analytics tools, including Google Analytics, for these purposes. You can set your browser to accept or block cookies; if you block them, parts of our website may not work properly.

Our website may contain links to, or feature, third-party websites. We are not responsible for the content or privacy practices of those websites - please review their own policies and contact them directly with any concerns.

13. Making a complaint

If you have a concern about how we have handled your information, please contact us first - we take complaints seriously and will work with you to resolve them. If you are not satisfied, you can also contact: the Office of the Australian Information Commissioner (oaic.gov.au); the Health Complaints Commissioner (Victoria) (hcc.vic.gov.au) for health information; and, for concerns about your NDIS supports, the NDIS Quality and Safeguards Commission (ndiscommission.gov.au).

14. Your choices

You can ask us to limit how your information is shared, opt out of marketing, opt out of AI processing, update your preferences, or withdraw a consent you have given, by contacting us. Where you need support to make these decisions, we will help you, and we will work with your representative where you have one.

15. Changes to this policy

We may update this policy from time to time. The current version is always available on our website, and we will make the updated date clear at the top. Please check it regularly. We will let you know about significant changes where appropriate.

16. Contact us and feedback

InPlace Living - privacy enquiries

Email: info@inplaceliving.com.au     Phone: 03 8639 0131

Post: Level 8, 179 Queen Street, Melbourne VIC 3000