Version 5.0 – April 2019
About this policy
We may amend or update this policy when our information collection and handling practices change. If this happens any updates will be published on our web site and we will use our best endeavours to notify you either by email or by posting a notice of the changes in the platform. If you do not agree with the changes you must cease accessing the platform. If you continue to access or use the platform after the changes come into effect, we will assume that you have agreed to them.
What is InnoWell?
InnoWell delivers digital health solutions to promote mental health and wellness and help people receive the right care at the right time. Through research and development, we seek to redesign health systems to better meet the holistic needs of people across their lifespan. We do this by using innovative co-design methodologies to engage all members of the community and integrate input and perspectives from those with a lived experience and insights from the health sector, as well as incorporating research evidence and product design knowledge into our digital solutions. InnoWell is the owner of the InnoWell platform. More information about InnoWell can be found here
1) For participants in the InnoWell platform
What is the InnoWell platform?
The InnoWell platform is a customisable digital platform that is designed to assist in assessing, monitoring and managing mental health issues and the maintenance of wellbeing. It does this by collecting and processing your personal information (including sensitive and health information). Your personal information and the information we create about you through processing is then made available to both you and your care service provider through the platform to support your mental health and to promote collaborative care partnerships.
The InnoWell platform is designed to provide services to you that are suitable for your individual needs as assessed by your care service provider. Because of this, the exact nature of the personal information that the platform collects and handles differs from person to person. All personal information is collected and handled in accordance with the requirements of the Privacy Act 1988 and the APPs. The InnoWell platform does not of itself provide stand-alone medical or health advice, diagnosis or treatment. It is designed to be used in conjunction with the clinical decisions and care provided by your care service provider.
The InnoWell platform is considered to be software as a medical device and is currently approved as such by the Australian Therapeutic Goods Administration.
The InnoWell platform is only available to people who are lawfully residing in Australia.
What personal information does the InnoWell platform collect from participants?
The InnoWell platform collects your personal information in order to provide you with services that assist you and your care service provider to assess, manage and monitor your mental health and wellbeing.
The main way we collect personal information about you is when you provide it to us. For example, when you create an account in the platform, you will be asked to complete an assessment that includes questions about you generally, and about your health and wellbeing in particular. The platform processes this information to produce personal information that will be displayed on a dashboard according to health domains (for example, physical health, sleep-wake cycle, alcohol use, psychological distress). For each health domain, you will be presented with a variety of care options that you can select from to match your needs. Some of these you can do yourself straight away while others will require you to work with your care service provider. Importantly, it is you that manages your own care options in collaboration with your service provider.
The platform can collect personal information about you from a family or support person only after you have expressly invited (via the platform) that family or support person to use the platform to answer questions. This information from the family or support person will also be incorporated in to the dashboard and will be accessible to you. The family or support person invited by you to use the platform will not have access to any of your personal information other than receiving your invitation to use the platform.
The platform also collects personal information about you from your care service provider. This can include information that relates to your treatment, clinical information and advice and recommendations entered in to your record by your care service provider. This information will also be incorporated in to the dashboard and will be accessible to you.
The InnoWell platform also collects other categories of your personal information in order to provide services to you. These include:
Identity data – the platform collects personal data when you create an account. This data includes information about your identity (such as full name and email address) and demographics (such as date of birth, gender and socio-economic information);
Self-reported health data – the platform collects data you enter in response to questions about your health when you use it (such as physical health, sleep-wake cycle, alcohol use, psychological distress, medical history);
Care-related data – the platform collects personal care-related data through your care plan. This data includes care options you choose to use alone (such as fact sheets, apps or etools) as well as those agreed between you and your service provider (such as psychological therapies or other clinical interventions); and
Behavioural data – the platform automatically collects behavioural data, including but not limited to, data on location, device (phone, tablet or computer) and usage.
2) For staff/contractors of care service providers
What personal information does the InnoWell platform collect from staff/ contractors of care service providers?
The InnoWell platform collects information from staff/contractors of care service providers when you are asked to create an account in the InnoWell platform. The information includes names, email, and professional details and demographics. The main purpose for which we use your personal information is to provide you with the platform’s services.
3) The following sections apply as relevant to both participants in the InnoWell platform and for staff/contractors of care service providers.
How does the InnoWell platform use personal information?
The main purpose for which we use your personal information is to provide you with the platform’s services. For participants, we process the personal information we collect from you and your care service provider to produce personal information about you that is made available to you within the platform.
We also use personal information for several other related purposes, including:
monitoring and assessing the operation of the platform;
providing technology and help desk support.
In addition, if you have provided permission, we will de-identify your personal information so that it can be used for research purposes by the University of Sydney’s Brain and Mind Centre.
How does the platform disclose your personal information?
For participants, the InnoWell platform discloses your personal information to your care service provider. If you have invited a family or support person to use the platform they will not have access to any of your personal information other than receiving your invitation to use the platform.
