Privacy Policy

Privacy Policy

1. Our Commitment to Your Privacy

Endless PossAbilities Disability & Aged Care Services Pty Ltd is committed to protecting the privacy, dignity and confidentiality of every person who engages with our disability support, NDIS, community care and aged care services.

We understand that NDIS participants, families, carers, nominees, advocates and support networks trust us with sensitive information about their health, disability, personal circumstances and support needs. We take this responsibility seriously and aim to handle all personal information respectfully, securely, transparently and only for legitimate service-related purposes.

This Privacy Policy explains:

  • What personal and sensitive information we collect

  • Why we collect this information

  • How we use, store and protect information

  • When information may be disclosed

  • How participants can access or correct their records

  • How to make a privacy enquiry or complaint

  • How we respond to privacy incidents and data breaches

This policy applies to participants, prospective participants, family members, carers, authorised representatives, nominees, advocates, referrers, employees, contractors, volunteers, website visitors and other people who interact with us.

2. About Endless PossAbilities

Endless PossAbilities Disability & Aged Care Services Pty Ltd is a family-operated disability and aged care provider delivering person-centred support services across Sydney.

Our services may include:

  • Assistance with employment and higher education

  • High-intensity personal care supports

  • Daily personal care and assistance

  • Transport and travel assistance

  • Community nursing care

  • Innovative community participation

  • Community-based activities

  • Children’s school holiday programs

  • Support planning and service coordination activities

  • Other disability and community care supports agreed with participants

We collect and use personal information only where it is reasonably necessary to understand a person’s needs, provide safe and suitable supports, meet our legal responsibilities and operate our organisation effectively.

3. Privacy Laws and Standards

We aim to manage personal and health information in accordance with applicable Australian privacy, disability and health information requirements, including:

  • The Privacy Act 1988 (Cth)

  • The Australian Privacy Principles

  • The Notifiable Data Breaches Scheme

  • The Health Records and Information Privacy Act 2002 (NSW)

  • The NSW Health Privacy Principles

  • The National Disability Insurance Scheme Act 2013

  • The NDIS Code of Conduct

  • Applicable NDIS Practice Standards and Quality Indicators

  • Applicable NDIS incident, complaints and record-management requirements

  • Other Commonwealth or NSW laws that apply to our services

Where different legal requirements apply, we will follow the requirement that provides the appropriate level of privacy protection and regulatory compliance.

4. What Is Personal Information?

Personal information is information or an opinion about an identified individual, or a person who can reasonably be identified from that information.

Personal information may include:

  • Full name

  • Residential or postal address

  • Email address

  • Telephone numbers

  • Date of birth

  • Gender or preferred pronouns

  • Emergency contact information

  • Identification documents

  • NDIS participant number

  • Medicare or healthcare details

  • Employment or education information

  • Financial, invoicing and payment information

  • Photographs, video recordings or audio recordings

  • Information about family members, carers or authorised representatives

  • Records of communications, enquiries, referrals and complaints

Some information we collect is classified as sensitive information and receives a higher level of protection.

5. Sensitive and Health Information

Because we provide disability, personal care and community nursing services, we may need to collect sensitive and health information.

This may include information about:

  • A person’s disability, injury, illness or medical condition

  • Physical health and mental health

  • Medical history, diagnoses and treatment

  • Medications, allergies and healthcare requirements

  • Mobility, communication or cognitive support needs

  • Personal care and high-intensity support requirements

  • Behaviour support needs and behaviour support plans

  • Risk assessments and safety plans

  • Hospital admissions or healthcare appointments

  • Nursing assessments and clinical notes

  • Incidents, injuries and emergency events

  • Cultural background

  • Country of birth

  • Preferred language

  • Aboriginal or Torres Strait Islander status

  • Religious beliefs where relevant to support delivery

  • Dietary, cultural or personal preferences

  • Criminal history or worker screening information where legally required

  • Biometric information, photographs or recordings where authorised

  • Information about abuse, neglect, exploitation or safeguarding concerns

We will generally collect sensitive information with the individual’s consent or the consent of an authorised decision-maker, unless collection is required or authorised by law or is otherwise permitted in an emergency or serious safety situation.

