Legal

Privacy Policy

Last updated: June 2026 · Version 2.0

This policy explains how Reassure Support collects, uses, stores, and protects your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Privacy Act Compliance Notice

Although Reassure Support operates as a sole trader, the software processes health information about NDIS Participants. Accordingly, the small business exemption under the Privacy Act 1988 (Cth) does not apply. Reassure Support is formally bound by the Privacy Act and the Australian Privacy Principles by virtue of its registration with the Office of the Australian Information Commissioner (OAIC) under Section 6EA.

Contents

Reassure Support ("we", "us", "our") is a sole trader operating in Queensland, Australia. We operate digital software at reassuresupport.services and app.reassuresupport.services that connects independent NDIS support workers and NDIS participants. We are a software business only — we do not employ, engage, or direct any support worker, and we are not a party to any support services arrangement between users.

By using our software or submitting information to us, you agree to the collection and use of your information in accordance with this policy.

1. Information We Collect

We collect personal information that you provide directly to us when registering or using the software, including:

For all users

  • Name, email address, and phone number
  • Location and suburb
  • Account login credentials (stored in encrypted form)
  • Messages and enquiries submitted through the software or contact form

For Support Workers

  • Employment history, skills, qualifications, and certifications
  • NDIS Worker Screening Card and government-issued photo identification
  • ABN and GST registration status
  • Insurance details (public liability and professional indemnity)
  • Audio recordings captured automatically when an emergency alert is triggered from the app, stored securely for the purpose of safety and incident review

For Participants

  • NDIS number, plan management type, and funding details
  • Support needs, disability-related information, and preferences (only as provided voluntarily by you or your authorised representative)

Automatically collected

  • IP address, browser type, and pages visited, for the purpose of maintaining site security and performance
  • Usage data generated by your interactions with software features (e.g. scheduling, documentation tools)

2. How We Use Your Information

We use your personal information to:

  • Create and manage your account on the software
  • Verify your identity and NDIS compliance status
  • Facilitate connections between Support Workers and Participants via connection codes
  • Provide and operate the software's tools, including scheduling, documentation, invoicing, and AI-assisted features
  • Respond to enquiries and provide customer support
  • Send transactional communications such as account verification, approval notifications, and billing alerts
  • Maintain the security and integrity of the software
  • Comply with our legal obligations under applicable Australian law

We do not use your personal information for unsolicited marketing. We do not sell, rent, or trade your personal information to third parties under any circumstances. We are not an employment agency and do not use your information to place you in employment or match you as an employee.

3. Participant Health Data and Sensitive Information

Shift notes, case notes, incident reports, and disability-related information about Participants are treated as sensitive information under the Privacy Act 1988 (Cth) and receive the highest level of protection we apply.

The software allows Support Workers to record shift notes, incident reports, service records, audio recordings triggered during emergency alerts, and other case documentation relating to Participants.

  • Access is strictly limited: Participant Health Data is accessible only to the Support Worker who created it, the Participant it relates to (and their authorised representative), and authorised Reassure Support personnel where required for software operation, compliance, or a legal obligation.
  • No third-party disclosure: We do not share Participant Health Data with any third party except where required by law, a court order, or to prevent serious harm.
  • Consent and withdrawal: Where a Participant withdraws consent for their information to be held or used, we will take prompt steps to action that request, subject to any overriding legal obligation. Please refer to Section 11 for information about how deletion requests interact with mandatory NDIS record-keeping obligations.

AI Voice Services — Overseas Processing Disclosure

Our support line uses an AI-powered voice agent operated by Retell AI Inc. (USA) and Anthropic PBC (USA). Information shared during a call — including your name and any details you provide — will be processed by these overseas services.

Retell AI operates under a Business Associate Agreement (BAA) and applies automated PII redaction protocols designed to clear identifying text from call transcripts. Retell AI is HIPAA, SOC 2 Type I & II, and GDPR certified.

Note: Automated PII redaction is designed to minimise the retention of identifying information, but no automated system guarantees 100% accuracy. In the event redaction is incomplete, data remains subject to Retell AI's BAA obligations and security controls.

Anthropic processes call content under a Data Processing Addendum with a maximum 7-day log retention and no model training on your data. Neither Retell AI nor Anthropic use verbal data or transcripts from your calls for foundational model training.

By calling our support line, you acknowledge and consent to this overseas processing. If you do not wish your information to be processed by these services, please contact us in writing at [email protected] instead.

4. Identity Document Verification

Support Workers and providers are required to submit identity documents — including an NDIS Worker Screening Card or Provider Registration Certificate and a government-issued photo ID — as part of the profile registration process.

