Privacy, Security & Responsible AI
A single place where participants, families, providers, hospitals and government can understand how Housing Match protects information, how AI is used, how consent works, and how security is maintained — in plain English.
Overview
Our commitment, in one statement
Our commitment to you
Housing Match has been developed using privacy-by-design and security-by-design principles. AI is used solely to assist with compatibility matching, information retrieval and administrative tasks. Housing Match does not provide clinical, medical or healthcare advice, nor does it make automated decisions on behalf of participants, providers or healthcare professionals. AI outputs are intended to support informed decision-making only. Final decisions regarding housing, support and referrals remain with participants, providers and authorised professionals. Personal information is handled in accordance with applicable privacy laws and is only shared where appropriate consent has been provided or where otherwise authorised by law.
Housing Match is
- a secure technology platform
- a compatibility matching platform
- a decision-support platform
- an information-sharing platform
Housing Match is not
- a healthcare provider
- a clinical assessment or diagnostic tool
- a medical device
- a solely automated decision-making system
- a SIL, SDA or Support Coordination provider
Privacy
Your rights and our policies
Your privacy, in plain English. Your information belongs to you. We only collect what we need to help match people with homes and supports. We only share information with your consent or where authorised by law. You can update your information and you can withdraw consent at any time.
Housing Match applies data minimisation — the platform does not require NDIS numbers, Medicare numbers or unnecessary government identifiers to facilitate matching. Participant matching profiles contain only information relevant to housing, support and compatibility.
Clinical documents are stored privately and accessed only through authorised, time-limited signed links. Uploaded participant documents are stored in Australia (AWS S3, Sydney).
Security
Controls currently implemented
Secure Authentication
Every account is protected by email and password authentication. All authenticated pages are gated behind access checks — unauthenticated users cannot reach participant or provider data.
Role-Based Permissions
Users are assigned a role (admin, provider, support coordinator, allied health, participant, or family/guardian). Each role sees only the data and actions relevant to them. Admin-only operations require an explicit admin role check on the server.
Private Document Storage
Participant clinical documents (OT reports, assessments, behaviour support plans, NDIS plans) are stored in private storage — never as permanent public URLs. An internal reference is used; the actual file is only accessible through a short-lived, authorised link.
Signed Document Access
Every document download or view request is authenticated and checked for consent on the server before a time-limited signed URL is issued. Signed URLs expire automatically. No permanent public link to a clinical document exists.
Immutable Audit Logging
Every sensitive action — profile changes, document access, AI processing, consent changes, application decisions, admin actions — is recorded in a permanent, append-only audit log. Records cannot be modified or deleted by application code. Administrators monitor the audit trail in real time through a centralised, MFA-gated Security & Audit Monitoring dashboard with filtering and CSV export for compliance evidence.
Consent History
Consent is not a single toggle. Every consent grant, withdrawal, amendment, and reconfirmation creates a new permanent record in an append-only ledger. The full history of who consented to what, when, and on what authority is preserved and visible to the participant.
Organisation Isolation
Each provider organisation can only see and act on its own properties, residents, applications, and participants. Cross-organisation data access is prevented at the query level.
Secure AI Processing
AI compatibility assessments use de-identified data — names, NDIS numbers, contact details, and dates of birth are stripped before processing. Document extraction that transmits raw clinical documents overseas is gated behind explicit participant consent and honestly logged.
Encryption in Transit
All data transmitted between your browser and the platform is encrypted using industry-standard TLS/HTTPS. Document access links are similarly protected.
Responsible AI
How AI is used — and what it does not do
Housing Match uses AI to assist with compatibility matching, information retrieval and administrative tasks. It supports informed decision-making — it does not replace professional judgement or participant choice.
How AI helps
- matching compatible homes
- identifying suitable housemates
- helping providers manage vacancies
- pre-filling profile fields from uploaded documents
AI does not
- choose where you live
- make decisions for you
- replace your support coordinator
- replace healthcare professionals
- provide clinical advice or make medical decisions
Every AI output that influences an outcome is reviewed by an authorised person before any action is taken. All AI processing is recorded in the audit log with an honest flag indicating whether the data was de-identified.
Read the full AI Governance PolicyAccessibility Statement
Our commitment to accessible, inclusive design
Housing Match has undergone internal accessibility testing and has been developed with accessibility in mind. A formal independent WCAG 2.1 AA accessibility assessment is planned as part of our enterprise readiness program.