6. Information We May Collect

The information we collect will depend on the person’s relationship with us and the services being requested or delivered.

Participant and Referral Information

We may collect:

  • Participant and referrer contact details

  • NDIS participant number and plan information

  • Plan management arrangements

  • Funding information

  • Service agreements

  • Support goals and desired outcomes

  • Requested services and preferred schedules

  • Details of current service providers

  • Support coordinator or plan manager details

  • Guardian, nominee, advocate or representative details

  • Communication and accessibility requirements

  • Interpreter requirements

  • Cultural and linguistic information

  • Emergency contacts

  • Consent forms and participant authorisations

Support and Care Information

We may collect:

  • Support plans

  • Personal care plans

  • Health management plans

  • Nursing and clinical records

  • Medication information

  • Mealtime management requirements

  • Manual handling and mobility information

  • Behaviour support plans

  • Risk assessments

  • Incident reports

  • Progress notes

  • Daily support records

  • Participant goals and progress

  • Community participation records

  • Transport and travel records

  • Appointment information

  • Feedback and complaints

  • Information supplied by healthcare professionals

Children and Young People

For children participating in our school holiday programs or receiving other supports, we may collect:

  • The child’s name and date of birth

  • Parent or guardian contact details

  • Medical conditions and allergies

  • Medication requirements

  • Disability and support needs

  • Emergency contacts

  • Behavioural or communication needs

  • Dietary requirements

  • Activity permissions

  • Collection and drop-off authorisations

  • Photography or media consent

  • Information needed to provide safe and inclusive activities

Employment and Workforce Information

For employees, applicants, contractors and volunteers, we may collect:

  • Contact and identity information

  • Employment history

  • Qualifications and professional registrations

  • References

  • Police checks

  • NDIS Worker Screening Check information

  • Working with Children Check information

  • Right-to-work information

  • Training and competency records

  • Payroll, superannuation and banking details

  • Health information relevant to workplace safety

  • Performance, conduct and incident records

Website and Digital Information

When a person visits our website or submits an online form, we may collect:

  • Name

  • Phone number

  • Email address

  • Service required

  • Referral details

  • Information included in enquiry messages

  • IP address

  • Browser and device type

  • Website usage information

  • Pages visited

  • Date and time of access

  • Cookie and analytics information

People should only provide information through our website that is reasonably necessary for their enquiry or referral.

7. How We Collect Personal Information

Where reasonable and practical, we collect personal information directly from the individual concerned.

We may collect information through:

  • Telephone conversations

  • Emails

  • Website enquiry forms

  • Referral forms

  • Face-to-face meetings

  • Participant intake and assessment processes

  • Service agreements

  • Consent forms

  • Support planning meetings

  • Progress notes and service delivery records

  • Incident and complaint reports

  • Surveys and feedback forms

  • Employment applications

  • Our website, cookies and analytics systems

We may also receive information from:

  • Parents, family members and carers

  • Guardians and nominees

  • Advocates and authorised representatives

  • Support coordinators

  • Plan managers

  • The National Disability Insurance Agency

  • The NDIS Quality and Safeguards Commission

  • Healthcare professionals

  • Hospitals and community health services

  • Allied health providers

  • Schools and educational organisations

  • Government departments

  • Other service providers

  • Emergency services

  • Referring organisations

When information is provided by another person, we will take reasonable steps to confirm that the person is authorised to provide it and that the participant has been informed where required.

8. Why We Collect Personal Information

We may collect, hold, use and disclose information to:

  • Respond to enquiries and referrals

  • Confirm a person’s identity

  • Assess support needs and service suitability

  • Develop individual support plans

  • Prepare and manage service agreements

  • Deliver safe, appropriate and person-centred supports

  • Provide personal care and community nursing

  • Support participant choice, control and independence

  • Communicate with participants and their representatives

  • Coordinate services with healthcare and allied health providers

  • Manage appointments, transport and community activities

  • Monitor participant progress and outcomes

  • Manage medications, health risks and emergency requirements

  • Prevent or respond to abuse, neglect, exploitation or harm

  • Manage incidents and reportable incidents

  • Process NDIS claims, invoices and payments

  • Communicate with plan managers and the NDIA

  • Manage complaints, feedback and service improvements

  • Conduct quality assurance, audits and compliance reviews

  • Meet NDIS registration or regulatory requirements

  • Train, supervise and manage workers

  • Maintain appropriate business and financial records

  • Meet insurance, legal and contractual obligations

  • Protect the rights, safety and wellbeing of participants and workers

  • Improve our services and internal systems

  • Manage recruitment and employment

  • Operate and improve our website

We will not use personal information for an unrelated purpose unless the person has consented or the use is required or authorised by law.

