Privacy Statement

SmartStart measures, assesses, reports, and provides advice on improving health. In this role, we are entrusted with private and confidential information concerning the health and fitness of our customers and children in their care. In return, SmartStart provides tailored health information, which can help our customers identify health risks and achieve personal and collective health goals.

SmartStart believes people have a right to the privacy and confidentiality of their personal health and fitness information and we will never wilfully disclose individual, personally identifiable information without the express permission and desire of that individual. SmartStart also collects individual data for the purpose of aggregate profiling (eg. Schools). The information from these profiles is also treated with the same degree of privacy and confidentiality.

We only collect data that is required to measure, monitor and track changes in the physical health and fitness of individuals and groups of individuals (eg. schools), and at no time or in any circumstances is an individual’­s data passed onto another organisation or person, without the agreement of that individual whose data we have collected.

All individuals and their parents (in the case of minors) have access to and may check their data for accuracy and/or interest. Please contact our office if you would like to have access to you or your child’s records and measures (an administrative fee may apply).

SmartStart enters into an agreement to assist schools in the measuring, and assessment of the school’s Personal Development, Health and Physical Education (PDHPE) program, so as to better meet the needs of their students. As such, the delivery of SmartStart becomes part of the school’s program and participation by the students in SmartStart, whilst not compulsory, is part of the schools PDHPE curriculum.

SmartStart’s Privacy and Confidentiality Policies

Staff

All staff members and contractors to SmartStart are specifically briefed and trained in the handling and treatment of private and confidential information collected and disclosed to them. Staff are required to agree to and sign a privacy and confidentiality agreement in order to protect the rights of our customers and enforce the SmartStart privacy and confidentiality policies and procedures.

Business practice

We believe people must know in advance how health and fitness characteristics of individuals and target groups are collected and utilised. SmartStart will always disclose its business practices in advance and will not deviate from its privacy and confidentiality policies without the express consent of the individuals who have relied upon it.

All information recorded by SmartStart is stored in the SmartStart database and remains strictly confidential.

Access to the database is limited to authorised personnel only

In accordance with Commonwealth Privacy Legislation and more specifically, the ten National Privacy Principles (NPPs), SmartStart carries out the following:

  1. Collection NPP Collects only what is necessary
    All information collected from schools, students, organisations and other individuals is used to analyse the physical health profile of the participants and is necessary to assist us in providing meaningful and accurate feedback to students, parents, teachers organisations and other individuals. Examples of information collected are names, date of births, class, physical health measures, injuries or medical and health conditions if applicable.
  2. Use and disclosure NPP Uses fair and lawful means to collect information
    Information obtained from schools, education authorities or directly from the students is collected directly from the schools, parents or students.

    Information obtained from other individuals and organisations are done so with the express consent of the organisation and the individuals involved.

    SmartStart informs participants of why we are collecting the information. SmartStart targets the health and fitness of individuals and only collects information for this purpose.

    Does not disclose an individualís information to any third party

    No individualís results or information is provided to any third party without the express and prior consent of that individual. Only aggregated data may be used in publications and other reports. This is similar to the use of Census information collected by the Australian Bureau of Statistics.

    Only discloses the information for the primary purpose

    The primary purpose of collecting information is to improve the physical health and fitness of Australians by providing statistical analysis and feedback to participants and significant stakeholders such as health and education departments.

  3. Data quality
    Makes sure the information is accurate

    All staff are qualified in the industry and specifically trained by SmartStart in the delivery of protocols and the collection of data. Our methods of statistical analysis have been reviewed by the AIHW. SmartStart also works closely with Canberra University and other experts in the field to ensure that the methods we use and the information we collect is accurate, complete and up-to-date.

  4. Data security
    Makes sure the information is secure

    All information collected is kept secure, under lock and key and stored on premises with security monitoring. The SmartStart software and database is maintained on a stand-alone computer system that has limited access to restricted users. The system is also pass word protected.

  5. Openness
    Discloses to the individual the information we have on them

    Individuals may contact SmartStart and obtain a report on all information SmartStart has on the individual. An administrative fee will apply.

  6. Access and correction
    Allows for corrections and limited access

    Access
    Individuals have access to their own information, for a base fee is. The fee is based on the level of data retrieval and/or reporting of the information requested by the individual.

    Correction
    Individuals may contact SmartStart to inform SmartStart of any incorrect, incomplete and non up-to-date information. Such corrections will be made if the individual can establish that the information held by SmartStart is indeed incorrect, incomplete, and not up-to-date.

  7. Identifiers
    Does not adopt. Use or disclose any identifiers

    SmartStart does not collect any identifying codes such as tax file numbers, Medicare numbers, passport numbers or any personal and sensitive information that can uniquely identify that person to the code/number. Because we do not use identifiers, it stands to reason that we do not collect them and therefore do not disclose identifiers to any parties.

  8. Anonymity
    Provides permission notes

    In the case of students, SmartStart provides permission notes that seeks the following:

    Parent’s willingness for their child to participate;

    If the child has any medical/health conditions that may affect their results; and

    If the parent chooses for their child to remain anonymous during the activities.

