Clear Boundaries
Privacy Policy
Last updated: 4 November 2026
Clear Boundaries Pty Ltd (ABN: 93 695 780 502) (“Clear Boundaries”, “we”, “us”, “our”) is committed to protecting the privacy of personal information we collect and handle in the course of providing our services.
This policy explains how we collect, use, disclose, store and protect personal information, and how you can access or correct information we hold about you.
1. Personal information we collect
The types of personal information we collect depend on the services we are providing. They may include but are not limited to:
General contact and engagement information:
Names and contact details (email, phone, address), position titles and employment details, organisation name and billing information.
Workplace investigation material include:
When we are engaged to conduct a workplace investigation, the information we collect typically includes the complaint itself and any referral material, along with witness statements from those involved. We will usually review email correspondence relevant to the complaint, meeting notes - such as return-to-work discussions, mediations, or similar records and any training records that bear on the matter. We also collect relevant workplace policies and procedures, and any other documentation provided by the client or gathered during the course of the investigation.
Psychosocial risk assessment material:
When we are engaged to conduct a psychosocial risk assessment or provide psychosocial consultancy, we collect workplace policies and procedures that relate to psychosocial hazards, along with incident and reporting records. Where available, we review health and safety committee meeting notes and any other documentation relevant to the client’s psychosocial risk management framework.
Sensitive information
In the course of conducting workplace investigations and psychosocial risk assessments, we may collect sensitive information as defined under the Privacy Act. This may include health and medical information, details of alleged conduct which may relate to racial or ethnic origin, sexual orientation or other sensitive categories, and information about mental health and psychological wellbeing.
We collect sensitive information only where it is reasonably necessary for the services we have been engaged to provide, and with the consent of the client organisation that has engaged us. Individuals who participate in an investigation or assessment process are informed of the purpose of collection at the time their information is gathered.
2. How we collect personal information
We collect personal information directly from individuals through interviews, written statements, questionnaires and correspondence. We also receive information from the client organisation that has engaged us, including documents, records and other material provided for the purposes of an investigation or assessment. Information may also come to us through our website via contact form submissions and consultation bookings, or from publicly available sources where relevant to an investigation or assessment.
Where practicable, we collect personal information directly from the individual concerned. In workplace investigations, we may also receive personal information about individuals from witnesses, complainants, respondents, and the engaging client.
3. Why we collect, use and disclose personal information
We collect, hold, use and disclose personal information for the purpose of delivering our services and running our business.
Service delivery
In delivering our services, we use personal information to conduct workplace investigations into complaints of bullying, harassment or inappropriate behaviour, to conduct psychosocial risk assessments and provide psychosocial hazard consultancy, to review workplace policies and procedures, to prepare investigation reports, risk assessments and recommendations, and to develop and deliver training materials and programs.
Business operations
We also use personal information to communicate with clients and prospective clients, to manage invoicing and payment processing, to fulfil our contractual obligations, to comply with legal and regulatory requirements, and to respond to subpoenas, court orders or directions from tribunals.
4. Use of artificial intelligence
Clear Boundaries uses artificial intelligence tools to assist in delivering its services. This includes a purpose-built AI platform hosted on a secure server in Australia. All data processed by the platform remains within Australia.
AI is used as an analytical tool to assist our consultants and investigators. It may be used to identify themes, patterns and inconsistencies across investigation documents, to prepare draft investigation reports based on evidence provided, to review workplace policies and procedures for gaps in psychosocial hazard risk management, to prepare draft risk assessments with associated controls, and to assist in drafting training content.
All AI-generated outputs are reviewed by a qualified Clear Boundaries consultant or investigator before being finalised. No AI output is provided to a client or relied upon without human review and professional sign-off. AI does not make decisions, our qualified professionals do.
We also use commercially available AI tools for general business tasks such as drafting correspondence and researching regulatory developments. These uses do not typically involve client personal information.
Clients may decline the use of AI in their engagement. This may affect the cost and scope of services.
5. Who we disclose personal information to
We may disclose personal information to the client organisation that engaged us, in the form of investigation reports, risk assessments and recommendations. We may also disclose personal information to courts, tribunals and regulators where required by law, subpoena or direction, including the Fair Work Commission, WorkSafe Victoria, or a court. We may share information with our legal advisers where we require legal advice in relation to a matter, and with our platform developer to the extent necessary for the operation and maintenance of our AI platform. We will only disclose personal information to other parties with consent or where required or authorised by law.
We do not sell personal information. We do not disclose personal information for direct marketing purposes.
6. Overseas disclosure
Our purpose-built AI platform is hosted in Australia and all data processed through it remains in Australia. We do not currently disclose personal information to overseas recipients as part of our service delivery.
If this changes, we will update this policy to identify the countries involved and take reasonable steps to ensure that any overseas recipient handles personal information in accordance with the APPs.
7. How we store and protect personal information
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Our AI platform is hosted on a secure local server in Australia. Access to personal information is restricted to authorised personnel only. We use password protection and encryption where appropriate, store physical documents in secure locations, and require confidentiality obligations of all staff and contractors.
No data transmission over the internet can be guaranteed as completely secure. While we take all reasonable precautions, we cannot guarantee the security of information transmitted electronically.
8. How long we keep personal information
We retain personal information for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, and to support the potential use of our work product in legal or tribunal proceedings.
Investigation records and risk assessment documentation are retained for a period consistent with relevant limitation periods and professional obligations. When personal information is no longer required, it is securely destroyed or de-identified.
9. Accessing and correcting your personal information
You have the right to request access to personal information we hold about you, and to request its correction if it is inaccurate, incomplete, or out of date.
To make a request, contact Clear Boundaries (details below). We will respond within a reasonable period. We may need to verify your identity before providing access.
Note: In the context of workplace investigations, access to investigation material may be limited where providing access would compromise procedural fairness or the integrity of the investigation process. Access to investigation reports is generally managed through the engaging client organisation.
10. Complaints
If you believe we have breached the APPs or handled your personal information inappropriately, you may make a complaint in writing. We will acknowledge your complaint within 7 business days and investigate it. We aim to resolve complaints within 30 days.
If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au, by phone on 1300 363 992, or by email at enquiries@oaic.gov.au.
11. Website and cookies
Our website (www.clearboundaries.com.au) may use cookies and analytics tools to monitor site traffic and improve user experience. These tools collect de-identified information such as IP addresses, browser type, and pages visited. They do not identify you personally.
You can manage cookie preferences through your browser settings. Our website may contain links to external websites. We are not responsible for the privacy practices of those sites.
12. Changes to this policy
We may update this policy from time to time to reflect changes in our practices, services, or legal obligations. The current version will always be available on our website. We encourage you to review it periodically.
13. Contact Us
If you have questions about this policy, wish to make an access or correction request, or want to make a complaint, contact:
Clear Boundaries Pty Ltd
Email: info@clearboundaries.com.au
Phone: +61 480 830 124
Based in Victoria, Australia
This policy applies to Clear Boundaries Pty Ltd and any related entities.