EQ Pathology

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Privacy Policy

 

1. Policy Statement

EQ Pathology Pty. Ltd. complies with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APP’s) and all relevant state-based health records and information privacy legislation.

EQ Pathology is committed to protecting all personal information. Our privacy policy and our practices and procedures are reviewed on a regular basis to ensure compliance.

This privacy policy (“policy”) explains:

  • what personal and sensitive information we collect;
  • how we collect personal and sensitive information and why;
  • how we use and disclose personal and sensitive information;
  • how we handle our website and internet links;
  • the security measures that we take;
  • the processes available to request access to or correction of your personal information or raise enquiries, concerns and make complaints; and
  • the process of breach notification.

This policy applies to the services and products provided by EQ Pathology and binds all our employees and health professionals. EQ Pathology employees are required to sign an agreement that includes a confidentiality clause on commencement of employment. EQ Pathology also expects its service providers to have a similar privacy policy in place.

2. What personal and sensitive information we collect

2.1 What is personal information?

Personal information is information or an opinion about someone we can identify or who we can reasonably identify from the information we have, whether it is true or not and whether it is recorded or not. It includes ‘sensitive information’ such as your information about your health (including in your health or medical record) as well as information about your racial or ethnic origin, political opinions, membership of political, professional or trade associations, or trade unions, religious beliefs, sexual orientation or practices and criminal record.

2.2 The kinds of personal information we collect

The personal information we collect about you depends on who you are and your interaction with us. As a provider of health solutions products and services, EQ Pathology may collect the following types of personal and sensitive information about you:

  • name and contact details;
  • financial and payment information;
  • health information including your medical history;
  • employment history and qualifications;
  • health insurance information and Medicare details;
  • details of your insurance claim or policy.

3. How we collect personal and sensitive information

We collect personal and sensitive information in many ways including when you:

  • call our Clinic or office or send EQ Pathology an email;
  • contact us as part of a health assessment;
  • contact us to receive medical consultancy;
  • are contacted and agree to a tele-interview;
  • consent to a third party, including medical service providers, insurers and EQ Pathology consultants, providing EQ Pathology with your information;
  • log in to and use the EQ Pathology website or submit an enquiry;
  • apply for employment at EQ Pathology;
  • provide services on our behalf.

4. Why we collect personal and sensitive information

EQ Pathology collects your personal and sensitive information to provide our services to you and/or provide information and services to our clients. EQ Pathology will only collect information that is necessary for these purposes.

5. Who we collect personal and sensitive information from

Where practicable, we will collect your personal information directly from you.

However, we may also need to collect information about you from others such as companies employing you, insurance companies, insurance brokers and financial planners, private medical insurers, financial institutions, medical or health service providers and other similar organisations that are permitted to share your personal information with us for the purposes of providing our services.

If we collect information about you from someone else we will, whenever possible, make you aware of this.

6. How we use and disclose personal and sensitive information

6.1 Uses of personal information
EQ Pathology will use your personal and sensitive information to provide you with services and products that:

  • you purchase;
  • are purchased by your employer or your relative’s employer;
  • are purchased by your health insurer or are part of a service provided through your health insurer;
  • are part of a service provided through an insurance company, insurance broker or financial planner; or
  • are part of your employment (eg: training or medical assessments).

EQ Pathology will also use your personal and sensitive information:

  • to respond to complaints, access and correction requests;
  • for purposes related to the primary purpose for which we collected the information that you would reasonably expect;
  • to comply with an Australian court/tribunal order or where required or authorised by law.

6.2 Disclosures of personal information
EQ Pathology will disclose your personal and sensitive information to third parties where:

  • you consented to the disclosure e.g. for a pre-employment medical assessment or fitness for duties assessment or for the purpose of purchasing a risk insurance policy or making a claim; or
  • the disclosure is necessary because you are at risk of harm without treatment and you are unable to give consent (eg. you might be unconscious after an accident); or
  • your health service provider is legally obliged to disclose the information (e.g. notification of certain infectious diseases or suspected child abuse, or a subpoena or court order); or
  • the information is necessary to obtain Medicare payments or other health insurance rebates; or
  • otherwise required or authorised by or under an Australian law or court/tribunal order.

6.3 Overseas disclosures of personal information
EQ Pathology will disclose your personal and sensitive information overseas only if required for the purposes of providing you with the services and products that:

  • you purchase;
  • are purchased by your employer or your relative’s employer;
  • are purchased by your health insurer or are part of a service provided through your health insurer;
  • are part of a service provided through an insurance company, insurance broker or financial planner; or
  • are part of your employment (eg: training or medical assessments).

7. Your online activity

The EQ Pathology website may contain links to other websites. These are provided as a convenience to you and not as an endorsement by EQ Pathology of the contents of other websites.

The EQ Pathology website uses cookies to identify a user session and collect information about activity on the website. A cookie is a piece of data stored on your hard drive containing information about you. EQ Pathology does not make any attempt to identify you from the cookie data collected.

