Introduction
This privacy policy (Privacy Policy) explains how Gullucks Pty Ltd t/a IndiDoc (ABN 43671310517) and our related entities (IndiDoc, we, us or our) handle and manage your personal information we collect about you as a:
Partners/Doctors, hospital or clinical staff (including alternate medicine practitioners) or other medical/health professional (Clinician) using or interested in using our tele health software (Platform) and/or referring health information to us;
Patient and/or health practitioner using the Platform (Patient);
Visitor to our website accessible at the domain https://indidoc.com.au/ (Website)
Contracted service provider, business partner or health professional, alternate medical specialist, hospital.
We are bound by and adhere to the Privacy Act 1988 (Cth), relevant State Privacy Laws and the Australian Privacy Principles under that Act (Privacy Act) and this Privacy Policy.
By registering to use the Platform, visiting the Website, using any of our services or otherwise providing us with any personal information you agree that you are 18 years of age or older and consent to our collection, use, holding and disclosure of your personal information in accordance with and as set out in this Privacy Policy.
If you are under 18 years of age, we will only permit you to use this Website and the Services if we receive the consent of your legal guardian and/or parent to you using this Website and the Services and agree to the Terms of Service on your behalf. We will keep all information you provide to us confidential and secure at all times. However, we may provide your confidential information to a third party in the following circumstances:
- if disclosure is required by Law or ordered by a court
- if we identify or are advised of an imminent threat of harm to yourself or another person
- if you (or your parent or legal guardian if you are under 18 years of age) have given express permission for us to discuss or provide your information to another person
- if disclosure of your personal information is to that third party (e.g your Doctor) for a purpose which is directly related to the primary purpose for which your personal information was collected (e.g., if you decide to change specialist doctors, your clinical file comprising notes of and information regarding your sessions will be shared with the new specialist as part of your clinical file. Your clinical records are kept confidential and are accessible only to authorised individuals involved in your consultation).
PROVIDING OTHER PEOPLE’S PERSONAL INFORMATION
If you (whether as a Referring Health Professional, which is defined below, or otherwise) provide us with the personal information (including sensitive information) of another individual (e.g., a Patient), you warrant that you have complied with your obligations under the Privacy Act and relevant State and Territory legislation relating to the collection and disclosure to us of personal information, sensitive information and health records and have obtained the individual’s prior consent: (i) for you to disclose such to us; and (ii) to our collection, holding, use and disclosure of their personal information in accordance with this Privacy Policy.
DEFINITIONS
All terms used in this Privacy Policy that are defined in the Privacy Act have the meanings given to them in the Privacy Act.
WHAT PERSONAL INFORMATION WE COLLECT, WHEN AND HOW
For Patients
- General information such as your name, location, date of birth, gender, Medicare details, family details including marital status, contact information (including your email address, telephone and fax number, residential, business and postal addresses), your registration details for the Platform, and details of your use of, or access to, the Platform
- Health information such as information about your health, the health services which have been or are to be provided to you, or other information which falls within the scope of ‘health information’ as that term is defined in the Privacy Act. Some common examples of the types of health information we might collect include: details of your appointments booked, confirmed or cancelled; the content of other communications or interactions you and your Practice have via the Platform; information contained in a digital form you complete via our Platform; information about any prescriptions you seek to fulfil
- Other ‘sensitive information’ as that term is defined in the Privacy Act (excluding health information, which is addressed above), such as information which might relate to, among other things, your racial or ethnic origin, sexual orientation or practices, criminal record or religious or philosophical beliefs. We will only collect this type of information if you provide it to us directly
- If you use our location-based appointment search functionality, the approximate location information you submit to the Platform or share from your device
- If you use our ‘check-in’ functionality, your location information at the time you check in to the relevant Practice (though this will only be captured if you allow it on your device’s settings)
- If you process a payment or other financial transaction with your Practice via the Platform, general details of that transaction (including a record), however credit card information will be held by a secure payment provider to ensure it is kept safe. We don’t see your full credit card number, nor do we store it, though we do have the ability to transact on your behalf to enable payment processing only
- If you use or access our Platform (including the website), aggregated statistical information such as information about your online preferences and movements, and other information which is typically obtained from cookies (although you can adjust your browser’s settings to accept or reject cookies). If you are an unregistered user, this statistical information will be collected on an anonymised basis only. If you are a registered user, this statistical information may in some circumstances be collected on an identifiable basis
- Any other Personal Information you send or disclose to us, including our records of any communications or interactions we have with you
For Partners/Doctors
We collect and hold personal information about individuals and individuals at businesses who supply their specialist services to Gulluck Pty ltd t/a IndiDoc and other individuals to facilitate our business activities and carry out our services.
