Privacy Policy

1. Introduction

NDBS Pty Ltd (ABN: [INSERT ABN]) (“NDBS”, “we”, “us”, “our”) is committed to protecting the privacy of all individuals whose personal information we collect, use, store and disclose.

NDBS provides independent Building Works Project Management services for NDIS participants and complex home modification projects.

In delivering these services, we necessarily collect and handle personal information including sensitive information relating to disability, about our clients, their families, occupational therapists, support coordinators, and other parties involved in home modification projects.

This Privacy Policy explains how NDBS handles personal information in accordance with:

  • The Privacy Act 1988 (Cth), including the 13 Australian Privacy Principles (APPs)
  • The Privacy and Other Legislation Amendment Act 2024, which received Royal Assent on 10 December 2024
  • The NDIS Act 2013 (Cth)
  • The NDIS Practice Standards and NDIS Code of Conduct
  • The Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988

As a company operating in the disability services sector, NDBS is an APP entity and is bound by the Australian Privacy Principles regardless of annual turnover.

2. Personal Information We Collect

2.1 Information about NDIS Participants

When providing project management services to or on behalf of NDIS participants, we may collect:

  • Full name, date of birth and contact details
  • NDIS participant number and plan details
  • Disability-related information, functional capacity assessments and OT reports
  • Home address and property details
  • Health and medical information relevant to the modification scope
  • Financial information including NDIS funding allocations and budgets
  • Next of kin, nominee, guardian or authorised representative details
  • Communication records and correspondence
  • Project documentation, photographs and site records

2.2 Information about Occupational Therapists and Practitioners

When working with OTs, allied health practitioners and support coordinators, we may collect:

  • Full name, AHPRA registration number and practice details
  • Professional qualifications and registration status
  • Contact details and practice address
  • Correspondence and referral documentation

2.3 Information collected through our website

When you visit www.ndbs.net.au or submit a form on our website, we may collect:

  • Name, email address and phone number
  • Information you provide in enquiry, referral or consultation request forms
  • Technical data including IP address, browser type and pages visited (via cookies)
  • Subscription preferences if you opt into our mailing list

2.4 How we collect information

We collect personal information:

  • Directly from you when you contact us, submit a website form, or engage our services
  • From OTs, support coordinators or family members referring or acting on behalf of a participant
  • From the NDIA or NDIS portal where authorised by the participant
  • From builders, contractors and other parties involved in a project where relevant
  • Through our website contact and enquiry forms

3. How We Use Personal Information

NDBS uses personal information only for the purposes for which it was collected, or for directly related purposes that you would reasonably expect.

These include:

  • Delivering Building Works Project Management services
  • Preparing and submitting NDIS funding applications and documentation
  • Assesssing, managing and supervising home modification projects
  • Communicating with participants, families, OTs, support coordinators and builders
  • Reviewing OT reports and builder quotations
  • Managing disputes, variations and compliance issues
  • Responding to enquiries submitted through our website
  • Sending service updates, sector news and resources (where you have consented)
  • Complying with our legal and regulatory obligations as an NDIS service provider
  • Improving our website and services

We will not use your personal information for direct marketing without your express consent.

You may withdraw consent for marketing communications at any time by contacting us at office@ndbs.net.au or using the unsubscribe function in any email we send.

4. Sensitive Information

NDBS regularly handles sensitive information as defined under the Privacy Act 1988, including information about disability, health and medical conditions.

This category of information receives a higher level of protection under the Australian Privacy Principles.

We will only collect, use and disclose sensitive information where:

  • You have provided express consent
  • It is directly necessary for the delivery of our services
  • We are required or authorised to do so by law
  • It is necessary to prevent or lessen a serious threat to the life, health or safety of any individual

NDBS recognises that disability-related information is among the most sensitive categories of personal data.

We treat it with the highest standard of care and discretion at all times.

5. Disclosure of Personal Information

5.1 Who we may share information with

NDBS may disclose personal information to the following parties, only to the extent necessary for the purposes described in Section 3:

  • Occupational therapists and allied health practitioners involved in your project
  • Support coordinators acting on a participant’s behalf
  • Licensed builders and contractors engaged on a project
  • The National Disability Insurance Agency (NDIA)
  • The NDIS Quality and Safeguards Commission
  • Legal and compliance advisors where required
  • Microsoft Corporation (as our cloud storage and productivity platform provider, see Section 7)
  • Mailchimp / Intuit Inc. (for mailing list management, where you have subscribed)

5.2 What we will never do

NDBS will not:

  • Sell, rent or trade your personal information to any third party
  • Disclose your information to overseas parties without your consent, except where required by law or where the overseas recipient is subject to equivalent privacy protections (see Section 7)
  • Use participant information for any purpose unrelated to your project or our services
  • Share sensitive disability-related information with any party not directly involved in your project without your express consent

6. Consent

Where we rely on consent to collect or use your personal information, we will obtain that consent clearly and explicitly. You have the right to withdraw consent at any time. Withdrawing consent will not affect the lawfulness of any processing carried out before withdrawal, but may affect our ability to deliver certain services.

For participants who are minors or who have diminished capacity, we will seek consent from the parent, guardian or authorised nominee as appropriate.

NDBS retains consent records for a minimum of 7 years from the date of last service delivery, consistent with the NDIS Practice Standards and general Australian record-keeping obligations. For participants who were minors at the time of service, records are retained until the participant turns 25 or for 7 years from last service — whichever is longer.