These documents are used solely to verify your identity and NDIS compliance status. They are stored securely and accessed only by authorised personnel at Reassure Support for compliance review purposes. Documents are not shared publicly or with other software users.

An automated AI-assisted process is used to assist with initial document checking. This process does not make final decisions independently — all verifications are subject to human review by our team. Automated verification is an assistive tool only and does not constitute a guarantee of identity, qualifications, screening status, or suitability.

5. Our Role as Software — Not an Employer or Agency

Reassure Support provides technology software only. We do not employ, engage, supervise, or direct any Support Worker. We are not a party to any support services arrangement between a Support Worker and a Participant.

We collect and process personal information for the purpose of operating the software and facilitating connections between users — not for the purpose of employment, labour hire, or workforce management. Any reference in this policy to "facilitating connections", "matching", or "support delivery" refers to the operation of software tools only. It does not imply that Reassure Support employs, controls, or is responsible for any Support Worker or the supports they deliver.

If any dispute arises between a Support Worker and a Participant, we may provide records held on the software if required by law or a court order, but we do not act as an employer, intermediary, or arbitrator in any such dispute.

6. Information Stored On Your Device

The Reassure Support app is designed to work offline for support workers on the road. To make this possible, certain information is cached or queued directly in your device's local browser storage, separately from the data we hold on our servers.

  • App preferences: your session login token, display language, font size, theme, and landing page setting.
  • Offline queued items: incident reports, timesheets, and emergency alerts that were submitted while offline are held on your device until a connection is available, then synced to our servers and removed from local storage.
  • Locally cached operational data: for offline access, a working copy of your receipts (including any photo attached), KM logbook trips, insurance details, tax inputs, incident report history, and nominated emergency contact is kept in your device's local storage.

This locally stored information remains on your device and is not directly accessible to Reassure Support unless and until it syncs to our servers as described elsewhere in this policy. It is only as secure as your device — we recommend using a passcode or biometric lock on any device used to access the app.

Clearing your browser's site data, uninstalling the app, or using a different device or browser will erase this locally stored information, including any items not yet synced. If you are a Support Worker who has switched devices, see Account Recovery in the app's Settings to restore synced data.

Shift Location Verification

When a Support Worker clocks in or out of a shift, the app attempts to capture their device's GPS location at that moment, along with the reported accuracy of that reading. This is compared against the geocoded address recorded for the shift to produce an approximate distance figure.

  • Never blocks clocking in or out: location capture is best-effort only. If location services are unavailable, denied, or the shift address could not be matched to coordinates, the shift proceeds normally with no distance recorded.
  • Not shown to either party by default: this data is not displayed to the Support Worker or the Participant during normal use of the app.
  • Used only for dispute resolution: the recorded location and distance figures are accessible only to authorised Reassure Support personnel, and only where a Participant, Support Worker, or their representative disputes that a shift was delivered at the agreed location.
  • Retention: this data is retained for the same period as the associated shift record (see Section 8).

7. AI-Assisted Features and Your Data

The software incorporates AI-assisted features including document classification, receipt data extraction, invoice verification, and compliance support tools. The following principles govern how these features interact with your personal information:

  • Structured data only: Software AI features process structured operational data such as invoice line items, NDIS price catalogue references, and document metadata. They do not process free-text case notes, shift narratives, or health information stored in the software.
  • No model training: Both Retell AI and Anthropic process call content under Data Processing Agreements that explicitly prohibit the use of your verbal data or transcripts for foundational model training. Retell AI's data storage logging is configured to minimise retention of call content beyond what is required to complete the call.
  • AI outputs are not advice: Any output generated by an AI-assisted feature is for convenience and information purposes only. It does not constitute legal, financial, tax, or medical advice and must be independently verified.
  • Human oversight: Automated AI decisions — such as document verification outcomes — are subject to human review and are not solely automated decisions within the meaning of the Privacy Act.

8. Data Storage and Retention

Your data is stored on secure cloud infrastructure. We take reasonable steps to protect your personal information from unauthorised access, disclosure, or loss, including encryption of sensitive data at rest and in transit, and access controls limiting who can view your information.

We retain your personal information and uploaded documents for as long as your account is active or as required to provide our services. Under NDIS Quality and Safeguards Commission requirements, Support Workers must retain Participant service records for a minimum of 7 years (or up to 21 years where the Participant was a child at the time of service). These mandatory retention obligations take precedence over any deletion request where the data in question constitutes a required NDIS service record.

