Privacy Policy

About this policy

Telo One (ABN 74 169 269 966), trading as telo, is an Adelaide provider of disability supports. In this policy, “TELO”, “we”, “us” and “our” mean Telo One.

This policy applies when you use telo.au, submit a referral or enquiry, join a program update list, communicate with us, receive or help coordinate supports, use a TELO portal account, apply to work with us, or otherwise deal with TELO.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) where they apply. As a disability support provider, we may be covered by the Privacy Act when handling health information even if a small-business exemption would otherwise be relevant.

Who this policy covers

This policy covers personal information about participants, prospective participants, children and young people, family members, nominees, guardians, carers, emergency contacts, support coordinators, plan managers, advocates, health professionals, workers, contractors, applicants, suppliers, visitors and people who communicate with TELO.

It also applies where a person acts for someone else. We may ask for evidence that a representative has authority to receive information, make decisions, manage funding, accept an agreement or exercise privacy rights. Authority for one purpose does not automatically authorise every other purpose.

This policy concerns living individuals. Information about a deceased person may still be protected where it also reveals personal information about a living person, is subject to confidence, forms part of a participant record or is protected by another law.

Key terms

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or recorded in a material form.

Sensitive information includes health and disability information and information about matters such as racial or ethnic origin, religious beliefs, sexual orientation, criminal record and biometric identifiers. Health information includes information or opinions about a person’s physical or mental health, disability, wishes about future health services and health services provided or to be provided.

Collect includes gathering, acquiring, recording, generating, inferring or obtaining personal information. Use generally means handling information within TELO. Disclosure generally means making information accessible outside TELO and releasing effective control of it.

Consent may be express or implied where the law permits, but must be informed, voluntary, current and specific, and given by a person with capacity or an authorised representative. Consent is not the only basis on which privacy law may permit information handling.

Information we collect

The information we collect depends on your relationship with TELO. It may include:

Contact, identity and relationship details

• name, preferred name, pronouns, date of birth and contact details;
• address, service location, emergency contacts and preferred communication method;
• your relationship to a participant, including whether you are a nominee, family member, carer, support coordinator, plan manager or authorised representative; and
• evidence of identity, authority or consent where reasonably needed.

Referral and service information

• referral details, requested supports, availability, preferences and service history;
• NDIS number, plan-management method, plan dates, budget or funding details and invoice recipient;
• support plans, goals, communication needs, access instructions, identified risks, agreed strategies and support preferences;
• progress notes, shift records, travel, participant confirmations, complaints, incidents and corrective actions; and
• service agreements, consents, signatures, documents and records of changes or acceptance.

Financial, workforce and digital information

• quotes, invoices, payment status and transaction references, but not full payment-card details unless a payment provider specifically requires them;
• job applications, qualifications, checks, credentials, availability, work history and contractor or employment records;
• portal account details, permissions, messages, notification preferences and audit history; and
• technical information such as IP address, browser and device information, timestamps, security events, form-verification results and pages requested.

Where reasonably necessary and lawful, we may collect government-related identifiers such as an NDIS, Medicare or Centrelink number. We do not adopt these identifiers as our own account number and do not use or disclose them except as permitted by law.

Service records

TELO creates and maintains records needed to understand, arrange and evidence the supports it provides. Depending on the service, these may include intake assessments, agreements, consent records, support plans, risk information, rosters, attendance records, progress notes, transport records, expenses, participant confirmations, communications, incidents, complaints and review outcomes.

Progress notes and other care records should be factual, relevant and proportionate to the support delivered. They may describe what occurred, assistance provided, progress towards an agreed goal, changes noticed, risks, follow-up required and whether the participant or representative confirmed the record. We do not require workers to record unrelated opinions or unnecessary intimate detail.

Some service records are append-first. If a completed note, acceptance, confirmation or incident record needs correction, TELO may preserve the original and add a dated amendment rather than silently replacing history. This protects the integrity of participant, worker, complaint, funding and audit records.

Participant-visible records are separated from internal administration and restricted safety, complaint, incident, workforce or legal material. A participant or representative may request access under the access section of this policy, but portal visibility is not the only measure of whether a record exists or may be accessed.

Where information is supplied by another person, the record may identify the source and whether the information was verified. A record of an allegation or concern does not mean TELO has accepted it as fact.

Identifiers and verification

TELO may need to verify a person’s identity, role or authority before discussing a referral, granting portal access, accepting an agreement, releasing records, changing payment instructions or responding to an access request. The verification required depends on the sensitivity of the action and may include matching existing contact details, a one-time code, an invitation, a government-issued document or evidence of appointment or authority.

