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Orthopaedic Clinics Gold Coast (OCGC)

1. OVERVIEW & OBLIGATIONS
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OCGC provides facilities and administrative services to businesses and practitioners to carry out their business. Personal and Sensitive Information, including the information of any person/s who engage in your business will always be collected and stored by fair and lawful means.

Orthopaedic Clinics Gold Coast (OCGC) respects your rights to privacy and takes our privacy obligations seriously. We comply with the Australian Privacy Principles (APP’s), found under the Australian Privacy Act 1988 (Privacy Act) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 together with the provisions of the equivalent State and Territory legislation.

Our responsibilities also apply to any third parties we engage in providing our services to you. All employees and third parties of OCGC are obligated to adhere to the Privacy Principles and to handle any Personal Information they encounter with utmost care and confidentiality. Any violation of these obligations would constitute a breach of contract. If you have any questions, concerns, or specific requirements regarding the collection of information about you or your patients, please let us know.

In this Privacy Policy, we use the term Personal Information – as defined in the Privacy Act includes a broad range of information, or an opinion, that could identify an individual. Personal Information may also include Sensitive Information which attracts a higher privacy standard under the Privacy Act and is subject to additional mechanisms for your protection.

This Privacy Policy may be amended from time to time. The client consents to any amendments to this Privacy Policy by continuing to use the services.

If you have any queries, concerns or feedback regarding our Privacy Policy, please do not hesitate to contact us:

Contact:             The Privacy Officer
Ph:                         07 2101 2650
Email:                   manager@ocgc.com.au
Post:                     Suite 5A, Level 6, Pacific Private Clinics, 123 Nerang Street, Southport, QLD, 4215

 

2. COLLECTION OF PERSONAL INFORMATION
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2.1   OCGC COLLECTS PERSONAL INFORMATION FOR THE PURPOSES OF

  • providing Administrative Services to clients and other associated third-party businesses;
  • employing Administrative staff of OCGC;
  • complying with legal, regulatory and licencing requirements; and
  • processing, where necessary, our legitimate business interests or those of a third party, provided this does not override any interests or rights that you have as an individual.

Our legitimate interests include understanding and responding to feedback and enquiries and providing the appropriate facilities and services to enable you to provide relevant services to carry out your business.

2.2   TYPES OF PERSONAL INFORMATION COLLECTED

OCGC collects Personal Information which may include;

  • Contact Information: name, position, role, company or organisation, telephone number, email address, residential, business and postal addresses, third-party usernames, social medial profiles and next of kin details;
  • Sensitive Information: information or opinions recorded on our services by our clients including records about individuals required for the client to provide their service;
  • Identity Information: signature, location, website address, date of birth, nationality, license and registration details, bank account details, employment details, educational qualifications, Medicare and Health Fund details;
  • Behavior Information: associations, memberships, finances and purchases;
  • Information from Public Sources: for example, from Social Media, Regulatory Bodies, Professional networks, directories and internet publications;
  • Internet Data: operating system, domain name and;
  • Business Information: information about a business or project, if it is run in the individual’s personal capacity, including information on professional affiliations or services offered;
  • Technical information: OCGC and some of the third-party service providers we use (such as Google Analytics) may engage in collection of data as follows:
    1. Logs: when you visit our website or use the Services, our server and analytics service may log details about your visit such as your IP address, the time and duration of visit, the link from you which you visited, and information about your browser and operating system; and
    2. Cookies: we will likely place a cookie on your device when you visit our website.

2.3   HOW WE COLLECT PERSONAL INFORMATION

We collect Personal information to provide our administrative services to clients and other third-party business in the following ways:

  • directly from you when you provide information verbally or written;
  • from our own records of your transactions and interaction;
  • from publicly available sources of information;
  • in forms filled out either online or in hard copy;
  • face to face or when you speak with us directly;
  • via other third-parties;
  • in voice or image recordings.

2.4   COLLECTING PERSONAL INFORMATION FROM THIRD PARTIES

When appropriate, OCGC may collect and receive Personal Information from third parties regarding the client in the following ways:

  • you have consented to such collection; or
  • to enable the client to provide a service and conduct their business; or
  • such collection is reasonably necessary to enable us to appropriately manage and conduct our business; or
  • it is legally permissible for us to do.

