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Privacy Policy

Overview

Calvary Amplar Health JV Pty Ltd (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act).

Further information on your rights under the South Australian Public Health System can be found in the “Your Rights and Responsibilities” booklet available on the SA Health website, which is available in 16 languages, at: https://www.sahealth.sa.gov.au/wps/wcm/connect/public+content/sa+health+internet/conditions/legal+matters/your+rights+and+responsibilities. We can provide a hard copy to you on request. Further information on your rights can also be found on the website of the Office of the Australian Information Commissioner (OAIC) at: http://www.oaic.gov.au/privacy/privacy-topics/health-for- individuals/.

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you such as your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What is your sensitive information?

When used in this privacy policy, the term “sensitive information” has the meaning given to it in the Privacy Act. In general terms, it includes (among other things) information or opinions concerning the health or disability of an individual, an individual’s expressed wishes about the future provision of health services, or a health service that is provided or to be provided to an individual. Sensitive information is a sub-category of personal information.

What personal information do we collect and hold?

The personal information we collect will vary depending on the service that you request or that we provide to you. However, the types of personal information we will collect may include:

  • your identification information, including: your name, mailing or street address, email address, telephone number, facsimile number, age or birth date, Medicare numbers, Individual Healthcare Identifiers, medical insurance details and your profession, occupation or job title, as well any relevant identification information of your family and carers;
  • sensitive information, including: information that is necessary to provide health care services to you such as your personal medical history, ethnic origins and lifestyle patterns, and if considered appropriate, clinical photographs of you to document your treatment;
  • details of medical services you have enquired about, together with any additional information necessary to respond to your enquiries;
  • any additional information relating to you that you provide to us, including directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and
  • information you provide to us through our receptions, service centres, customer surveys or visits by our representatives from time to time.

We also collect some information that is not personal information because it does not identify you or anyone else. We collect anonymous answers to surveys and aggregated information about how users use our website for statistical purposes. In most other circumstances it is impractical for us to interact with you anonymously or pseudonymously as we must collect your personal information in the provision of healthcare services.

If you have chosen to opt-in to Australia’s eHealth record system then we are required to collect and use your personal information in accordance with the My Health Records Act 2012 (Cth). An eHealth record is an electronic summary of your key health information such as prescribed medications,

allergies and treatments you have received. If you have opted in to this system we may collect and disclose personal information such as identification information, contact details and your medical history. For more information please visit www.ehealth.gov.au.

If you are a patient in My Home Hospital we may collect your Individual Healthcare Identifier from the Healthcare Identifiers Service Operator and use it for the purposes authorised under the Healthcare Identifiers Act 2010 (Cth). Individual Healthcare Identifiers are used to identify and access patient records in the eHealth record system described above.

How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. The ways in which we will collect personal information include the following:

  • during conversations between you and our representatives;
  • using equipment we provide to you for your care, which may include through a tablet or medical monitoring equipment;
  • by accessing (through our existing clinical information systems) your eHealth record and your Independent Healthcare Identifier;
  • when you complete any documentation in paper or on line requested by us relating to admissions, discharges, requests, purchases or any other request relating to your personal or health information that is necessary for us to treat you and provide health care services; or
  • if you are a patient in My Home Hospital, by completing surveys, feedback forms, questionnaires or other documentation for the purpose of providing feedback on your treatment or the My Home Hospital services.

Depending on your circumstances we also collect personal information from third parties including:

  • from third party companies such as credit reporting agencies, law enforcement agencies and other government entities; and
  • other medical professionals, family members or carers, holders of your power of attorney and from other health service providers in order to assist us in our provision of services to you.

In some circumstances, we are required to obtain your consent before collecting your personal information. While sometimes your consent may be inferred, we will ordinarily seek your written consent for certain activities as part of the admission process for My Home Hospital.

We will also collect your personal information without your consent in circumstances where your consent cannot be obtained, such as when there is an immediate need to provide you with health care services by way of immediate emergency medical treatment where your state of health and/or life is at risk.

What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, or give us your consent to collect it, some or all of the following may happen:

  • we may not be able to provide the requested products or services to you, including health care services either to the same standard or at For example, we may not be able to admit you to the My Home Hospital if you not give us certain consents to collect your personal information;
  • we may not be able to provide you with information about the health care services or products and services that you may want, including information about treatment or contractual obligations; and
  • we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions, including providing health care services and customer services.

