Virtual-care PTY LTD Privacy Policy

1.1 Privacy Framework

As a company which provides healthcare patient management and other solutions to hospitals and other health service providers, Virtual-Care Pty Ltd ABN 96 646 283 445 (Virtual-Care) recognises the importance of privacy and is committed to the management and handling of Personal Information in an open and transparent way in compliance with the Privacy Laws. This policy creates a framework to ensure that any Personal Information Virtual-Care holds is collected, used, stored and disclosed in accordance with the Privacy Laws.

Virtual Care ensures that all Personal Information is held securely in accordance with this Privacy Policy and privacy laws and is treated with respect and care. You have the right to contact us to access or correct your Personal Information. We encourage you to contact us if you have questions or concerns about your privacy or how your Personal Information is handled by Virtual-Care.

In addition, Virtual-Care assesses whether the GDPR applies to any personal data it collects, processes or stores. Accordingly, please notify Virtual-Care in writing if you are currently, or in the future become, a resident of the European Union, so that Virtual-Care can assess whether any Personal Information it holds falls within the scope of the GDPR.

1.2 Scope

This Privacy Policy applies when you sign up for, access, or use Virtual-Care’s solutions and in relation to Personal Information we may otherwise collect during the course of our business as set out in this Privacy Policy. This also applies to you if you are a hospital patient or user of other medical services who obtain access to and use Virtual-Care applications via your healthcare service provider, even if you are not aware that the application was implemented or is serviced by Virtual-Care.

Virtual-Care may amend the Privacy Policy at any time, with effect from the time the updated version is posted on Virtual-Care’s website. This policy does not apply to the handling of Personal Information about Virtual-Care employees.

Virtual-Care may access, collect and hold information about individuals who may be customers, hospital patients, job applicants, business contacts and others. The information Virtual-Care typically collects, holds and processes is detailed below.

2.1 Customers and Potential Customers

  • Information obtained when you access Virtual-Care’s websites

  • Information obtained during sales calls and presentations, such as name, contact information, role/position details, summary of discussions

  • Hospital clinical users – name, gender, contact information, hospital department details, personal identification

  • Information used for customer identity verification such as full name, date of birth and which may also include, drivers’ license number and state of issue, passport number and country of issue, Medicare card details (card colour, card number, individual reference number, expiry date)

  • Customer contact details – work address, email, phone number

  • Responses to customer surveys

2.2 Hospital Patients

Virtual-Care will potentially obtain access to the following patient information in the course of providing support services to hospital customers. Further details of how this information may be used are detailed in section Access to Personal Information Through Hospital Operated Patient Management Systems below.

  • Full name

  • Gender

  • Contact information – residential address, phone and email

  • Information used for identification and verification such as full name, date of birth and which may also include, drivers’ license number and state of issue, passport number and country of issue, Medicare card details (card colour, card number, individual reference number, expiry date)

  • Date of birth

  • Vital statistics such as weight, height, blood pressure, blood glucose level, cholesterol, heart rate and other similar information

  • Workout and activity levels

  • Sleep data

  • Medical care plan

  • Medical information such as relevant disease states or clinical information

  • Medications

  • Medical care team members

  • Statistics regarding patient use of Clinical Apps

  • Responses to patient surveys

  • Details of communication with patient

2.3 Other Business Contacts

  • Name, business address, ABN

  • Contact information for relevant personnel, including telephone number(s) and email address(es)

  • Work, professional and employment references, reports and assessments

  • Information from public domain websites

  • Bank information for payment of invoices

  • Financial and other information obtained from credit checks and reports

  • Vaccination status for COVID-19 and/or other pandemics (for contractors)

2.4 Job Applicants

The types of Personal Information Virtual-Care collects from job applicants, including for both employment and contract positions, may include:

  • Employment history and qualifications

  • Contact information, including email address, phone number(s) and residential address

  • Opinions about suitability for employment from referees and previous employers

  • Taxation and banking details and superannuation fund details

  • Information from public domain and social media websites

  • Identification information, such as driver’s licence/passport details and date of birth

  • Confirmation of working rights (for non-Australian residents)

  • Vaccination status for COVID-19 and/or other pandemics

  • Police clearance, where required for customer facing roles employment purposes

Job applicants have the right to not disclose Personal Information, however Virtual-Care may not be able to assess a candidate’s suitability for employment when it does not receive all necessary information. Virtual-Care will only disclose the Personal Information of job applicants to third parties with the consent of the job applicant, or as otherwise permitted in limited circumstances by law. Once a position has been filled, all applications received by Virtual-Care are filed and kept in Virtual-Care’s human resources files. However, the following information, if previously collected, will not be retained for applicants who do not commence employment or a contract position with Virtual-Care: bank account details, driver’s licence/passport, Tax File Number, superannuation fund details, next of kin.

