My Meaning — Privacy Policy

My Meaning is designed to help people share and understand information about how a Participant communicates. Because this information can be personal and sensitive, protecting privacy is fundamental to how the Service should operate.

Last updated: 17th September 2026

Your privacy matters

This Privacy Policy explains what information we collect, why we collect it, how we use and disclose it, who may have access, how we protect it, how long it may be retained, how Participants and other individuals can access or correct their information, and how to contact us about privacy.

My Meaning is a registered business name operated by The Tenti Co Pty Ltd (ABN 33 702 481 329). In this Privacy Policy, “My Meaning”, “we”, “us” and “our” refer to The Tenti Co Pty Ltd when operating the My Meaning service.

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

Australian privacy law gives additional protection to sensitive information, including health information.

1. About My Meaning

My Meaning is a participant-centred communication profile and communication-observation service.

It is designed to help Participants and authorised communication partners understand and share practical information about:

  • how a Participant communicates
  • what particular communication signals may mean
  • how the Participant expresses choices, preferences and needs
  • communication methods and AAC
  • agreed communication strategies
  • everyday communication observations
  • practical ways to support effective communication

My Meaning is not intended to operate as a medical record, electronic health record, clinical case-note system or practice management system.

Clinical assessments, diagnoses, clinical reasoning, treatment notes and other records required as part of a practitioner’s formal clinical record should be maintained in the practitioner’s own clinical or practice-management system.

However, information stored within My Meaning may still constitute personal information, sensitive information or health information depending on its content and the circumstances in which it is collected.

2. Our privacy principles

We aim to design and operate My Meaning according to the following principles:

Participant-centred
Information about a Participant should be used to support that Participant and their communication.

Only what is needed
Users should only collect and enter information reasonably necessary for the communication purposes of My Meaning.

Appropriate access
Information should only be available to people who have an appropriate role, authority and need for access.

Transparency
Participants and their representatives should understand what information is being collected, why it is being collected and who can access it.

Choice and control
Where appropriate, Participants or their authorised representatives should be able to control who has access to their profile.

Privacy by design
Privacy and access controls should be built into the Service rather than relying solely on policies and user behaviour.

3. What personal information we collect

The information we collect depends on how a person uses My Meaning.

We may collect account and identity information such as:

  • name
  • email address
  • telephone number
  • organisation
  • role
  • account identifiers
  • login and authentication information
  • relationship to a Participant
  • invitation and access information
  • information needed to verify authority or manage an account

Passwords may be managed through our identity or authentication provider rather than directly stored by My Meaning.

4. Participant profile information

A Participant’s communication profile may contain information such as:

  • preferred name
  • communication preferences
  • how they express yes and no
  • how they make choices
  • how they ask for help
  • how they indicate discomfort, distress or the need for a break
  • gestures, signs, words, sounds, facial expressions or movements
  • AAC systems or devices
  • communication access requirements
  • processing time
  • communication strategies
  • preferred ways information is presented
  • communication partner guidance
  • interests or preferred conversation topics
  • other communication-related information reasonably necessary for the Service

5. Communication observations

Authorised users may contribute observations about everyday communication interactions. These may include:

  • what was happening
  • who was present
  • what the Participant did or communicated
  • what the contributor thought the communication might mean
  • how the contributor responded
  • what happened afterwards
  • whether the response appeared successful
  • whether a similar communication interaction has occurred previously
  • questions or matters raised for future discussion

The service model deliberately distinguishes between what was observed and what someone interpreted it to mean, so that an individual interpretation does not automatically become accepted as established fact.

Users should only contribute information that is reasonably necessary for communication purposes.

6. Sensitive and health information

Some information collected through My Meaning may constitute sensitive information or health information under Australian privacy law. This may include information relating to:

  • disability
  • communication impairment or needs
  • health conditions where relevant to communication
  • AAC use
  • pain or discomfort communication
  • behavioural or emotional presentation where relevant to communication
  • supports or services received
  • photographs, audio or video where those materials reveal sensitive information

Health information receives additional protection under Australian privacy law.

We aim to collect sensitive information only where it is reasonably necessary for the purposes of My Meaning and where the collection is otherwise permitted by applicable law.

My Meaning should not be used as a repository for comprehensive medical histories, clinical case notes, diagnoses or unrelated sensitive information.

7. Photos, videos and audio

Where My Meaning allows media to be uploaded, this may include photographs, short video recordings, audio recordings or other supporting media relating to communication.