9. Consent, Choice and Control

We support the right of participants to understand and control how their information is collected and used.

Before collecting sensitive information, we will take reasonable steps to explain:

  • What information is being requested

  • Why the information is needed

  • How it will be used

  • Who it may be shared with

  • Whether collection is required by law

  • What may happen if the information is not provided

  • How consent may be changed or withdrawn

Consent may be written, verbal or otherwise clearly communicated, depending on the circumstances and legal requirements.

Participants may withdraw or change their consent by contacting us. Withdrawal will not affect actions already taken with valid consent, and some information may still need to be retained or used where required by law.

Where withdrawing consent means we cannot safely or lawfully deliver a service, we will explain the consequences and discuss available options.

10. Participants with Communication or Decision-Making Support Needs

We aim to provide privacy information in a language, format and communication method that the participant is most likely to understand.

This may include:

  • Easy Read information

  • Plain English explanations

  • Interpreters

  • Visual or picture-based information

  • Additional time to consider decisions

  • Communication devices

  • Assistance from an advocate

  • Involvement of a guardian, nominee or authorised representative

We will involve the participant in privacy and consent decisions to the greatest extent possible, even where another person has legal authority to make decisions on their behalf.

We will verify the authority of guardians, nominees and representatives before disclosing personal information to them.

11. Children and Young People

We take additional care when handling information about children and young people.

Depending on the child’s age, understanding and circumstances, consent may be obtained from:

  • The child or young person

  • A parent

  • A legal guardian

  • Another legally authorised representative

We will consider the child’s maturity, capacity, best interests, safety and right to participate in decisions affecting them.

Information about a child will only be shared with authorised people, service providers or authorities where necessary for safe service delivery, where consent has been provided or where disclosure is required or permitted by law.

12. When We May Share Information

We may disclose personal information where reasonably necessary to provide services, protect a person’s safety, meet legal requirements or operate our organisation.

Information may be disclosed to:

  • The participant’s authorised family members or carers

  • Guardians, nominees and advocates

  • Employees and support workers involved in service delivery

  • Community nurses and healthcare professionals

  • Allied health professionals

  • Support coordinators

  • Plan managers

  • The National Disability Insurance Agency

  • The NDIS Quality and Safeguards Commission

  • Hospitals and emergency services

  • Government departments and regulators

  • Schools or activity providers, where authorised

  • Auditors and quality assessors

  • Insurers

  • Lawyers and professional advisers

  • Financial and accounting providers

  • Information technology and cloud-service providers

  • Records-management and document-storage providers

  • Contractors who assist us in delivering services

We seek to limit disclosures to the minimum information reasonably necessary for the relevant purpose.

Our employees, contractors and service providers are expected to protect confidential information and only access information required for their authorised duties.

13. Disclosure Required by Law or for Safety

We may use or disclose information without consent where permitted or required by law, including where:

  • There is a serious threat to a person’s life, health or safety

  • Emergency medical assistance is required

  • We reasonably suspect abuse, neglect, exploitation or unlawful conduct

  • Mandatory reporting obligations apply

  • A reportable incident must be notified

  • A court, tribunal or law-enforcement authority lawfully requires information

  • Disclosure is necessary for an investigation

  • Disclosure is necessary to establish or defend a legal claim

  • The disclosure is otherwise authorised under applicable privacy or health information laws

Where possible and lawful, we will inform the affected person about the disclosure.

14. Photographs, Videos and Audio Recordings

We will generally obtain consent before taking or using identifiable photographs, video recordings or audio recordings.

Consent will describe the intended purpose, which may include:

  • Participant records

  • Support planning

  • Progress monitoring

  • Incident investigation

  • Training

  • Program activities

  • Website or social media marketing

A participant’s decision not to consent to marketing photography will not affect their access to services.