  9. Transborder data flows
    Does not provide personally identifiable information to any external organisation or individual within Australia or external Territory or any foreign country.

    SmartStart will only provide information in such a way that conforms to the NPPs.

  10. Sensitive information
    Does not collect sensitive information that is not also personal information relating to the individualís health and fitness.

    Health status – SmartStart takes the necessary steps to ascertain the individual participantís health status at the time of measurement. We do not seek sensitive information about the individual prior to any activity that we conduct, unless that information is pertinent to the individualís previous, present or future health that is likely to affect the information collected at the day of the measure.

GENERAL DISCLAIMER – NO MEDICAL ADVICE

The information and content contained in SmartStart products are for assessing and monitoring progress and changes in health and fitness only. They are not intended to be used for medical diagnosis, medical treatment or to replace evaluation by a qualified physician. SmartStart strongly recommends that all individuals consult with a physician before following the recommendations of any content provided or before starting any diet or exercise program. Never disregard, avoid or delay in obtaining, medical advice from a licensed practitioner based solely on information provided by SmartStart.

CONTENT DELIVERY

Software

One of SmartStartís strength is its robust software which has been specifically designed to (among other things) allow the filtering of highly individualised health content, based on information contained in a individual’s health and fitness records. SmartStart identifiers, allow us to maintain client privacy while delivering very specific messages, alerts and informational data.

Use of aggregate data

SmartStart believes in the individual’s right to privacy and confidentiality and will never wilfully disclose personally identifiable health information to third parties nor anyone else without the express prior authorised consent and desire of that individual. SmartStart will engage in aggregating the data collected of client non-identifiable information. SmartStart reserves the right to supply the aggregate data only to sponsoring organisations such as State and Government Departments, Universities, Health Insurers and others for population analysis and planning and also to schools from which the data was sourced.

Report Delivery

All parent reports ordered are individually sealed in envelopes addressed to the parent(s) and delivered to the school for distribution. Reports ordered after the due date for that particular school are sealed and posted to the parent(s). School reports are sealed and delivered personally by a SmartStart Officer to be presented during a debriefing. The SmartStart officer will explain all aspects of the report and highlight target areas of concern and perhaps provide general advice on how to deal with some areas. More specific advice will come in written form, enumerating the trouble areas and providing options that the school can implement in order to remedy these areas.

THE INTERNET

Use of Content and Copyright

The policies outlined in this document shall form the basis of the Terms and Conditions of use of the SmartStart website. Upon acceptance of these Terms and Conditions, SmartStart authorizes users to view or download a single copy of the material on the SmartStart website solely for personal, non-commercial use.

The contents of the SmartStart site, such as text, graphics, images and other material including software to permit users to access the SmartStart site (’Content’), are protected by copyright under both Australian and foreign laws, and title to the Content shall not pass to the user. Unauthorized use of the Content may violate copyright, trademark, and other laws. None of the Content may be reverse-engineered, disassembled, de-compiled, reproduced, transcribed, stored in a retrieval system, translated into any language or computer language, retransmitted in any form or by any means (electronic, mechanical, photo reproduction, recordation or otherwise), resold or redistributed without the prior written consent of SmartStart except that you may reproduce limited excerpts of the data for personal use, provided that each such copy contains a copyright notice as follows:

SECURITY

Every endeavour is made to ensure that all SmartStart material, whether personal data and details of clients or promotional material is safe and secure and are disclosed strictly on a need to know basis. All material also includes the SmartStart website, itís contents and scripts and software necessary for basic functions. However, users should be aware that the World Wide Web is an insecure public network that is open to a potential risk that a user’s transactions are being viewed, intercepted or modified by third parties or that files which the user downloads may contain computer viruses or other defects.

SmartStart accepts no liability for any interference with or damage to a user’s computer system, software or data occurring in connection with the site. Users are encouraged to take appropriate and adequate precautions to ensure that whatever is selected from the SmartStart site is free of viruses or other contamination that may interfere with or damage the user’s computer system, software or data.

DISCLAIMER OF WARRANTY

SmartStart, to the fullest extent permitted by law, disclaims all warranties, either express or implied, statutory or otherwise, including but not limited to the implied warranties of merchantability, non-infringement of third parties’ rights and fitness for a particular purpose of any of its products or services.

LIMITATION OF LIABILITY

In no event shall SmartStart be held responsible or liable for any indirect, direct, incidental, special or consequential damages or costs whatsoever resulting from or related to the use or misuse of any of its products and services, even if SmartStart has been advised, knows or should be aware of the possibility of such damages. SmartStart shall be liable only for gross negligence or willful misconduct. Remedies under this agreement are exclusive and are limited to those expressly provided for in this agreement.

SmartStart assumes no liability or responsibility for damage or injury to persons or property arising from any use of any product, information, test, procedure, or instructions contained in the materials provided to you.

© Copyright SmartStart (Australia) Pty Limited, Canberra ACT All rights reserved.