 

3. HOW WE USE PERSONAL INFORMATION
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3.1   PERSONAL INFORMATION MAY BE USED FOR THE FOLLOWING PURPOSES

  • to enable you to provide a service and conduct your business;
  • to provide administrative services to you including to appropriately manage your business, such as conducting audits, undertaking accreditation processed, to mange finances and train staff;
  • to enable us to appropriately manage and conduct our business;
  • effectively communicate with you and third parties;
  • compliance with law, including circumstances where disclosure is required without the client’s consent. We may obtain further information from the client to comply with the law if required;
  • for quality assurance and improvement of processes, for example risk management;
  • the disclosure of the your Personal Information is necessary for the enforcement of criminal law or a law imposing a penalty or sanction, or for the protection of public revenue;
  • the disclosure of your information will prevent or lessen a serious and imminent threat to somebody’s life or health; or
  • OCGC is required or authorised by law to disclose your information for another purpose.

 

4. DISCLOSURE PERSONAL INFORMATION
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4.1   PERSONAL INFORMATION MAY BE DISCLOSED FOR THE FOLLOWING PURPOSES

  • consistent with or directly related to the purpose for which it is collected;
  • to OCGC employees and third-party providers in order for us to provide administrative services to you;
  • to allow us to manage our business;
  • if we are legally obliged to do so by a court subpoena, statutory authority, search warrant, coronial summons or to defend a legal action.

OCGC engages in third-parties who assist us in delivering our services to you.

 

5. OVERSEAS RECIPIENTS
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5.1   DISCLOSURE OF INFORMATION OVERSEAS

OCGC and our third parties are within Australia. We will not store or disclose any of your Personal Information to any overseas entities, third-parties or persons.

 

6. DATA STORAGE, QUALITY AND SECURITY
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OCGC is committed to ensure the security and accuracy of your personal information.

We may keep your Personal Information in physical and electronic form (or a combination) in accordance with the Privacy Act (subject to legal obligations). We will store and process your information securely using good practice physical, technical and administrative security measures.

Exchanging information, including Personal Information, by the internet is not completely secure. Although we will take reasonable measures to protect your Personal Information, we cannot guarantee the security of information you transmit, so any transmission is at your own risk.

Your personal data is stored on secure servers within controlled facilities within Australia. Our employees and data processors are obligated to uphold confidentiality and adhere to our privacy policy and procedures.

We strive to maintain the reliability, accuracy, completeness and currency of the Personal Information we hold and to protect its privacy and security. All Personal Information is protected from unauthorised access, misuse, interference, loss, modification or disclosure.

6.1   REASONABLE MEASURES WE TAKE TO SAFEGUARD YOUR DATA & PERSONAL INFORMATION

  • we maintain physical security over our paper and electronic data and premises;
  • OCGC staff undertake annual training on privacy;
  • we have detailed internal processes and systems to protect your Personal Information;
  • our IT security includes virus controls, firewalls, encryption, user identifiers and passwords to control access to computer systems where your Personal Information is electronically stored;
  • we use an Australian hosted data centre to store and back-up our data. This is managed by professional IT consultants and we have written agreements with them which includes requirements for backup, security and that they abide by the Australian Privacy Principles.

 

7. DESTROYING YOUR PERSONAL INFORMATION
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OCGC have secure destruction bins on site, for hardcopy files or documents. Records are destroyed securely to maintain your confidentiality and to protect the information against misuse or unauthorised access, disclosure or modification, and damage, loss or theft.

If services with OCGC are terminated, your data will be transferred to your nominated entity. OCGC will keep data (electronically and in hardcopy form) in line with the Australian Law and Regulations for our record keeping obligations.

 

8. ACCESSING AND AMENDING YOUR PERSONAL INFORMATION
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8.1   ACCESSING YOUR PERSONAL INFORMATION

At OCGC, you have the right to access your Personal Information, with any exceptions as allowed by law. All individuals have a right to request access to their Personal Information. Please contact us if you would like to access your Personal Information. We will generally provide you with access to your Personal Information within a reasonable period (but being no more than 30 days after your request). Depending on the amount of information requested, we may charge an administration fee to cover the cost of retrieving the information and supplying it to you.