We collect only the verification information reasonably needed for the task. Where practical, we record that a document was checked rather than retaining a complete copy. If a copy must be retained, access is restricted and the copy is kept only for an appropriate period.

Government-related identifiers are handled only where reasonably necessary and permitted. We do not use an NDIS, Medicare, Centrelink, tax file or similar number as TELO’s general-purpose internal identifier. Tax file numbers, if lawfully collected for workforce administration, are segregated from participant records and subject to additional restrictions.

TELO may decline or pause a high-risk request if identity or authority cannot be established. We will explain what is missing where doing so would not compromise security or another person’s privacy.

How we collect information

We collect information directly from you wherever practical, including through our forms, portal, email, phone, text message, documents, meetings and delivery of supports.

We may also collect information from a person you authorise, such as a nominee, parent or guardian, family member, carer, support coordinator, plan manager, health professional, another provider or an emergency contact. We may receive information from the NDIA, the NDIS Quality and Safeguards Commission, government agencies, screening bodies, insurers or professional advisers where authorised or required.

If you give us information about another person, you must have a reasonable basis and authority to do so. Where practical, please tell them that you have shared their information and direct them to this policy.

If we receive personal information we did not request, we assess whether we could lawfully have collected it. If not, and if lawful and reasonable, we destroy or de-identify it.

Collection notices

Where reasonable in the circumstances, at or before collection—or as soon as practicable afterwards—we provide a notice or otherwise make a person aware of matters relevant to that collection. This may include:

• TELO’s identity and contact details;
• the facts and circumstances of collection, including the source where information was obtained from someone else;
• whether collection is required or authorised by law and, where appropriate, the relevant law;
• the purposes for collection and the main consequences if requested information is not provided;
• the usual types of people or organisations to which the information may be disclosed;
• how to access and correct information or make a privacy complaint; and
• whether TELO is likely to disclose information overseas and the likely countries where practicable.

A notice may appear on a form, in the portal, in an agreement, in an email, in a recorded script or in another format suited to the person and the collection. A notice explains a particular collection; this policy explains TELO’s broader privacy practices.

Choice and anonymity

You may deal with TELO anonymously or using a pseudonym where it is lawful and practicable. General website browsing and an initial general question may not require your full identity.

Anonymity will often not be practicable where we need to assess a referral, verify authority, enter a service agreement, arrange safe support, respond to a complaint or incident, maintain required records, manage funding or provide access to a secure portal. We may explain what minimum information is needed and why.

You may choose not to provide information, withdraw an optional consent or ask us to limit a particular use. We will explain any reasonably foreseeable effect, such as being unable to provide a requested service safely, verify a claim, contact an emergency person or meet a legal obligation.

How we use information

We use and disclose personal information for the purpose for which it was collected and related purposes you would reasonably expect, including to:

• respond to enquiries and assess, accept, waitlist or decline referrals;
• verify authority, identity, eligibility, funding and service suitability;
• plan, schedule, deliver, document, review and improve supports;
• communicate with participants and authorised members of their support network;
• manage safety, incidents, complaints, emergencies, quality and continuity of support;
• prepare service agreements, invoices, records, reports and payment reconciliations;
• operate secure accounts, messages, notifications, documents and audit records;
• manage workers, applicants, contractors, credentials and assignments;
• run the Social Club interest list and other programs a person chooses to hear about;
• prevent fraud, spam, misuse and unauthorised access; and
• meet legal, insurance, taxation, record-keeping and NDIS Code of Conduct obligations.

If information is required by law, or if not providing it means we cannot assess a referral or safely provide a service, we will explain this where practical. Otherwise, providing information is voluntary, but we may be unable to respond or provide the requested service without enough relevant information.

Consent and other legal bases

Where consent is required, we take reasonable steps to explain what is proposed, the information involved, the purpose, likely disclosures and how consent may be withdrawn. Consent may be recorded through a signed form, portal action, email, verbal agreement or conduct where that method is suitable and lawful.

Withdrawing consent does not invalidate handling that occurred while consent was current. It may also not require TELO to delete a record that must be kept for legal, safety, insurance, accounting, complaint, incident or evidentiary reasons.

Privacy law may permit or require collection, use or disclosure without consent. Examples include where the handling is required or authorised by law, reasonably necessary for certain enforcement-related activities, needed to locate a missing person, or necessary to lessen or prevent a serious threat to life, health or safety. We consider the circumstances and keep a written note where required.

