Privacy Policy
This Privacy Policy is issued by Resparke Technology Pty Ltd (ACN 623 653 261), trading as Resparke (“we,” “our,” “us”) to comply with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).
This document sets out how we collect, use, store, and disclose personal and sensitive information provided to us, directly or indirectly, in connection with the services we offer.
Our services, including the Resparke Platform and associated features such as “Lifestory,” are specifically designed for use in aged care settings. We acknowledge the significant responsibilities associated with handling sensitive personal information and apply stringent security and governance measures to protect that information.
This Privacy Policy reflects our commitment to transparency, compliance with Australian laws, and ethical data practices. By engaging with our services or providing personal information, you agree to the terms of this Privacy Policy.
1. Defined roles and access permissions
To protect the privacy of individuals, Resparke employs a tiered access control model. Access to personal and sensitive information is restricted based on roles and responsibilities.
Staff user access (aged care personnel)
- Authorised staff can view and edit resident profiles, including multimedia content and sensitive personal details, for the purpose of providing care.
- Each user is issued credentials, and access is subject to audit trails and monitoring to ensure compliance.
Resident access
- Residents may access their profiles to review and update their personal preferences, subject to cognitive and legal capacity.
- Access may be delegated to a legal guardian where necessary, in accordance with guardianship laws of the relevant state of Australia.
Family member access
- Family members authorised by the aged care provider may access and input data to linked resident profiles to assist with user experience.
- Access for family members is limited to view-only unless express authorisation for editing is granted by the resident or their legal representative.
These access levels comply with the principle of data minimisation, ensuring users only access the data required for their role.
2. Scope of information collected
2.1 Categories of information
We collect and process the following categories of information:
Personal information
- Residents: first name, year of birth, place of birth, religion, next-of-kin contact details, and content preferences (e.g. music and videos)
- Family members: first and last name, email addresses, and contact details
- Staff users: employer location and contact details
Sensitive information
- Limited sensitive data may be collected to deliver personalised experiences, including:
- religious or cultural preferences
- multimedia content such as photos, videos, or narratives
- This information is used only to enhance care experience or where permitted by law
- Sensitive data is handled with a high level of confidentiality
Multimedia and “Lifestory” content
- Photos
- Videos
- Narrative content used to personalise resident profiles
Technical and usage data
- Device identifiers
- IP addresses
- Login timestamps
- Session activity logs
2.2 Methods of collection
We collect information through:
- Direct user inputs (forms, onboarding, profile updates)
- Organisational uploads from aged care homes
- Cookies and tracking technologies for analytics and usability
Users can manage cookie preferences via browser settings, though functionality may be limited.
2.3 Information provided by third parties
Where someone provides information about another individual, they confirm that:
- consent has been obtained, or
- they are legally authorised to provide it (e.g. Power of Attorney)
3. Consent and authorisation
3.1 Informed consent framework
Resparke adheres to the requirements for informed consent as outlined under the Privacy Act. Consent may be:
- Explicit: Required for sensitive data, multimedia uploads, and disclosures outside primary purposes
- Implied: Where necessary for service delivery (e.g. during the resident admission process) or where consent is reasonably inferred from interactions
3.2 Specific consent for “Lifestory” feature
- Residents or their legal representatives must provide consent for the inclusion of multimedia content in their “Lifestory”
- Family members uploading content warrant they have obtained any necessary permissions
- The aged care home must ensure that consent aligns with the resident’s capacity and legal rights under guardianship laws
3.3 Withdrawal of consent
Individuals may withdraw consent for the collection, use, or disclosure of their personal information at any time, subject to applicable legal and operational requirements.
To withdraw consent, individuals should contact our Privacy Officer (see Section 9).
4. Use and disclosure of information
4.1 Primary uses
We collect and use information to:
- Facilitate tailored care through multimedia and personalised content
- Enable secure access to resident profiles for staff, residents, and family members
- Provide features like “Lifestory” to enrich the resident experience
- Comply with legal and regulatory obligations
4.2 Secondary uses
De-identified and aggregated data may be used for:
- Internal analytics to improve service delivery
- Research and reporting, ensuring no identifiable personal information is included
4.3 Disclosures to third parties
Information may be disclosed to:
- Authorised users: Staff, residents, and family members as per role-based access permissions
- Service providers: IT contractors, cloud storage providers, and technical support teams under binding confidentiality agreements
- Legal authorities: Courts, regulators, or law enforcement agencies as required by law
Sensitive information is disclosed only with explicit consent or where required by law (e.g. to prevent harm).
Overseas disclosures
While Resparke primarily stores data in Australia, limited access by overseas providers (e.g. disaster recovery services) may occur.
In such cases, we ensure compliance with APP 8 by implementing contractual and technical safeguards equivalent to Australian standards.
5. Data security and breach response
5.1 Security measures
We employ industry-standard measures to protect data, including:
- AES-256 encryption for data at rest and TLS protocols for data in transit
- Regular security audits and penetration testing to address emerging threats
5.2 Data breach notification
In the event of a suspected or actual data breach that is likely to result in serious harm:
- Resparke will promptly investigate the incident
- Affected individuals and the Office of the Australian Information Commissioner (OAIC) will be notified in accordance with the Notifiable Data Breaches Scheme
6. Individual rights
Individuals have the right to:
- Access: Request a copy of their personal information, subject to verification and legal limitations
- Correction: Propose updates to inaccurate or incomplete data
- Withdraw consent: Revoke consent for certain uses, subject to legal requirements
Requests should be directed to the contact details provided in Section 9.
7. Amendments to this policy
We may update this Privacy Policy periodically. Substantive changes will be communicated directly to affected users via email notifications or in-app alerts.
8. Definitions
- Sensitive Information: As defined under the Privacy Act, including racial or ethnic origin, health information, and other protected categories
- Data Breach: Unauthorised access, disclosure, or loss of personal information likely to result in serious harm
9. Contact us
For inquiries, corrections, or complaints:
Contact Person: Privacy Officer
Email: info@resparke.com
Our Privacy Policy was last updated on 14.01.2025.