Privacy policy

Draft for legal review. Not legal advice. Do not publish as final.

Last updated: [DATE]

1. Who we are

We are [COMPANY NAME], ABN [ABN], of [ADDRESS]. We make and run this software for children's contact services and contact supervisors in Australia. In this policy, "we" and "us" mean [COMPANY NAME]. A "service" is a children's contact service or a solo contact supervisor that uses our software.

Contact our privacy officer at [PRIVACY EMAIL] or [PRIVACY POSTAL ADDRESS].

This policy is written with the Australian Privacy Principles in mind: https://www.oaic.gov.au/privacy/australian-privacy-principles

2. Services collect family information. We hold it for them.

A service collects information about the families it works with. The service decides what to collect, why, and who sees it. We store and process that information for the service, under our agreement with the service. We do not use it for our own purposes.

If you are a parent or a carer, the service you deal with is your first contact for questions about your information. The service gives you its own collection notice. You can also contact us, and we will pass your request to the service.

Each service must get its own advice about which privacy laws apply to it. Our research found that the question is open for many services. For example, it is not clear for every service whether the small business exemption applies. See the OAIC page on small business: https://www.oaic.gov.au/privacy/privacy-for-organisations/small-business

3. What we collect

From service staff

Name, email address, role and the service you work for.
Your password (stored as a hash) and your two factor login settings.
Records of the work you do in the software, such as visits, notes and reports.
Staff records the service keeps, such as Working With Children Check details and training.
Technical data: IP address, browser type, and the times you sign in and out.

From parents and other people, through a service

A service can enter or collect, through our software:

Names, contact details and addresses of parents, carers and other contacts.
Details about children, including health details such as medical needs and allergies.
Court orders, family violence orders and other documents.
Intake and risk assessment answers.
Visit records, session notes, incident records, messages and reports.
Invoices and payments.
Technical data when a parent uses the family app: IP address, browser type and sign in times.

Some of this is sensitive information, such as health information.

From website visitors

What you type in a form, such as a contact form, an application or a referral.
Technical data: IP address and browser type.
We use cookies needed to run the site and to keep you signed in. [CONFIRM: NO ANALYTICS OR ADVERTISING COOKIES].

From services that buy our software

Business name, ABN, contact details and billing details.
Card payments go through Stripe. We do not store full card numbers.

4. Why we collect it

To give each service the software it pays for.
To let staff and parents sign in and to keep accounts secure.
To bill services for the subscription.
To give support when a service asks.
To answer website forms.
To meet our legal duties.

We do not sell personal information. We do not use family information for marketing.

5. Where we store it

We store information at [HOSTING REGION], with [HOSTING PROVIDER]. This will be confirmed before launch.

6. Who we share it with

We share information only with the providers we need to run the software:

Provider	What for	What they get
`[EMAIL PROVIDER]`	Sending email	Email address, name, the email text
`[SMS PROVIDER]`	Sending SMS reminders	Phone number, the message text
Stripe	Subscription and card payments	Billing and payment details
`[AI GATEWAY PROVIDER]`	AI features, only if the service turns them on	Text with names, email addresses, phone numbers and addresses removed
`[HOSTING PROVIDER]`	Hosting and storage	All stored data, encrypted where shown in our security overview

A service can also release a report or other records to people it chooses, such as lawyers, the independent children's lawyer or the court. The service decides this, not us.

We can also disclose information when a law, a court order or a subpoena requires it. If the information belongs to a service, we tell the service first, unless the law stops us.

7. Overseas disclosure

[OVERSEAS DISCLOSURE: LIST EACH PROVIDER THAT STORES OR ACCESSES DATA OUTSIDE AUSTRALIA, AND THE COUNTRIES. TO CONFIRM WHEN PROVIDERS ARE CHOSEN.]

8. Access and correction

You can ask to see the personal information we hold about you, and ask us to correct it.

Service staff and service customers: contact us at [PRIVACY EMAIL].
Parents and other people in a service's records: ask the service first. The service controls these records. If you contact us, we pass your request to the service and help it answer.

We answer within 30 days. We do not charge to ask. We can refuse access in some cases that the law allows. If we refuse, we tell you why and how to complain.

A service can keep a locked record that it cannot change, such as a signed session note. A correction is then a new record that points at the old one.

9. Complaints

Contact our privacy officer first at [PRIVACY EMAIL]. Tell us what happened and what you want us to do. We confirm we got your complaint within [NUMBER] business days and give an answer within 30 days.

If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (OAIC): https://www.oaic.gov.au/privacy/privacy-complaints

If your complaint is about a service's records, the service handles it first.

10. How long we keep information

A service sets how long it keeps its case records. The software holds a closed case until its retention date. Then a review asks the service to keep the case longer or to destroy it. Destruction needs two approvals.
When a service stops using our software, the service can export its records. We then delete them after 90 days, unless the service asks us to keep them under a separate agreement.
Some financial records stay for the time tax law requires.
We keep our own account and billing records for [PERIOD].

11. Security

We protect information in these ways:

Each staff user signs in with a password and a two factor code.
Each sign in ends after a time with no activity.
Each service sees only its own records.
We encrypt the most sensitive fields, such as addresses, phone numbers, email addresses of parents and health details of children. We encrypt every stored file.
We keep a log of who changes a record and who views a sensitive record.
Signed records cannot change. Deleted records can be restored until the retention process destroys them.
Before text goes to an AI feature, we remove names, email addresses, phone numbers and addresses.

No system is fully secure. If a data breach is likely to cause serious harm, we follow our data breach response plan. We tell the services affected, and we notify the OAIC and affected people where the law requires.

12. Changes to this policy

We can change this policy. We put the new version on this page with a new date. If a change is important, we tell services by email.