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 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.
No general exemptions under the Act apply to us, or to any of our acts or practices.
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
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.
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).
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).
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.
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.
Generally, we collect personal information about you if you send us an email or complete our online application form to join us.
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.
We do not attempt to specifically identify or track individuals using cookies.
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.
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.
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.
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/.
You may contact us if you require further information about the ways we manage your personal information.
2/250 Glen Osmond Road, Fullarton SA 5063
Phone: (08) 7129 5000
Fax: (08) 7129 5009