PRIVACY POLICY
1. We respect your Privacy
We are committed to managing your Personal Information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable State and Territory privacy laws.
This Privacy Policy sets out how we handle your Personal Information, including the collection, storage, use and disclosure of your Personal Information, how you can access and correct the Personal Information that we hold about you, provide us with feedback or make a complaint.
When you contact us, visit our Website, apply to become a registered user of our Website, or participate in consultations with Practitioners facilitated via the Website, you agree to the handling of your Personal Information in accordance with this Privacy Policy.
In this Privacy Policy:
(a) “Canwell”, "we" and "us" refers to Canwell Australia Pty Ltd (ACN 650 184 795);
(b) Personal Information has the meaning that it is given under the Privacy Act, namely, information or an opinion, whether true or not, and whether recorded in material form or not, about an individual whose identity is apparent or can be reasonably ascertained from the information or opinion;
(c) Practitioner means a health practitioner that is registered with the Australian Health Practitioner Regulation Agency (AHRPA) and provides consultation services using the Website;
(d) Patient refers to individual users of the Website in accordance with the Canwell Website Terms and Conditions;
(e) Website refers to our website at the domain www.canwellaustralia.com.au; and
(f) you refers to any Patient or individual who shares Personal Information with us via the Website. In the case of a Patient who is under 18 years of age, 'you' refers to the Patient's authorised carer, parent or guardian (as appropriate).
2. Collection of your Personal Information
2.1 The types of Personal Information we collect
The amount and type of Personal Information that we collect from you will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
When you sign up as a Patient of the Website, a record is made which includes your Personal Information.
When you have a consultation with a Practitioner facilitated via the Website, the Practitioner may also collect health information, medical and medication history from you and any other information the Practitioner deems necessary to assess and deliver the service to you. This information may be considered to be sensitive information under the Privacy Act and will be managed in accordance with this Privacy Policy.
3. Collection of your Personal Information?
3.1 How do we collect your Personal Information?
We will collect your Personal Information directly from you or from Practitioners who provide health services to you through the Website.
We may collect your Personal Information in a range of ways, including:
(a) forms that you complete and submit to us to register as a Patient;
(b) when you request an online booking with a Practitioner via the Website;
(c) in correspondence with you (whether in writing or electronically via telephone or using video conferencing technology);
(d) during the course of your consultation with a Practitioner;
(e) when conducting customer satisfaction and market research surveys;
(f) when conducting promotions; and
(g) when you liaise with our customer support team. We and the Practitioner will only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act.
3.2. Request for anonymity and refusal to provide Personal Information
You can always decline to give us or a Practitioner any Personal Information we request or to remain anonymous or use a pseudonym in your dealings with us or the Practitioner. However, that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about Personal Information requested by us or a Practitioner, please let us know. Our contact details are provided in section 7 below.
You may visit our Website without identifying yourself. If you do identify yourself (for example, by providing your Personal Information in registering to be a Patient or make an appointment with a Practitioner via the Website), any Personal Information you provide to Canwell will be managed in accordance with this Privacy Policy.
3.3 Online data collection and use
Our Website uses cookies. A “cookie” is a small text file stored on your computer's browser, which assists in managing customised settings of the Website and delivering content. We may use cookies from time to time to collect non-personal information such as:
(a) your device type;
(b) your browser type;
(c) your IP address;
(d) your operating system;
(e) pages you have accessed on our Website and on third-party websites immediately before and after visiting our Website;
(f) peak usage times; and
(g) other information that helps us make our Website easier and more efficient for you to use.
You are not identifiable from such information. This information is used for Website analysis, administration, statistical and maintenance purposes.
You can adjust the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our Website.
3.4. Third Party Websites
Our Website may contain links to third-party websites not owned or controlled by us. These links are provided for your convenience only. Canwell is not responsible for the content or privacy practices of any such websites that are linked to our Website. We encourage you to read and familiarise yourself with the privacy policies of every website you visit.
Canwell uses Google analytics to monitor the visitors to our Website. Based on your interactions with our Website, Google and third-party sites may elect to show you content and advertising that directs back to our Website.
4. Use and disclosure of your Personal Information
We treat your Personal Information as strictly private and confidential.
4.1 How do we use your Personal Information?
The purposes for which Canwell collects and uses your Personal Information depends on the nature of your interaction with us and the services we are providing to you, but may include:
(a) for purposes directly related to your care and treatment by a Practitioner who provides you with health services via the Website;
(b) facilitating appointments with a Practitioner via the Website;
(c) responding to your requests for information, general inquiries and complaints;
(d) contacting you and maintaining records of your interactions with us and a Practitioner;
(e) informing you about new and additional services and product offerings available via our Website;
(f) for administrative purposes associated with providing remote consulting services including training and reporting statistical information about our services; and
(g) to comply with any legislation or regulations as required.
