This policy is to inform and govern the manner in which InterHealthcare Pty Ltd ACN 626 672 642 and its subsidiaries and related entities (collectively, the IHC Group) collect, use, and manage personal information in accordance with the Australian Privacy Principles as contained in the Privacy Act 1988 (Cth) (the Act).

This policy does not create any legally enforceable obligations on the part of any company within the IHC Group or any combination of any of them and does not grant to any individual any rights beyond the rights created under the Act.

A current version of the policy is available at http://www.interhealthcare.com.au/privacy-policy.

What is personal information?

Personal information means information or an opinion about an identified individual (or an individual who is reasonably identifiable), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Personal information can include sensitive information. Sensitive information means information or an opinion about health and related information, including about a person’s physical, mental health, general and specific conditions and illnesses, safety and personal management issues, and a person’s race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.

Due to the nature of the services that the IHC Group provides, the personal information which may be collected, used, and managed by the IHC Group, may include sensitive information.

What kinds of personal information are collected and held by the IHC Group?

Examples of the kinds of personal information that may be collected by the IHC Group include:

a person’s name;

a person’s residential address, postal address, email address, telephone number, and other contact details;

a person’s employer and/or place of business;

patient health and medical information (physical and mental) including emergency contact(s) and Medicare and health fund information; and

video and audio recordings of individuals;

surveillance and security footage and material.

The IHC Group does not use any government related identifiers, such as Medicare numbers, as its own identifier of any individual. The IHC Group will not use or disclose any government related identifiers other than in accordance with the Act.

Cookies

We may use “cookies”, traffic management software and similar technologies to collect data. Most cookies will only collect de-identified personal information however some cookies do collect personal information. For example, if you click “Remember me” when you log in to a website, a cookie will store your username.

We may collect information about:

your IP address;

the device you use to access our websites or applications (for example, we may collect information about the operating system or the browser version and the type of computer or mobile device); and

the date, time and length of your visit to a website.

If you do not want information to be collected through the use of cookies or measurement software, your device and/or browser may enable you to delete or “turn off” cookies or some of the measurement software features. However, some or all parts of our website may not function correctly if such features are disabled.

How does the IHC Group collect and hold personal information?

The IHC Group collects personal information from:

individuals directly (including patients);

health care professionals and service providers in the course of them providing health services;

its suppliers and contractors;

related entities within the IHC Group; and

through CCTV cameras and other security technologies.

If you provide us with sensitive information about other individuals, such as health information, please ensure that the individual or the individual’s representative is aware of the disclosure and that he or she consents to the disclosure to the IHC Group as well as to the handling of their personal information in accordance with this policy.

How does the IHC Group deal with personal information?

The IHC Group may collect, hold, use and disclose personal information for the following purposes:

to represent all allied health modalities to provide a broad range of health services;

to supply our products and services representing all allied health modalities in clinical practice, mobile and technology –based health services and to conduct our other business activities;

to respond to requests and inquiries;

to contact individuals, via email, regular mail, telephone or otherwise;

to provide you with information that we believe may be of interest to you;

advertising, marketing and business development (including direct marketing to you);

to develop and improve programs, products, services and content;

to protect the IHC Group’s rights and property;

for security and occupational health and safety purposes;

to investigate or report suspected unlawful activity;

to protect someone’s life, health, safety or welfare;

to comply with a law or regulation, or a court order or other legal process.

Disclosure to other parties

The IHC Group may disclose personal information to:

related entities within the IHC Group;

contractors we use to support our business (including IT support and other IT services, delivery services and financial institutions);

our suppliers;

our lawyers, accountants and other business advisers;

health care professionals and health service providers;

government health agencies such as Medicare;

private health care insurers and providers;

law enforcement officers, regulators, courts and government agencies – if required by law or regulation, court order or other legal process, or in order to protect the IHC Group’s rights, property, or if necessary to prevent a threat to any person’s life, health or safety.

The IHC Group will not sell or exchange your personal information except in conjunction with a corporate sale, merger, dissolution, acquisition or other similar events.

Disclosure outside of Australia

We are unlikely to disclose your personal information overseas.

Direct marketing

We may from time to time use your personal information such as your email address or other contact details to contact you to tell you about products or services we believe may be of interest to you (including third party products and services).

If we do, each communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. If at any time you do not wish to receive any future communications or you wish to have your details deleted from our mailing lists, please contact us at the address below.

Data integrity and security

The IHC Group takes reasonable steps to ensure that the personal information that it collects, uses and discloses is accurate, up-to-date and complete. We encourage individuals to assist us with this by contacting us if you are aware that any of your personal information is not accurate, up-to-date or complete.

The IHC Group takes reasonable steps to protect personal information it holds from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

The IHC Group’s data is securely stored in Australia and is not stored or transferred outside of Australia.

When the IHC Group no longer needs personal information for any purpose for which the information may be used or disclosed under the Australian Privacy Principles, we take reasonable steps to destroy the information or ensure that it is de-identified, except if the information is part of a Commonwealth record or the IHC Group is required by law or a court or tribunal order to retain the personal information.

Access and correction

Individuals have a right to request access to their personal information and to request its correction. To do so, please contact the IHC Group’s Privacy Officer. Contact details are provided below. The IHC Group does not impose a charge for making a request for access, however, we may charge for reasonable administrative costs incurred in providing access.

The IHC Group encourages individuals to advise our Privacy Officer if your personal information requires correction or updating. The IHC Group does not impose any charge with respect to requests for correction or updates. Before correcting or providing access to personal information in response to a request, the IHC Group will require your identity to be confirmed.

Requests for access or correction may be refused upon the grounds contained in the Act. If we refuse to provide access or to correct personal information, the IHC Group will provide you with reasons for the refusal.

Complaints

A person who wishes to complain about a breach of the Australian Privacy Principles by the IHC Group should contact our Privacy Officer. The IHC Group will not impose any charge for making a complaint, or for dealing with the complaint. Once a complaint has been lodged, our Privacy Officer will acknowledge its receipt to you as soon as possible. We will do our best to ensure that our investigation is completed, and a decision on your complaint is communicated to you, within 30 days from our receipt of the complaint. We will contact you if we need more time.

You may also contact the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218

SYDNEY NSW 2001

Telephone: 1300 363 992

Fax: 02 9284 9666

Website: www.oaic.gov.au

The IHC Group’s Privacy Officer

The IHC Group’s Privacy Officer’s contact details are:

The Privacy Officer

InterHealthcare Pty Ltd

PO Box 1585

BROADBEACH QLD 4218

Telephone: 07 3186 6440

Email: [email protected]

Changes to our Privacy Policy

We may change this Privacy Policy at any time by publishing a new Privacy Policy at www.interhealthcare.com.au/privacypolicy. Your continued use of our applications, websites, products or services constitutes your acceptance of that updated Privacy Policy.

This policy is current as at 16 November 2021.