A Growing Understanding Pty Ltd – Privacy Policy
About this policy
A Growing Understanding Pty Ltd (“us”, “we”, or “our”) recognises the importance of your privacy and respects your right to control how your personal information is collected and used.
We are an APP Entity as defined in the Privacy Act 1988 (Cth) (the “Act”). This privacy policy is aligned with the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) (Privacy Act) and describes the way that we may collect, hold and disclose personal information.
This Privacy Policy applies to our website, www.agrowingunderstanding.com.au (the “Site”) which is operated by us, and to the services provided by us.
In this policy “Personal Information” means any information that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address, and phone number.
“Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, memberships of a political organisation, religious belief or affiliation, philosophical belief, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.
Collection
To provide our services to you, we may collect Personal Information, such as your contact details, including your name, email address and contact phone number, your business or company name; your payment and billing information, which we use to bill you for the Services and to process your payments, including credit card details. We may also collect details of conversations we have had with you or any other information relevant to us.
We may also collect Sensitive Information about you, such as medical reports, referrals, medication, health history and other important health information where you consent and such information is reasonably necessary to provide our services to you.
We automatically collect through our Site and Services, information that is often not personally identifiable, such as the website from which visitors came to our Site, IP address, browser type and other information relating to the device through which they access the Site. We may combine this information with the Personal Information we have collected about patients.
We recognise that personal information should only be collected when necessary, and this especially relates to members of the LGBTQ+ community. Therefore, we undertake to ensure that:
- any personal information collected from LGBTQ+ individuals must be necessary for, or directly related to, a relevant health service
- LGBTQ+ individuals must be aware of the purpose for which their personal information is being collected and stored
- conversations requiring LGBTQ+ individual to disclose personal information are always confidential
- LGBTQ+ individuals must give consent if there is a need to share their personal information
We can assure you that our team are trained on how to communicate the privacy policy, how patient data is shared and stored, and who else has access to it, and that privacy policy training will continue on an ongoing basis for new and current team members.
Use and Disclosure
At A Growing Understanding, the use of and access to your records is strictly limited to those team members who need it to provide you with our services. This ensures that sensitive information remains confidential and is handled responsibly.
We hold assessments in the strictest confidence. They are disclosed only with the express permission of the client or their authorised representative, ensuring your privacy is protected.
We are transparent about the sharing of your information. We disclose personal information only for the purposes for which it was collected. This includes service provision, account and contact management, and payment processing. We may also share your information with third-party contractors and other health professionals integral to delivering our services, but only with your consent or as necessary for providing our services or as required by law.
Occasionally, we might use your information for related purposes that would be reasonably expected, such as meeting our professional obligations or managing transactions. In such cases, we may consult with legal, accounting, or other professionals under conditions of confidentiality.
We do not sell, share, or trade your personal information to third parties without your explicit consent. However, with your approval, we may provide necessary health information to other medical service providers (e.g., GPs, specialists) for continuity of care or to government offices for billing and Medicare purposes, or in situations where it is imperative to lessen a serious threat to a client’s life, health, or safety.
Access and Accuracy
You can access and/or correct information we hold about you at any time by contacting us at 02 4044 1122. We encourage you to contact us to keep your Personal Information up to date.
We will respond to your request for access or correction of Personal Information within a reasonable time. We reserve the right to charge an administration fee to cover the costs of responding to your request, for example, where Personal Information is held in off-site storage.
If required by law or where the information may relate to existing or anticipated legal proceedings, we may deny your request for access to your information. We will respond to your request, setting out the reasons for our refusal in writing.
Storage and Security
We will take reasonable steps to protect your Personal and Sensitive Information from misuse, loss, unauthorised access and modification or disclosure. We use commercially reasonable physical, technical and administrative measures to protect Information that we hold, including, where appropriate, password protection, encryption, and SSL to protect our Site.
Despite taking appropriate measure to protect Personal and Sensitive information used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. We cannot guarantee the security of any information transmitted to us via the internet and such transmission is at your risk.
If we no longer require the use of your Personal information, we will take reasonable steps to destroy or permanently de-identify it. Health records will be destroyed in accordance with our professional obligations.
Personal information may be stored electronically through third party data centres, which may be located overseas, or in physical storage at our premises or third-party secure storage facilities.
You are solely responsible for the maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
Data Breach Notification Scheme
If we have reason to suspect a data breach has occurred, we will undertake an assessment in accordance with the Notifiable Data Breach Scheme. If we determine there has been an eligible data breach, we will notify you as soon as reasonably practicable.
If the breach relates to the My Health Records Act, we may disclose your personal information to the My Health Records System Operator under s 73A of that Act.
Identifiers
An identifier is a unique number assigned to an individual to identify them. Identifiers include Medicare Numbers and Tax File numbers. We will not adopt as our own any identifier of you, or use or disclose an identifier of you which has been assigned by a government agency, unless permitted under the Act.
Career Applications
Employment applications and resumes collected by us are securely stored and only used for the purpose for which they were collected.
Cookies, Web Beacons and Analytics
When you interact with our Site, we strive to make your experience easy and meaningful. We, or our third-party service providers, may use cookies, web beacons (clear GIFs, web bugs) and similar technologies to track site visitor activity and collect site data. We may combine this data with the Personal Information we have collected from patients. Examples of information that we may collect include technical information such as your computer’s IP address and your browser type, an information about your visit such as the products you viewed or searched for, the country you are in, what you clicked on and what links you visited to get to or from our site. If we identify you with this information, any use or disclosure of that information will be in accordance with this Privacy Policy.
Third-party Websites
At times, our Site may contain links to other, third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
Marketing Emails
We may send you direct marketing emails and information about products and services that we consider may be of interest to you. These communications will only be sent via email and in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth) as you consented to upon registering for our Services. If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. If you opt-out of receiving emails or promotions from us, we still may send you emails about your Services you have requested or received from us, or for other customer service purposes. We do not provide your Information to other organisations for the purposes of direct marketing.
If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.
Consent to International Transfer
We may transfer your Personal or Sensitive Information to organisations in other countries. Recipients may include our related entities or employees, external service providers such as administration providers or information technology providers such as cloud storage and data processing. We only transfer information where we reasonably believe that the recipient is legally or contractually bound by principles that are substantially similar to the Australian Privacy Principles.
Changes to this Policy
We may change this Privacy Policy from time to time. Any updated versions of this Privacy Policy will be posted on our Site – you should check periodically to review our current Privacy Policy, which is effective as of the effective date listed below. Your continued use of any of our Site and Services constitutes your acceptance and understanding of the Privacy Policy as in effect at the time of your use. If we make any changes to this Privacy Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavour to provide you with notice in advance of such change by highlighting the change on the Site, or where practical, by emailing patients. This policy current as of 24th July, 2024
Complaints and Enquiries
If you have any questions or complaints regarding privacy, or if at any time you believe we may have wrongfully disclosed your Personal and Sensitive Information or breached our privacy obligations, please contact us on 02 4044 1122 or lodge your complaint in writing to:
Privacy Officer
A Growing Understanding
PO Box 238
Kotara NSW 2289
or at hello@agrowingunderstanding.com.au
If you are not satisfied with our response you are entitled to contact the Office of the Australian Information Commissioner, by phoning 1300 363 992 or writing to the Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.