4.2 Who do we disclose your Personal Information to?
Access to your Personal Information will be restricted to those persons who require access in order to deliver our services to you and who have been properly authorised.
The Personal Information collected at the time of applying to become a Patient and/or making a booking with a Practitioner via the Website, will be made available to any Practitioner that consults with you via the Website.
Canwell may be required to disclose your Personal Information to third parties where necessary to complete a request from you or carry out a service. Examples include:
We may also disclose your Personal Information to third parties for research purposes, however this will always be in an aggregated and de-identified format.
4.3 Does Canwell disclose your Personal Information overseas?
We do not disclose or store your Personal Information overseas.
If our data handling practices change and your Personal Information is intended to be sent outside of Australia, we will require your consent before doing so and will only disclose your Personal Information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your Personal Information. We will, where practicable, advise you of the countries in which any overseas recipients are likely to be located.
4.4. Does Canwell use or disclose your Personal Information for direct marketing?
Canwell may use or disclose your Personal Information for the purpose of informing you about our services, product offerings via our Website, upcoming promotions and events that are directly related to the purpose for which we collected your Personal Information. If you do not want to receive direct marketing communications from us, you can opt-out at any time by contacting us using the contact details in section 7 below or using the unsubscribe function in any communication that you receive.
If you opt-out of receiving marketing material from us, Canwell may still contact you in relation to its ongoing relationship with you.
We will not disclose your Personal Information to third parties for marketing purposes without your consent.
5. Security and storage of your Personal Information
We take reasonable steps to ensure that your Personal Information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure. This includes by maintaining:
(a) physical security over any paper-based and electronic data, such as through locks and security systems at our premises and secure databases (including trusted third-party storage providers located in Australia); and
(b) computer and network security, for example, we use firewalls, password protected secure system access and data encryption.
The Website is hosted in Australia. If you use the Website or our services from outside Australia, you are voluntarily transferring content (potentially including personally identifiable and health information) to Australia and agreeing that Canwell's collection, use, storage and sharing of that content is exclusively subject to the laws of Australia rather than the laws of the country in which you are located. If you choose to provide Canwell with Personal Information, you are consenting to the collection, use and disclosure of that information and to the transfer of that information to our servers in Australia.
Transmission and exchange of Personal Information with us or a Practitioner is at your own risk. We cannot guarantee the security of any information that you transmit to us or a Practitioner, or receive from us or a Practitioner.
We will retain your Personal Information for as long as it is required to provide you with our services and to comply with legal requirements. If we no longer require your Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify your Personal Information.
6. How can you access or seek correction of your Personal Information?
You are entitled to request access to, and correction of, your Personal Information that we hold about you at any time. To do so, please contact us using the contact details set out in section 7 below.
6.1 Your right to access your Personal Information
We will always endeavour to meet your request for access within a reasonable time and in the manner requested by you, if it is reasonable to do so. However, in some circumstances we may decline a request for access. If we decline your request for access, we will give you written reasons for our decision when we respond to your request. If you have any concerns about the refusal, please see section 7 below.
We reserve the right to charge you an administrative fee for access to some types of Personal Information that we hold about you, including for example the preparation and copying of medical files. These charges will be limited to the cost of recouping our expenses for providing you with the requested information.
6.2 Correcting your Personal Information
We will take reasonable steps to ensure that the Personal Information we hold about you is accurate, complete and up-to-date at the time of collecting, using or disclosing the information. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change. We will respond to your request within a reasonable period and take reasonable steps to amend our records. In the event that we disagree with the changes you have requested to your Personal Information, we will give you written reasons for our decision and notate your records that you disagree with our decision.
7. How to Contact us
You may contact Canwell at any time if you have any questions or concerns about this document, or about the way in which your Personal Information is handled. Please direct all correspondence to:
Mail: Canwell Australia, 'The Hub', Level 1, 2 Loraine Street, Capalaba, QLD 4257
Email: [email protected]
We take all enquiries and complaints seriously. We endeavor to investigate and respond to any complaint within 30 days of receipt. If the matter is more complex or our investigation may take longer, we will let you know. If you are not satisfied with our handling of your complaint, you may contact the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992, by email [email protected] or by using the contact details on the OAIC website.
8. How are changes made to this Privacy Policy?
Canwell may amend this Privacy Policy from time to time to reflect our current data collection and disclosure practices, with or without notice to you. The most recent version of our Privacy Policy is available on our Website. We recommend that you visit our Website regularly to keep up to date with any changes to this Privacy Policy.
This Privacy Policy was last updated in July 2021.