Personal Information is information or an opinion, about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. Common examples are an individual’s name, signature, address, telephone number, date of birth, medical records, bank account details, employment details and commentary or opinion about a person.
Sensitive Information is information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record that is also personal information, health information about an individual, genetic information about an individual that is not otherwise health information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or biometric templates.
Health Information is information or opinion about the health, including an illness, disability or injury (at any time) of an individual, an individual’s expressed wishes about future provision of Health Services to the individual, or a Health Service provided, or to be provided, to an individual that is also personal information. It also includes other personal information collected to provide a Health Service, donation or intended donation of body parts, organs or body substances and genetic information.
A Health Service is any activity that is intended or claimed by the individual or the person performing it to assess, maintain or improve the individual’s health, where the individual’s health cannot be maintained or improved – to manage the individual’s health, to diagnose the individual’s illness, disability or injury, to treat the individual’s illness, disability or injury or suspected illness, disability or injury, to record the individual’s health for the purposes of assessing, maintaining, improving or managing the individual’s health, the dispensing on prescription of a drug or medicinal preparation by a pharmacist. The Act applies to all private sector organisations that deliver these types of services, including all small Health Services that hold Health Information.
GTCG will only collect the information necessary to deliver the Telehealth Platform. GTCG’s role as a Health Service Provider is related to [facilitating the provision of medical and business telehealth consultations]. For GTCG to provide the Telehealth Platform we need to manage, collect and hold Personal Information (including Sensitive Information) and Health Information to facilitate the provision of these services. The types of Personal Information (including Sensitive Information) and Health Information we collect and hold may include, but not limited to:
(a) user details such as name, address, qualifications, medical role, career level, company, user name and password, provider number, healthcare provider identification, email, phone, mobile and fax number, other relevant certifications in relation to working with children in applicable jurisdiction including Australian Health practitioner Regulation Agency registration number, prescriber number, working with children check and police check;
(b) patient and/or third party details such as name, address, date of birth, gender, marital status, primary language, addresses, hospital identification number, Medicare number, name of health insurer, provider number, email, phone, mobile and fax number; GP details; specialist and other health worker details and demographic details;
(c) health information such as patient and/or third party data (including weight/height, medical records, medical history, pathology results, and tests), procedure information (including date/time/location, and proceduralist), patient medical databases (including Medicare and hospital databases), drug dose calculations, episodes of care (including types of anaesthesia interventions performed, airway management, blood transfusion), incident monitoring (including incident type, outcome, duration); guardianship, relevant social history, Department of Health and Human Services history, Children Protection Services history (including whether a child is a vulnerable child) and refugee or asylum seeker status;
(d) invoicing, support calls/emails, complaints, feedback and enquires; and
(e) any other information recorded or otherwise required by the Telehealth Platform or provided by you.
GTCG have a number of methods available for the collection of Personal Information, including but not limited to patient profile forms, mobile forms, website forms, request forms, medical databases, mail, email, feedback forms, phone and video calls, fax, secure messaging, and software application data screens. We usually collect Personal Information directly from the Telehealth Platform user or an authorised representative. We may also collect Personal Information from trusted third parties. Such collection is conducted in a fair and reasonable manner and is reasonably necessary for the functions and activities of GTCG. We will notify the owner of the Personal Information where practically possible as to the third party we obtain the information from.
Unless express consent is obtained, GTCG collects and uses Personal Information in a de-identified form for various purposes including, but not limited to the following:
(a) contact and communicate with the user;
(b) provide information, products and services;
(c) facilitate users of the Telehealth Platform to undertake a diagnoses;
(d) perform medical and other procedures;
(e) internal research, data analytics and record keeping; and
(f) better understand the needs of the user.
GTCG only uses your Personal Information:
(a) for the purpose you have given the information;
(b) to provide you with Health Services;
(c) for our administrative purposes, such as staff training, accounting, billing, product and service evaluation;
(d) to facilitate help-desk operations that include diagnostics, monitoring, and troubleshooting;
(e) if required by or authorised under law or by an enforcement body; and
(f) to third parties, including your authorised representative, our agents or sub-contractors, who assist us in providing information, products, services. This may include parties located, or that store data, outside of Australia.
If there is a change of control of GTCG or a sale or transfer of GTCG business assets, we reserve the right to transfer to the extent permissible by law all the information and data collected in whatever form collected, used, recorded or associated with the Telehealth Platform, including any user databases, together with any Personal Information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser. We would seek to only disclose information in good faith and to maintain confidentiality.
(c) Access: In certain circumstances set out in the Act, you may request details of Personal Information that we hold. An administrative fee may be payable for the provision of such information. We may refuse to provide you with information that we hold about you in certain circumstances as provided under the Act.
(d) Correction: If you believe that any information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us by email. We rely upon users updating the Personal Information on the Telehealth Platform or otherwise advising us when the Personal Information changes. We will respond to any request within a reasonable time and promptly correct any information found to be inaccurate or incomplete.
(e) Complaints: If you believe that we have breached the APPs and wish to make a complaint about that breach, please contact us by email. We will promptly investigate your complaint and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach (if any) and any other action we will take to deal with your complaint.
(f) Anonymity: Where practical, you may deal with us on an anonymous basis or by using a pseudonym. In some instances, because of the services we provide, if you do not provide us with the Personal Information we may not be able to provide you with Health Services under the Telehealth Platform, and its related products or services.
(g) Unsubscribe: To unsubscribe, or opt out of communications, please contact us at firstname.lastname@example.org.
For any questions or notice, please contact us at:
Global Telemedicine Consulting Group Pty Ltd (ACN 638 451 706)
c/- DPM, 1 Palmerston Crescent, South Melbourne, Victoria 3205
Further information on privacy legislation is available from: Office of the Australian Information Commissioner
1300 363 992
Office of the Health Services Commissioner Victoria
1300 582 113
Information and Privacy Commission New South Wales
1800 472 679
Office of the Information Commissioner Queensland
07 3234 7373
ACT Health Services Commissioner
02 6205 2222
Health and Disability Services Complaints Office Western Australia
1800 813 583
Office of the Information Commissioner Northern Territory
1800 005 610
1800 001 170
Privacy Committee of South Australia
08 8204 8786
Last update: July 2020