Marketing images or testimonials will not be published without appropriate consent. A person may withdraw consent for future use by contacting us, although it may not always be possible to remove material that has already been lawfully printed, distributed or shared by third parties.

15. Anonymity and Pseudonyms

People may contact us anonymously or use a pseudonym when making a general enquiry, where practical.

However, we will generally need accurate identifying information to:

  • Complete participant intake

  • Verify NDIS funding

  • Provide disability or nursing supports

  • Manage health and safety risks

  • Respond to emergencies

  • Maintain service records

  • Process payments

  • Meet legal and regulatory requirements

We will explain when identifying information is required.

16. Direct Marketing

We may use contact information to provide service updates, program information or other communications where:

  • The person has consented

  • The person would reasonably expect the communication

  • The communication is otherwise permitted by law

People may opt out of marketing communications at any time by using the unsubscribe option or contacting us directly.

We will not sell participant contact information to third-party marketing organisations.

17. Website Cookies and Analytics

Our website may use cookies and similar technologies to support website functionality and understand how visitors interact with the website.

This information may include:

  • IP address

  • Browser type

  • Device information

  • Pages viewed

  • Time spent on the website

  • Referral source

  • General location information

Website analytics are generally used to improve website performance, accessibility and user experience.

Users may be able to control cookies through their browser settings. Disabling some cookies may affect website functionality.

Our website may contain links to external websites. We are not responsible for the privacy practices or content of external websites, and users should review the privacy policies of those organisations.

18. Overseas Storage and Disclosure

Some technology, email, data-hosting, software or cloud-service providers may store or process information using systems located outside Australia.

Before using third-party systems, we aim to consider their privacy, confidentiality and security arrangements.

Where personal information may be disclosed or accessed overseas, we will take reasonable steps required under applicable privacy laws to ensure that the information is handled appropriately.

Further information about relevant technology providers or overseas data arrangements may be requested from our Privacy Officer.

19. How We Protect Personal Information

We take reasonable administrative, physical and technical measures to protect personal information from:

  • Misuse

  • Interference

  • Loss

  • Unauthorised access

  • Unauthorised modification

  • Unauthorised disclosure

  • Cybersecurity threats

Our safeguards may include:

  • Password-protected systems

  • Access controls based on worker roles

  • Secure cloud storage

  • Multi-factor authentication where available

  • Secure email and communication practices

  • Locked storage for paper records

  • Confidentiality agreements

  • Worker privacy and information-security training

  • Secure disposal processes

  • System backups

  • Software and security updates

  • Incident and data-breach response procedures

  • Regular review of access permissions

  • Monitoring and auditing of information-management practices

Only workers who require information to perform their duties should be permitted to access participant records.

Participants should understand that no method of electronic transmission or storage can be guaranteed to be completely secure. We will nevertheless take reasonable steps to reduce privacy and cybersecurity risks.

20. Data Breaches

A data breach may occur when personal information is lost, accessed, disclosed or altered without authorisation.

If we become aware of a suspected privacy or data-security incident, we will take reasonable steps to:

  1. Contain the incident and prevent further unauthorised access.

  2. Investigate what information and individuals may be affected.

  3. Assess the likely risk of harm.

  4. Take remedial action where possible.

  5. Notify affected individuals and relevant regulators where required.

  6. Review the incident and improve our systems.

Where the Notifiable Data Breaches Scheme applies, we will assess whether the incident is likely to result in serious harm and notify affected individuals and the Office of the Australian Information Commissioner when legally required.

We may also notify the NDIS Quality and Safeguards Commission, the NDIA, law-enforcement authorities, insurers or other regulators where required or appropriate.

21. Accuracy and Correction of Information

We take reasonable steps to ensure that personal information is accurate, complete, relevant and up to date.

Participants and representatives should tell us when information changes, including:

  • Contact details

  • Emergency contacts

  • Medical conditions

  • Medications

  • Allergies

  • Support needs

  • Guardianship or nominee arrangements

  • NDIS plan or funding information

A person may request correction of information they believe is inaccurate, incomplete, out of date, irrelevant or misleading.

