We respect your privacy and are firmly committed to complying with our obligations under applicable privacy laws, including the Australian Privacy Principles. This Policy outlines how we collect, handle and use your personal information, how you may request access or correction of your personal information and how you may complain about a privacy breach by us.
“Personal Information” means information or an opinion about an individual whose identity can be apparent or can reasonably be ascertained from the information.
“Sensitive information” is a subcategory of Personal Information and includes Personal Information of a particularly sensitive nature, including information or an opinion about your health, racial or ethnic origin, religious beliefs or affiliations, sexual orientation or practices, criminal record, political opinions, membership of a political or trade association or philosophical beliefs.
This Policy is available from our website. You can also request a free copy by contacting our Privacy Officer at info firstname.lastname@example.org or by writing to Privacy Officer at P.O.Box 509 North Ryde NSW 1670.
What information do we collect and why?
We collect different types of Personal Information depending on what category you fall into below. We only use your Personal Information for the purposes set out below, unless we have your consent or are required or authorised by law to use your Personal Information for another purpose.
Our hearing clinic customers
We collect Personal Information about our hearing clinic customers. Personal Information is commonly collected when:
• a customer visits or calls a clinic to attend a hearing screening.
• we provide customers with a hearing screening.
• a customer speaks to a member of our Client Care team by phone or completes a customer survey.
• we provide services using the government’s Hearing Services Online portal.
• you are referred to us (for example, by your GP, or family member) for a hearing check.
In most situations we collect Personal Information directly from you, but in some situations Personal Information may be collected from your healthcare provider, your nominated person or other persons provided with your consent. We may also collect Personal Information from client referrals and third party data providers. Where we obtain Personal Information from other persons, we only collect and retain this Personal Information where we believe that you have consented to the provision of this Personal Information to us.
The Personal Information we collect includes your name, signature, address, phone numbers, email address, date of birth, credit card and payment details. It also includes Sensitive Information such as your medical history, hearing test results and general health and lifestyle information. We also collect government identifiers such as Department of Hearing Services (OHS identifiers), Pensioner & Department of Veteran Affairs numbers as relevant.
We collect Personal Information from you so that we can provide you with excellent customer service and deliver suitable services and products. We also collect Personal Information to provide you with information about products and services that we believe may be of interest to you. We also collect your Personal Information for the purposes of confirming, on your behalf, your eligibility for a hearing services voucher from the Office of Hearing Services.
Our Business Clients
We collect Personal Information from our business clients. If you are a health professional we may collect Personal Information about you including your name, contact details, business details, your use of our products and services and any other information that you provide to us as part of your dealings with us. We collect this Personal Information in order to ensure that we can provide you with excellent customer service and tailored goods and services.
In some situations we organise for our business clients to attend seminars, conferences and other professional development activities. Where you agree to attend such an event or activity, we may collect additional Personal Information from you including your travel itinerary, the details contained in your passport, information about any medical conditions or dietary requirements that you may have and any other information that you may provide us in connection with our facilitation of your travel, transport, accommodation and attendance at the seminar, conference or professional development activity. We collect this Personal Information to help facilitate your attendance at these seminars, conferences and professional development activities.
Our Job Applicants
If you make an application for employment with us, we will collect the Personal Information that you provide us as part of your job application, including the information contained in your resume, driver’s licence or passport. We may collect further Personal Information from referees and past employers set out in your resume or employment application. With your consent, we may in some situations also collect other Personal Information about you as part of background checks, including criminal records checks. This information is solely used for the purposes of determining your suitability for the role that you have applied for.
Our Suppliers and Contractors
We collect Personal Information about our customers and suppliers, such as name and contact details. We may also collect Personal Information from third parties relating to the performance of our contractors or suppliers. We collect this Personal Information so that we can contact our suppliers and contractors and ensure that we are able to provide our customers with quality goods and services.
Anonymity and pseudonymity
You can request to remain anonymous or for us to use a pseudonym in your dealings with us, unless it is impracticable for us to deal with you on such a basis. We may be limited in the services that we can provide you, if you chose to remain anonymous.
How do we store information and how long is it kept?
The safety and security of your Personal Information is very important to us. All Personal Information that we hold, whether in hardcopy or electronic form, is stored securely in our clinics or our central offices. Only our authorised personnel or contractors have access to your Personal Information if it is relevant to their role.
