© 2019 by SDA Living

Privacy Policy

We 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 and have a legal obligation to abide by the provisions of the Privacy Act 1988 (Cth) (the Act). The rules that an organisation must follow under the Act are known as the Australian Privacy Principles, and cover areas including the collection, use, disclosure, quality and security of personal information.

1. What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include 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. Our privacy policy covers all people who use our services or otherwise provide their personal information to us.

For the purposes of this privacy policy, no distinction has been made between the handling of personal information and sensitive information (as that term is defined in the Act); therefore, all information will be referred to as "personal information" throughout this document.

What personal information do we collect and hold?

We may collect the following types of personal information:

• your name, address, email and telephone number;

• your age or date of birth;

• information relevant to your medical care, including but not limited to your previous and current medical history and your family medical history (where clinically relevant); and

• any additional information relating to you that you provide to us directly through our representatives.

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

2. How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in ways including:

• by you completing one of our registration or information forms; or

• through your access and use of our website.

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

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide the requested services to you, either to the same standard or at all.

3. 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 and to provide the best possible quality of service to you.

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

• 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 any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country;

• for the purposes of data research and analysis and for the purpose of sending you direct marketing communications in relation to these;

• to answer enquiries and provide information or advice about existing and new products or services and all matters relevant to the services we provide to you;

• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;

• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of the IPN Group, its contractors or service providers; and

• to meet obligations of notification to our medical defence organisations or insurers.

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

4. To whom may we disclose your information?

We may disclose your personal information to:

• our employees, related bodies corporate, contractors, Government agencies or service providers for the purposes of operation of our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators and professional advisors such as accountants, solicitors, business advisors and consultants;

• suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;

• any organisation or person for any authorised purpose with your express consent.

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

5. Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with all applicable marketing laws, such as the Spam Act 2003 (Cth). If, in your dealings with us, you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.

6. How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be as advised from time to time. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold; however, we will only do so in accordance with our rights and obligations under the Act. For example, we may need to 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 personal information we hold about you is incorrect, incomplete or inaccurate, then you may send us a written request us to amend it, including the basis on which you are requesting the amendment. 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.

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

If you believe that your privacy has been breached, please contact us in accordance with the arrangements set out below and provide details of the incident so that we can investigate it.

Our procedure for investigating and dealing with privacy breaches is for the incident or complaint to be dealt with in the first instance by the particular Clinic or Call Centre at which you received our services. If the issue cannot be resolved at this level, it will be escalated to the relevant Area or State Manager for review and resolution.

8. Do we disclose your personal information to anyone outside Australia?

We do not disclose your personal information to overseas recipients. In the event that we would like or are required to do so, we will obtain your consent.

9. Security

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.

As our website is 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. 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 is transmitted at your own risk.

10. Links

Our websites may contain 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.