Thriving Sons

Privacy Policy

Version
3.1 — Final Draft for Legal Review
Document owner
THRIVING SONS PTY LTD
Effective date
To be confirmed upon approval
Review frequency
Every three months
Legal entity
THRIVING SONS PTY LTD
ACN
703 333 242
ABN
89 703 333 242
Website
www.thrivingsons.com.au
Privacy contact
hello@thrivingsons.com.au

1. Our Commitment to Privacy

At Thriving Sons, trust, respect and safety are fundamental to the relationships we build with young people, families and organisations.

We recognise that individuals may share personal and sensitive information when seeking mentoring, guidance and support. We are committed to handling this information responsibly, respecting individual privacy and maintaining appropriate confidentiality and child safeguarding practices.

This Privacy Policy explains how THRIVING SONS PTY LTD, operating as Thriving Sons, collects, uses, stores, protects and discloses personal information.

We handle personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles where applicable.

2. Who This Policy Applies To

This Privacy Policy applies to:

  • Parents and carers enquiring about mentoring.
  • Children and young people participating in mentoring.
  • Schools, organisations and community partners.
  • Individuals participating in workshops, programs and activities.
  • Visitors to the Thriving Sons website.
  • Other individuals who communicate or interact with Thriving Sons.

It covers initial enquiries, applications, onboarding, mentoring services, organisational partnerships and associated communications.

3. Personal Information We Collect

The information we collect depends on your relationship with Thriving Sons and the services requested or provided.

Parents and Carers

We may collect:

  • Full name and contact details.
  • Suburb, town or general location.
  • Your son's name and age.
  • Information voluntarily provided about your son's circumstances or mentoring needs.
  • Application details and communication history.
  • Relevant consent forms and service agreements.

Children and Young People

Where appropriate for mentoring, we may collect:

  • Name, age and relevant contact details.
  • Interests, strengths and mentoring goals.
  • Information relevant to family, education or personal circumstances.
  • Information provided during onboarding.
  • Attendance and mentoring session records.
  • Progress, achievements and areas requiring support.
  • Information relevant to wellbeing and safety.

Some information may be sensitive, including information about health, disability, wellbeing or family circumstances.

We seek to collect only information reasonably necessary for our services and handle sensitive information with additional care.

Schools and Organisations

We may collect:

  • Names, professional roles and contact details of representatives.
  • Organisational and referral information.
  • Relevant participant information.
  • Partnership and service agreements.
  • Consent and administrative documentation.

Website Visitors

Our website and connected technologies may collect technical information, including IP addresses, browser and device information, website activity, cookies and related identifiers.

Further information is provided in Section 14.

4. How We Collect Information

We may collect personal information through:

  • Website applications and enquiry forms.
  • Telephone calls, SMS messages and emails.
  • Mentoring onboarding and consent documentation.
  • Service agreements.
  • Mentoring sessions and session tracking records.
  • Parents, carers and young people.
  • Schools, organisations and authorised referral partners.
  • Website hosting, analytics and advertising technologies.

Where practicable, information is collected directly from the individual concerned or an appropriate parent, carer or authorised representative.

We may also receive information from third parties where appropriate and lawful.

5. Why We Collect and Use Information

Thriving Sons collects and uses personal information to:

  • Respond to enquiries and mentoring applications.
  • Communicate with families and organisations.
  • Assess mentoring suitability and support needs.
  • Arrange introductory conversations.
  • Complete onboarding and consent processes.
  • Deliver mentoring, workshops and related services.
  • Establish and review mentoring goals.
  • Record mentoring activities and progress.
  • Support child safety, wellbeing and safeguarding.
  • Manage organisational partnerships.
  • Administer agreements, payments and business operations.
  • Respond to concerns, complaints and incidents.
  • Meet applicable legal and regulatory requirements.
  • Improve our services and internal processes.

We do not use private mentoring session records for unrelated advertising or promotional purposes.

6. Applications, Consent and Onboarding

Submitting a family mentoring application is an initial enquiry and does not commit a parent, carer or young person to mentoring.

