Privacy Policy

November 2024

In this Privacy Policy, 'us', 'we' or 'our' means My Plan Manager Group (MPMG) Pty Ltd (ABN 35 634 629 280), the operator of the Kinora Platform, our website and any related services (Platform). We are committed to respecting your privacy and are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). Our Privacy Policy sets out how we collect, use, store, disclose and otherwise handle your personal information.

Policy Overview 

By providing personal information to us, including through MPMG Platforms (e.g. Client Portal, Kinora), you consent to our collection, use and disclosure of that personal information in accordance with this Privacy Policy and any other relevant arrangements between us such as the Platform Terms.  

We may change our Privacy Policy from time to time by publishing changes to it on the Platform and our website. We encourage you to periodically check our website and Platform to ensure that you are aware of the most up-to-date version of the Privacy Policy. 

This Privacy Policy should be read in conjunction with any other specific collection notice or consent that we provide to you.  

Collection of Personal Information 

Personal information includes information or an opinion about an individual that is identifiable. Within this Privacy Policy unless indicated otherwise, references to personal information also include sensitive information. 

  1. The types of personal information we collect from you may include: 

    • Name, date of birth, and contact details, including address, phone number, and email address.  

    • Information about preferred modes of communication.  

    • Your NDIS plan details, including government identifiers such as your participant NDIS number (NDIS) if applicable   

    • Information relating to your “consent to obtain and release” information  

    • Any information or documents which you provide or upload to an MPM platform in relation to the services and supports provided  

    • Any information about your interactions with MPMG or MPMG services, platforms or websites including engagement with others whilst using MPM platforms (e.g. feedback, “likes,” comments, choices, preferences, messages) 

    • Details about the services or products we have provided to you or that you have enquired about, including any additional information necessary to deliver those services and products and respond to your enquiries 

    • Information relating to bank accounts if you choose “reimbursements” as a payment option for Plan Management Services.  

    • Audio recordings; and  

    • Any other relevant information required by MPMG for us to undertake the roles and responsibilities of a Plan Manager.  

Collection of Sensitive Information 

If you are a NDIS Participant, due to the nature of our business and our service platforms – and only where necessary in relation to our business – we may also collect 'sensitive information', as that term is defined in the Privacy Act, about you.  

This will include information about you which would be classified as 'health information' under the Privacy Act, such as information or opinions about your health and/or disability, your wishes about the future provision of services to you (including any goals and aspirations in your NDIS Plan, if disclosed) and information about services which have or will be provided to you (including those facilitated through our service platforms). 

While we will collect such sensitive information directly from you (as part of registration, or your interactions with MPMG and/or MPMG platforms), we may also collect such sensitive information from third parties where it is unreasonable or impracticable to collect it directly from you, including where information is provided by: 

  • Your Primary Decision Maker, or for MPMG platforms your Primary Account Manager, such as a parent, guardian, or decision maker, on your behalf 

  • A service provider (including a provider of disability services to you) for example in the form of information provided on an invoice or in relation to a service booking; or 

  • Members of your chosen community of support but only when they upload information such as appointment reminders, or notes to you or about you in our community platform (i.e. Kinora) 

Unless otherwise specified, all references to 'personal information' in this privacy policy should be read to include sensitive information. 

How We Collect & Hold Personal Information 

MPMG may collect this information from you or your nominated decision maker, or the National Disability Insurance Agency (NDIA) when you: 

  • Sign up or register for one or more of our services 

  • Visit our websites or platforms (e.g. client portal, Kinora) 

  • Communicate or interact with us by any method, such as telephone, email, post, website, MPMG platforms or in person 

  • Authorise us to process invoices on your behalf 

  • We contact you while undertaking our Plan Management or Individual Capacity Building roles and responsibilities (e.g. budget discussions, seeking approvals, individual capacity building and coaching, social and community engagement using MPMG platforms etc) 

  • We represent a matter, with your consent as applicable, to the NDIA 

  • Otherwise as notified to you from time to time 

In addition, MPMG may collect information from other third parties such as nominated Service Providers, including your Support Co-Ordinators, and persons approved by yourself for participation in MPMG platforms (e.g. when information is posted on one of our platforms).  

Audio Recordings 

MPMG shall seek consent from clients when they telephone MPMG before proposing to record their voice or using that recording for internal training. MPMG shall advise clients if a supervisor or other staff member is to monitor a telephone call for the purpose of training or supporting MPMG staff. 

Use of your Personal Information 

MPMG will only collect, use, and disclose personal information consistent with undertaking the role and responsibilities set out in the MPMG Service Agreement and the services and supports purchased.  

