Global Telemedicine Consulting Group Pty Ltd (ACN 638 451 706) and its associated entities (GTCG) is committed to ensuring the privacy and confidentiality of your personal information. GTCG must comply with the Privacy Act 1988 (Commonwealth) (Act) and the Australian Privacy Principles (APPs) and any other applicable privacy laws that govern how private sector Health Service Providers handle personal information and the personal information of your patients (inclusive of Sensitive Information and Health Information) (Personal Information). This Privacy Policy explains how GTCG manages the Personal Information that we collect, use and disclose and how to contact us if you have any questions about the management of your Personal Information. For GTCG to provide Health Services (including through the use of the medical and business telehealth software applications), GTCG will need to collect and use Personal Information in order to maintain the medical and business telehealth software applications, website and support services that you use (together the Telehealth Platform). If you provide inaccurate or incomplete Personal Information, we may not be able to provide you with the Health Services provided by GTCG. If you are a Health Service Provider, by accepting the terms of this Privacy Policy, you are agreeing to obtain from patients and/or third parties all and every consent required in relation to the collection and storage of third party Personal Information, Sensitive Information and Health Information. This Privacy Policy outlines our obligations to protect the privacy of your Personal Information that we collect, use, and hold directly from you or through the Telehealth Platform. The following key terms are used throughout this Privacy Policy.
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.
When Personal Information about your patients and/or third parties is provided by you for the abovementioned purposes, you agree to follow this Privacy Policy regarding the handling of this information, and you agree to comply with the Act and APPs and any other applicable privacy laws that govern how private sector Health Service Providers handle Personal Information, including the Personal Information about third parties and/or your patients (inclusive of Sensitive Information and Health Information). Where we disclose Personal Information to third parties for the abovementioned purposes, we will request that the third party follow this Privacy Policy regarding the handling of the Personal Information, except as otherwise provided in this Privacy Policy.
GTCG will take all reasonable steps to ensure that your Personal Information which we may collect, use or disclose is accurate, complete and up-to-date. GTCG will take all reasonable steps to make sure that Personal Information we collect from the abovenamed sources are protected and held in a secure environment. GTCG takes all reasonable steps to safeguard the confidentiality, integrity and security of the Telehealth Platform and stored information. In order to prevent any data breaches or unauthorised access or disclosure, information security is built into the Telehealth Platform software including physical, electronic and managerial procedures to safeguard and secure the information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. Important Notice: No Personal Information transmitted over web based software applications can be guaranteed to be secure. The transmission and exchange of Personal Information is carried out at your own risk. Although we take all reasonable steps to safeguard against unauthorised disclosures of Personal Information, we cannot assure you that the Personal Information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
(a) Choice and Consent: Providing us with Personal Information is optional. You can choose not to provide Personal Information. When you provide Personal Information, you consent to the terms in this Privacy Policy, and to us disclosing or receiving your Personal Information for the abovementioned purposes.
(b) Restrict: You may choose to restrict the collection or use of Personal Information. If you have previously agreed to us using Personal Information for any of the abovementioned purposes, you may change your mind at any time by contacting us at the email address listed in this Privacy Policy.
(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 admin@kidsdoconcall.com.au.
(h) Transborder disclosure of Personal Information: We may store, process or back-up Personal Information on servers that are located outside Australia (including through third party service providers). GTCG remains in control of the handling, use, or processing of the Personal Information. The privacy laws in other countries might not be the same as in Australia. However, if we are required to provide Personal Information to third parties overseas, GTCG will take all reasonable steps to ensure that Personal Information is handled and stored in accordance with Australian privacy laws and the Privacy Policy. Important Notice: In the event that the processing or use of your Personal Information involves the disclosure of any information outside Australia, you acknowledge that by providing us with the Personal Information, you consent to such overseas disclosure. By consenting to such disclosure, you acknowledge and accept that GTCG will not be accountable under the Act for any breach of your privacy by the overseas recipient and you will not be able to seek redress under the Act for any breach of your privacy by the overseas recipient.
This Privacy Policy may be amended, including with changes, additions and deletions, from time to time in our sole discretion. Your continued use of the Health Services though the Telehealth Platform following any amendments indicates that you accept the amendments. You should check this Privacy Policy regularly, prior to providing Personal Information, to ensure you are aware of any changes, and only proceed to provide Personal Information if you accept the new Privacy Policy.
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
admin@kidsdoconcall.com.au
Further information on privacy legislation is available from: Office of the Australian Information Commissioner
1300 363 992
www.oaic.giov.au
Office of the Health Services Commissioner Victoria
1300 582 113
www.health.vic.gov.au/hsc/index.htm
Information and Privacy Commission New South Wales
1800 472 679
www.ipc.nsw.gov.au/privacy/ipc_index.html
Office of the Information Commissioner Queensland
07 3234 7373
www.oic.qld.gov.au
ACT Health Services Commissioner
02 6205 2222
www.hrc.act.gov.au/health
Health and Disability Services Complaints Office Western Australia
1800 813 583
www.hadsco.wa.gov.au/home/index.cfm
Office of the Information Commissioner Northern Territory
1800 005 610
https://infocomm.nt.gov.au
Ombudsman Tasmania
1800 001 170
www.ombudsman.tas.gov.au
Privacy Committee of South Australia
08 8204 8786
www.archives.sa.gov.au/content/contacting-privacycommittee-sa
Last update: July 2020