Most browsers are initially set up to accept cookies. Though most cookies expire after a certain period of time, you can choose to delete a cookie file at any time. You can do so by resetting your browser to refuse all cookies or to indicate when a cookie is sent. However, some EQ Pathology features or services may not function properly without cookies.

8. Information Security

EQ Pathology has an Information Security Policy, that provides the organisational commitment to protect your information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

To deliver on the commitments of the Information Security Policy, EQ Pathology has implemented an Information Security Management System to meet the requirements of a Certifiable International Standard. Based on the standard, a layered set of controls have been implemented covering people, processes, technology and facility within a continuous improvement environment.

8.1 How long do we keep health records for 
In the case of information that forms part of a health or medical record, your information will be held for at least seven years from the last time a health service was provided, in accordance with the Health Records Act. If someone under the age of 18 used the health service, the information will be held at least until that person has turned 25.

EQ Pathology destroys or de-identify personal information we no longer need or are required to keep for any business or legal purpose, wherever possible.

9. Access and Correction

9.1 Access
You are entitled to access the personal information EQ Pathology holds about you.

9.1.1 Procedure
The procedure for requesting access is as follows:

  • A written request must be made by email or post to the Privacy Officer at the details below.
  • Please provide as much detail as possible regarding what information you require access to, including the person to whom the information has been provided, and when.
  • EQ Pathology will acknowledge your request within 14 days and providing EQ Pathology has the personal information requested, access should usually be granted within 14 days. EQ Pathology will inform you if this timeframe is not achievable in the particular circumstances.
  • You will be asked to verify your identity.
  • A fee may be charged to cover EQ Pathology’s reasonable costs of providing access in the event that the request is onerous or time consuming.
  • We will endeavour to provide you with access in the manner requested, however in some circumstances the nature of the information or the record it is contained in may mean that we can only provide you with access in a particular manner. Depending on the circumstances, this may be by mail, email, or you may personally be given access to inspect the information.

9.1.2 Can my request be refused?
In some circumstances, EQ Pathology may not be in a position to provide you access.

If access is refused to some or all of the information, our reasons will be provided to you in writing with details of the complaint mechanisms available to you if you are not satisfied with our decision.

If EQ Pathology has collected your personal information on behalf of a third party, we recommend that you approach the third party directly for access to your information.

9.2 Correction
If your details change, or you believe that your personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, you can request correction by contacting the Privacy Officer on the details below.
If EQ Pathology is satisfied that your information needs correcting or if you make a request, EQ Pathology will take reasonable steps to amend that information. EQ Pathology will need to verify your identity first.

9.3 Can my request be refused?
If we refuse to correct all or part of your information, reasons will be provided in writing with details of the complaint mechanisms available to you if you are not satisfied with our decision.

If EQ Pathology does not make the correction and, if you request, EQ Pathology will take reasonable steps to associate with the record of that personal information a statement that you believe the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, as applicable.

10. How we manage a Privacy Breach

As required by the Privacy Amendment (Notifiable Data Breaches) Act 2017, EQ Pathology has developed a data breach response plan that sets out the steps that EQ Pathology will follow when it becomes aware or suspects that a data breach has occurred.

The EQ Pathology Privacy Officer must be notified of the breach or potential in the first instance. Where it is considered that a data breach is likely to result in serious harm to any of the individuals whose information is involved we will notify those individuals who are at risk of serious harm and will prepare a statement for the Privacy Commissioner in an appropriate form.

10.1 What is a Data Breach?

A data breach is when personal information held by EQ Pathology is lost or subjected to unauthorised access, modification, disclosure or other misuse or interference.

11. Complaints resolution

EQ Pathology has a designated Privacy Officer. If at any time you have a privacy related issue or wish to make a complaint, please contact our Privacy Officer on the details below.

11.1 The complaints procedure
You should put any complaint you have in writing and give as much detail as you can about the nature of your complaint and the information affected.

The Privacy Officer will manage the investigation of your complaint or concern and communicate with relevant parties. EQ Pathology will respond to you within a reasonable period, which will generally be within 30 days of receiving your complaint.

11.2 External review
If you are not satisfied with our resolution of your complaint, you can contact the Privacy Commissioner’s Office on 1300 363 992 or go to their website at www.oaic.gov.au to enquire about your privacy rights or to lodge a complaint about how we have handled your personal information. The Privacy Commissioner has the power to investigate the matter and make a determination.

12. EQ Pathology Contact Details

For all privacy related inquiries and complaints and for access and information requests, please contact the Privacy Officer on the following details:

Address:  Level 4, 80 Market Street, SOUTH MELBOURNE
Telephone:  1300 891 368
Email:  enquiries@eqpathology.com.au

13. Changes to this policy
EQ Pathology may amend and update this policy from time to time to reflect changes to our practices and procedures, systems or obligations. Any amendments to this policy will be notified by posting an amended version on our website, and the changes will take effect at that time.

This policy was last updated on June 24, 2019.