Privacy Policy

1.Who we are and how to contact us

SAFE Consortium Pty Ltd (ABN 16 697 284 790) provides SAFE and the website at safe.inc.

Registered address: 13/477 Pitt Street, Haymarket, NSW, Australia.

Privacy enquiries, access and correction requests, and complaints: privacy@safe.inc.

2.What this policy covers

This policy explains how we collect, use, disclose and protect personal information in connection with the SAFE website (safe.inc) and the SAFE application.

In alignment with the Online Safety Act 2021 (Cth) and eSafety Commissioner online safety standards, SAFE accounts and platform access are restricted strictly to authorised adult professionals aged 18 years or older. Children are not direct users of the website or application and do not have SAFE logins. Information about children is entered by authorised adult staff (for example educators and service leaders) of the relevant approved provider or service.

3.The kinds of personal information we collect

• Staff and accounts: Identity, organisation, service, position, login credentials, fine-grained access privileges, and audit records of use.
• Children and relevant family members: Identity the service already holds so it can tell which child an assessment is about. This can include name, date of birth, and any government-related identifier the service supplies (for example a Customer Reference Number). Where the service records them, it can also include guardian contact details. SAFE does not adopt a government identifier as its own identifier for the child.
• SAFE Assessments: Yes/No answers, Concern Ratings (1 to 5) on Yes answers, optional Response notes, optional file attachments, and any mandatory reports or regulatory notifications the service records in SAFE.
• Generated and review records: Risk Probability, Preliminary Guidance (Act Now or No Urgent Flag), Human-in-the-Loop (HITL) Expert Case Review marks (At risk or Not at risk), and reviewer notes.
• Support and website use: Support interactions, and measurement of public website pages as described below.

Sensitive information relating to a child's safety or wellbeing is handled with extra care and ringfenced behind authenticated adult practitioner accounts.

4.How we collect personal information

We collect personal information from:

• authorised staff of the approved provider or service, who enter child records the service already holds and complete SAFE Assessments
• the organisation's administrators, when they create staff accounts and assign fine-grained user privileges
• the staff member, when they create a login, contact support, or use SAFE
• automated logging and website measurement, as described in this policy

We do not collect personal information directly from children through the public website. Children do not have SAFE logins.

Families are not asked to create a SAFE account. They are informed through the service's own enrolment and privacy notices, and through this policy.

5.Why we collect and use personal information

We collect and use personal information because it is reasonably necessary to provide SAFE to the approved provider, including to:

• record SAFE Assessments and related service records for upstream early identification and structured risk assessment
• support deterministic triage and Human-in-the-Loop (HITL) Expert Case Review
• secure the system, enforce fine-grained access privileges and keep audit records
• support the approved provider's governance under the National Principles for Child Safe Organisations and the Education and Care Services National Law and National Regulations
• communicate with the customer about the service
• comply with law
• produce de-identified aggregate insights that cannot reasonably re-identify a child

Sensitive information is collected and used only where permitted by law, including with consent, where required or authorised by or under Australian law (including child-protection duties under section 167 of the Education and Care Services National Law), or where a permitted general situation under the Privacy Act 1988 (Cth) applies (such as lessening or preventing a serious threat to the life, health or safety of any individual under section 16A).

We do not sell personal information.

6.Automated analysis and human-in-the-loop review

Reflecting Australian Institute of Family Studies (AIFS) best-practice risk assessment, which combines empirical actuarial consistency with clinical professional judgement, SAFE pairs a structured Random Forest model (operating on seven structured fields) with mandatory Human-in-the-Loop (HITL) Expert Case Review to produce a Risk Probability and support review prioritisation.

On submission, the service sees Preliminary Guidance: Act Now or No Urgent Flag. That guidance is decision support for the service's next step. It is not a legal decision by SAFE, and it is not the Expert Case Review mark.

Response notes are for people. The live machine-learning model does not read them, and identifiable safeguarding records are never placed into public generative-AI services.

Human-in-the-Loop Expert Case Reviewers review every submitted assessment and record At risk or Not at risk. Required safeguarding action does not wait for that mark. SAFE does not lodge mandatory reports or regulatory notifications, and does not perform statutory government case management; educators, service leaders and approved providers lodge required reports through the proper statutory channels.