We collect, hold, use and disclose your personal information for the following purposes:

  • to provide health care services to you;
  • in relation to your profession, occupation and job title, using that information to assist with possible occupational illnesses and assistance with diagnoses and treatment;
  • in relation to identification information, to verify your identity;
  • to send communications requested by you, to answer enquiries and provide information or advice about existing and new products or services;
  • to provide personal information to our related bodies corporate, contractors (such as our doctors and surgeons), allied healthcare service providers (such as pharmacists, radiologists and pathologists) or other third parties (such as health care funds) in order for us to provide health care services to you;
  • for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of us and our related bodies corporate, contractors and service providers;
  • for the purpose of promoting community awareness, promoting My Home Hospital and for educational purposes;
  • to provide your updated personal information to our related bodies corporate, contractors and service providers;
  • to update our records and keep your contact details up to date;
  • to process and respond to any complaint made by you;
  • to comply with our obligations to the Department for Health and Wellbeing SA, who fund the My Home Hospital; and
  • to comply with any law, rule, regulation, lawful and binding determination, reporting obligation, decision or direction of a regulator, or in co-operation with any governmental authority of any country or in response to any subpoena or lawful request for production of information.

We may also hold, use and disclose your personal information for any other purpose permitted or required by law.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

Your personal information is important to us. Information on how we secure your personal information is provided in the security section below.

To whom will we disclose your information?

We may disclose your information to the following individuals or entities for the provision of health care services:

  • your treating specialist or surgeon;
  • your general practitioner;
  • our staff and related health service providers including pathology, radiology, or any other medical service provider in order to provide you with health care services;
  • your family, carers, friends, legal representatives, guardians and attorneys;
  • in the event of a transfer, the receiving health care facility to help ensure continuity of care;
  • Department for Health and Wellbeing SA, in connection with our obligations to them for the My Home Hospital;
  • the PCEHR System Operator by uploading information to your eHealth record;
  • in relation to Individual Healthcare Identifiers, other entities in accordance with the Healthcare Identifiers Act 2010 (Cth); and
  • for the purposes of accounting, invoicing, billing and liaising with the party funding the health care services, Medicare or any relevant Government department.

Again, in some circumstances we are required to obtain your consent before disclosing your personal information to such persons.

In addition to the above, in the general operation of providing health care services we may also disclose your personal information to:

  • our staff, related bodies corporate, contractors and service providers for the purposes of the operation of our website, fulfilling requests from you, and to otherwise provide services to you including web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
  • other third parties with whom we have relationships for business and healthcare related purposes, for example with our allied healthcare providers such as physiotherapists and pathologists; and
  • any organisation or other third party for any authorised purpose with your express

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).

We may also disclose your personal information as otherwise permitted or required by law.

Direct marketing materials

We will not use your personal information for direct marketing.

Use of your personal information in our marketing materials

From time to time, we may seek your consent to use your personal information, such as your story or visual / audio materials from you, to promote our services. However, you are not required to provide us with such consent.

How can you access and correct your personal information?

You can request access to any personal information or health information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you). Depending on the nature of the personal information you seek we could charge you a reasonable amount to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and we will not charge for making any corrections to your personal information. If you wish to make such a request, please use the contact details which are set out in the “Contacting Us” section at the end of this policy.

For more information on accessing your health records please email: enquiries@cahjv.com.au

There may be instances where we cannot grant you access to the personal information or health information we hold. For example, we will refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, then you can request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached by us, please contact our Privacy Officer in the first instance using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will respond to your complaint as soon as possible and in any event within 30 days of receipt of your complaint. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

If you are not satisfied with the outcome provided above then you can make a complaint to the Office of the Australian Information Commissioner, by calling 1300 363 992 or by writing to GPO Box 5218 Sydney NSW 2001.

Do we disclose your personal information to anyone outside Australia?

We will not disclose your personal information to anyone located overseas.

Security

We understand the importance of protecting your personal information. We take steps to address the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of the personal information we hold. Such measures include keeping a record of when someone adds, changes or deletes personal information and routine checks to ensure that staff only access records they need to. We commit to conduct internal and external audits to assess whether we have adequately implemented these measures and that your personal information is protected.

While we endeavour to protect the personal information on our system, as our systems are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online or via email. We

also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online or via email is transmitted at your own risk.

We may hold your information in either electronic or hard copy form.

Links

Our website contains links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Contacting us

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Please contact our Privacy Officer at:

Privacy Officer, Calvary Amplar Health Joint Venture
Post:          208 Greenhill Road, Eastwood, SA, 5063
Tel:            08 8227 7242
Email:        enquiries@cahjv.com.au

Changes to our privacy policy

We will update this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. Please review it regularly.

This privacy policy (version 1.0) was last updated December 2020