We do not rely on a broad or bundled consent to justify unrelated handling. A consent to coordinate supports, for example, is not automatically consent to publish a photograph or receive promotional messages.

Sensitive information

Sensitive information includes health, disability, racial or ethnic origin, religious beliefs, sexual orientation and other information given additional protection by law. We collect it only where reasonably necessary for our functions and with consent, or where another legal exception applies.

Worker access is restricted to information reasonably needed to deliver the assigned support. Finance, complaints, incident and administrative information is restricted further according to role and purpose.

In an emergency, or where permitted by law, we may collect, use or disclose information without prior consent when reasonably necessary to lessen or prevent a serious threat to life, health or safety.

Children and representatives

When information concerns a child, young person or adult who uses decision-making support, TELO takes reasonable steps to identify who can make or assist with the relevant decision. Depending on the circumstances this may be the person, a parent, guardian, nominee, attorney, advocate or another authorised representative.

We do not assume that a person lacks capacity because of age, disability, communication style or the involvement of a representative. We seek to communicate in a way the person can understand, involve them to the greatest extent practicable and respect their preferences, will, dignity and right to privacy.

We may verify identity, relationship and scope of authority before sharing information or accepting instructions. We may decline an instruction where authority is unclear, where it conflicts with the person’s known wishes or rights, or where acting on it would be unlawful or unsafe. We may also record competing instructions and the steps taken to resolve them.

A Social Club registration for a person aged 12–17 must be completed by a parent or guardian. Additional consent, emergency-contact and participation information may be requested before any program begins.

Sharing information

We do not sell or rent personal information. Depending on the circumstances and authorisations, we may disclose relevant information to:

• TELO administrators, assigned support workers and authorised contractors;
• participants, nominees, guardians, family members, carers and emergency contacts;
• support coordinators, plan managers, health professionals and other providers involved in a person’s supports;
• the NDIA, NDIS Quality and Safeguards Commission, police, courts, emergency services or other authorities where required, authorised or reasonably necessary for safety;
• insurers, accountants, auditors, lawyers and other professional advisers; and
• service providers that host or support our website, portal, identity checks, file storage, email, communications, bot protection, invoicing and other business systems.

We require service providers to handle information only for agreed purposes and apply appropriate safeguards. We may also disclose information with your consent or at your direction.

Workers and access controls

TELO uses role-based and relationship-based access. An administrator may need broad access to operate the service, while a worker ordinarily receives only information needed for participants they are currently assigned to support. A worker’s access may include the participant’s preferred name, communication needs, relevant goals, service location, access instructions, identified support risks and agreed strategies.

Workers do not receive funding, referral, complaint, incident, financial or unrelated clinical information merely because they work with a participant. Access to those records is separately restricted unless the worker has a legitimate operational need and disclosure is permitted.

Access may be removed when an assignment ends, a role changes or an account is suspended. Some audit records remain after access ends so TELO can establish who viewed or changed important information. Workers and contractors are required to maintain confidentiality and use information only for authorised work.

Where a participant or authorised representative uses the portal, their permissions may be limited to particular records, messages, agreements, confirmations, invoices or documents. A nominee’s access is not necessarily identical to the participant’s access.

Workforce and recruitment

TELO may collect information from applicants, workers, contractors, referees and screening or credential bodies to assess suitability, engage and manage workers, meet safety and insurance requirements, allocate supports and administer payments. This may include qualifications, experience, contact details, availability, service areas, work rights, licences, insurance, screening checks, training, performance, complaints and payroll or contractor payment information.

We may ask referees questions relevant to the role and verify qualifications or checks with the issuing body. Applicants should provide referee details only where the referee has agreed to be contacted. We do not ask for health or disability information unless it is reasonably relevant to inherent requirements, safety, workplace adjustments or another lawful purpose.

Information about an unsuccessful applicant may be retained for a reasonable recruitment, complaint and legal period, and may be considered for a future role where the applicant has agreed or would reasonably expect it. An applicant may ask TELO not to retain their details for future opportunities.

Where an employee-record exemption applies to a record directly related to a current or former employment relationship, that record may not be governed by the APPs in the same way as other personal information. TELO nevertheless aims to handle workforce records securely, fairly and on a need-to-know basis. Contractor and applicant records remain subject to applicable privacy obligations.