7.Disclosure of personal information

We disclose personal information to:

• hosting and related infrastructure providers (Amazon Web Services in Sydney)
• Expert Case Reviewers, under strict confidentiality and access controls
• authorised staff and administrators of the customer's organisation, according to their assigned service and fine-grained user privileges
• analytics and website-measurement processors, as described below
• government agencies, courts or regulators, where required or authorised by law

Safeguarding records can include information about more than one person. Reporter identity is protected where statute requires that. We do not treat a parent or guardian as automatically entitled to a complete safeguarding file where safety or confidentiality exemptions apply.

We do not sell personal information.

8.Overseas disclosure and Australian hosting

SAFE is hosted in Australia on Amazon Web Services in Sydney (ap-southeast-2). Child records, SAFE Assessments, Response notes and Expert Case Review marks are stored there.

Public SAFE website pages may load Google Tag Manager for website measurement. Product analytics (PostHog) use internal identifiers and event names, not child names, dates of birth, government identifiers, assessment answers or Response notes.

9.Security

We take reasonable technical and organisational steps to protect personal information, including:

• encryption in transit (HTTPS/TLS) and encryption at rest
• fine-grained access controls scoped to the organisation, service and authorised user privileges, ringfencing sensitive child-protection and trauma records behind authenticated 18+ practitioner accounts in line with eSafety Commissioner standards
• audit logging and protected backups
• core hosting on Amazon Web Services in Sydney

If we suspect an eligible data breach, we contain and assess it under the Notifiable Data Breaches scheme and notify the Office of the Australian Information Commissioner and affected individuals or customer organisations where required.

10.Access and correction

You may request access to, or correction of, personal information we hold about you by contacting privacy@safe.inc. Where a request relates to a child or service record held on behalf of an approved provider or service (the primary data controller), we coordinate with that approved provider to verify identity, parental authority and any applicable court or parenting orders. Requests concerning a child are assessed with regard to the child's capacity, the requester's authority and applicable law.

Safeguarding records may contain information about several people and information protected by law. We assess each request before releasing information. Access may be restricted or refused where permitted or required by law, including because of a serious threat to life, health or safety, an unreasonable impact on another person's privacy, statutory reporter confidentiality or applicable investigation-related grounds. Where appropriate, we consider redacted or alternative forms of access.

We take reasonable steps to correct information as required by law while preserving records that must be retained. A correction may be recorded as a dated amendment or supplementary statement where appropriate. Disagreement with an assessment does not, by itself, establish that it is inaccurate. If we decline a requested correction, you may ask for a statement of your disagreement to be associated with the record.

We respond within a reasonable period, generally within 30 days. If we refuse access or correction, we provide written reasons unless it would be unreasonable to do so, and explain available complaint options. There is no charge to make a request or to correct information.

11.Retention, closure and deletion

SAFE holds service records as custodian for the approved provider (the data controller), and abides by Australian early-childhood and child-protection recordkeeping laws. Safeguarding records may need to be retained after a child leaves a service or a service stops using SAFE. Account closure, withdrawal of consent or a deletion request by a parent or user does not override a legal retention requirement or another lawful basis for retaining a record.

Under the Education and Care Services National Regulations (reg 183) and ACECQA Quality Area 7 recordkeeping guidance, child incident, trauma and safeguarding records must generally be retained until the child reaches 25 years of age, and records relating to actual or alleged child sexual abuse are retained for 45 to 50 years in accordance with Royal Commission recordkeeping standards. Neither the service nor SAFE can delete records that must be preserved by law. Requests by an approved provider to export or transfer records are assessed against authority, applicable confidentiality requirements and the relevant service arrangements; an export does not automatically result in deletion of the original record.

When personal information is no longer needed for a permitted purpose and retention is not otherwise required by law, we take reasonable steps to securely destroy or de-identify it, including appropriate handling of archived and backup copies.

12.Direct marketing

Marketing communications are only sent where permitted by law or with consent, and you may opt out at any time. We never use child safeguarding records for marketing or advertising.

13.Complaints

Contact privacy@safe.inc if you have a privacy question or complaint. We will acknowledge your complaint, investigate it and respond within a reasonable period, generally within 30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au.

14.Changes to this policy

We will publish any updated version of this policy on our website and application with an updated effective date.