Media should only be uploaded where:

  • it is reasonably necessary for the communication purpose
  • the person uploading it has appropriate authority
  • appropriate consent has been obtained
  • the content is respectful and relevant
  • the upload complies with applicable legal and organisational requirements

8. Information about other people

A Participant’s profile may contain information about other people, such as:

  • nominees
  • authorised representatives
  • family members
  • support workers
  • practitioners
  • teachers
  • provider staff
  • other communication partners

Users must only add information about another person where they have an appropriate reason and authority to do so.

Users should avoid recording unnecessary personal details about third parties.

9. How we collect information

We may collect information:

  • directly from a Participant
  • from a nominee, parent, guardian or authorised representative
  • from an invited family member or trusted person
  • from support workers
  • from practitioners or providers
  • when an organisation creates or administers access
  • when a user enters or uploads information into My Meaning
  • when someone contacts our support team
  • through our website
  • through authentication and security systems
  • through technical logging necessary to operate and secure the Service

Where information is provided about a Participant by another person, the person providing that information should have appropriate authority to provide it.

10. Why we collect and use information

Providing the communication service
To create, maintain and display a Participant’s communication profile and dictionary.

Supporting communication
To provide authorised communication partners with practical guidance about how best to communicate with the Participant.

Gathering observations
To enable authorised people to contribute communication observations from everyday interactions.

Supporting discussion and review
To allow relevant observations to be considered by authorised Participants, family members, support workers and practitioners.

Updating communication guidance
To allow communication profiles and dictionaries to be updated where appropriate.

Managing permissions
To invite users, assign roles, control access and manage Participant-authorised sharing.

Maintaining continuity
To help preserve the Participant’s communication profile when workers, practitioners or providers change.

Operating the Service
To provide support, maintain accounts, troubleshoot problems and improve functionality.

Security
To prevent unauthorised access, investigate suspected misuse and maintain audit records.

Legal obligations
To comply with applicable law, regulatory requirements and lawful requests.

11. Who can access a Participant's information

Access to My Meaning should be based on a person’s role, authority and permissions. Depending on the Participant’s circumstances and account arrangements, authorised users may include:

  • the Participant
  • their nominee or authorised representative
  • family members or trusted people
  • support workers
  • speech pathologists
  • other authorised allied-health practitioners
  • provider administrators
  • other authorised communication partners

Access to a Participant’s information does not automatically give a person authority to change every part of the profile or invite other users.

12. Participant and representative control

Subject to applicable law, authority arrangements and Service functionality, Participants or their authorised representatives should be able to:

  • see the Participant’s communication profile
  • see who has access
  • approve or withdraw access
  • nominate an authorised person to assist with account administration
  • request correction of information
  • obtain or export relevant information
  • manage continuity when providers change

Where a Participant requires assistance with decision-making, My Meaning should support appropriate authorised or supported decision-making arrangements rather than assuming another person automatically has authority to act for them.

13. Practitioner and provider access

Practitioners and provider organisations may have access to Participant information where they are appropriately authorised. Practitioner access may allow them to:

  • review relevant communication observations
  • identify matters to discuss
  • request additional communication observations
  • participate in multidisciplinary discussion
  • identify possible changes to practical communication guidance
  • contribute to or update the Participant’s profile where their permissions allow

Their access does not make My Meaning the practitioner’s formal clinical record.

Practitioners remain responsible for transferring or documenting information in their own clinical record where required by their professional, organisational or legal obligations.

14. Sharing information

To authorised My Meaning users
According to Participant authority, role-based permissions and account settings.

To service providers
We may engage organisations that provide services such as cloud hosting, databases, identity and authentication, email delivery, technical support, monitoring, data backup, cybersecurity, customer support, payment processing where applicable, and analytics where appropriate. These organisations should only receive information reasonably necessary to provide their service to us.

Where required or authorised by law
We may disclose information where required or authorised by law, including in response to a valid court order, statutory requirement or lawful government request.

To protect serious safety interests
There may also be limited circumstances where disclosure is authorised or required by law in connection with serious threats, safety, safeguarding or other legal obligations.

15. We do not sell Participant information

My Meaning does not sell Participants’ personal information to advertisers or data brokers.

16. Service providers and subprocessors

My Meaning relies on third-party technology providers to operate the Service.

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Subprocessor details

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17. Where information is stored

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18. Security

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

Security measures may include:

  • identity and access controls
  • role-based permissions
  • encryption in transit
  • encryption at rest
  • secure authentication
  • logging and audit records
  • backups
  • security monitoring
  • vulnerability management
  • restricted administrative access
  • processes for responding to security incidents

19. Audit and security information

We may collect technical information necessary to operate and protect the Service, including:

  • login times
  • account identifiers
  • IP addresses
  • device or browser information
  • changes made to records
  • invitations
  • access changes
  • authentication events
  • security events
  • other system activity

We may use this information to maintain security, investigate suspected unauthorised access, provide an audit history, troubleshoot problems, enforce permissions and meet legal or regulatory obligations.