Workers may be told only the participant information needed to assess or perform a proposed assignment. Participants may be given a worker’s client-safe profile, relevant experience, availability and verified credential status, but not unrelated workforce or private information.

Service providers

TELO uses specialist suppliers to operate its business. These may include providers of website hosting, identity and account management, databases, file storage, email, telecommunications, spam protection, mapping, document generation, electronic signatures, accounting, invoicing, payment processing, analytics, backups and professional support.

We assess the information a supplier needs and seek to limit access to that purpose. Depending on the service, safeguards may include contractual confidentiality and security terms, access restrictions, encryption, audit records, deletion requirements, incident-notification obligations and review of supplier security information.

A supplier may act only on TELO’s instructions or may independently determine some handling under its own terms and legal obligations. Where a third party deals directly with you—for example, an identity, payment, email or map service—its privacy policy may also apply. TELO remains responsible for obligations that cannot lawfully be transferred to a supplier.

We do not publish a permanent vendor list in this policy because providers and subprocessors can change. You may ask privacy@telo.au for current information about the category and likely location of a provider handling your information.

Payments and billing

TELO handles billing information to prepare and send invoices, reconcile payments, manage plan-manager or self-managed funding, respond to billing questions, prevent duplicate claims and meet accounting, taxation and audit obligations. Records may include service dates, support item numbers, quantities, rates, kilometres, cancellation reasons, invoice recipients, invoice references and payment status.

Where a plan manager, nominee, financial administrator or other payer is involved, TELO may disclose the minimum service and participant information reasonably required to issue, explain or reconcile an invoice. The payer’s authority and the participant’s preferences are considered when deciding what information appears in an invoice or supporting document.

Bank feeds and accounting integrations may provide transaction descriptions, dates, amounts and partial account references. TELO may use exact invoice references and totals to suggest or apply a match. Ambiguous or redacted transaction descriptions should be reviewed rather than automatically treated as proof that a particular invoice was paid.

TELO does not ordinarily receive or retain full debit or credit card credentials. If an external payment service is offered, card or bank credentials are entered into that provider’s service and are handled under its security and privacy terms. TELO may receive a token, receipt, status or limited reference needed to identify the transaction.

Billing records may be retained for at least the period required by taxation, corporate, insurance and other applicable laws, even after a service relationship ends or a portal account closes.

Authorities and emergencies

TELO may disclose relevant information to the NDIA, NDIS Quality and Safeguards Commission, police, emergency services, courts, tribunals, regulators, screening units, insurers or other authorities where disclosure is required or authorised by law, directed by a valid legal process, or permitted to protect safety.

Where practicable and lawful, we check the identity and authority of the requester, clarify the scope, disclose only information reasonably responsive to the request and keep a record of the disclosure. We may not be permitted to notify the person before or after a disclosure.

If TELO reasonably believes there is a serious threat to life, health or safety, we may contact emergency services, a guardian, nominee, emergency contact or another person able to reduce the threat. Information shared will be limited to what is reasonably necessary in the circumstances.

Records about incidents, allegations or complaints may contain information about several people. Privacy rights are considered alongside safety, procedural fairness, confidentiality, legal privilege and the rights of others.

Overseas processing

Some technology providers and their subprocessors store or process information outside Australia. The United States is a likely location for parts of our secure portal, identity and cloud infrastructure. Other countries may be involved where a provider uses global support or subprocessing arrangements.

Before making a cross-border disclosure, we take steps that are reasonable in the circumstances to protect the information and address the requirements of APP 8. Depending on the arrangement, overseas cloud processing may sometimes be a use of information under our effective control rather than a disclosure. You may contact us for current information about the location or category of a particular service provider.

Reasonable steps may include reviewing the provider’s location and safeguards, limiting the information supplied, imposing contractual controls and considering whether TELO retains effective control. In some circumstances an APP 8 exception may apply, including where informed consent is validly obtained or a disclosure is required or authorised by law.

Overseas recipients may be subject to foreign laws. Those laws may allow access by courts, governments or regulators and may not provide privacy protections or complaint rights equivalent to Australia. We do not treat a general statement in this policy as consent to avoid taking reasonable cross-border steps.

Website and portal data

Our site uses essential technical storage and security tools needed to operate forms, remember limited preferences, maintain sessions and protect against misuse. Cloudflare Turnstile may process device, browser, network and interaction signals to distinguish genuine visitors from automated submissions. TELO receives the verification result; Turnstile does not need the referral text itself to perform that check.