We may need to verify the person’s identity before making a correction. Where we do not agree to a requested correction, we will explain the reason where required and may attach a statement to the record noting the person’s requested correction.

22. Accessing Personal Information

Individuals may request access to personal information we hold about them.

A request can be made by contacting our Privacy Officer using the contact details below.

We may ask for:

  • Proof of identity

  • Details of the information being requested

  • Evidence that a representative is authorised to act for the participant

Access may be provided through:

  • A copy of the relevant documents

  • Inspection of records

  • A written summary

  • An explanation of the information

  • Access through an agreed healthcare professional where appropriate

We will respond within applicable legal timeframes.

Access may be refused or limited where permitted by law, including where access would:

  • Create a serious threat to a person’s life, health or safety

  • Unreasonably affect another person’s privacy

  • Reveal confidential commercial information

  • Prejudice an investigation

  • Be unlawful

  • Relate to legal proceedings or anticipated legal proceedings

  • Be otherwise restricted under applicable privacy or health records legislation

Where access is refused, we will generally provide written reasons and information about available complaint options, unless it would be unlawful or inappropriate to do so.

A reasonable administrative fee may apply where permitted by law, but we will not charge for making an access request.

23. Retention and Disposal of Records

We retain participant information for as long as it is needed for service delivery, legal compliance, quality assurance, insurance, auditing and legitimate business purposes.

Where NSW health-record retention requirements apply, health information collected while a person was an adult will generally be retained for at least seven years from the last occasion on which a health service was provided.

Health information collected while a person was under 18 will generally be retained until the person reaches 25 years of age.

Some records may need to be retained for a longer period because of NDIS, taxation, employment, insurance, incident-management, safeguarding, contractual or legal requirements.

When information is no longer required and there is no legal requirement to retain it, we will take reasonable steps to securely destroy or permanently de-identify it.

Secure disposal may include:

  • Shredding paper records

  • Securely deleting electronic records

  • Destroying storage devices

  • Using approved confidential-waste services

We will maintain required records relating to the disposal or transfer of health information.

24. De-Identified Information

We may remove information that identifies an individual and use the remaining de-identified information for:

  • Service evaluation

  • Quality improvement

  • Staff training

  • Statistical reporting

  • Funding or regulatory reporting

  • Organisational planning

  • Research where legally permitted

We will take reasonable steps to reduce the risk that de-identified information could be linked back to an individual.

25. Privacy Complaints

People have the right to raise concerns about how their personal information has been handled.

Privacy complaints may relate to:

  • Unauthorised access or disclosure

  • Inaccurate records

  • Failure to provide access

  • Inappropriate collection

  • Information being used for an unexpected purpose

  • Lost documents

  • Email or cybersecurity incidents

  • Photography or recording concerns

  • Failure to respect consent preferences

A complaint should include:

  • The person’s name and contact details

  • A description of what happened

  • Relevant dates

  • The information affected

  • The outcome being requested

  • Copies of relevant documents, where available

We will treat complaints respectfully and confidentially. Making a complaint will not negatively affect a participant’s access to services.

We will acknowledge the complaint, investigate the circumstances and aim to provide a response within 30 days. More complex matters may require additional time, and we will keep the complainant informed.

If a person is not satisfied with our response, they may contact:

  • The Office of the Australian Information Commissioner

  • The Information and Privacy Commission NSW

  • The NDIS Quality and Safeguards Commission, where the concern relates to NDIS services

  • Another relevant regulator or complaints body

26. Contact Our Privacy Officer

For privacy enquiries, access requests, correction requests, consent changes or complaints, please contact:

Privacy Officer
Endless PossAbilities Disability & Aged Care Services Pty Ltd

Address: 13A Mort Street, Blacktown NSW 2148
Phone: 0415 055 651
Email: peter.tawdrous@hotmail.com
ABN: 24 690 139 783

Please write “Privacy Enquiry” or “Privacy Complaint” in the email subject line so your request can be directed appropriately.

27. Changes to This Privacy Policy

We may update this Privacy Policy when our services, information-management systems, legal obligations or regulatory requirements change.

The current version will be published on our website with the date of the latest update.

We encourage participants, families, representatives, employees and website visitors to review this policy periodically.