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Early Start Australia Pty Ltd (ESA) is a subsidiary of APM Human Services International Limited (APM). ESA’s collection, use, disclosure and storage of your personal information is regulated by the Privacy Act 1988 (Commonwealth), the Australian Privacy Principles and related legislation.
We are strongly committed to maintaining the privacy of personal information we collect as part of the services we offer. We place great importance on protecting the privacy of our employees/contractors, valued clients, customers and other stakeholders.
Personal information collected by us will usually fall into one of the following categories:
We may collect personal information about:
We may collect your information from you in a variety of ways including when:
Sometimes we will collect personal information from a third party or a publicly available source, for example where we have your consent, where we are required by law to do so, or if it is unreasonable or impracticable to collect the personal information directly from you (e.g. checking a candidate’s work history, or obtaining client information from a parent, guardian or carer (where applicable), or from your treating healthcare professionals). The Client Consent Form more specifically outlines where client-related personal information might be collected from.
You may choose to deal with us anonymously or under a pseudonym where lawful and practical. Where anonymity or the use of a pseudonym will render ESA unable to provide the relevant service or reasonably conduct business, we may request that you identify yourself.
You may also choose not to provide us with your personal information. Depending on the circumstances in which you do so, however, we may be unable to provide you with our services as a result.
Where we are collecting personal information from a child or young person, we will use our judgement to determine if that person has the capacity to consent. Where we are unsure, we will seek consent from a parent, guardian or carer.
We collect, use, disclose and store your personal information to provide you with our services which include:
We may also collect, use and store your personal information:
You may opt out of receiving marketing information by notifying us accordingly, or by using any unsubscribe facility we provide for that purpose. If you opt out of receiving marketing information, we may still contact you in connection with the services we provide to you, such as for appointment reminders and follow-ups. Refer also to the Marketing section below.
Our services, functions and activities, as well as those of our contracted service providers, may change from time to time.
We understand the importance of keeping personal information secure and safe. Some of the ways we do this are:
Personal information may be stored in documentary form but will generally be stored electronically on our software or systems.
We will take reasonable steps to ensure that personal information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner.
In order to carry out our services, functions and activities, ESA may disclose your personal information to third party suppliers or contractors such as cloud computing technology and data storage service providers, data analytic and marketing services, legal services providers, insurance brokers, security service providers, business advisors and financial service providers. We may disclose personal information to these third parties in connection with their provision of goods or services to us. In addition, we may share your personal information to other APM entities for promotional purposes including direct marketing.
We may also disclose your personal information to government agencies, private sector organisations or other entities where required or permitted by law, which may include the following circumstances:
Information is shared between APM Group Members. We may transfer or disclose your personal information to APM Group Members.
The persons and organisations which ESA may disclose your personal information to will handle your personal information in accordance with their privacy policies.
We may use your personal information to contact you (including by telephone call, SMS or email) in relation to products, services or other offers we think may be of interest to you (such as plan management and support coordination services. These products and services may be offered by us, other APM Group Members, our other business partners or our service providers.
We may also market our products to you through third-party channels (such as social networking sites or digital advertising), or via other companies who assist us to market our products and services. Your personal information may be provided to other entities (including APM Group Members and third party agents, contractors or organisations) for promotional purposes, including direct marketing. Those entities may use the personal information we provide to them to market to you, including by sending you information or contacting you (by telephone, post or electronically) about our or their products and services.
You may opt-out of receiving some or all direct (marketing information from ESA or other APM Group Members by:
Please allow five working days for your request to be actioned.
We take steps to help ensure that all personal information we collect, use or disclose is accurate, complete and up to date. Please contact the ESA Privacy Officer (details below) if you are aware that personal information that we hold about you does not meet this objective.
You can request access to personal information that we hold about you.
The procedure for requesting and obtaining access is as follows:
We have a designated Privacy Officer who is responsible for the management of:
For information regarding privacy, our Privacy Officer can be contacted at
If you have any concerns or complaints about the way your personal information has been collected or handled by ESA, please advise us of your concern or complaint in writing and send it to the Privacy Officer using the contact details above. ESA will endeavour to acknowledge receipt of a written complaint within 5 business days.
ESA’s Privacy Officer will investigate the complaint and attempt to resolve it within 20 business days after the written complaint was received. Where it is anticipated that this timeframe is not achievable, we will try to contact the person making the complaint to provide an estimate of how long it will take to investigate and respond to it.
It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Office of the Australian Information Commissioner and/or the relevant privacy regulator in your State/Territory who may investigate your complaint further.