Torrens Health Privacy Policy
We understand that your
privacy is important and are committed to safeguarding personal information
about individuals that we handle. This
Privacy Policy describes generally how we manage this personal information and protect
privacy, including how we comply with the Privacy Act (Act) and the Australian Privacy Principles contained in the Act.
1.
Privacy
Act
Torrens Health and its related
bodies corporate (we, us or our) are organisations and “APP Entities” for the purposes of the Act, and are bound by the Australian Privacy Principles.
This Privacy Policy is intended to provide a
general overview of our policies in respect of the handling of your personal
information. “Personal information” is
essentially information or an opinion about an identified or reasonably
identifiable individual.
Other policies may override this Privacy
Policy in certain circumstances. For
example, when we collect personal information from you, we may advise a
specific purpose for collecting that personal information, in which case we
will handle your personal information in accordance with that purpose.
This Policy is intended to cover most
personal information handled by us, but is not
exhaustive. If you have any queries
about our handling of your personal information, please contact us for further
information.
2.
Exemptions
No general exemptions under the Act apply to
us, or to any of our acts or practices.
3.
How we
collect, hold and use personal information
3.1
Collection
Generally speaking we may
collect personal information in the course of providing our products and
services to you or your organisation.
We will collect your
personal information directly from you unless it is unreasonable or
impracticable to do so, and will limit the personal
information we collect to that which is reasonably necessary for our functions
or activities.
The personal information we
may collect and hold includes but is not limited to:
·
your name and address, email address and contact telephone number;
·
if you join us as a care provider, additional personal information that
includes your classification and specialty as a care worker, your current
employment details, information in your CV or resume, and details of your
referees; and
·
other personal information you volunteer to us (for example,
information you include in your CV).
We may collect this
information in circumstances that include where (as applicable):
·
you contact us or submit an enquiry (such as
through our website or by telephone);
·
you apply for employment with us or join us
as a care provider; or
·
we deal with suppliers, service providers or
other businesses and collect personal information incidentally to those
dealings.
We do not generally collect (or, if it is provided, retain) any sensitive information. Specifically, we do not retain or store any health information. Where we do collect sensitive information, we ensure that we have consent as required by the Act
When collecting your
personal information, we will take reasonable steps to make you aware of the
purposes for which we are collecting it, the types of organisations to which we
would usually disclose it, whether we are likely to disclose it to overseas
recipients (and where practicable the countries in which they are located),
whether there are laws or court/tribunal orders which require or authorise us
to collect it, and the main consequences for you if you fail to provide it to
us. This Privacy Policy provides these
details as they typically apply in most cases, however different details may
apply depending on our specific interaction with you. If we do not notify you of such other
details, the information in this Privacy Policy applies.
If you fail to provide
personal information requested by us, there may be a range of consequences, for
example we may be unable to process or respond to your request. There will not usually be Australian laws or
court/tribunal orders which require or authorise us to collect your personal
information.
Where you provide us with
personal information of another individual (for example, a referee), we request
that you inform them that their personal information will be disclosed to us
and the purpose for doing so, and that they may contact us or review this
Privacy Policy for further information.
3.2
Use
We will generally only use
your personal information for the purpose for which we collected it, and for
related purposes we consider would be within your reasonable expectations.
We generally use personal
information for the following purposes (as applicable in the circumstances):
·
to provide our nursing, care and healthcare placement services for you;
·
to provide services or information that is requested, to respond to
your enquiries, to send you information that you request, or otherwise achieve
the purpose for which we have been contacted;
·
to provide you with information that we consider is likely to be of
interest to you relating to our products or services;
·
to seek feedback from you and perform market research; or
·
to engage in other activities where required or permitted by law.
We may use personal
information to contact you for marketing and promotional purposes (such as to
provide you with information about our products and services). You may request not to receive these
communications by contacting us (see section 11 below), or by using the opt
out function provided for in those communications. If you do not opt out in either of these ways
you will be taken to have consented to receiving such communications from us.
There are no consequences of
opting out of receiving our marketing and promotional communications except
that you will no longer receive them, and you may elect to rejoin our marketing
list at a later stage if you wish.
Where we propose to use your
personal information for a purpose other than as outlined above, we will seek
your permission (unless we are required or permitted by law to do so without
seeking consent).
3.3
Storage
We will take reasonable
steps to protect your personal information from misuse, interference and loss
as well as unauthorised access, modification or disclosure.
For example, information
stored on our computer network is protected by security features and
procedures. We undertake regular
monitoring of our practices and systems to ensure the effectiveness our
security policies and identify and implement improvements where appropriate.
We will endeavour to destroy
or de-identify your personal information as soon as it is no longer required by
us (where permitted by law).
4.
Access to
and correction of personal information
You may contact us to request access to or correction
of the personal information about you that we hold. We may refuse to allow access or to amend
your personal information if we are legally required or entitled to do so. If we do so, we will provide you with written
reasons for the refusal (unless it is unreasonable to do so) together with
information about the options available to complain about the refusal.