2.5 How Will Virtual-Care Collect Your Personal Information

Wherever possible, Virtual-Care will collect Personal Information about you directly from you. Nevertheless, on some occasions Virtual-Care may collect your Personal Information from other sources, such as:

  • Third party agents or data providers

  • Public domain websites on the Internet

  • Publicly available directories and listings

  • Newspapers, magazines, professional journals and the electronic media

  • The date, time and domain from which you access Virtual-Care’s website

  • Personal interactions and/or communications with Virtual-Care employees and/or contractors

Personal information about you which Virtual-Care collects and holds may vary depending on your particular interaction with Virtual-Care and will be for a legitimate business purpose. This may include financial and other Sensitive Information.

2.6 Collection of Your Personal Information Through Virtual-Care’s Website

Virtual-Care’s website may provide for direct input of Personal Information under some circumstances. In addition, Virtual-Care’s websites make use of ‘cookies’ which are small text files that are stored in the visitor's local browser cache. This enables recognition of the visitor's browser to optimise the website and simplify its use. Most browsers are set up to accept these cookies automatically, however you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. Data collected via cookies will not be used to determine the personal identity of the website visitor.

Virtual-Care collects non-personally-identifying information from web browsers and servers, such as the browser type, language preference, referring site, and the date and time of each visitor request. This assists Virtual-Care better understand how visitors use its website. Virtual-Care may release aggregated non-personally-identifying information and may use third-party services such as Google Analytics to collect and store this information.

Virtual-Care expects to increasingly makes use of web analytics, including analysis by third party service providers, which may use IP addresses. While this may in some circumstances be ‘Personal Information’ neither Virtual-Care nor the service providers have any interest in an individual’s browser activities and will not use the information to identify website visitors or take any action targeted to individuals without having obtained that person’s consent.

2.7 Access to Personal Information Through Hospital Operated Patient Management Systems

Virtual-Care will potentially obtain access to patient information in the course of providing support services to hospital customers using a patient health data management platform or other software or service licensed or provided by Virtual-Care. Patient information will not ordinarily be downloaded or retained by Virtual-Care, although a hospital customer may request that Virtual-Care run a patient or clinical report on behalf of the hospital, which could contain confidential patient information.

2.8 How Will Virtual-Care Hold and Use Your Personal Information

Virtual-Care may disclose information about you in the course of any of the uses described above, including to related businesses and third-party service providers for routine business purposes such as order collection, refund processing, marketing, data processing and validation, data storage or archiving, printing and mailing. Virtual-Care will use only reputable service providers and will ensure that it enters into appropriate contractual provisions with service providers to safeguard your privacy.

3.1 Overseas Recipients

Virtual-Care may transfer your Personal Information to Virtual-Care service providers located outside of Australia. Under these circumstances, your Personal Information will always be stored in a secure manner which is at least as robust as the practices followed by Virtual-Care in Australia.

In addition, the developers of software solutions provided by Virtual-Care in the Australian market may from time to time obtain access to Personal Information contained in these systems in the course of providing product support or updates. Some of these software vendors are based outside of Australia, and Personal Information may therefore be accessed by such persons outside of Australia. Whilst Virtual-Care has ensured that such parties have appropriate policies in place to ensure the protection of Personal Information, Virtual-Care does not take responsibility for the actions of these parties or their personnel.

3.2 European General Data Protection Regulation (GDPR)

If you are a European resident, Virtual-Care may be subject to GDPR in relation to Personal Information it holds about you. Accordingly, we request that you notify us if you are a European resident when you transfer your Personal Information to us or if you are aware that we are collecting your Personal Information. Your Personal Information will still be subjected to the same information security standards as are applied to all Personal Information held by Virtual-Care and its global affiliates. However, we may manage your Personal Information in a different manner to take account of data portability entitlements and other GDPR-specific requirements, as outlined in Virtual-Care’s Privacy Policy.