Emergency audio recordings are retained for a minimum of 7 years in accordance with NDIS incident record-keeping requirements. Recordings are held by Reassure Support on secure cloud infrastructure and are accessible to authorised Reassure Support personnel for safety, compliance, or legal purposes. Support Workers should be aware that as the registered provider of the support at the time of the incident, they may also hold independent obligations to retain incident records under the NDIS Practice Standards.

If you wish to have your data deleted, please contact us at [email protected]. Deletion requests will be actioned as described in Section 11.

9. Disclosure of Information

We do not sell, trade, or rent your personal information to third parties. We may disclose your information only in the following circumstances:

  • Where required or permitted by Australian law or a court order
  • To the NDIS Quality and Safeguards Commission or NDIA where we are legally required or authorised to do so
  • To protect the safety of any person or to prevent fraud or illegal activity
  • To third-party service providers who assist us in operating the software, under strict confidentiality obligations and only to the extent necessary
  • With your explicit consent

Overseas Recipients

Some software services involve overseas processing. The following providers may receive personal information as part of delivering our services:

Retell AI Inc.USA · Voice Processing
Voice agent orchestration for the AI support line. Operates under a BAA with HIPAA, SOC 2 Type I & II, and GDPR certification. Automated PII redaction protocols are applied to call content.
Anthropic PBCUSA · Language Model
Language model processing for the AI support line. Operates under a Data Processing Addendum. Data retained for a maximum of 7 days and never used for model training.
Cloudflare Inc.USA · Traffic & Security
Traffic routing and web application security. All software data transmitted through Cloudflare infrastructure is fully encrypted in transit (TLS), ensuring payload contents — including Participant Health Data — remain unreadable to routing nodes.
Google WorkspaceUSA · Communications
Operational communications and administration. Participant Health Data is not transmitted via email unless initiated by you.
Square Inc.USA · Payments
Payment processing only. No health or Participant data is transmitted to Square.
Telnyx LLCUSA · SMS Notifications
SMS delivery for emergency alert notifications only. When a Support Worker triggers an emergency alert, the nominated emergency contact's phone number and the worker's approximate GPS coordinates are transmitted to Telnyx solely for the purpose of delivering that SMS. No Participant health data or shift records are transmitted to Telnyx.

Where personal information is disclosed to overseas recipients, we take contractual steps to ensure protections comparable to the Australian Privacy Principles apply, including through Data Processing Addenda and Business Associate Agreements. You remain entitled to make a complaint to the OAIC if you believe an overseas recipient has mishandled your information.

10. Cookies

Our website and software may use cookies and similar technologies to maintain your login session and improve your experience. These are functional cookies necessary for the software to operate correctly. We do not use advertising or tracking cookies, and we do not share cookie data with third-party advertisers.

11. Your Rights

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate or outdated information
  • Request deletion of your personal information (subject to legal retention obligations — see below)
  • Withdraw consent where processing is based on consent
  • Lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au

Deletion Requests and NDIS Record-Keeping Obligations

Where a deletion request relates to personal information that forms part of an NDIS shift note, service record, incident report, or other documentation required by law to be retained, we may be unable to permanently delete that information.

In such cases, rather than deleting the records outright, we will:

  • Restrict access to the archived records to authorised compliance personnel only
  • Notify the relevant Support Worker so they can fulfil their own NDIS record-keeping obligations
  • Delete or anonymise all other personal information not subject to mandatory retention

You will be informed of the specific records that cannot be deleted and the reason why.

To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable time and in any case within 30 days.

12. Children's Privacy

Our software is designed for adults. We do not knowingly collect personal information directly from persons under the age of 18.

We recognise that children and young people may also require NDIS or disability support services. Where a child or young person is a Participant, all account creation, profile management, and software interactions must be carried out by a parent, legal guardian, or authorised NDIS representative on their behalf.

If you believe we have inadvertently collected personal information directly from a minor without appropriate guardian involvement, please contact us immediately at [email protected] and we will take prompt steps to address it.

13. Complaints

If you have a complaint about how we have handled your personal information, please contact us first at [email protected]. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

  • Website: www.oaic.gov.au
  • Phone: 1300 363 992
  • Post: GPO Box 5218, Sydney NSW 2001

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page and, for material changes, notify registered users by email or in-software notification. We encourage you to review this policy periodically. Continued use of the software following any changes constitutes acceptance of the updated policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us:

This Privacy Policy is not a substitute for independent legal advice. Reassure Support recommends periodic legal review of this policy as your software grows.