Access to Personal Information may be refused in a number of circumstances, such as where the information relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, you will be provided with a written explanation.

If you have any concerns about the way your Personal Information is stored, disclosed or otherwise managed, or believe that a breach of your privacy has occurred, please contact us in writing. We will respond to your concerns as soon as reasonably practicable (and no more than 30 days after your request).

If you are for whatever reason not satisfied with the response or resolution of your concerns or complaint, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or by visiting www.oaic.gov.au.

8.2   AMENDING YOUR PERSONAL INFORMATION

If you believe that any Personal Information that we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us in writing.

To make such requests, kindly submit a written request to manager@ocgc.com.au.

It is your responsibility to advise of any changes to your Personal Information (for example change of residential address, email address or phone number). We will respond within a reasonable time (but being no more than 30 days after your request) and will endeavour to correct any Personal Information. You may request that you be provided with your Personal Information or it be deleted. Any written request by you cannot be unreasonably withheld. However, in some limited circumstances the requested corrections to Personal Information may be refused, in which case you will be provided with written reasons for this decision.

We are committed to maintaining the accuracy, relevance, and completeness of your personal data. If any information is found to be inaccurate, out-of-date, or incomplete, we will take reasonable steps to correct it. If access or correction is refused, we will provide written reasons in compliance with the APPs.

 

9. THIRD PARTY WEBSITES
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Our website, email updates and other communications may, from time to time, contain links to and from the websites of others. The Personal Information that you provide through these websites is not subject to this Privacy Policy and the treatment of your Personal Information by such websites is not our responsibility.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

 

10. INDIVIDUALS OF OCGC CLIENTS
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If you are an individual that engages with any of the clients that use OCGC’s administrative services, this Privacy Policy does not apply to you.

We encourage you to read their privacy policy.

 

11. DEFINITIONS WITHIN THIS POLICY
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In this Privacy Policy, the following terms have the meaning given to them below unless the context requires otherwise:

  • APPs: means the Australian Privacy Principles;
  • Privacy Policy: means this privacy policy as amended from time to time made available in a physical or electronic copy upon request;
  • Personal Information: has the meaning given to it in the Privacy Act, which includes information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not or in a material form or not;
  • Privacy Act: means the Privacy Act 1988as amended from time to time;
  • Sensitive Information: has the meaning given to it in the Privacy Act, which includes information or an opinion about an individual’s racial or ethnic origin, political opinions, religious beliefs, sexual orientation or criminal record;
  • OCGC/we/us/our: Orthopaedic Clinics Gold Coast Services Trust ABN: 85 562 022 163
  • You/Your/The Client: means the individual who we collect the Personal Information from and about.

 

12. COMPLAINTS
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If you have a complaint relating to an alleged breach of the APPs, you should contact us using the details listed in this Privacy Policy.

When you notify us of a complaint about our handling of your Personal Information, we will deal with the complaint by responding to it in writing within a reasonable period (usually 10 business days from the day we receive your written notification).

We will endeavour to work with you to resolve the complaint entirely within 30 days, although that period may be longer if it is reasonable to take longer given the nature of your complaint.

If you are unsatisfied with our response, you may make refer the complaint to the Office of the Australian Information Commissioner (OAIC) https://www.oaic.gov.au/ or The Office of the Privacy Commissioner on 1300 363 992 or visit https://www.privacy.gov.au/complaints.

 

13. CHANGES TO THIS PRIVACY POLICY
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Orthopaedic Clinics Gold Coast reserves the right to make amendments to this Privacy Policy at any time.  If you have objections to the Privacy Policy, you should not access or use our service.

Orthopaedic Clinics Gold Coast welcomes your comments regarding this Privacy Policy. If you have any questions or complaints about this Privacy Policy, the way we hold or disclose Personal Information or would like to see the current version, please contact us by any of the following means;

Contact:             The Privacy Officer
Ph:                         07 2101 2650
Email:                   manager@ocgc.com.au
Post:                     Suite 5A, Level 6, Pacific Private Clinics, 123 Nerang Street, Southport, QLD, 4215