We may also disclose your personal information for purposes permitted by the APPs. These include disclosure:
to third parties at your express request;
where it is necessary to lessen a serious threat to the life, health, safety of any individual or to public health or safety and it is unreasonable or impractical for us to obtain your consent; and
if required or authorised by or under an Australian law or a court/ tribunal order or regulatory authority. InnoWell’s policy is that we will not disclose your personal information for such a purpose unless we are legally required to do so, for example by a court order or a law enforcement agency warrant.
For care service provider staff or contractors, we disclose your personal information to the care service provider for account oversight and maintenance purposes.
Maintaining the integrity of your personal information
Some of your personal information that is collected by the platform is entered directly into the platform by you and is always accessible to you when you log in to the InnoWell platform. If your contact details change, we ask that you update this information promptly.
For participants, for personal information entered by your care service provider, we take steps through training and education as well as platform design to ensure so far as we can that the information they enter is accurate, complete and up to date.
If you wish to correct or amend any of your personal information, please read the information we have provided about access and correction below.
How do we keep your personal information secure?
We take all reasonable steps to protect your personal information from misuse, interference and loss as well as from unauthorised access, modification and disclosure.
Your personal information is stored on computer systems located in Australia. Access to these systems is highly restricted and controlled. Personal information we collect is protected by organisational, physical and logical security measures. Data communications between the platform services are protected by strong encryption. Hence data traffic via the Internet between the platform and the systems is encrypted. Only staff who have a need to access your information to perform a specific task or function are granted access to such information.
Although we take appropriate measures to safeguard the security of your personal information we cannot guarantee its security. To assist in preventing unauthorised use or disclosure of your personal information, you must keep confidential any sign-in information and passwords related to the platform. Further, you can protect the data in the platform on your smart device (phone, tablet or computer) by use of a PIN code to restrict unauthorised access to your smart device. Whenever you have finished using the platform you should log out. You should not leave your device unattended while you access the platform.
In the event of any data breach, we will follow the specific requirements of the Privacy Act 1988 and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) and notify you and other affected individuals as appropriate.
How can you access and correct your personal information?
For participants, you can access, view, manage and update your personal information details, research data sharing consent status and permissions associated with family or support persons, health domains and care options at any time. Simply sign in to the platform to view and update your information via the dashboard or settings menu. For staff/contractors of service providers you can access, view, manage and update your personal information details, and research data sharing consent status at any time. Simply sign in to the platform to view and update your information via the settings menu.
If you think that your personal information is inaccurate in the platform, please get in touch by emailing email@example.com and we will take reasonable steps to ensure that it is corrected. In order to protect your personal information we may require identification from you before changing or releasing any requested information.
InnoWell Privacy Officer
Call: +61 2 86276933
Mail: InnoWell Pty Ltd, Shop 1-3, 66-70 Parramatta Road,
Camperdown NSW 2050, Australia
We will quickly acknowledge access or correction requests, or complaints, and use our best endeavours to respond fully within 30 days of receipt of your request.
If you think that we have failed to resolve a complaint satisfactorily or you still have a concern, or would like more information you can contact the Office of the Australian Information Commissioner in any of the following ways:
Office of the Australian Information Commissioner
Call: 1300 363 992
Fax: +61 2 9284 9666
Mail: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001, Australia (or GPO Box 2999, Canberra ACT 2601, Australia)
How and when is my data deleted?
InnoWell will only keep your personal information about you for as long as is necessary for the purposes of the InnoWell platform, or as required by law. When your personal information is no longer needed for the purpose for which it was collected, we will take reasonable steps to destroy or permanently de-identify it. However, most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years.
We are required by the Privacy Act to notify you and the Office of the Australian Information Commissioner in the event of a serious data breach, for example:
A database containing personal information is hacked
Personal information is mistakenly provided to the wrong person
Our notification to you will be sent as soon as practicable and will contain:
A description of the data breach
The kinds of information concerned
Recommendations about the steps you should take in response to the data breach.
Last updated: April 2019
Welcome to the InnoWell platform
Version 3.0 – March 2019
‘InnoWell’ is InnoWell Pty Limited A.C.N.617 239 166, Shop 1-3 66 -70 Parramatta Rd, Camperdown, NSW, 2050, Australia.
The ‘InnoWell platform’ (also previously known as Synergy or the Synergy Online System) means the whole or any part of the InnoWell web site and its associated functionality located at https://platform.innowell.org and includes all content embodied in it.
If you are a person registered with a care service provider, in order to use the platform you must first be invited to do so by a care service provider approved by InnoWell and the InnoWell platform is provided to you free of charge by InnoWell.
If you are a family member or support person of a person registered with a care service provider, in order to use the platform you must first be invited to do so by a person registered with a care service provider and the InnoWell platform is provided to you free of charge by InnoWell.
If you are staff/contractor of a care service provider who is licenced to use the platform, in order to use the platform you must first be invited to do so by your service manager or his/her nominee and the InnoWell platform is provided to you as part of your organisations licence.
All text, graphics, user interfaces, visual interfaces, photographs, trademarks, logos, sounds, music, artwork and computer code (‘content’), including but not limited to the design, structure, selection, coordination, expression, ‘look and feel’ and arrangement of content, embodied in the platform is owned, controlled or licensed by or to InnoWell, and is protected by intellectual property rights and laws.
