OT INSPIRE AUSTRALIA – PRIVACY POLICY
Privacy Commitment
As a health practice, we are committed to providing quality services to you as a patient and this privacy policy outlines our ongoing obligations to you in respect of how we manage your personal information.
The Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.
A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/australian-privacy-principles.
A copy of this Privacy Policy can be obtained on our website at www.otinspire.com.au or in person at our practice.
Purpose of Policy
This Privacy Policy applies to our collection, use, disclosure, and handling of your personal information, and explains how you may access the information and how you may seek to correct any information, as well as how to make a complaint about a suspected breach of privacy legislation.
What is Personal Information?
“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.
Some of your personal information may be considered “sensitive information”. We will only collect sensitive information when it is reasonably necessary to provide you with the Services. Sensitive information includes any information or opinion about your health. If we collect your sensitive information, we will do so only with your consent, or if a permitted general situation exists, such as if it is necessary to lessen or prevent a serious and imminent threat to life or health, or as otherwise required or authorised by law.
Personal and sensitive information may include (but may not be limited to) your:
Name;
Residential, mailing and email address;
Phone number;
Date of Birth;
Gender;
Health Information including full medical history including personal and mental health data, medication, scans, diagnosis and usual GP;
Medicare/Private Health Fund details; and
Billing/account/NDIS payment details.
When we collect personal information from you, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you.
Collection
We may collect personal information from you to the extent that it is reasonably necessary and relevant for us to provide you with the Services and manage the practice.
We can do this in a number of different ways, including directly from you or in the course of our dealings with you, and when you provide personal information to us when you contact and correspond with us including when:
you interact with us over the phone;
you interact with us in person;
you interact with us by email or through our website;
you complete our in-practice patient details/intake forms;
you participate in our surveys or questionnaires;
you attend one of our events;
you subscribe to our mailing list;
you apply for a position with us as an employee, contractor or volunteer; -
we record our opinion about your diagnosis or what you said; or
you provide your referrals from another doctor;
In an emergency situation, we may need to collect your personal information from relatives or other sources, where we are unable to obtain your prior express consent.
Collecting Personal Information from Third Parties
We may also collect your personal information from third parties directly involved in your health care, for example from NDIS, remote health centres, Medicare, the Office of Public Guardian or other medical practitioners, such as GPs and specialists who refer you to us and other health care providers, hospitals and day surgery units. We collect your personal information from these third parties only for the purposes of providing the Services to you.
We may also collect your personal information from others associated with your health care to attend to your occupational therapy needs and for associated administrative purposes.
Use and Disclosure
We will treat your personal information as strictly private and confidential. We will only use or disclose your personal information for the primary purpose for which it was collected and in accordance with Australian law, such as:
to provide you with the Services;
to verify your identity;
to contact you;
to manage our relationships with our third party providers regarding the Services;
where you have specifically signed up to receive offers of additional products and services and other special offers and promotions related to the Services, for those purposes;
where you have specifically consented to being contacted for the reasons of us promoting our business to our clients and individuals who may be interested in the Services either for the business with which they are associated or personally and to provide them with information about developments, events or other products or services that may interest them, by way of direct marketing and otherwise;
to facilitate our internal business operations, including to fulfil our legal requirements, to provide customer support, to support and manage our employees, to protect our property, to prevent and investigate crime or possible crime, and to provide information to external service providers so that they can provide financial, administrative or other services in connection with the operations of our business and
to communicate with others for one or more of those purposes;
when it is permitted in a general situation by the APPs, such as where it is unreasonable or impracticable to obtain your consent or we reasonably believe the use or disclosure is necessary to lesson or prevent a serious threat to the life, health or safety of any individual, or to public health or safety;
if the disclosure is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety where conditions under the APPs are met; and
where otherwise required or authorised by law.
