Privacy Policy

Privacy and Conflict of Interest Policy

Introduction

Yamba Behaviour Support and Assessments Pty Ltd (“we,” “us,” “our”), trading as The Neurodiverse Clinic and Participant Choice Services, is committed to protecting the privacy, rights, and safety of our clients, employees, and partners. We manage personal information in compliance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), the National Disability Insurance Scheme Act 2013 (Part 2 – Privacy), the NDIS Practice Standards, and the NDIS Code of Conduct.

Collection of Personal Information
We collect personal information necessary to deliver and improve our services. This may include:

Clients: Name, date of birth, contact details, NDIS plan details, medical and disability information, and other relevant details to provide supports.
Employees and Contractors: Name, contact details, qualifications, employment history, and other relevant information.
Service Providers: Business contact information required to manage professional relationships.

We only collect sensitive information (such as health and disability data) with consent or as authorised by law.

Use of Personal Information

Personal information may be used to:

Deliver and manage services including assessments, therapy, skill development, Specialist Support Coordination, Key Worker support, and parent/carer training.
Communicate with clients, employees, and stakeholders.
Process billing and invoicing.
Meet legal and regulatory requirements.
Conduct research and continuous service improvement.
Artificial Intelligence (AI): We may use AI tools to assist with preparing reports, analysing data, drafting resources, and improving service delivery. All AI use is subject to strict privacy and ethical controls. By signing our service agreements or plans, you consent to the use of AI tools in the delivery and administration of our services.

Disclosure of Personal Information
We may share personal information with:

The NDIA and the NDIS Quality and Safeguards Commission.
Healthcare providers and other professionals involved in your care.
Contractors and third‑party service providers who assist in service delivery.
Legal, financial, or professional advisors.
Others where required by law or with your consent.

We ensure third parties are bound by confidentiality and privacy obligations.

Information Storage and Security
All personal information is stored securely in Google Drive systems with two‑factor authentication enabled. Access is restricted to authorised staff and contractors only. We use encryption, access protocols, and robust organisational measures to protect your data.

Data Breach Response
In the event of a data breach likely to result in serious harm, we will comply with the Notifiable Data Breaches Scheme, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

Conflict of Interest Management
As a provider delivering multiple types of services under separate trading names, we maintain strict boundaries to avoid conflicts of interest in line with the NDIA Position Statement on Conflicts of Interest.

Participant Choice Services delivers only Key Worker and Support Coordination services.
The Neurodiverse Clinic delivers Specialist Behaviour Support, Functional Capacity Assessments, Functional Behaviour Assessments, mentoring, skill development, and parent/carer training.
We use separate client record management (CRM) systems for each trading name to ensure information is secure and kept confidential between services.
All participants are presented with at least three provider options for any referred service to support informed decision‑making.
Conflicts of interest are declared, recorded, and managed using the NDIA’s Conflict of Interest Declaration form, with regular reviews.

Participant Rights
You have the right to:

Access and request corrections to personal information we hold.
Withdraw consent for the collection or use of your personal information (where lawful).
Receive information about how your data is stored, used, and shared.
Make a complaint if you believe your privacy or rights have been breached.

Consent
By signing our service agreements, plans, or intake forms, you consent to:

The collection, use, and disclosure of your personal information as outlined in this policy.
The use of AI technology to support service delivery and administration.
Our conflict of interest management practices, including transparent disclosure of any conflicts.

Changes to This Policy
We may update this policy to reflect changes in legislation, best practice, or our operations. Updates will be published on our website or communicated through appropriate channels.

Yamba Behaviour Support and Assessments Pty Ltd
Trading as The Neurodiverse Clinic and Participant Choice Services
Phone: 02 6646 8942
Email: ceo@yambabehavioursupportandassessments.com

If you are dissatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) or the NDIS Quality and Safeguards Commission.