We may require you to pay certain costs in
order to access your personal information held by us. We will advise the amount payable (if any)
once we have assessed your application for access. We will not however charge a fee for you to
lodge a request for access to or correction of your personal information.
If you lodge a request for access to your
personal information, we may fulfil that request in any of a range of ways (for
example, by supplying you with a copy of that personal information or providing
you with the opportunity to inspect our records). We may require you to comply with certain
procedures before we allow access to or amendment of your personal information
to ensure the integrity and security of information that we hold. Depending on the nature of your request, this
may include completing a personal information request form or otherwise
verifying your identity to our satisfaction.
We will take reasonable steps to ensure that
the personal information that we collect is accurate, up-to-date and complete
and the personal information we use and disclose is accurate, up-to-date,
complete and relevant. If we are
satisfied that any personal information we hold about you is inaccurate,
out-of-date, incomplete, irrelevant or misleading, we will amend our records
accordingly.
Please notify us if your personal details
change so that we may keep our records current.
5.
Disclosure
of personal information to other organisations and overseas
We will generally
only disclose your personal information for the purpose for which we collected
it, and for related purposes we consider would be within your reasonable
expectations.
We may disclose your personal information to
the following third parties (as applicable in the circumstances):
·
certain contractors or subcontractors of ours that provide services to
us (for example, mail processing businesses, printers, market research
companies or other service providers).
We generally ensure such organisations are contractually required to
ensure that information we disclose is used only for the limited purposes for
which we provide it;
·
hospitals or other health care providers that contract for your services,
if you join us as a care provider;
·
references named in your application for employment or to join us; and
·
members of our corporate group.
We are not generally likely to disclose
personal information to overseas recipients.
6.
Online
privacy
This section of our
Privacy Policy sets out the manner in which we handle your personal information
in respect of online services provided by us (which includes any services
provided by us via the Internet, such as our website, and also includes email
communications between us).
Generally, we collect personal information
about you if you send us an email or complete our online application form to
join us.
6.1
Automatic server logs
Our servers automatically
collect various details when you use our website, including:
·
your IP (Internet Protocol) address (generally, an identifier assigned
to your computer when it is connected to the Internet);
·
the operating system and Internet browser software you are currently
using; and
·
the data you access (such as web pages or other document files or
software), and the time that you access it.
We do not attempt to
identify individuals using this information, and only use it for statistical
analysis, system administration, and similar related purposes. This information is not disclosed to any
other party.
6.2
Cookies
We use “cookies”, which
identify your computer to our servers when you visit our website. Our website may store cookies on your
computer in order to improve and customise your future visits to the
website. By using cookies, our site can
provide customised content to you. If
you do not want information collected through the use of cookies, you may be
able to configure your Internet browser to disable cookies.
We do not attempt to specifically identify or track
individuals using cookies.
6.3
Email and messages
We may collect personal
information from you (such as your name and email address, and any other
personal information you volunteer) if you send us email or if you submit
information to us using our online application process. We will use this to contact you to respond to
your message, to send you information that you request, and for other related
purposes we consider are within your reasonable expectations. We will not use or disclose any such
information for any other purpose without your consent.
6.4
Storage and transmission of
personal information online
If you provide any personal
information to us via our online services (including email) or if we provide
such information to you by such means, the privacy, security and integrity of
this information cannot be guaranteed during its transmission unless we have
indicated beforehand that a particular transaction or transmission of
information will be protected (for example, by encryption).
If we receive your personal
information, we will take reasonable steps to store it such that unauthorised
access, modification, disclosure, misuse and loss are prevented.
6.5
Other online services
If any of our online
services (including any email messages we send to you) contain links to other
online services that are not maintained by us, or if other services link to our
online services, we are not responsible for the privacy practices of the
organisations that operate those other services, and by providing such links we
do not endorse or approve the other services.
This Privacy Policy applies only in respect of our online services.
7.
Data
breach
If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals. In such a situation we will comply with the requirements of the Act which may require notification to the Office of the Australian Information Commissioner (OAIC) and affected individuals. Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk mitigation and notification activities as required.
8.
Changes
We reserve the right to amend this Privacy
Policy at any time. We publish our
current Privacy Policy on our website, and you may obtain a copy of our Privacy
Policy from that website or by contacting us.
9.
Complaints
If you believe that a breach of your privacy
has occurred, we encourage you to contact us to discuss your concerns. Our contact details can be found in section
10 below.
Your complaint will be considered and dealt
with by our nominated representative, who may escalate the complaint internally
within our organisation if the matter is serious or if necessary to resolve it.
Please allow us a reasonable time to respond
to your compliant. If you are not
satisfied with our resolution, you may make a complaint to the Office of the
Australian Information Commissioner, whose contact details can be found at: http://www.oaic.gov.au/.
10.
Further
information
You may contact us if you require further
information about the ways we manage your personal information.
11.
Contact
information
Torrens Health
2/250 Glen Osmond Road,
Fullarton SA 5063
Phone: (08) 7129 5000
Fax: (08) 7129 5009
Email: info@torrenshealth.com.au