- Internal accessibility testing against WCAG 2.1 AA principles, with ongoing improvement.
- Keyboard navigation and visible focus states across core journeys.
- Compatibility with common screen readers and assistive technologies.
- Plain language in participant-facing content, avoiding unnecessary jargon.
- Responsive design that works across desktop, tablet and mobile devices.
- Continuous improvement based on user feedback and accessibility reviews.
If you need assistance using Housing Match, or want to give accessibility feedback, we want to hear from you.
Request assistance or give feedbackEasy Read versions of key participant information (What Housing Match is, Privacy, Consent, AI and Participant Rights) are being developed and are available on request via our Contact page.
Participant Rights
You stay in control
Your rights
- Access — see the information we hold about you.
- Correct — ask us to fix information that is wrong or out of date.
- Withdraw consent — stop sharing or AI processing at any time.
- Ask questions — about how your information is used or protected.
- Make a complaint — if you are unhappy with how we have handled your information.
Your consent
We ask for your consent before sharing your information, before including you in matching, and before processing your documents with overseas AI. Consent is recorded in a permanent ledger so we can always show what you agreed to and when. You can withdraw consent at any time — withdrawal is logged and access is revoked.
Keeping your information safe
- Secure login with required TOTP multi-factor authentication for administrators.
- Encryption for information in transit and at rest.
- Limited staff access — only authorised people, only what they need.
- Australian hosting for uploaded participant documents.
- Monitoring and a permanent audit trail of sensitive actions.
- Privacy controls you can manage yourself.
Policies
Download and review
Housing Match Trust & Security Pack
The recommended starting point — an executive overview of the whole governance framework before reading individual policies.
Governance & Trust Overview
Start here — the cover document for the whole governance pack.
Governance Status
What is complete, in progress and planned — honestly, in one page.
Privacy Policy
What we collect, why, and your rights.
Consent & Information Sharing Policy
How consent works and is managed.
Data Retention & Deletion Schedule
How long each data type is retained, and how data is securely deleted when retention periods expire or consent is withdrawn.
Accessibility Commitment
Our accessibility testing approach, known limitations, and feedback mechanism for accessibility issues.
Security, Privacy & Data Protection
Security controls and data protection.
Terms of Use
Acceptable use, AI disclaimer, responsibilities.
Data Processing Agreement
Controller/processor responsibilities (enterprise).
AI Governance Policy
Responsible AI principles and approved uses.
APP 1.7–1.9 ADM Readiness Assessment
Automated decision-making transparency readiness for the Privacy Act requirements commencing 10 December 2026.
Enterprise Trust Centre
ISM-aligned enterprise security overview.
Sub-Processor Register
All third parties that process data on behalf of Housing Match, their roles, and data locations.
Provider Trust & Security Pack
Branded downloadable pack.
Founding Partner Pilot Agreement
Pilot participation terms.
Shared Responsibility Model
What Housing Match secures, and what your organisation is responsible for.
Business Continuity Plan
How we keep services running through disruptions.
Disaster Recovery Plan
How we restore systems and data after a disaster.
Security Risk Register
Common SaaS risks, controls and residual risk.
Information Classification & Data Retention Policy
How information is classified, retained and securely disposed of.
Vulnerability Management Policy
How vulnerabilities are identified, assessed and addressed.
Third-Party Supplier Security Policy
How third-party suppliers are evaluated and managed.
Logging, Monitoring & Audit Strategy
How security and operational events are recorded and used.
Evidence Register
Verified evidence for each security and compliance control.
Housing Match Document Library
Master register of every document — single source of truth.
AI & Privacy FAQ
Common questions, clear answers
Does AI make decisions?
Housing Match uses automated matching, scoring and AI-assisted decision-support tools, but does not use these systems to independently make final housing placement, provider acceptance or support eligibility decisions. AI assists with compatibility matching, document extraction (consent-gated) and administrative tasks. Every material housing decision — about placement, referrals or eligibility — is made by an authorised person. AI is a decision-support tool, not a solely automated decision-maker.
Does AI see participant names?
For compatibility assessments, AI receives de-identified data — name, NDIS number, email, phone and date of birth are removed before processing. For document extraction, the raw uploaded document is processed by an overseas AI provider; this is consent-gated and transparently logged in the audit trail.
How is information protected?
Encryption, multi-factor authentication, role-based access, server-enforced Row-Level Security on participant data (consent enforced at the database level), private document storage, time-limited signed access links, immutable audit logging, and Australian storage (Sydney) for uploaded participant documents.
