Privacy Policy

Thrive By Pathways Privacy Policy

  1. We respect your privacy

(a) Thrive By Pathways respects your right to privacy and is committed to safeguarding the privacy of our clients and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information. Any relevant person wishing to receive more information about the operational aspects of this policy can seek that information from the Group Operations Manager of Pathways Residences who is the Privacy Officer for Thrive By Pathways.

(b) “Personal information” is information we hold which is identifiable as being about you.

(c) The Policy applies to all persons / stakeholders involved in Thrive By Pathways. This includes:

    • Residents
    • Prospective employees and current employees
    • Clients, business associates and potential clients and their employees
    • External service providers (medical officers, allied health practitioners/personnel, suppliers and contractors) and their employees.


  1. Collection of personal information

(a) Thrive By Pathways will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms.

(b) You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our client support.

(c) Additionally, we may also collect any other information you provide while interacting with us. This includes information necessary to provide health services and to comply with our obligations under Australian law (e.g. tax office obligations, immigration legislation, industrial instruments, etc.) or a court/tribunal order.

The potential consequences of not allowing us to collect and hold the required personal information may be that we are unable to:

    • Provide appropriate health care and health services and meet our legislated obligations.
    • Meet the individual requirements of the residents.
    • Provide continuing employment to an employee.
    • Continue with the services of a contractor or volunteer.


  1. How we collect your personal information

(a) Thrive By Pathways collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.


  1. Use of your personal information

(a) Thrive By Pathways may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.

(b) Thrive By Pathways may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.


  1. Disclosure of your personal information

(a) We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

(b) We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

(c) We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Thrive By Pathways,, its clients or third parties.

(d) Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.

(e) If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

(f) Personal information may be disclosed to other persons as part of the provision of health services, including:

    • Other health care professionals that are or may be involved in the care of residents, clients or employees including general practitioners, hospitals, and other allied health providers.
    • Other external agencies that we have contracts with to provide services to residents, clients and employees on our behalf. In circumstances where this is necessary, these external agencies are required to provide confirmation of their compliance with the Privacy Act 1988 (Cth).
    • Funding bodies and other government agencies as required by Commonwealth and State legislation.
    • The person designated by the client as the “person responsible” for giving and accessing their information.

(g) If it is necessary to transfer personal information to someone overseas, we will comply with this policy and the APPs, and take reasonable steps to ensure that the recipient does not breach the APPs in relation to that information.

(h) Personal information relating to residents, clients and employees will not be used for other purposes such as fundraising or direct marketing activities without seeking written consent of the resident, client or the “person responsible” for the resident.

(i) Residents, clients, representatives and visitors must also maintain the privacy of other residents living in the home. Protocols in the facility will also reinforce this requirement, for e.g. not providing information to a resident or a (visitor) without the resident’s consent.

(j) By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.


  1. Security of your personal information

(a) Thrive By Pathways is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

(b) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

(c) Staff who have access to personal information are provided with education and information about their obligations concerning confidentiality of personal information and the privacy of individuals.

(d) Thrive By Pathways will ensure secure disposal of electronic and paper-based records.

(e) Where we no longer require your personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.


  1. Access to your personal information

(a) You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at

(b) We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. We may not provide access to the personal information we hold about an individual when:

    • Release of the personal information would be unlawful.
    • The information may be subject to legal proceedings.
    • Release of the personal information would pose a serious threat to the life, health or safety of an individual or to public health or public safety.
    • Release is likely to have an unreasonable impact upon the privacy of other individuals.
    • The information could compromise our business operations.
    • The request is assessed as vexatious or frivolous Thrive By Pathways will provide reasons for denying or refusing access to personal information in writing. This correspondence will include information concerning the mechanisms for lodging a complaint.


  1. Surveillance

(a) Any devices in use will be supplied by the facility. Staff are advised and supported to not use personal devices for surveillance. Staff are encouraged to report any matters of concern relating to the delivery of care and services to the Executive Manager or Care Manager of the Pathways Residences facility where Thrive By Pathways resides.

(b) To support the privacy and confidentiality rights of residents, staff, clients of Thrive By Pathways and visitors to Pathways Residences, the facility in which Thrive By Pathways resides, we will meet the requirements of the Surveillance Devices Act 2007 to ensure all resident, staff and visitors are informed of and understand the surveillance mechanisms in place and the requirements of the Surveillance Devices Act 2007.

(c) To support the privacy and confidentiality rights of residents, clients, staff and visitors to Pathways Residences and Thrive By Pathways by meeting the requirements of the Surveillance Devices Act 2007 and to ensure all residents, clients, staff and visitors are informed of and understand the surveillance mechanisms in place and the requirements of the Surveillance Devices Act 2007 are met at the facility.

(d) Any surveillance material stored electronically will be archived and destroyed as per policy.

(e) Listening devices will not be used at our service other than to record a conversation or meeting to which all parties consent, expressly or impliedly, to the listening device being used. Permission to use the device must be documented at the commencement of the meeting and stored with minutes of the meeting.


  1. Optical Surveillance Devices

(a) Cameras will only be used with the consent of a resident, client or staff member. The camera will be a device supplied by the facility. Personal cameras are not to be used under any circumstances. Examples of approved camera use may include: recording of clinical progress, e.g. wound healing or recording of social events for publishing in a newsletter or on social media. CCTV is installed at the facility and signage is installed to advise all visitors to the service of the use of this device. CCTV is installed in common areas only excluding bathrooms and change rooms.


  1. Complaints about privacy

(a) Where a person believes that a breach of this policy or the Privacy Act has occurred, it should be referred to the Group Operations Manager in writing. If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed, please contact the Group Operations Manager to request an internal review. This application should be made within six months from the time the applicant became aware of the alleged breach or inappropriate disclosure. All complaints will be dealt with confidentially and promptly. Residents, clients, families, friends or staff who have complaints about how Thrive By Pathways have dealt with personal information may apply for an internal review.

(b) Applications for an internal review may concern conduct a person believes is:

    • A breach in information protection procedure.
    • A breach in the code.
    • An inappropriate disclosure by us of personal information.


Application for the internal review should be made in writing to the Group Operations Manager. This application should be made within six months from the time the applicant became aware of the alleged breach or inappropriate disclosure.


  1. Changes to Privacy Policy

(a) Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.


  1. Website

(a) When you visit our website

When you come to our website ( we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

(b) Cookies

We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

(c) Third party sites

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Thrive By Pathways is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.


  1. Refusal to provide information

(a) You are not obliged to give us your personal information. However, if you choose not to provide Pathways Residences with personal details we may not be able to provide accommodation for a resident, a position of employment or service agreement in our facilities. It may also restrict our ability to assist you in accessing some other services.

(b) You can obtain further general information about your privacy rights and privacy law from the Office of the Australian Information Commissioner by:

    • Calling their Privacy Hotline on 1300 363 992
    • Visiting their web site at
    • Emailing:
    • Writing to: The Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 200


Approved by Group Operations Manager of Pathways Residences, Diana Gautier – Last Updated December 2021.