4.1 Data Security

Virtual-Care uses technical and organisational security precautions to protect your data from misuse, interference or loss and from unauthorised access, modification or disclosure. Virtual-Care’s CyberSecurity procedures are continuously revised based on new technological developments to ensure that any Personal Information that is provided to Virtual-Care by you through Virtual-Care’s systems will be protected against possible misuse by third parties. In the event of an actual or suspected data breach, Virtual-Care will follow the procedures outlined in its Mandatory Data Breach Response Plan, including

  • containing the data breach

  • conducting a risk assessment to assess the severity rating of a suspected or known data breach

  • assessing whether an Eligible Data Breach has occurred.

If an Eligible Data Breach has occurred, Virtual-Care may report the data breach to third parties as required by the Privacy Act, or to other Virtual-Care business partners or service providers. Virtual-Care will contact you if you have been personally impacted by an Eligible Data Breach.

4.2 Data Retention

Virtual-Care will maintain your Personal Information for as long as is necessary to fulfil the purposes for which it was collected and for additional legal purposes related to Virtual-Care’s legitimate business interests. If Virtual-Care becomes aware that you are a European resident, it will ensure that your personal data is kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Virtual-Care will delete from its records Personal Information which is no longer required.

4.3 Data Access and Correction

You may request access to Personal Information Virtual-Care holds about you at any time. If you believe your Personal Information is inaccurate, out of date, incomplete, irrelevant or misleading, you may request to have it corrected and/or supplemented.

Requests to access or correct Personal Information should be sent to the Privacy Officer. Please provide as much detail as possible to assist in the location of information Virtual-Care may be holding about you, such as your name, contact details, any former name(s), and if possible the context, for example, your relationship with Virtual-Care. Please specify if you are seeking access to specific Personal Information.

Virtual-Care will respond to your request within 30 days of receipt or within any further time notified to you in writing, or if you are a European resident, will correct any of your inaccurate personal data without undue delay. Virtual-Care will take reasonable steps to verify the identity of any person requesting access to or correction of their Personal Information to ensure that the person making the request is actually the data subject.

4.4 Deletion of Data

You may notify Virtual-Care at any time if you do not wish Virtual-Care to retain your Personal Information. Virtual-Care will comply with all such requests wherever practicable and lawful. Virtual-Care will take reasonable steps to verify the identity of any person requesting erasure of their Personal Information to ensure that the person making the request is actually the data subject. If you are a European resident, Virtual-Care will correct any of your inaccurate personal data without undue delay where the right to be forgotten applies.

5.1 Complaints

All complaints regarding your Personal Informational should be made in writing to Virtual-Care’s Privacy Officer. Virtual-Care will respond to your complaint within 30 days of receipt of your correspondence or within any further time notified to you in writing.

If you are not satisfied with the outcome of the response you receive, we can refer you to the Office of the Australian Information Commissioner (as applicable) for further investigation.

5.2 Privacy contact information

All requests relating to access, correction or deletion of Personal Information, or any other information relating to Virtual-Care’s Privacy Policy should be made in writing to:

The Privacy Officer
Virtual-Care Pty Ltd

Address: 8/41-43 Higginbotham Road, Gladesville, NSW, 2111

Email: info@virtual-care.com.au

Phone: +61 2 9098 4438

Terms and Definitions

Data Breach - An incident, in which Personal Information is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference.

Eligible Data Breach - A Data Breach which has caused serious harm to an individual or otherwise requires notification under Privacy Laws.

GDPR - The General Data Protection Regulation (EU).

Personal Information - Any information or an opinion about an identified individual, or an individual who is reasonably identifiable, as defined in the Privacy Act.

Privacy Act - Privacy Act 1988 (Cth).

Privacy Laws - Include:

    1. the Privacy Act;

    2. the Australian Privacy Principles contained in the Privacy Act;

    3. the GDPR, where relevant to Virtual-Care’s activities;

    4. any approved privacy codes that apply to Virtual-Care; and

    5. any other applicable laws that require a person to observe privacy or confidentiality obligations in respect of Personal Information,

in each case as amended from time to time;

Sensitive Information - Personal Information categorised as Sensitive Information under the Privacy Act, including but not limited to health records.