You may use information published in the platform (such as the personal information you and/or that InnoWell collects or produces) and any similar information InnoWell makes available for you to access or download from the Site, provided that you use such information only for your personal, non-commercial informational purpose and do not copy or post such information on any networked computer or broadcast it in any media through any means not purposely made available by InnoWell; make no modifications to any such information; and that you do not make any additional representations or warranties relating to such information.
Your use of the platform
You may not use any “deep-link”, “page-scrape”, “robot”, “spider” or other automatic device, program, algorithm or methodology, or any similar or equivalent manual process, to access, acquire, copy or monitor any portion of the platform or any content, or in any way reproduce or circumvent the navigational structure or presentation of the platform or any of its content, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available by InnoWell. InnoWell reserves the right to bar any such activity.
You may not attempt to gain unauthorised access to any portion or feature of the platform, or to any of the services offered on or through it, by hacking, password “mining” or any other illegitimate means.
You may not probe, scan or test the vulnerability of the platform or any connected network, nor breach any security or authentication measures. You may not reverse look-up, trace or seek to trace any information on any other user of or visitor to the platform or any other customer of InnoWell, including any the platform account not owned by you, to its source, or exploit the platform or any service or information made available or offered by or through the platform in any way where the purpose is to reveal any information, including but not limited to personal information, through any means not purposely made available by InnoWell, other than your own personal information, as provided for by the platform.
You agree that you will not take any action that imposes an unreasonable or disproportionately large load on the infrastructure of the platform.
You agree not to use any device, software or routine to interfere or attempt to interfere with the proper functioning of the platform or any transaction being conducted on, or any other person’s use of, the platform.
You may not forge headers or otherwise manipulate identifiers in order to disguise the origin of any message or communication you send to InnoWell on or through the platform or any service offered on or through it. You must not pretend that you are, or that you represent, someone else, or impersonate any other individual or entity.
Accounts, passwords and security
If you are a person registered with a care service provider, in order to use the platform you must first be invited to do so by a care service provider approved by InnoWell and then complete the account creation process nominated by InnoWell.
If you are a family member or support person of a person registered with a care service provider, in order to use the platform you must first be invited to do so by a person with an InnoWell platform account and then complete the account creation process nominated by InnoWell.
If you are a staff/contractor of a care service provider who is licenced to use the platform, in order to use the platform you must first be invited to do so by your service manager or his/her nominee and then complete the account creation process nominated by InnoWell.
You are entirely responsible for maintaining the confidentiality of the information you hold for your account, including your password, and for any and all activity that occurs under your account as a result of your failing to keep this information secure and confidential. You agree to notify InnoWell immediately of any unauthorised use of your account or password, or any other breach of security. You may be held liable for losses incurred by InnoWell or any other user of, or visitor to, the platform attributable to using your password or account as a result of your failing to keep your account information secure and confidential.
You may not use anyone else’s password or account at any time without InnoWell’s express, prior, written permission. InnoWell will not be liable for any loss or damage arising from your failure to comply with these obligations.
The platform may contain links to other independent third-party web sites or resources (‘linked sites’). These linked sites are provided solely as a convenience. Linked sites are not under InnoWell’s control, and InnoWell is not responsible for and does not endorse their content, including any information or other content embodied in them. You will need to make your own independent assessment of linked sites.
While every effort is taken to ensure that the information on the platform is accurate, InnoWell makes no representations and gives no warranties that this information is correct, current and complete.
InnoWell takes reasonable steps to ensure that the platform remains available. However, InnoWell takes no responsibility for, and will not be liable for, the platform being temporarily unavailable due to technical issues beyond our control, or for maintenance or other technical reasons. We do not warrant that the functions of the platform will be uninterrupted or error-free, that defects will be corrected, or that the platform or the servers that make it available are free of viruses or other harmful components.
In no event will we be liable for any loss or damage including without limitation, any direct, indirect, incidental, consequential, special or exemplary loss or damage, for:
any loss or damage whatsoever arising from the use of or inability to use the platform;
any transaction conducted through or facilitated by the platform;
any claim arising from errors, omissions, or inaccuracies appearing on the platform;
unauthorised access to, or alteration of, data or communications; or
any loss of data arising out of, or in connection with, the use of the platform.
If you are dissatisfied with the platform, your sole and exclusive remedy is to discontinue using it.
Your visits to the platform
We may also collect and store information about your visits to the platform, including:
The name of the domain from which you accessed the Internet;
The Internet address of the email invitation from which you accessed the platform;
The date and time you accessed the platform;
The pages you accessed while using the platform;
The type of device from which you accessed the platform; and
The location from which you accessed the platform.
All of the information we collect is aggregated and is not used to identify you. This information is used to measure visitor numbers and to assess how the platform was used in order to maintain its effectiveness.
We do not collect this information for any type of advertising.
The platform is only made available to people who are lawfully residing in Australia at the time of using the platform. If you are not lawfully residing in Australia, you must not use it.
Your use of the platform and any dispute arising out of such use is subject to, and governed by, and will be interpreted in accordance with the laws of New South Wales, without regard to any conflict of law’s provisions.
Last updated: April 2019