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Privacy Policy
Last updated 15 November 2019
1.Application
We take your privacy seriously and understand the importance of protecting your personal information and health information.
This Privacy Policy (Policy) explains how we and our subsidiaries and related bodies corporate and any website we operate (website), collect, handle and protect your personal information and health information.
This Policy outlines the types of personal information and health information that we usually collect, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure and your rights in relation to your personal information and health information, including how to complain and how we deal with complaints.
By visiting our website or providing us with your personal information or health information (either directly or allowing another person to do so on your behalf), you acknowledge and agree that the personal information or health information we collect about you will be collected and handled in accordance with this Policy. If you do not agree with any part of this Policy, you must not provide your personal information or health information to us.
2.Important Terminology
We, our, or us refers to:
We may collect information from you or about you, including your:
The laws we comply with in our dealings with your personal information or health information will depend on your location. We will always comply with Applicable Privacy Laws and Applicable Anti-Spam Laws which means:
the Privacy Act 1988 (Cth) (Australian Privacy Act), the Australian Privacy Principles and the Spam Act 2003 (Cth); and
3.Dealing with us anonymously
Where it is lawful and practicable to do so, you may deal with us anonymously (e.g. when enquiring about our services generally). However, we usually need your name, contact information and other details to enable us to provide our services or products to you.
4.Why do we collect personal information or health information?
We will only collect personal information or health information from you when it is reasonably necessary to undertake our business activities and functions, or as otherwise permitted by law. We may also collect your personal information or health information for one or more of the following purposes:
We may also use your personal information or health information for other purposes not listed above which will be made clear to you at the time we collect your personal information, or for such purposes as may be required or permitted by the Applicable Privacy Laws.
5.What personal information do we collect and hold?
The personal information or health information collected depends on the dealings you have with us, and may include your:
If you are making an application or enquiry in relation to employment, or you have a dental practice and are interested in joining us, or you are an existing employee or practice, we may collect additional information from or about you such as:
6.Sensitive Information
We only collect sensitive information where it is reasonably necessary for our functions or activities and either you have explicitly consented, or we are required or authorised by law to do so. This may include health information, medical history, details about medication you take, or information for the purposes of a job application such as information about national origin or immigration status, or optional demographic information such as race.
7.Financial information
We may collect your credit card details or other financial information where you provide them to us at one of our clinics for the purposes of arranging direct debit or payment plans you have requested. We will only use your financial information for the purpose for which it was collected and in accordance with this policy. We may also collect financial information from you through our sales facilities, to be used by us solely to facilitate payment for the services you have requested. Financial or credit card information we collect from you is strictly confidential and held on secure servers in controlled facilities.
8.Using government identifiers
In certain circumstances we are required, to collect government identifiers such as Medicare, National Health Index, pension or Veterans Affairs numbers. We will only use or disclose this information in accordance with the applicable laws.
9.How is personal information or health information collected?
We will, if reasonable and practicable to do so, collect personal and health information directly from you. This may take place when you fill out documents such as a form. Information may also be collected from you in other ways, including:
We may collect personal and health information from third parties such as:
10.Using and disclosing personal information and health information
We will not sell, distribute, rent, licence, disclose or reveal, share or pass your personal information or health information on to any third parties, other than in accordance with this Policy, and to those who are contracted to us to keep personal information or health information confidential.
We may disclose personal information or health information:
11.Marketing and your consent/opting out
We may use your personal information to identify a product or service that you may be interested in or to contact you about an event or promotion. We may with your consent or where required by Applicable Anti-Spam Laws, use the contact details you have provided to contact you from time to time (whether by phone, post, email or SMS) to tell you about new products or services and special offers that we believe may be of interest to you.
You can withdraw your consent to receiving direct marketing communications from us at any time by unsubscribing from the mailing list by clicking ‘unsubscribe’ at the bottom of any email from us, by contacting us on the details at the end of the policy or by using the unsubscribe facility set out in any other electronic communication you receive. Once you have unsubscribed from the electronic communication, you will be removed from the corresponding marketing list as soon as is reasonably practicable and in accordance with Applicable Anti-Spam Laws.
We may occasionally engage other companies to provide marketing or advertising services on our behalf. Those companies will be permitted to obtain only the personal information they need to deliver the service. If we provide those companies with any of your personal information, it is to provide you with a better or more relevant and personalised experience and to improve the quality of those services. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
We may also use your personal information and information collected about you using third parties such as Google Analytics to provide you with a better or more personalised and relevant experience when using our website. We may do this by combining behavioural data we collect by the use of cookies and combining it with the personal information we have collected from you.