Most Personal Information we collect about you will be received from you directly, your patients or potential patients, or the Practice that employs or otherwise engages you. However, and depending on the nature of your relationship (or potential relationship) with us, we may also collect your Personal Information from other sources such as advertising, public records, mailing lists, contractors, our staff and our business partners. We may also display online reviews of Practices on the Platform, which may refer to you personally (although we do not host or store this information)
The types of Personal Information we may collect about you include
- General information such as your name, location, date of birth, contact information (including your email address, telephone and fax number, residential, business and postal addresses), your log-in details for the Platform, and details of your use of, or access to, the Platform
- Financial information such as any of your bank or credit card details used to transact with us, or other financial information that allows us to transact with you or provide you with our services
- Details of any communications or interactions you have with a patient using the Platform – for example, details of an appointment with you that is managed using the Platform (and any related communications)
- As relevant to your relationship with us, information about your online preferences and movements, location information, trends, decisions and other information which is typically obtained from cookies (although you can adjust your browser’s settings to accept or reject cookies), and other information about your preferences and purchases in relation to our products/website
- Information about your professional registration, credentials and experience, associations or memberships, or any other information that you or your Practice provide about you to be published on your profile or listing
- Any other Personal Information you send or disclose to us, including our records of any communications or interactions we have with you
For Visitors
As a Visitor we collect your personal information (such as your name, email address and phone number) if/when you provide it to us on the Website. We also use cookies on our Website, which are discussed below.
For everyone
We may also collect personal information about you via third parties including from our suppliers, merchants, direct mail, exhibition and trade events or online marketing.
If you use or access our Platform or website, or receive subscription email communications from us, we may collect statistical information using cookies or analytical services (although you can adjust your browser’s setting to accept or reject cookies), or by using pixel tags, which enable us to send email messages in a format customers can read and they tell us whether mail has been opened. If you are an unregistered user, this statistical information will be collected on an anonymised basis only. If you are a registered user, this statistical information may in some circumstances be collected on an identifiable basis
If you choose not to provide your personal information to us, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.
HOW WE USE YOUR PERSONAL INFORMATION
For Partners/Doctors/Specialists (including Referring Health Professionals)
We use the personal information that we collect about you for the purpose of managing our relationship with and providing the Platform and associated services to you, including:
- To provide you with a trial of the Platform and associated services
- To provide support and helpdesk services
- To analyse and improve the Platform and other services we provide
- To provide you with a Health Professional account
- To manage your Health Professional account, including invoices and payments, collecting overdue amounts, and managing fraud and risks
For Patients – Product/service development
If we wish to undertake any research product/service development or to improve our software using your data we will de-identify your personal information and, only once de-identified, use the resulting de-identified datasets for such. When we say de-identify, as regards the Information Package, we mean that we will permanently delete or permanently de-identify all unique individual identifying information. Once de-identified, not even your Referring Health Professional (nor anyone else) will be able to look up who the de-identified information relates to via any identifying information (as this will have been de-identified or removed). We have controls in place to ensure that the data is truly de-identified and cannot be re-identified prior to our use for these purposes.
Occasionally we may use or share de-identified information with research institutions/bodies for academic and clinical research purposes but will only do so under strict contractual obligations governing their use of the de-identified data and prohibiting re-identification.
For Visitors
We use your personal information for the purposes set out in this Privacy Policy and for which you provide it to us as a Visitor. If you subscribe to our mailing list, we will use your contact details to provide you with news and updates about our company and our activities. If you send us a query via our Website, we will use your personal information to reply to your query.
We may also use your personal information to:
- Personalise and customise your experiences on our Website
- Help us research the needs of our customers
Personal information may be collected by using “cookies” on our website. Cookies are small text files that a website can use to recognise Visitors who revisit our website to facilitate their ongoing access to and use of the Website. They enable usage behaviour to be tracked and aggregate data to be compiled to facilitate more informative content on our website. Typically, cookies involve the assigning of a unique number to the Visitor. You can prevent the use of cookies by setting up your web browser to block them.
For Partners
If you are a Partner we will use your personal information for our business and service dealings with you, including to contact you in relation to products or services we are ordering or receiving from you and to provide you with information, products or services you have requested.