Applicants acknowledge this Privacy Policy and agree to be contacted about their enquiry, including by SMS or telephone where indicated.

Before mentoring commences, Thriving Sons requires appropriate onboarding documentation, including relevant consent forms and service agreements.

Where mentoring is arranged through an organisation, school or community partner, appropriate service agreements and consent arrangements must be established before services begin.

An organisation's agreement does not automatically replace any parent, carer or young person's consent required by law or the circumstances.

We consider a young person's age, maturity, understanding and ability to participate in decisions affecting their personal information.

7. Mentoring Records and Confidentiality

Thriving Sons maintains mentoring records to support continuity, quality, accountability and safeguarding.

Mentors complete individual session tracking sheets documenting relevant mentoring activities, goals, progress, discussions and follow-up actions.

These records are stored within the Thriving Sons Google Workspace environment.

Routine access to each mentor's tracking sheet is restricted to that mentor and authorised Thriving Sons leadership responsible for overseeing mentoring.

Access may be extended where appropriately authorised, required by law or necessary for safeguarding or other lawful purposes.

Mentoring discussions are treated respectfully and confidentially. However, confidentiality is not absolute.

Information may need to be disclosed where safety concerns arise, legal obligations apply or disclosure is otherwise permitted or required by law.

8. Sharing Personal Information

Thriving Sons does not sell personal information.

We may share relevant information with:

  • Authorised Thriving Sons mentors and personnel.
  • Parents, carers or authorised representatives, where appropriate.
  • Schools, organisations and referral partners where appropriately authorised or otherwise lawful.
  • Technology and administrative service providers.
  • Relevant professionals or authorities where appropriate.
  • Child protection, emergency or law enforcement authorities where required or permitted by law.

We aim to limit information sharing to what is reasonably necessary for the relevant purpose.

An organisation arranging or funding mentoring does not automatically receive unrestricted access to a young person's private mentoring discussions or records.

Relevant information-sharing arrangements are addressed during onboarding and through appropriate agreements and consent documentation.

9. Child Safety and Safeguarding

The safety and wellbeing of young people are central to Thriving Sons.

Where information raises concerns about the safety of a young person or another individual, we may need to take appropriate safeguarding action.

This may include recording concerns and sharing relevant information with parents, carers, authorised safeguarding personnel, professionals or relevant authorities, depending on the circumstances and applicable law.

We aim to protect confidentiality while meeting our responsibilities to prevent and respond to harm.

Our Child Safety Policy, mentoring agreements and internal safeguarding procedures provide further guidance on these responsibilities.

10. Information Storage and Security

Thriving Sons uses digital systems to support its operations.

Google Workspace

Google Workspace, including Google Drive, is used to store mentoring tracking sheets and relevant operational documents.

Access to individual mentor tracking sheets is restricted to the relevant mentor and authorised Thriving Sons leadership.

GoHighLevel

GoHighLevel is used for:

  • Mentoring applications and enquiry forms.
  • Contact management and CRM.
  • SMS and email communications.
  • Website forms and funnels.
  • Administrative workflows and related records.

Netlify

Netlify is used to host and deliver the Thriving Sons website.

Meta

Meta platforms are used for Facebook and Instagram advertising and associated measurement technologies, where enabled.

We take reasonable technical and organisational steps to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure.

These measures include restricting access according to responsibilities and periodically reviewing our information-handling practices.

No electronic storage or communication system can be guaranteed completely secure.

11. Overseas Handling of Information

Some technology providers used by Thriving Sons operate internationally.

Personal information may be stored, processed or accessed outside Australia through cloud storage, CRM, communication, website hosting, technical support or advertising services.

Our providers include Google Workspace, GoHighLevel, Netlify and Meta.

HighLevel identifies international processing and support arrangements, including in the United States and India. Other providers may also process information internationally according to their service arrangements.

Where information is disclosed overseas, we aim to comply with applicable Australian privacy obligations and take reasonable steps appropriate to the circumstances.