Authenticated portal activity may create security and audit records, including sign-in identity, role, access time, document actions, agreement acceptance, IP-derived information and browser information. These records help protect participants, prevent unauthorised access and maintain reliable evidence of important actions.

We use basic server-side traffic totals to understand demand for our public website and identify delivery problems. These totals count requests, not individual people: public page, UTC day, approximate country, device and browser category, broad referral source and response status. Known automated requests are counted separately. Query strings, referral search terms, full referring addresses, form contents and IP addresses are not stored in this analytics dataset. IP addresses and request headers are necessarily processed by our hosting provider to deliver and secure the website; its operational records are separate from these totals.

If you submit an enquiry using a recognised TELO advertising link, we may keep the campaign label with your enquiry to understand which campaigns generate requests for support. This label contains no visitor identifier, search term or advertising click ID. It stays in the page address while you follow support and enquiry links; it is not stored in advertising cookies or browser storage. We do not send your enquiry or its campaign attribution back to Google or other advertising platforms. A campaign label is an indication of the link used, not proof that you personally clicked an advert.

Daily traffic totals are retained for approximately 180 days and minute-level totals for approximately 24 hours, with scheduled deletion. These totals do not use cookies, persistent visitor identifiers, advertising identifiers or cross-site profiles. They cannot tell us who visited, how many unique people visited or the path an individual took. Country estimates may be incorrect because of VPNs and network routing.

Optional Cloudflare Web Analytics and live country-level activity run only after you select “Accept analytics”. Cloudflare measures visits, pages and site performance without analytics cookies. Live activity uses a random key held only in a page’s memory while it is open; visible pages send a heartbeat approximately every 30 seconds. A page stops being counted within 90 seconds of its last heartbeat, and temporary presence records are deleted within approximately 15 minutes of their last update. Administrators see country totals, never the page keys, visitor identities or precise locations. Multiple open tabs may be counted separately. Rejecting analytics leaves these optional features off. We do not send referral or application form contents to either feature, use advertising pixels or record browsing sessions.

With your optional analytics acceptance, Google Analytics also measures public page visits, sessions, broad traffic sources, approximate location, device and browser information. It uses first-party _ga cookies on the public website for up to 180 days. Event-level data is retained in Google Analytics for two months; aggregated reports may remain longer. We supply only recognised public page addresses without query strings or fragments, fixed page titles, recognised search/social referral origins and an allowlisted campaign label. Automatic form, search, outbound-link and video measurement is off. We do not send names, email addresses, phone numbers, enquiry answers, participant identifiers or disability information to Google Analytics. Google advertising personalisation and Google Signals are off; no session recordings, enhanced conversions or customer-data uploads are enabled. Google necessarily processes technical request information to provide the service and may process data outside Australia. Read how Google uses information from sites that use its services.

We store your analytics choice in this browser’s local storage under telo.analytics-consent.v3 for up to 180 days. This preference is not a tracking identifier. Existing rejections remain respected; earlier acceptances require a fresh choice before Google Analytics is activated. You can change your choice using “Analytics preferences” in the footer; withdrawing consent clears this public website’s Google Analytics cookies and refreshes the page to stop analytics scripts. The choice applies to this browser and public website, not every device or our separately authenticated portals, where this Google Analytics tag is not installed. First-party traffic totals and temporary presence are processed using our Cloudflare and Convex infrastructure; access to the dashboard is restricted to active administrators. Rejecting analytics leaves all optional browser analytics off without preventing an enquiry.

Hosting, network and security logs still operate when optional analytics is rejected. Cloudflare Turnstile remains available to protect forms and may use essential security storage. Rejecting optional analytics does not prevent you from making an enquiry. Read Cloudflare’s analytics documentation for information about the service.

Portal sessions, forms and documents may be unavailable during maintenance, network interruption or a security response. If an urgent operational or safety matter cannot wait for the portal, use an appropriate direct or emergency contact method.

Communications

TELO may communicate by phone, email, text message, portal message, video call, post or in person. The chosen channel depends on urgency, accessibility, the person’s preferences, security and the nature of the information. Standard email and text messages can be misdirected, forwarded, intercepted or viewed on a shared device, so highly sensitive material may be placed in a secure portal or protected attachment instead.

We may retain correspondence, call notes, delivery and read status, attachments and records of significant verbal discussions where reasonably necessary for continuity, safety, agreements, complaints, billing or evidence. We do not routinely record telephone or video calls. If a call is to be recorded, we will give notice and obtain the consent or authority required by law.