What information does AI use?
Structured profile data — support needs, preferences, funding, accessibility and household preferences — for compatibility matching; and uploaded documents for profile field extraction (with separate consent). NDIS and other government identifiers are never captured by AI extraction.
How is consent managed?
Consent is granular and recorded in a permanent, event-based ledger. Separate consent is captured for sharing, matching and overseas AI processing. Consent can be withdrawn at any time; withdrawal is logged and access revoked.
How can information be corrected?
Participants can update their profile at any time or contact us to request corrections. Corrections and their source are logged. Support coordinators and allied health professionals can also request corrections on a participant's behalf.
Is Housing Match a healthcare provider?
No. Housing Match is a secure technology and compatibility matching platform. It does not provide clinical, medical or healthcare advice and is not a clinical assessment, diagnostic or medical tool.
Governance & Security Overview
The seven questions providers and government ask most
How is data protected?
Defence in depth: authentication with required TOTP MFA for administrators, role-based permissions, organisation isolation (providers see only their own data), server-enforced Row-Level Security on participant profiles (consent is enforced at the database level — not a UI check), private document storage with signed access links, encryption in transit and at rest, and an immutable audit trail for every sensitive action. RLS was validated August 2026 with 13 production-like scenarios.
How does AI work?
AI produces compatibility scores from de-identified structured data, and extracts structured fields from participant-uploaded documents (consent-gated). It also generates plain-language explanations and reports.
Does AI make decisions?
Housing Match uses automated matching, scoring and AI-assisted decision-support tools, but does not use these systems to independently make final housing placement, provider acceptance or support eligibility decisions. AI supports decisions; it does not make them. All placement, referral and housing decisions are made by authorised people.
What security controls exist?
Authentication, role-based access, organisation isolation, server-enforced Row-Level Security on participant data (consent is a database-level boundary), private document storage, signed short-lived links, immutable audit logging, Australian document storage, and a published security roadmap toward independent testing.
How is consent managed?
Through a permanent, event-based consent ledger. Consent is granular, withdrawable, and recorded with its legal basis and authority.
Where is data stored?
Application hosting and metadata on the Base44 managed platform; uploaded participant document files in AWS S3, Sydney (ap-southeast-2) — Australian data residency; AI compatibility assessment uses de-identified data with overseas LLM providers; document extraction sends raw documents overseas (consent-gated).
What happens if there is a breach?
We investigate using the audit log, identify affected records and individuals, take corrective action, and notify affected participants and providers in accordance with our Privacy Policy and the Australian Notifiable Data Breaches scheme where applicable.
Data Residency
Where your data is stored and processed
| Data Type | Location |
|---|---|
| Application hosting | Base44 cloud platform |
| Database storage | Base44 managed database |
| Uploaded participant documents (files) | AWS S3, Sydney (ap-southeast-2) — Australian data residency |
| Document metadata & audit information | Base44 managed cloud (metadata only — never file contents) |
| AI compatibility assessment | Overseas LLM provider (de-identified data) |
| AI document extraction | Overseas LLM provider (raw documents, consent-gated) |
| Email delivery | Resend (third-party email service) |
| Backups | Base44 platform-managed |
Housing Match is built on the Base44 platform, which manages infrastructure, storage, and backups. Uploaded participant documents are stored separately in AWS S3 in the Sydney region (ap-southeast-2), keeping document files in Australia. AI compatibility assessments use de-identified data sent to overseas LLM providers. AI document extraction transmits raw clinical documents overseas — this is consent-gated and transparently disclosed in our audit log and privacy policy.
Incident Response
How we monitor and respond
All sensitive actions — document access, profile changes, consent changes, AI processing, admin actions — are recorded in an immutable audit log, providing a complete record of who did what, when, and why.
Administrators actively monitor the audit trail through a centralised, MFA-gated Security & Audit Monitoring dashboard. Security-relevant events — failed logins, permission denials, blocked actions, role changes, and document access — are surfaced in real time with filtering and CSV export for compliance evidence and incident investigation.
In the event of a suspected security or privacy incident, Housing Match will investigate using the audit log, identify affected records and individuals, and take corrective action. If a privacy breach occurs, affected participants and providers will be notified in accordance with our Privacy Policy and applicable Australian privacy law, including the Notifiable Data Breaches scheme where applicable.
Security researchers who identify a vulnerability are encouraged to report it responsibly via our Contact details. We will acknowledge receipt and work with you to resolve the issue.
