About this policy
This policy was developed in accordance with Australian Privacy Principle (APP) 1.3. The JBC website was updated 24 February 2025 and will be reviewed no later than 1 September 2025.
The policy includes:
• Security
• Data collection, handling and storage
• Google Analytics
• Cookies
• Data breaches
• Access to information
• Complaints and enquiries
John Badwater Consulting is a sole trader business that is owned and operated by John Badwater. ABN is 42016344690. This privacy policy will refer to the business as “JBC” and the website as the “JBC website”. The business collects and uses personal data, and John Badwater has chosen to operate within the principles of The Australian Privacy Act 1988 (The Act).
Security
As a sole trader, John Badwater is able to exercise control over the use of any data collected and stored. While every attempt is made to secure and protect any data held, there is a risk of external breaches. Due to the nature of data collected, which may be deemed sensitive, up to date system protection software is maintained through the use of subscription.
JBC subscribes and uses a suite of McAfee products which includes:
• AntiVirus Plus
• Real-time scanning
• Advanced firewall
• Security reporting
• Web protection
The application is continuously updated against new and evolving viruses.
McAfee protection satisfies the requirements of consultancy services and protects client data through real time monitoring and saving business and banking related information.
Halaxy
JBC uses Halaxy practice management software for information transfers, appointments and communication with NDIS participants, Job Seekers and individuals, such as employees, candidates or those currently being recruited into employment. This application is used in clinical service delivery and uses secure servers that are based in Australia. As a primarily clinical system, its requirements to be fit for that purpose ensure that a high level of protection is in place for the transmission and storage of personal data. Any business transacted via Halaxy is subject to Halaxy’s privacy policy, which can be accessed via this link: https://www.halaxy.com/article/privacy
Enquiry Forms on the JBC website
JBC uses Microsoft 365 Forms to enable persons who are NDIS participants and Job Seekers with disabilities to request information. The forms are accessed on the corresponding webpages, and contain fields that request information that may be regarded as personal and private in nature. Submitted forms are stored on a Microsoft server. JBC extracts data from these files and stores them on a local disk. Once the data has been extracted, the form is deleted from the Microsoft server. The Privacy and cookies policy on the forms is a link to this document on the JBC website.
Google reCAPTCHA
When submitting the standard contact form JBC uses Google reCAPTCHA (version 2) as a means to eliminate spam attacks and to be able to distinguish users from bots. The tool may collect data about how you interact with the website’s smart forms, including:
• mouse movements;
• device IP address;
• date and time when pages were accessed;
• device type, operating system and browser information;
• device screen size; and
• geographic location (city).
This information will be stored on Google’s servers outside of Australia. Content that you enter in the JBC website web forms will not be collected through the use of this tool.
To view Google’s privacy statement visit: https://policies.google.com/privacy?hl=en
Google Analytics
John Badwater Consulting uses Google Analytics as a website analytics tool to collect data about how you interact with the JBC website, including:
• device IP address (collected and stored in an anonymized format);
• search terms and pages visited on the JBC website;
• date and time when pages were accessed;
• downloads, time spent on page and bounce rate;
• referring domain and out link if applicable;
• device type, operating system and browser information;
• device screen size; and
• geographic location (city).
This information will not ordinarily be personal information, because you will not be identified, or reasonably identifiable from it.
Cookies
Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to improve your website user experience.
Visitors to the JBC website are provided with an opportunity to accept or decline cookies.
Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing the JBC website. Please note however, that some data may still be collected separately by tools such as Google Analytics, even though you may have set your browser preferences to reject all cookies.
The information collected about you using cookies will not ordinarily be your personal information, because you will not be identified or reasonably identifiable to JBC from it.
Data Breaches
As mentioned in the Security section, JBC makes every effort to protect the personal and general data of site visitors, clients and associated organisations. JBC only shares data and information with third parties with the consent of the person whose information is being shared. Data is never sold to third parties or used for marketing purposes.
If you believe your data has been breached, contact John Badwater immediately. If you do not have his mobile number, email john@badwaterconsulting.com.au so that your concerns can be investigated as a matter of urgency. In the event illegal activity has been identified, JBC will work with the appropriate law enforcement authorities to bring any perpetrators to justice. All affected individuals will be kept informed of procedures and outcomes.
Access to Information
John Badwater uses a laptop attached to secure broadband wifi, with a login that only he knows. It is, mostly, used in his home office. When travelling, he uses his personal mobile phone as a secure hotspot, and does not use hotel, or other public, wifi connections.
Data stored on the hard disk is backed up to an external drive, which is stored in a fireproof safe.
Personal information may be requested by an individual whose personal information is stored. This request must be in writing, either by email, SMS, Halaxy message or postal mail. Requests will be assessed within two business days and further communication will be undertaken between John Badwater and the requestor, to ensure that the correct information will be provided, the manner in which it is provided, and whether the information will continue to be stored by John Badwater Consulting.
Complaints and Enquiries
As an independent trader, all complaints are handled by John Badwater. For privacy reasons a phone number is not posted on this website, but John can be reached at john@badwaterconsulting.com.au or by submitting a request by using the form located at https://badwaterconsulting.com.au/contact For postal enquiries, send a letter to the following address: John Badwater Consulting, PO Box 1628, Bathurst NSW 2795.
Services provided to NDIS participants are covered by the NDIS Quality and Safeguards Commission Code of Conduct. Complaints should initially be addressed to John Badwater. If a complaint cannot be resolved by John Badwater, the NDIS process will be initiated. For further information visit https://www.ndiscommission.gov.au/complaints/make-complaint-about-provider-or-worker