Access to audit information should itself be controlled.

20. Information retention

My Meaning should retain information only for as long as reasonably necessary for:

  • the purposes for which it was collected
  • continuity of the Participant’s communication profile
  • the Participant’s access and export rights
  • applicable legal requirements
  • dispute or complaint management
  • security purposes
  • other legitimate operational requirements permitted by law

21. When provider sponsorship ends

Ending a provider subscription should not automatically mean the Participant loses their profile.

Where provider sponsorship ends, My Meaning may:

  • provide a transition period
  • remove or change the outgoing provider’s access
  • allow the Participant to retain their profile
  • allow the Participant to export information
  • allow another provider to be invited
  • move the profile to an appropriate continuity arrangement

The detailed rules should align with the Terms of Service and your final subscription model.

22. Account closure and deletion

A Participant or appropriately authorised representative may request account closure, subject to:

  • verification of authority
  • applicable legal requirements
  • legitimate retention requirements
  • any circumstances where information cannot lawfully or reasonably be immediately deleted

Where information is no longer required and there is no lawful reason to retain it, we may delete or de-identify it in accordance with our retention and deletion processes.

23. Access to personal information

An individual may request access to personal information we hold about them.

A request can be made by contacting:

Privacy Officer
My Meaning
The Tenti Co Pty Ltd
ABN 33 702 481 329
Email: info@mymeaning.co

We may need to verify identity or authority before providing access.

There may be circumstances under applicable privacy law where access can be refused or limited. Where required, we will explain the reason.

24. Correcting information

Individuals may ask us to correct personal information they believe is:

  • inaccurate
  • out of date
  • incomplete
  • irrelevant
  • misleading

An objective account record error, such as an incorrect name or contact detail, can generally be corrected.

For Communication Journal material, a correction or clarification may be attached to an existing observation while maintaining an appropriate history rather than silently rewriting the historical observation.

Requests to correct personal information can be made to the Privacy Officer using the contact details in section 32.

25. Consent, authority and withdrawal

Where processing relies on consent, a Participant or appropriately authorised person may be able to:

  • withdraw consent
  • amend a previous consent
  • remove a person’s access
  • change sharing permissions
  • request that particular information no longer be used for a particular purpose

Withdrawing consent may affect the ability to use some Service features.

26. Children and Participants requiring decision-making assistance

Some Participants may:

  • be children
  • require a legally authorised representative
  • use supported decision-making
  • have a guardian for particular matters
  • be able to make some decisions independently while requiring assistance with others

My Meaning should not assume that a parent, family member, provider or practitioner automatically has authority over all of a Participant’s information.

Where required, we may ask for information reasonably necessary to establish the appropriate authority or access arrangement.

27. Privacy breaches and security incidents

If we become aware of a suspected privacy or security incident, we will investigate and take appropriate steps to contain and respond to it.

Where a breach meets applicable legal notification requirements, we will notify affected individuals and relevant regulators as required.

28. Privacy complaints

If you have a concern about how My Meaning has handled personal information, please contact:

Privacy Officer
My Meaning
The Tenti Co Pty Ltd
ABN 33 702 481 329
Email: info@mymeaning.co

We will acknowledge privacy complaints and investigate them appropriately. We aim to provide an outcome within 30 days, although some matters may require additional time. If we need additional information or more time, we will let you know.

Where a person remains dissatisfied, the policy should identify any external complaint rights available, including the Office of the Australian Information Commissioner, where applicable.

29. Website information, cookies and analytics

When someone visits the public My Meaning website, we may collect limited technical information such as:

  • browser type
  • device type
  • pages visited
  • approximate location derived from technical information
  • referring website
  • date and time of access
  • website performance information

We may use cookies or similar technologies where reasonably necessary for:

  • authentication
  • security
  • preferences
  • website functionality
  • limited analytics

30. Third-party links

Our website may contain links to third-party websites or resources.

My Meaning is not responsible for the privacy practices of third-party sites that we do not operate.

Users should review the privacy information of those services before providing personal information to them.

31. Changes to this Privacy Policy

We may update this Privacy Policy where:

  • the Service changes
  • our information-handling practices change
  • our technology providers change
  • legal or regulatory requirements change

Where changes are material, we will take reasonable steps to notify affected users.

The current version and effective date will always be published through the My Meaning website or Service.

32. Contact us

Questions about this Privacy Policy or how information is handled can be directed to:

Privacy Officer
My Meaning
A registered business name of The Tenti Co Pty Ltd
ABN 33 702 481 329
Email: info@mymeaning.co