A person may nominate preferred contacts and communication methods. TELO may use another method where the preferred channel is unavailable, an urgent safety matter exists, the law requires it or identity cannot be safely verified through that channel.

Messages may contain information about several people. Before forwarding, copying or uploading a communication, consider whether doing so would reveal another person’s confidential information. Portal members must not share messages or documents beyond the authority and purpose for which access was provided.

TELO may use approved templates and automated delivery for routine notices, but important service, complaint, incident and access decisions remain subject to appropriate human review.

Location and travel

To arrange community access, in-home support or transport, TELO may collect service addresses, access instructions, destinations, planned routes, kilometres and travel purposes. Workers may record actual stops and distances for service evidence, timesheets, invoices, safety and reimbursement.

TELO does not currently require continuous GPS tracking of participants or workers through its portal. If a map or routing service is used, it may receive the addresses or place names entered and technical information associated with the request under its own terms.

Location details can reveal sensitive information, including where a person lives, receives health services, worships or participates in community activities. Access is limited to people who need the information for the support, billing, safety or audit purpose.

In an emergency or where a worker is overdue and there is a reasonable safety concern, TELO may use known schedule, destination and contact information to check welfare or contact an emergency person or service. We record the reason and limit the information used to what is reasonably necessary.

If TELO later introduces live location or GPS functionality, it will first assess necessity and proportionality, provide a specific notice and obtain any consent required. This policy does not constitute advance consent to continuous tracking.

Automation and AI

TELO may use automation for form validation, spam detection, notifications, scheduling checks, invoice reconciliation, document preparation, search, security monitoring and administrative workflow. These systems may compare information, flag an inconsistency or recommend that a staff member review a record.

TELO does not currently use personal information in a solely automated decision that has a legal or similarly significant effect on a person. Important decisions about accepting a referral, providing or ending support, participant safety, worker access, complaints and incidents are made or reviewed by a person.

We do not intentionally place participant health information, support notes or confidential documents into a general-purpose public AI service. If TELO introduces an AI tool that handles personal information, we will assess necessity, supplier terms, security, data location, retention, human oversight and whether a new notice or consent is required.

You may contact us if you believe an automated process has produced an incorrect result. We can review the information and, where appropriate, arrange human consideration.

Analysis and de-identification

TELO may use information to measure service delivery, identify missing records, understand demand, forecast staffing, monitor funding use, improve accessibility, investigate recurring problems and meet quality or reporting obligations. Wherever practical for the purpose, we use aggregated or de-identified information rather than directly identifying records.

De-identification involves removing or altering identifiers and considering whether a person could reasonably be re-identified from the remaining data and other available information. Simply removing a name may not be enough, particularly for a small service, unusual event or detailed location history.

We may create internal operational reports such as delivered hours, cancellation patterns, invoice ageing, credential status, incident categories and complaint outcomes. Access to an underlying identifiable record remains governed by role, assignment and purpose even if a summary is available more broadly inside TELO.

TELO does not currently sell participant data, build advertising profiles from service records or provide identifiable participant information for unrelated commercial research. If TELO proposes research or publication involving identifiable or sensitive information, it will assess ethics, consent, legal authority, data minimisation and the risk of re-identification separately.

De-identified or aggregated information may be retained for longer than source records where it no longer constitutes personal information and retention remains lawful and useful. TELO will not deliberately attempt to re-identify information received as de-identified unless permitted by law and required for a legitimate purpose.

Updates and marketing

We send Social Club or similar program updates only where a person has asked to receive them or another lawful basis applies. Where a message is a commercial electronic message, we obtain or rely on the consent required by the Spam Act 2003, accurately identify TELO, provide current contact details and include a clear, functional way to unsubscribe.

You can opt out at any time by using the unsubscribe option or contacting us. We do not charge for opting out, require you to create or sign into an account, or require unnecessary information. We action a valid unsubscribe request within five working days and keep the unsubscribe facility working for at least the period required by law.

Operational messages about an enquiry, support, agreement, invoice, safety issue or account are not marketing and may still be sent where necessary to provide or administer the service.

We keep records of marketing consent and opt-out requests. We do not use address-harvesting software or lists created by address-harvesting software, and we do not sell contact lists.

Images and recordings

TELO may create photographs, video, audio or other recordings for a defined service, safety, training, evidentiary or communication purpose. We explain the purpose and seek the consent required in the circumstances before using an identifiable image for marketing, a testimonial, social media or public promotion.

