National Privacy Principles
The National Privacy Principles established by the Privacy Act 1988 apply to Global Health Limited (“GLH”) and Working Systems Solutions Pty Ltd (“WSS”) both of Level 11, 607 Bourke Street, Melbourne, VIC 3000. This policy is concerned with the privacy of information relating to the clients of GLH and WSS.
Type of Personal Information Held
Personal information that we collect and hold relating to clients usually falls into the following categories:
- Information required from clients and potential clients in order to assess requirements for products and services;
- Products and services performance information;
- Information obtained to assist in managing client and business relationships;
- We are custodians for a server containing electronic health records;
- We may also obtain with the client’s consent, access to client’s databases including medical patient databases in order to test or carry out maintenance of our products.
Purposes for which We Hold Personal Information
We primarily hold personal information relating to clients for the following purposes:
- Marketing;
- Assessment of client requirements;
- Testing and maintenance of products;
- Subscriber based health records;
- Client and business relationship management.
Disclosures
We may disclose your personal information for the purposes for which it is primarily held or for a related secondary purpose and you will not be added to a mailing list or used for any other purpose without your consent.
We will only disclose personal sensitive information with your consent.
We will not reveal, disclose, sell, distribute, rent, license, share or pass your personal information to third parties except where we are under a legal duty to do so, including circumstances where we are under a lawful duty of care to disclose information.
All our employees have signed a confidentiality undertaking on commencement of their employment.
WSS and GLH maintain back-up records. Where you request the deletion of personal information from our records, it is not practical, and we will not remove or delete all your information, from all data back-ups.
Access to Medical Databases
We maintain personal health records for our HotHealth products and you should refer to our specific privacy policy for HotHealth. For all our other products and services the following applies. Where we are given access to medical patients’ databases then in addition to complying with the other privacy requirements set out in this policy the following will also apply:
- We understand that medical information is highly confidential and will observe the highest standard of confidentiality when viewing such records and will not allow any third parties to access this information without your consent;
- All patient information will remain the property of the client;
- We will ensure that this data is protected against misuse and loss and from unauthorized access, modification or disclosure.
- The data will only be accessed for the purpose agreed with you and will be either destroyed or returned to you as directed by you when no longer required and copies will not be retained by us on our computers or in any other form except in the form of data back-ups as referred to above.
- If there is any potential or actual breach of confidentiality you will be notified immediately.
- If patient data is released to us and retained to construct test databases the data will be converted until de-identified and the original destroyed.
Contractors
We contract out a number of services from time to time. Our contractors may see some of your personal information. Typically our contractors would include:
- IT contractors, who are required to sign confidentiality undertakings;
- Technical service contractors;
- Computer programmers.
- Cleaners and other tradesmen;
Where practical we take all reasonable precautions to prevent these contractors accessing or using your personal information.
Inquiries and Complaints
You can make further inquiries or complaints about our privacy policies to our Privacy Co-ordinators whose contact details are:
tel: +61 3 9675 0600
You can also make complaints to the Office of the Federal Privacy Commissioner.
Access to Your Information
Subject to some exceptions that are set out in the National Privacy Principles, you can gain access to the personal information that we hold about you.
We do refuse access if it would interfere with the privacy rights of other persons or if it breaches any confidentiality that attaches to that information.
If you wish to obtain access to your personal information you should contact our Privacy Co-ordinator. You will need to be in a position to verify your identity.
We might impose a moderate charge in providing access. Our Privacy Co-ordinator would discuss these with you.
You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from our archives and review information in order to determine what information may be provided.
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