12.Information via the website and online software
Every time you use our website, information may be collected by us or on our behalf via services such as Google Analytics.
Types of information collected may include:
The information that may be collected provides us with details about how the website is being used including the frequency and duration of visits, and which web pages you have accessed on the website.
We may provide third parties with aggregate statistics about our visitors, traffic patterns and related site information. This data reflects site-usage and does not contain identifying information.
13.Cookies
Most commercial websites use cookies. Cookies are data that a website transfers to your browser and are stored in your hard drive, and are be used to track your ongoing access to and use of the website. We may use cookies to allow us to track usage patterns and help us improve and tailor our service to you. Cookies are used to ‘remember’ when your computer or device accesses our website. Cookies are essential for the effective operation of our website and to help you interact with us online. They are also used to tailor the products and services offered and advertised to you, both on our website and elsewhere. Cookies will not identify you personally. If you would prefer not to receive cookies, you can alter your security settings on your web browser to disable cookies or to warn you when cookies are being used. However this may mean you may not be able to take advantage of all features of the website.
14.Links to other websites and third party advertising services
Our websites may contain links to other websites that are not under our control. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the Privacy Policy on all third party websites to ensure you are comfortable with third party cookies.
We may also utilise certain third-party advertising services (e.g. organizations such as FastClick or Google) to display advertising for our advertisers. These third-party services may also place a cookie on your computer for the purposes of ad tracking and presentation. We do not share personally identifiable visitor information with these third-party services.
We have no responsibility for linked websites or third-party advertising services, and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.
15.Storing personal information and health information
We take all reasonable and appropriate steps (including organisational and technological measures) to protect your personal information and health information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. Some of the ways this is done include:
Where we store your personal information and health information depends on what interaction you have had with us. These include:
However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that your personal information will be secure at all times. Transmission of personal information over the Internet is at your own risk and you should only enter, or instruct the entering of, personal information within a secure environment.
16.Data breaches
The Australian Privacy Act requires us to notify affected individuals and the Australian Information Commissioner about ‘eligible data breaches’. An eligible data breach occurs when the following criteria are met:
If it is not clear whether a suspected data breach meets these criteria, we will investigate and assess the breach to determine whether the breach is an ‘eligible data breach’ that requires us to notify the affected individuals. This is to ensure that you are notified if your personal information is involved in a data breach that is likely to result in serious harm. Even if the criteria are not met, we may decide it appropriate to notify you anyway as part of our commitment to taking privacy seriously.
17.Keeping personal information and health information accurate and up to date
It is your responsibility to ensure that the personal information or health information you provide us is accurate, complete and up-to-date. However, as required by Applicable Privacy Law, we will also endeavour to ensure that the personal information and health information collected from you is up to date, accurate and complete.
Medical records are our property – however you have a right to access them subject to some exceptions allowed by applicable laws. In the case of pathology services, it is recommended that you obtain the information from the referring doctor. We will disclose the medical record to an authorised personal representative or legal adviser where you have provided written authority, unless any of the applicable legislative exceptions apply.
You may request access to or correction of your personal information and health information we hold about you at any time by contacting the relevant Privacy Officer using the details set out at the end of this Policy. We will need to verify your identity. Subject to any applicable exceptions or requirements, we will provide you with access to the personal information or health information you request within a reasonable time and usually within 28 days in Australia. If we decide to refuse your request, we will tell you why in writing and how to complain.
We may charge a reasonable fee for collating and providing access to personal and health information.
18.Contact us
If you have a question or comment regarding this Policy or wish to make a complaint or exercise your privacy rights, please contact our Privacy Officer on the following details:
Australia
Phone: +61 (03) 9333 8077
Post:
Attn: Privacy Officer
Craigieburn Dental Gallery
49 Hanson Road, Craigieburn VIC 3064
E-mail:
We will need to verify you, and we will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
If you are not satisfied with our response, you may complain to:
Australia: The Office of the Australian Information Commissioner (OAIC) via the OAIC website: www.oaic.gov.au.
19.Changes to our Privacy Policy
We may revise this Policy from time to time as we add new features or as laws change that may affect our businesses or websites. When we make changes to our Privacy Policy, they are reflected on this page. Any revised Privacy Policy will apply both to information we already have about you at the time of the change, and any personal information or health information created or received after the change takes effect. We encourage you to periodically reread this Privacy Policy, to see if there have been any changes to our policies that may affect you. Your continued use of our services following an update to this Privacy Policy constitutes acceptance of those changes.