About this policy
188 Medical (“us”, “we”, or “our”) recognises the importance of your privacy and respects your right to control how your personal information is collected and used.
In this policy “Personal Information” means any information that may identify you, or by which your identity might bereasonably determined. The information you provide us may include,amongst other things, your name, address, email address, and phone number.
“Sensitive Information” means any information about an individual’s racial or ethnicorigin, political opinions, memberships of a political organisation, religious belief or affiliation, philosophical belief, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.
In this policy “Health Record” means information held by us concerning your health. It may include your medical records, clinical history, medications, diagnoses, treatment, tests and results, medical procedures, your genetic information, file notes, consents, referrals and clinical correspondence, medical imaging, immunisation records and any other information provided or collectedby us relating to your health.
The purpose for which we collect personalinformation is to provide you with the best service experience possible on the website and for our internal business purposes thatform part of normal business practices. Some provision of personal information is optional. However, if you do not provide us with certain types of personal information, you may be unable to enjoy the full functionality of the website.
To provide our services to you, we may collect Personal Information, such as your contact details, including your name, email address and contact phone number, your business or company name; your payment and billing information, which we use to bill you for the Services and to process your payments, including credit card details. We may also collect details of conversations we have had with you or any other information relevant to us.
We may also collect Sensitive Information about you, such as medical reports, referrals, medication, health history and other important health information where you consent, and such information is reasonably necessary to provide our services to you.
We automatically collect through our Site and Services, information that is often not personally identifiable, such as the website from which visitors came to our Site, IP address, browser type and other information relating to the device through which they access the Site. We may combine this information with the Personal Information we have collected about you.
Use & Disclosure
Personal information collected by us will generally only be used and disclosed for the purpose it was collected. This includes maintaining your account and contact details, providing you with our products and services and processing payments. We may disclose your personal information to third party contractors who are integral to the provision of our services.
We may from time to time use personal information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act, including to effectuate or enforce atransaction, procuring advice from legal and accounting firms, auditors and other consultants. We may also disclose your personal information in circumstances where we are compelled by Australian legislation or a court of law to do so.
We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent.
In the event that we sell our business, or engage in a transfer, mergers, restructure or change of control or other similar transactions, customer information (containing personal information) is generally one of the business assets that forms partof the transaction. Your personal information may be subject to such a transfer. In the unlikely event of insolvency, personal information may be transferred to a trustee or debtor in possession and then to a subsequent purchaser.
We may provide health Information to other medical service providers, such as your general practitioner or specialist medical practitioners. We will only supply this information with your consent, or in circumstances where it is required for the delivery of health services, such as referral to another health service provider, billing and liaising with government offices regarding Medicare entitlements and payments, where it is necessary to prevent or lessen a serious threat to a patient’s life, health or safety, or other reason as permitted by law.
Our practice may use de-identified health information to review and improve our healthcare services and for research and quality improvement processes aimed to improve patientcare and health outcomes. We may share de-identified health information with the local Primary Health Network in order to promoteand improve healthcare within our community. De-identified data is data that has had all identifying information removed. We use best practice data extraction tools, such as Primary Sense and Pen CS Clinical Audit Tool software to ensure no personally identifying information is used in clinical and quality improvement processes. If you would prefer that your de-identified data is not shared for these purposes, or you would like more information about how we de-identify your data, please contact us on the details below.
Access & Accuracy
You can access and/or correct information we hold about you at any time by contacting us on at admin[at]188medical.com. We encourage you to contact us to keep your Personal Information up to date.
We will respond to your request for Personal Information within a reasonable time. We reserve the right to charge an administration fee to cover the costs of responding to your request, for example, where Personal Information is held in storage.
If required by law or where the information may relate to existing or anticipated legal proceedings, we may deny your request for access to your information. We will respond to your request, setting out the reasons for our refusal in writing.
Storage & Security
We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access and modification or disclosure. We use commercially reasonable physical, technical and administrative measures to protect Personal Information that we hold, including, where appropriate, password protection, encryption, and SSL to protect our Site.
Despite taking appropriate measure to protect personal information used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. We cannot guarantee the security of any information transmitted to us via the internet and such transmission is at your risk.
Health Records will be kept in accordance with ourstatutory obligations. If we no longer require the use of your personal or health information, we will take reasonable steps to destroy or permanently de-identify it.
Personal information may be stored electronically through third party data centres, which may be located overseas, or in physical storage at our premises or third-party secure storage facilities.
You are solely responsible for the maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
Data Breach Notification Scheme
If we have reason to suspect a data breach has occurred, we will undertake an assessment in accordance with the Notifiable Data Breach Scheme. If we determine there has been an eligible data breach, we will notify you as soon as reasonably practicable.
If the breach relates to the My Health Records Act, we may disclose your personal information to the My Health Records System Operator under s 73A of that Act.
An identifier is a unique number assigned to anindividual to identify them. Identifiers include Medicare Numbers andTax File numbers. We will not adopt as our own any identifier of youor use or disclose an identifier of you which has been assigned by agovernment agency, unless permitted under the Act.
Employment applications and resumes collected byus are safely and securely stored and only used for the purposes for which they were collected.
Cookies, web beacons and analytics
We may send you direct marketing emails and information about products and services that we consider may be of interest to you. These communications will only be sent via email and in accordance with applicable marketing laws, such as the SpamAct 2004 (Cth) as you consented to upon registering for our Services. If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you email about your account, your account or any Services you have requested or received from us, or for other customer service purposes. We do not provide your personal information to other organisations for the purposes of direct marketing.
Consent to international transfer
We may transfer your Personal Information to organisations in other countries. Recipients may include our related entities or employees, external service providers such as administration providers or information technology providers such as cloud storage and data processing. We only transfer information where we reasonably believe that the recipient is legally or contractually bound to principles that are substantially similar to the Australian Privacy Principles.
Changes to this policy
Complaints and Enquiries
188 Brisbane Road
If you are not satisfied with our response you are entitled to contact the Office of the Australian Information Commissioner, by phoning 1300 363 992 or writing to the Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 1042.