We may also use and disclose your personal information for a secondary purpose where:
you have consented to the use and disclosure; or
the use or disclosure is related to a purpose for which we collected it where you would reasonably expect us to use or disclose your personal information for that secondary purpose:
for personal information, for purposes that are related to the primary purpose of collection; and
for personal information that is sensitive information (such as health information), for purposes that are consistent and directly related to your health care in ways that are consistent with your expectations.
Third Parties
We may also disclose your personal information to third parties, including where the use or disclosure is authorised or required by or under an Australian law or court/tribunal order. These third parties include but are not limited to:
NDIS, your health provider, Territory families and Office of Public Guardian;
Our online providers including Halaxy , SLACK and Kajabi;
Third parties used for professional accreditation, quality assessments, clinical audit and billing;
debt collection agents; and
Parties where you have otherwise expressly or impliedly consented to the use or disclosure of personal information by or to those third parties.
We will not disclose your personal information to an overseas recipient unless we have your consent, or we are required to do so by law.
Halaxy Personal Health Record
We may upload information to your electronic Halaxy Personal Health Record. This is a secure online summary of your occupational therapy treatment plan using Halaxy Practice Software. You are able to have your own Halaxy account to manage your health and communicate directly and securely with your care network.
Access and Changes
You have a right to request access to, or the correction of, your personal information held by us. You may also request that we give a third party organisation access to your health information, or we may receive a request for access to your information from a third party on your behalf, with your consent.
If you wish to access, correct or update any personal information we hold about you, please contact us as set out below. However, we may charge an administrative fee for providing access to this information and we may refuse access for a valid reason in accordance with the APPs.
In order to protect your personal information, we may require identification from you before releasing or correcting the requested information.
You may request in writing that your personal information is changed where you dispute the accuracy of the information we have recorded. We will take all reasonable steps to record all of your corrections on your file, but we will not erase the original record.
If we refuse to allow you to access or to correct your information for a valid reason in accordance with the APPs, we will advise of the reason(s) at the time of the refusal.
Maintaining the Quality of your Personal Information
It is important to us that your personal information is up-to-date. We will take reasonable steps to make sure that your personal information is accurate, complete and up-to-date. If you find that the information we have is not up-to-date or is inaccurate, please advise us as soon as practicable in writing.
Complaints Process
We take privacy questions and complaints seriously. If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy, please contact us in writing.
We will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. When contacting us, please provide as much detail as possible in relation to the query, issue or complaint. We will aim to respond to or resolve any such question or complaint in a timely and efficient manner, and our target response time is 30 days. We request that you cooperate with us during this process and provide us with relevant information we may require.
If you are dissatisfied with the outcome of your complaint, you may make an application to the Australian Information Commissioner or the Privacy Commissioner of your State or Territory.
If you have any questions or concerns about our Privacy Policy, we would be happy to answer them for you. For any complaints or queries, please contact our Director, Mia Poklepovich who will personally address any concerns you may have and take appropriate action where necessary. Mia’s contact details are:
admin@otinspire.com.au or mia@otinspire.com.au
Storage and Security of your Personal Information
We will take reasonable steps to store your information securely. We may store your files in hard copy or electronically in our ordinary IT systems. These may include Australian-based cloud servers or the servers of third parties within Australia. We will take reasonable steps to ensure that your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure including by:
having a robust physical security of our premises and databases / records;
taking measures to restrict access to only personnel who need that personal information to effectively provide the Services;
having technological measures in place (for example, anti-virus software, fire walls); and
requiring all of our personnel to sign, and be strictly bound by, a confidentiality agreement.
However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security.
Changes to this Privacy Policy
We may change this Privacy Policy at our discretion. By engaging us to provide the Services and by using the Platforms, you accept this Privacy Policy as it applies from time to time.
Defined Terms
In this policy, the terms below have the following meanings:
“Services” means the occupational therapy services supplied by us.
“We, us and our” means OT Inspire and includes our subsidiaries, agents, employees, officers, representatives, affiliated or related entities, assigns and successors.
“Website” means our website: https://www.otinspire.com.au/
“You” means you, the person accessing or using the Services.