← GapCheck

Data Processing Addendum

Version 0.2 · for the GapCheck portal and worker app

These documents are published for review before launch. They describe the software as it is today and have not yet been checked by a lawyer. Questions: hello@gapcheck.net.

Draft 0.2, 6 October 2026. Written to match what the software does today. Not yet reviewed by a lawyer. Version 0.2 · 6 October 2026

Forms part of the Terms of Service. This is the document your compliance person will ask for.

1. Roles

You decide what information about your staff, workers and participants is entered and why. We hold and process it only to provide the service to you, and only on your instructions. You remain accountable to your workers and participants for it.

Australian privacy law does not use the controller/processor split, so nothing here imports GDPR meanings. The practical position is what matters: it is your data, held by us on your behalf.

2. Scope

In — your staff: name, email, role, password hash, settings, sign-in times.

In — your workers: names, the identifiers you choose, roles, work emails, training assignments, due dates, assessment responses and scores, competency sign-offs with the assessor's name, credentials and their numbers and expiry dates, documents you upload against a worker, availability, time off and its kind (including sick leave), shifts, offers, clock-in and clock-out times, the phone's location at clock-in and clock-out where you switch it on, pay rates and approved hours, and announcement read receipts. While a CSV of workers or participants is being imported, the parsed rows are held for up to 30 minutes.

In — your participants: the identifiers and labels you choose, NDIS numbers, plan dates, plan management type and plan funding, plan manager name and email, shifts and support items, travel recorded against shifts, agreed support hours, the regular team, progress notes, chart entries, medicine lists and medicine records (where we switch that feature on for you), the bowel flag setting, and incident records including internal ones.

Health information in that list: progress notes, chart entries, medicine lists and records, incident records, and sick-leave markers. You are the party that decides to collect them and owes notice to the people concerned.

Out: participants' full names beyond the label you choose, dates of birth, addresses, care plans, behaviour support plans and restrictive-practice authorisation documents. There is no field for them and the service refuses documents against a participant. (An incident record can say a restrictive practice was used.) Do not put them in notes. If we notice them, we will tell you and ask you to supersede the note.

3. Our undertakings

We will:

4. Security

5. Sub-processors

WhoWhat forWhere
BinaryLaneServer and storageSydney, Australia
Zoho MailEmail we send (training links, reminders, resets, roster notices, Monday summary)Australia

Not sub-processors but worth knowing: the nightly database copy goes to a machine we control ourselves in Australia, not to a third party; Apple and Google distribute the app and receive no service data; Google Maps is opened in a staff member's own browser only if they click "Map" on a clock-in position; the NDIA and plan managers receive only what you download and send yourself.

We will give you [NUMBER] days' notice before adding a sub-processor, and you may terminate without penalty if you object.

6. Breach notification

If we become aware of unauthorised access to, disclosure of, or loss of your information, we will:

7. Return and deletion

On termination, or on your written request at any time, we will give you a machine-readable export (CSV files plus the documents you uploaded) and delete the data from live systems within [NUMBER] days and from backups within a further [NUMBER] days as backups age out.

We will not delete data during a billing dispute in a way that costs you evidence you are required to hold.

8. Audit

On reasonable notice, no more than once a year, we will answer a reasonable written security questionnaire and provide what documentation we have. We are a small supplier: expect honest answers about what exists, not certifications we do not hold.

9. Your responsibilities

Contact: Gap Check, Shop 2/290 Boundary Street, Spring Hill QLD 4000, hello@gapcheck.net