Consent to receive supports does not by itself authorise promotional use. A person may decline promotional photography without losing access to otherwise available supports. Consent may identify where material may appear, how long it may be used and whether a name or other identifying detail may accompany it.

If promotional consent is withdrawn, TELO will stop new use within a reasonable period and remove material we control where reasonably practicable. Withdrawal may not remove copies already lawfully printed, downloaded, archived by third parties or incorporated into records that must be retained.

Recording another participant, worker or visitor without their permission may breach their privacy or these terms. A person who needs to make a recording as an accessibility adjustment or for a lawful protective purpose should discuss this with TELO where it is safe and practicable to do so.

Data quality

We take steps that are reasonable in the circumstances to ensure personal information is accurate, up to date, complete and relevant before using or disclosing it. The steps depend on the sensitivity of the information, its age, its source, the purpose and the possible consequences of an error.

For important decisions or disclosures, we may confirm details with the individual or an authorised representative, distinguish observed facts from opinions, record the source and date, or note where information is disputed or not independently verified.

Participants, representatives, workers and other contacts should tell TELO when contact details, authority, risks, medication information supplied for safety, access instructions, plan-management arrangements or other material facts change. A portal update does not always replace the need to tell the relevant TELO contact about an urgent safety change.

Security

Our safeguards include role-based access, authenticated accounts, access logging, protected file delivery, encrypted connections, spam and bot controls, supplier controls, backups and staff confidentiality practices. No system is completely secure, so we also maintain processes for responding to suspected incidents.

Reasonable safeguards are selected having regard to the volume and sensitivity of information, foreseeable harm, the way information is stored and accessed, available security measures and the cost and practicality of implementation. Controls may include least-privilege permissions, multifactor or managed authentication, password and session protections, secure configuration, software updates, monitoring, recovery procedures and restricted administrative access.

Workers and service providers are expected to use approved systems, protect devices and credentials, avoid sharing records through unauthorised channels, report suspected loss or access promptly and return or securely dispose of records when no longer authorised.

You also play a role in security. Keep account credentials and verification methods private, use a secure device, sign out of shared devices, check recipients before sending sensitive information and tell us promptly if a device, email address or account may be compromised.

Retention and deletion

We retain information only for as long as reasonably needed for the purpose for which it may lawfully be used or disclosed, continuity and safety of support, participant rights, complaints and incidents, insurance, audit and legal or regulatory record-keeping.

Retention periods differ by record type and may be affected by a participant’s age, the date of the last service, limitation periods, taxation and accounting rules, NDIS requirements, employment and screening obligations, an unresolved complaint or incident, anticipated litigation, a legal hold or an order from an authority.

Closing an account, ending supports, withdrawing consent or asking for deletion does not automatically erase all records. We may archive records and restrict routine access where continued retention is required or reasonably necessary. An archived record remains protected and is not used for unrelated purposes.

When information is no longer required and no law, order or legitimate need requires us to keep it, we take reasonable steps to destroy it securely or ensure it is de-identified. De-identification aims to remove the reasonable likelihood that an individual can be identified, having regard to other available information.

Deletion from active systems may not immediately remove encrypted backup copies. Backups are protected, not used as ordinary records and removed or overwritten through the normal backup cycle. If restored after a security event, deletion controls are reapplied where practicable.

Access

You may ask for access to personal information we hold about you. Contact privacy@telo.au and describe the records, period or subject matter you need and your preferred format.

We may need to verify your identity and, for a representative, the scope of authority. We respond within a reasonable period and, where reasonable and practicable, provide access in the requested manner. Access may be provided through a secure download, inspection, copy, summary, assisted explanation or another suitable method.

We generally do not charge for making a request. A reasonable charge for giving access may apply where permitted, but it will not be excessive and will be explained in advance.

Privacy law permits access to be refused or limited in some circumstances, including where access would pose a serious threat, unreasonably affect another person’s privacy, reveal evaluative information from a confidential process, prejudice negotiations, be unlawful, relate to legal proceedings, reveal commercially sensitive decision-making or interfere with enforcement activity. Where possible, we consider giving partial access or using redaction instead of refusing the whole request.

If access is refused, we provide written reasons and available complaint options unless it would be unreasonable or unlawful to do so.

Correction

You may ask us to correct personal information that is inaccurate, out of date, incomplete, irrelevant or misleading. You may provide supporting material and ask us to notify another person or organisation to which we previously disclosed the information.