Responsible Disclosure
How security researchers can report vulnerabilities
Housing Match welcomes responsible security research and vulnerability disclosure. If you believe you have identified a security vulnerability in our platform, we ask that you report it to us responsibly so we can investigate and remediate before any public disclosure.
Reporting process
- Email hello@housingmatch.com.au with a clear description of the issue, its potential impact, and steps to reproduce.
- We acknowledge receipt within 2 business days and provide an initial assessment within 5 business days.
- We keep you informed of remediation progress and notify you when the issue is resolved.
- We request that you allow reasonable time for remediation before publishing details.
What we ask of researchers
- Do not access, modify, or delete data belonging to other users.
- Do not attempt to obtain PII, NDIS numbers, or health data.
- Do not degrade platform availability for other users.
- Report vulnerabilities promptly and before public disclosure.
Our security.txt file is published at /.well-known/security.txt per RFC 9116.
ISO 27001 Alignment
Where we stand against Annex A controls
Housing Match is not yet ISO 27001 certified. However, our platform architecture and security controls have been designed with ISO 27001 Annex A control families in mind. The table below summarises our current alignment.
| Annex A Control Area | Status |
|---|---|
| A.5 — Organisational controls (policies, roles, legal, IP, supplier relationships) | Implemented |
| A.5.15–17 — Access control & authentication (RBAC, MFA, password management) | Implemented |
| A.5.23–31 — Web filtering, threat intelligence, secure coding, legal compliance | Implemented |
| A.5.30–37 — ICT readiness, redundancy, compliance, operational procedures | Partial |
| A.8 — People controls (training, awareness, disciplinary process) | Partial |
| A.8.10–16 — Information deletion, data masking, logging, monitoring activities | Partial |
| A.8.21–29 — Network security, cryptography, secure development, security testing | Partial |
Key gaps to close before formal certification: (1) independent penetration testing, (2) centralised security logging with alerting, (3) documented and tested backup/DR procedures with RTO/RPO, (4) IPv6 + DNSSEC + CAA at the platform/DNS layer, (5) formal ISMS management framework.
Authentication & MFA
How we verify who you are
Password authentication
All accounts use email and password authentication with industry-standard hashing. Authentication is managed by the platform — passwords are never stored in application code or logs.
MFA for administrators
Time-based One-Time Password (TOTP) multi-factor authentication is required for all administrator accounts and provider organisation admins, enforced via authenticator apps with recovery codes.
Role-based access
Every user is assigned a role (admin, provider, support coordinator, allied health, participant). Server-side checks enforce that users only access data and actions permitted for their role.
Organisation isolation
Provider organisations can only see their own properties, residents, applications and participants. Cross-organisation access is prevented at the query level.
Infrastructure, Encryption & Backup
How the platform is built and protected
Hosting platform
Housing Match runs on the Base44 managed cloud platform, which provides infrastructure, database, serverless functions, and CDN distribution. The platform handles TLS termination, automatic scaling, and platform-level security patching.
Encryption in transit
All traffic between browsers and the platform is encrypted using TLS 1.2+ over HTTPS. The platform enforces HSTS via upgrade-insecure-requests in the Content-Security-Policy. Document access links use signed, time-limited URLs.
Encryption at rest
Uploaded participant documents are stored in AWS S3 (Sydney, ap-southeast-2) with server-side encryption. Platform database and metadata are encrypted at rest by the Base44 managed platform.
Backups
Platform-level backups are managed by Base44. We are working to document formal backup frequency, retention, and tested restore procedures with defined RTO/RPO targets.
Security-by-Design
Principles embedded in the platform architecture
- Least privilege: Every role sees only the minimum data needed. Server-side checks enforce access on every request, not just in the UI.
- Defence in depth: Authentication, role checks, organisation isolation, private document storage, signed URLs, immutable audit logs, and CSP headers work together — no single control is relied upon.
- Privacy by design: AI processing uses de-identified data where possible. Overseas processing of clinical documents requires explicit consent. Consent is granular, withdrawable, and permanently logged.
- Data minimisation: NDIS numbers, Medicare numbers, and unnecessary government identifiers are not required for matching. Only housing-relevant data is stored.
- No-silent-automation principle: AI never sends emails, LinkedIn messages, or makes outreach decisions automatically. Every AI output is reviewed by an authorised person before action.
- Australian data residency: Uploaded participant documents are stored in AWS S3, Sydney (ap-southeast-2).
Contact
Questions about privacy or security