Further information about relevant service providers may be obtained through their published privacy and data-processing documentation.

12. Retention and Deletion of Information

Thriving Sons aims to retain personal information only for as long as reasonably necessary for service delivery, safeguarding, accountability and applicable legal obligations.

Different retention arrangements apply to different categories of records.

Enquiries That Do Not Proceed

Unsuccessful or inactive mentoring enquiries are generally retained for up to 12 months after the last meaningful contact, unless a longer period is reasonably necessary or required by law.

Routine Mentoring Records

Routine mentoring session records are generally retained for seven years after the mentoring relationship ends, subject to applicable legal, contractual, safeguarding and other recordkeeping requirements.

Consent Forms and Service Agreements

Consent documentation and service agreements are generally retained with the relevant mentoring records, subject to any longer applicable requirements.

Child Safeguarding and Incident Records

Records relating to actual or alleged child sexual abuse are retained for at least 45 years, or longer where required by law or necessary because of an ongoing matter.

Other serious safeguarding and incident records are assessed for appropriate extended retention.

Financial and Business Records

Financial, taxation and other business records are retained for the applicable statutory periods.

Records relevant to a complaint, investigation, legal proceeding or reasonably anticipated claim will not be destroyed solely because a standard retention period has expired.

When information is no longer required, we take reasonable steps to securely delete or de-identify it, unless continued retention is required or permitted by law.

13. Accessing and Correcting Information

Individuals may contact Thriving Sons to request access to personal information held about them or to request correction of inaccurate, incomplete or outdated information.

We may need to verify identity or authority before responding.

Requests involving a young person's information are considered with regard to their age, maturity, privacy, safety, applicable law and the authority of the person making the request.

Access may be restricted where permitted or required by law. Where appropriate, we will explain the reasons for our decision.

Requests may be directed to hello@thrivingsons.com.au.

14. Cookies, Website Analytics and Meta Advertising

Our website and connected services may use cookies and similar technologies to support website functionality, understand visitor interactions and measure advertising performance.

Thriving Sons uses Meta platforms for Facebook and Instagram advertising.

Where enabled, Meta Pixel and related conversion tracking technologies may collect website interaction information, such as page visits, device or browser information, advertising identifiers and conversion events.

Depending on the technologies and settings used, tracking information may be associated with an identifiable person or account.

Thriving Sons does not intentionally send private mentoring session records or sensitive information supplied in mentoring applications to Meta for advertising purposes.

We aim to configure advertising measurement to avoid transmitting young people's personal information, sensitive mentoring details or private application responses.

Visitors may manage certain cookies through browser settings and applicable privacy controls.

15. Marketing Communications

Thriving Sons may provide information about mentoring services, programs, workshops and activities.

Where required by law, we seek appropriate consent before sending marketing communications and provide a way to opt out.

Permission to contact a parent or carer about a mentoring application does not automatically constitute permission to send unrelated marketing messages.

Private mentoring records are not used for unrelated promotional activities.

16. Privacy Questions and Complaints

If you have a concern about how Thriving Sons handles personal information, please contact us.

We will review the matter, make appropriate enquiries and respond within a reasonable timeframe.

We aim to provide a substantive response within 30 days where practicable.

If you are dissatisfied with our response, you may be able to contact the Office of the Australian Information Commissioner, depending on the circumstances and applicable law.

Website: www.oaic.gov.au

17. Contact Details

Thriving Sons
Operated by THRIVING SONS PTY LTD

ACN: 703 333 242
ABN: 89 703 333 242

Email: hello@thrivingsons.com.au
Website: www.thrivingsons.com.au

For privacy enquiries, access requests, corrections or complaints, please email us with the subject line Privacy Enquiry.

18. Policy Reviews and Updates

Thriving Sons reviews this Privacy Policy at least every three months and sooner where significant changes occur to our services, technology systems, legal obligations or information-handling practices.

Updated versions will be published on our website with the applicable effective date.