We take reasonable steps to correct information where satisfied it should be corrected, having regard to the purpose for which it is held. A clinical or support opinion is not necessarily inaccurate because another person disagrees with it, but the record should distinguish fact, observation, source and opinion appropriately.

If we do not agree to a correction, you may ask us to associate a statement with the record explaining that you consider it inaccurate, out of date, incomplete, irrelevant or misleading. We take reasonable steps to do so in a way that makes the statement apparent to users of the record.

We respond within a reasonable period and do not charge for making a correction request, correcting information or associating a statement. A refusal includes written reasons and complaint options unless it would be unreasonable or unlawful to provide them.

Data breaches

A data breach occurs when personal information is lost or subjected to unauthorised access or disclosure. Examples may include an email sent to the wrong recipient, a lost device, compromised credentials, improper worker access, a supplier incident or deliberate misuse.

If we suspect a breach, we take steps appropriate to the circumstances to:

• contain the incident and prevent further access or disclosure;
• preserve evidence and identify the affected systems, records and people;
• assess the nature and sensitivity of the information, likely access, possible consequences and risk of serious harm;
• change credentials, recover records, correct recipients or take other remedial action;
• work with affected suppliers, insurers, advisers, authorities and individuals; and
• review controls and record the response.

Under the Notifiable Data Breaches scheme, an eligible data breach generally arises where unauthorised access or disclosure, or loss likely to lead to it, is likely to result in serious harm and remedial action has not prevented that likely harm. Where notification is required, we notify the Office of the Australian Information Commissioner and affected individuals in the manner required by law.

A notification may describe the incident, the kinds of information involved, recommended protective steps and how to contact TELO. If you believe information has been sent to you in error or an account has been compromised, do not forward or use the information; contact privacy@telo.au promptly.

Privacy complaints

Send a privacy complaint to privacy@telo.au. Include enough detail for us to understand the issue and how you would like it resolved. You may also call 0494 826 368 or write to Telo One at 52/92 Walkerville Tce, Walkerville SA 5081.

You may use an advocate, interpreter or authorised representative. We may ask for identity or authority evidence and may seek further information, but we will not require unnecessary sensitive details. Making a complaint will not adversely affect a person’s access to supports.

We aim to acknowledge a privacy complaint within five business days and provide an outcome within 30 calendar days. If a matter is complex and requires longer, we will explain why and provide an updated timeframe.

We assess the complaint impartially, review relevant records, give affected people a reasonable opportunity to provide information where appropriate, document findings and communicate an outcome and any action. Possible outcomes may include an explanation, correction, access, apology, process change, worker guidance, supplier action or security improvement.

If you are not satisfied, you may complain to the Office of the Australian Information Commissioner. The OAIC generally expects you to complain to TELO first and allow a reasonable time for response. Concerns about the quality or safety of NDIS supports can also be raised with the NDIS Quality and Safeguards Commission.

Business changes

If TELO considers a genuine restructure, merger, financing, sale, transfer or closure, personal information may need to be reviewed by professional advisers or transferred with the relevant part of the business. Any handling remains subject to confidentiality, privacy law and the purposes for which the information was collected.

Before a transfer, TELO considers whether the proposed recipient can lawfully perform the relevant services and protect the information. Where appropriate and legally permitted, information may first be de-identified, access may be staged, and only records needed to assess or complete the transaction may be disclosed.

If responsibility for active participant records changes, TELO will take reasonable steps to give affected people clear information about the new entity, contact details, effective date, ongoing access and correction rights, and any choices available. A transfer of records does not by itself transfer consent for unrelated marketing or public use.

If TELO closes without a successor, records will not simply be abandoned. We will arrange secure retention, lawful transfer, return, de-identification or destruction according to the record type and applicable obligations, and maintain a contact pathway for rights that continue after closure where reasonably possible.

Nothing in this section permits TELO to sell personal information as a standalone commercial list. It addresses only legitimate changes involving the operation or continuity of the business or its services.

Changes and contact

We review this policy when our practices, systems, suppliers or legal obligations materially change. The current effective date appears at the top of the page. Changes apply prospectively unless the law requires otherwise.

If a change materially affects how information already collected will be used or disclosed, we consider whether a new notice, consent or other step is required rather than relying only on publication of an updated policy.

You can request this policy in a more accessible or alternative format, ask a privacy question or request current information about our practices by contacting:

General enquiries may be sent to hello@telo.au, referrals to referrals@telo.au, and service complaints to complaints@telo.au.