7. Data Storage and Security

7.1 How we store your information

All personal information collected and managed by NDBS is stored on Microsoft OneDrive, linked to the company’s Microsoft 365 Business subscription. Microsoft stores Australian business data in its Australian datacentres located in New South Wales and Victoria, in accordance with its Australian Data Residency commitments.

Our Microsoft 365 Business subscription provides:

  • Encryption of data at rest and in transit using industry-standard protocols
  • Role-based access controls limiting data access to authorised NDBS personnel only
  • Multi-factor authentication (MFA) on all NDBS Microsoft 365 accounts
  • Audit logging of data access and modifications
  • Compliance with ISO 27001 and SOC 2 Type II security standards

7.2 Retention periods

NDBS retains personal information for as long as necessary to deliver services and meet our legal obligations:

  • Client project records: 7 years from completion of project or last service delivery
  • NDIS documentation and submissions: 7 years minimum, consistent with NDIS Practice Standards
  • Website enquiry records: 2 years
  • Mailing list subscriber data: until unsubscribed, then deleted within 30 days

 

When information is no longer required, it is securely deleted from our systems.

7.3 Security measures

NDBS takes reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. These steps include:

  • Secure cloud storage with enterprise-grade encryption (Microsoft 365 Business)
  • Multi-factor authentication on all staff accounts
  • Restricted access — only staff directly involved in a project can access that project’s files
  • Secure website (HTTPS/TLS encryption)
  • Staff awareness of privacy obligations and data handling procedures

8. Access to and Correction of Your Information

Under the Australian Privacy Principles, you have the right to request access to personal information NDBS holds about you, and to request correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading.

To make an access or correction request, please contact us in writing at:

Privacy Officer, NDBS Pty Ltd

Email: office@ndbs.net.au

Phone: (08) 8233 5895

Post: Level 30, RAA Place, 91 King William St, Adelaide SA 5000

We will respond to access and correction requests within 30 days.

In some circumstances we may decline a request — if so, we will explain why in writing and advise you of your right to complain to the Office of the Australian Information Commissioner (OAIC).

We do not charge a fee for making an access or correction request.

9. Data Breaches

NDBS is subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988. In the event of a data breach that is likely to result in serious harm to any individual whose information is involved, NDBS will:

  • Contain the breach as quickly as possible
  • Assess whether the breach is likely to result in serious harm
  • Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable
  • Notify affected individuals directly as soon as practicable

 

Given the sensitive nature of the disability-related information we handle, NDBS treats any actual or suspected data breach as a serious incident requiring immediate response. We maintain internal breach response procedures consistent with OAIC guidance.

 

To report a suspected privacy breach or security incident involving your information, contact us immediately at office@ndbs.net.au or (08) 8233 5895.

10. Website Cookies and Analytics

Our website (www.ndbs.net.au) uses cookies — small text files stored on your device — to improve your experience and analyse how the site is used. We use:

  • Essential cookies: required for the website to function correctly
  • Analytics cookies: to understand how visitors use our site (via aggregated, anonymised data)
  • Form cookies: to remember form fields and prevent duplicate submissions

 

You can control cookie settings through your browser preferences. Disabling certain cookies may affect website functionality. We do not use cookies for behavioural advertising or sell cookie data to third parties.

11. Mailing List and Marketing Communications

If you subscribe to the NDBS mailing list, we will use your name and email address to send you updates, sector news and resources relevant to NDIS home modifications. We use Mailchimp (operated by Intuit Inc.) to manage our mailing list.

By subscribing, you consent to your name and email address being transmitted to Mailchimp’s servers. Mailchimp is subject to its own privacy policy. Your mailing list data is used only for sending NDBS communications and is never shared with or sold to third parties.

You may unsubscribe at any time by clicking the unsubscribe link in any email we send, or by contacting us at office@ndbs.net.au. On unsubscription, your data will be removed from our mailing list within 30 days.

12. Complaints and Concerns

If you believe NDBS has mishandled your personal information or breached your privacy, we encourage you to contact us in the first instance so we can attempt to resolve the matter promptly.

Please direct privacy complaints to:

Privacy Officer, NDBS Pty Ltd

Email: office@ndbs.net.au

We will acknowledge your complaint within 5 business days and endeavour to resolve it within 30 days. If you are not satisfied with our response, you may escalate your complaint to:

  • Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | 1300 363 992
  • NDIS Quality and Safeguards Commission: www.ndiscommission.gov.au | 1800 035 544

13. Updates to This Policy

NDBS reviews this Privacy Policy at least annually and whenever our information handling practices change materially. The current version is always published at www.ndbs.net.au/privacy-policy.

We will notify subscribers of material changes to this policy by email prior to the changes taking effect.

14. Contact Us

For any privacy-related enquiries, requests or concerns, please contact:

NDBS Pty Ltd — Privacy Officer

Level 30, RAA Place, 91 King William St, Adelaide SA 5000

Email: office@ndbs.net.au

Phone: (08) 8233 5895

Website: www.ndbs.net.au

This Privacy Policy was prepared with reference to the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Privacy and Other Legislation Amendment Act 2024, the NDIS Act 2013, the NDIS Practice Standards, and the Notifiable Data Breaches scheme. It is intended as a general guide and does not constitute legal advice. NDBS recommends seeking independent legal advice to ensure full compliance with all applicable obligations.

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