This may also include: 

  • Providing you with information in relation to the services and products we provide, 

  • Providing you with information in relation to the services and products we offer or propose to offer, 

  • Providing you with information to “opt-out” of or temporarily “suspend” access to services and products we offer or propose to offer, 

  • Sending SMS or email notifications, 

  • Responding to your questions or suggestions,  

  • Improving the quality of our products or services, 

  • Improving the quality of your visit to our website or 

  • If applicable, improving the quality of your visit to our community platform, Kinora:- 

  • To provide you with use of our Platform and manage our relationship with you (including setting up your Kinora account as well as verifying your identity) 

  • To operate, protect, moderate, improve and optimise our Platform, business, and our users' experience, such as to perform analytics to identify user segments who share common characteristics and traits, and conduct research on use of the Platform. This may include disclosure of personal information to MPMG or third parties which perform moderation or other activities on the Platform on our behalf 

  • To send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you and respond to any of your queries or requests 

  • To present you or, where relevant, your parent, guardian, or decision maker, with content about the Platform (including specific discussion topics or posts), other users of the Platform, or other services and products (on or off the Platform) that you or your parent, guardian or decision maker might be interested in 

  • To comply with our legal or industry obligations (including the NDIS Code of Conduct), resolve any dispute that we or a user may have with any of our users and enforce our agreements with third parties 

  • To verify your identity and ensure that our Platform remains safe and secure for all users; and 

  • For other purposes identified in the Platform Terms of Use and Community Guidelines  

Sharing your Personal Information 

We may disclose personal information to third party contractors (including information technology suppliers, administration service providers, communication suppliers and our business partners including entities engaged by MPMG to oversee and moderate user interactions on the MPMG community platform, Kinora), who help us conduct our business or as required, authorised or recommended by applicable law, the NDIS Act and Rules or other policy requirements of the National Disability Insurance Agency. 

Some third-party contractors may be located outside of Australia, including in India, New Zealand, the Philippines, and the USA. 

Where information is shared with these third parties, we will take all reasonable steps to ensure that third parties observe the confidential nature of such information and are prohibited from using or disclosing such information beyond what is necessary to assist us. 

Other than third party contractors, MPMG will seek written consent from the client to release any information about them to an external party. For example, consent to speak with other support providers. This is ordinarily documented in our “Consent to Obtain and Release” form. 

If the Consent to Obtain and Release Information form is not completed MPMG may ask the person(s) seeking information to liaise directly with the client or their nominated person.  

All clients have the right to withhold consent. MPMG will advise clients of any known impacts this may have on service delivery and the ability of MPMG to provide services. 

MPMG shall work with nominated representatives / guardians in circumstances where clients are unable to give informed consent (e.g. to a service agreement). In these cases, nominees and guardians must reflect the needs and goals as identified by the person with disability and make decisions regarding privacy and dignity to best maximise the client’s wellbeing in all aspects of his/her/their life. MPMG will try to work with the nominee as required to achieve this end. 

Storing your Personal Information 

The personal information we collect will be stored electronically and securely protected. We take appropriate security measures to protect your personal information from misuse, interference, or loss, and from unauthorised access, modification, or disclosure. 

This includes the use of technologies and security software, network firewalls and physical security to protect the privacy of your personal information. 

We will store your personal information while we continue to provide our services to you, unless otherwise required by law. After this time, we will continue to archive your personal information to the extent required by any law applicable to our business, as may vary from time to time. 

We store your data in Australia, but our use of; 

  • Third party service providers and some features of third-party applications may involve access to information by individuals located outside of Australia, including in India, New Zealand, the Philippines, and the USA; and 

  • Third party applications may involve access of information by third parties as overseas recipients of information for them to make their functionality available for Platform use 

Access to your Personal Information 

We take reasonable steps to ensure that your personal information is accurate, complete, and UpToDate whenever we collect or use it. Clients may access their personal information at any time. If a client disagrees with any personal information the client has the right to ask for the information to be changed. In such circumstances, an amendment note shall be added to the relevant file to advise the client disagrees with the information and sets out how the client wishes to see the information presented. 

All clients have the right to refuse to provide personal information to MPMG. If a client refuses to provide MPMG with the information requested MPMG will try to advise how this may impact upon the delivery of services and supports and whether it will be possible to provide services without the required information. 

Links 

Our platforms or website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ from our Privacy Policy, so we encourage individuals to read them before using those websites. 

Feedback & Complaints 

Clients may make a complaint or provide feedback about privacy matters. In doing so, clients should access the MPMG Feedback and Complaints Policy, located on the MPM website, and send such complaints to contact@kinora.com.au. MPMG shall treat all complaints in a confidential manner. 

Nothing in this Policy prevents a complaint about how MPMG has treated your personal information from being made to the Office of the Australian Information Commissioner (Tel 1300 363 992) at any time. 

 

Last Reviewed: August 2024 

Last Updated: August 2024 

Authorised by: Jane Kittel (CEO, My Plan Manager Group) 

Glossary of Terms 

Australian Privacy Principles (APPs)  

These outline how all private sector and not-for-profit organisations with an annual turnover of more than $3 million, all private health service providers and some small businesses (collectively called ‘APP entities’) must handle, use, and manage personal information. The APPs are included in the Australian Privacy Act (1988) (Cth).  

Client  

A Client of MPMG or the nominated decision-maker person 

Confidential information  

Any information made available to or generated by MPMG which is not already publicly available or about to become publicly available. All personal information is strictly confidential.  

Personal information (includes sensitive information) 

Information or an opinion about an identified individual, or an individual who is identifiable:  

  • Whether the information or opinion is true or not  

  • Whether the information or opinion is recorded in a material form or not.  

Personnel / Staff  

Anyone, paid or unpaid, who works for or with MPMG. It includes members of the governing body, or any other similarly empowered committee constituted by MPMG.  

Platforms 

Any MPMG Technology platform used for Plan Management and/or Individual Capacity Building including the Kinora community platform. 

Policy   

A statement of intent that sets out how an organisation should fulfil their vision, mission, and goals  

Procedure  

A statement or instruction that sets out how a policy will be implemented and by whom