Privacy Policy

About this policy

The Privacy Act 1988 requires entities bound by the Australian Privacy Principles to have a Privacy Policy. This privacy policy outlines the personal information handling practices of Sublime HealthPro.

This policy is written in simple language. The specific legal obligations of the Sublime HealthPro when collecting and handling your personal information are outlined in the Privacy Act 1988 and in particular in the Australian Privacy Principles found in that Act. We will update this privacy policy when our information handling practices change. Updates will be publicised on our website and through our email lists.

Overview

We collect, hold, use and disclose personal information to carry out functions or activities under the Australian Information Commissioner Act 2010 (AIC Act), the Privacy Act 1988 (Privacy Act) and the Freedom of Information Act 1982 (FOI Act) and other legislation that confer powers or functions on the OAIC including the My Health Records Act 2012 (My Health Records Act).

These functions and activities include:

• handling privacy and freedom of information (FOI) complaints and FOI reviews
• taking other regulatory action under the Privacy and FOI Act
• providing advice on privacy, FOI, and information policy issues
• consulting with stakeholders, for example, on privacy or FOI guidance
• maintaining registers, such as organisations that have opted-in to Privacy Act coverage
• responding to access to information requests
• communicating with the public, stakeholders and the media including through websites and social media
• assessing suitable candidates for career opportunities within the OAIC.

Collection of your Personal Information

At all times we try to only collect the information we need for the particular function or activity we are carrying out.
The main way we collect personal information about you is when you give it to us. For example, we collect personal information such as contact details and complaint, review, request, data breach notification or report details when you:

• contact us to ask for information (but only if we need it)
• make a complaint about a privacy breach to us
• ask for access to information the Sublime HealthPro holds about you
• notify the Sublime HealthPro about a data breach
• report a matter for investigation
• apply for a job vacancy at the Sublime HealthPro.

We may also collect contact details and some other personal information if you are on our committees or participating in a meeting or consultation with us.

Collecting sensitive information

Sometimes we may need to collect sensitive information about you, for example, to handle a complaint. This might include information about your health, racial or ethnic origin, political opinions, association memberships, religious beliefs, sexual orientation, criminal history, genetic or biometric information.

Indirect collection

In the course of handling and resolving a complaint, data breach notification, review or an investigation, we may collect personal information (including sensitive information) about you indirectly from publicly available sources or from third parties such as:

• your authorised representative, if you have one
• applicants, complainants, respondents to a complaint, investigation, application or data breach notification or the third parties’ employees and witnesses.

Anonymity

Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact our Enquiries line with a general question we will not ask for your name unless we need it to adequately handle your question.

However, for most of our functions and activities we usually need your name and contact information and enough information about the particular matter to enable us to fairly and efficiently handle your inquiry, request, complaint or application, or to act on your report.

Collecting through our websites

There are a number of ways in which we collect information though our website.

Analytics

We use Google Analytics and Piwik to collect data about your interaction with our website. We host Piwik ourselves, while Google Analytics is hosted by a third party. The sole purpose of collecting your data in this way is to improve your experience when using our site. The types of data we collect with these tools include:

• referring domain and out link if applicable
• search terms and pages visited
• date and time when website pages were accessed

Cookies

Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the website.

Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing our website.

Email lists, registrations and feedback

We will collect information that you provide to us when signing up to mailing lists and registering for our events, or when submitting feedback on your experience with our website.

Social Networking Services

We use social networking services such as Twitter, Facebook, Linkedin and YouTube to communicate with the public about our work. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These services have their own privacy policies.

Electronic forms

Sublime HealthPro uses various forms to enable you to, for example, lodge a complaint, application, data breach notification, enquiry or apply for a job.

Transfer of your personal data to overseas

We may process your Personal Data outside of the country in which you are based for the purposes set out in this notice. When we transfer your Personal Data to other countries, we take reasonable steps to ensure that applicable laws are being followed.

Your Personal Information will be used in Connection With

• Our assessment of your suitability for registration with us;
• Necessary validation (including from appropriate third party sources) of your resume, CV, nominated references, or stated qualifications, experience, training or abilities. Where we require third party validation we will tell you how we propose to obtain it;
• Your actual or possible work placement;
• Your performance appraisals;
• Any test or assessment (including medical tests and assessments) that you might be required to undergo;
• Our assessment of your ongoing performance and prospects;
• Our identification of your training needs;
• Suggestions we may make to you, whilst you remain registered with us, for further training in connection with work of the type that you are seeking through us;
• Any workplace rehabilitation in which you and we are involved;
• Our management of any complaint, investigation or inquiry in which you are involved;
• Any insurance claim or proposal that requires disclosure of your personal or sensitive information;
• Any reference that we may give concerning your work;
• Our statutory compliance obligations;

Your Personal Information May be Disclosed To

• Potential and actual employers and clients of Sublime HealthPro;
• Referees;
• Person who seeks a reference about you;
• Other members of the Sublime HealthPro;
• Our insurers;
• Professional association or registration body that has a proper interest in the disclosure of your personal and sensitive information;
• Workers Compensation body;
• Our contractors and suppliers – e.g. our I.T. contractors, internet service suppliers and database designers, some of whom may be off shore;
• A parent, guardian, holder of an enduring power of attorney (or like authority) or next of kin whom we may contact in any case in which consent is required or notification is to be given and where it is not practicable to obtain it from or give it directly to you;
• Any person with a lawful entitlement to obtain the information.

You can gain Access to your Information to correct if it is wrong

Subject to some exceptions which are set out in privacy legislation you have a right to see and have a copy of personal information about you that we hold.

If you are able to establish that personal information that we hold about you is misleading, irrelevant, not accurate, complete or up-to-date, we will take reasonable steps to correct it.

If we are unable to agree that personal information that we hold about you is not misleading, relevant accurate, complete and up-to-date, you may ask us to place with the information a statement by you that claims that particular information is misleading, irrelevant, not accurate, incomplete or out of-date.

If you wish to exercise your rights of access and correction you should contact our privacy coordinator, whose details are shown above.

In some cases we may impose a moderate charge for providing access to personal or sensitive information. We will not charge you simply because you lodge a request for access.

Electronic Transactions

We conduct transactions electronically as well as in hard copy and by face to face measures. It is important that you understand that there are risks associated with the use of electronic technologies and the use of the internet and you should take all appropriate steps to protect your personal information.

Marketing

We may use your personal information to keep you informed of our Services and promotions. We provide individuals with easy opt-out request service if they do not wish to receive marketing and/or career management promotions.

How to make a complaint

If you wish to complain to us about how we have handled your personal information you should complain in writing. If you need help lodging a complaint, you can contact us.

If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.

If we decide that a complaint should be investigated further, the complaint will usually be handled by a senior officer than the officer whose actions you are complaining about.

When we receive a complaint from you, we will tell you promptly that we have received your complaint and then respond to the complaint within 30 days.

If you are not satisfied with our response you may ask for a review by a more senior officer within Sublime HealthPro or you can complain to the Commonwealth Ombudsman.