We protect electronically stored information from inappropriate use or disclosure by a range of technical systems, such as firewalls and antivirus software.
We regularly undertake audits to monitor our security mechanisms.
We only keep Personal Information for as long as required by law and needed for our business functions and activities.
Who we may disclose your Personal Information to?
If you are a hearing clinic customer we may disclose your Personal Information to persons involved in the management of your hearing and healthcare, including your GP or specialist and to persons that have been nominated by you. We may also disclose your Personal Information to government entities in connection with the provision of hearing and healthcare services to you.
In the course of providing you with products or services we may also disclose your Personal Information to our contractors and agencies, which may include entities that facilitate marketing activities to you on our behalf.
We may also use or disclose your Personal Information to other third parties with your consent or if required or authorised by law.
If you are a business client and we organise for you to attend a seminar, conference or other professional development activity we may disclose your Personal Information to third parties to provide you with this service, such as conference providers, travel agents and accommodation and travel providers.
Transfer of Personal Information outside Australia
For our business functions and purposes (including statistical analysis), we may disclose your Personal Information to businesses and entities within the wider international William Demant Holdings Group, which includes several overseas entities. For a list of countries in the William Demant Holding Group please access the link http://www.demant.com/contacts.cfm
In order to provide goods and services to you, there may also be some situations where we may disclose your Personal Information to a contractor or supplier that is located overseas.
We may store Personal Information in the “cloud” that may be located on servers in a number of overseas countries. We take reasonable steps to ensure that these overseas entities protect your Personal Information and only use it for the purposes set out in this Policy or as otherwise authorised by you or required or permitted by law.
From time to time we may use your Personal Information to provide you with direct marketing communications to promote goods and services that we believe may be of interest to you. This could be through a variety of channels, including telephone, SMS, mail, email or online advertising.
We will only participate in direct marketing practices in accordance with the law. If you receive direct marketing material from us you may request that you no longer receive any material and we will promptly action all such requests. For all email communications we provide you with an easy unsubscribe mechanism.
Use of our Website
When you access our website we gather information through “cookies”, which may result in some information about your use of our websites being logged, including the time of your access, your IP address and the pages that have been viewed. We use this information for the purely statistical purposes to analyse and monitor the effectiveness of our website, including trends in website traffic.
If you do not wish to receive “cookies”, you may be able to change the settings of your browser to refuse all “cookies” or to notify you each time a cookie is sent to your computer, giving you the choice to accept it or not.
Our websites may contain links to external websites that are not affiliated to us. We are not responsible for the content or privacy policies of these websites.
The data generated and processed by Google Analytics may be used and stored by Google on servers located outside Australia. Google may use this data in accordance with its policies, including for the purpose of generating reports on website activity and internet usage. Further information about Google Analytics and how Google uses Google Analytics data is available at www.google.com/policies/privacy/partners/.
Queries and Complaints
If you have a query or complaint in relation to the way we have handled your Personal Information, you can contact us at email@example.com or by writing to our Privacy Officer at P.O.Box 509 North Ryde NSW 1670. So that we can fully deal with your query or complaint please include the below details:
• a summary of the alleged breach of privacy concern, including details of where the alleged privacy breach or privacy concern occurred (business name and location) and who you have dealt with in relation to the issue.
• copies of relevant documentation in connection with the complaint.
We will investigate the issue and will endeavour to respond to all requests within 20 business days, unless extenuating circumstances exist.
We will take immediate steps to redress any proven privacy issues or breaches.
Requests for Access and Correction of Personal Information
Subject to legal exceptions and appropriate evidence and verification of your identity, you can request a copy of your Personal Information from us by contacting us at firstname.lastname@example.org or by writing to the Privacy Officer, P.O.Box 509 North Ryde NSW 1670. There is no charge to make a request, but we may charge you a reasonable fee to cover applicable photocopy charges. We will endeavour to action your request within 20 business days, unless extenuating circumstances exist.
It is important to us that all Personal Information that we retain is kept up-to-date, accurate and complete. Again, subject to adequate proof of your identity, you may also request that we update or correct any Personal Information about you that is inaccurate, incomplete or out of date. We will action all such requests within a reasonable time.
More information about Privacy law and the National Privacy Principles is available from the Federal Privacy Commissioner at http://www.privacy.gov.au
The Policy is subject to regular review and may be updated from time to time.
This Policy was last reviewed on 1st June 2017.