For everyone
We may also use the personal information we collect about you
- To notify relevant organisations (such as medical insurers and/or legal advisors) of an incident/accident, including when a claim is made against Gullucks Pty Ltd t/a IndiDoc
- To undertake quality assurance activities, customer satisfaction surveys, statistical analysis and complaint handling
- To conduct research for the purposes of improving existing products or services or creating new products or services
- To provide you with ongoing information about us and our activities
- To allow us to provide third party information and offers in which we believe you may be interested
- To use aggregated or de-identified information for the purposes of data analysis, research and reporting
- For other purposes as required or authorised by law
SHARING YOUR PERSONAL INFORMATION (DISCLOSURE)
For Patients
As a Patient, Gullucks Pty Ltd t/a IndiDoc will share your personal and health information with:
- Your Referring Health Professional(s), employees and other health professionals in your Referring Health Professional’s clinic or hospital where they are working and any other health professional that your Referring Health Professional has asked us to share your personal information with
- Support team members for the purpose of completing billing, managing appointment bookings, resolving service issues, etc
- Overseas entities for the purpose of data entry into Gullucks Pty Ltd t/a IndiDoc platforms, resolving service requests, managing appointments, billing, etc (in accordance with their respective privacy policies)
- Between our group companies and verified consultant medical specialists or other registered health professionals involved in your ongoing health care who have been requested to provide further advice on your medical condition
For Visitors
We may disclose your personal information to our Website host or service providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner. To the extent that we do share your personal information with a service provider, we would only do so if that party has agreed to comply with its obligations under the Privacy Act or our privacy standards as described in this Privacy Policy.
For everyone
We may share your personal information:
- With our professional advisers (such as auditors and legal advisers)
- With Gullucks Pty ltd t/a IndiDoc related bodies corporate within our corporate group structure
- For other purposes as required or authorised by law
Gullucks Pty ltd t/a IndiDoc will use personal information to carry out evaluations of our service quality and timeliness, internally. If we require other parties to assist us with these activities, we will provide de-identified information to these other parties.
You can contact the Gullucks Pty ltd t/a IndiDoc Privacy Officer at the contact details below if you have any questions about the disclosure of your personal information
MARKETING COMMUNICATIONS
For Clinicians (including Referring Health Professionals)
If you are a Clinician/Referring Health Professional, we may use your personal information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your personal information from a third party. Direct marketing material may include promotional material about us or the products or services we offer.
We do not sell your personal information to third parties for marketing purposes.You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials.
ACCESS TO AND CORRECTION OF YOUR INFORMATION
For everyone
You may request access to personal information we hold about you, including reports of any mental health services provided by Gullucks Pty ltd t/a IndiDoc. If you ask for a copy of a report of any mental health services provided by Gullucks Pty ltd t/a IndiDoc, we may request personal information (such as your requesting doctor, date of birth, mobile number or email address) from you to verify your identity before providing the requested information. In some instances, charges may apply to provide copies. We will tell you about any costs before they are incurred. In some limited circumstances we may refuse your request but will provide you with our reasons. You may complain about our refusal (see ‘Complaints’ section below).
Gullucks Pty ltd t/a IndiDoc endeavours to ensure that the personal information we collect, use and disclose is accurate, up-to-date and complete. The accuracy and completeness of that information depends on the information you provide to us. Please let us know if there are any errors in the information we hold and of any changes to your information (such as your name, address, phone number or Medicare number)
DATA SECURITY
We take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Records are held securely for future retrieval in accordance with applicable laws and good business practice. If Gullucks Pty ltd t/a IndiDoc no longer needs, or is no longer required, to retain Personal Information, Gullucks Pty ltd t/a IndiDoc will destroy or de-identify your personal information.
In particular, we have security controls in place with our cloud provider including redundancy protection and monitoring, strict access controls, in-transit and at-rest encryption and industry-standard authentication protocols. We also have a Data Breach Response Plan (DBRP) which identifies and explains the specific responsibilities and actions employees are required to take when a breach occurs.
INFORMATION WE RETAIN
Your personal information is retained in order to document what happens during sessions and enables the Service Provider to provide a relevant and informed Service to you. When you first contact Gullucks Pty ltd t/a IndiDoc (either by phone, email or through the platform), you will generally provide information like your name, phone number, address, Medicare and payment details. You may also provide some background information relating to your need for the Services. This information is held in our secure database and, if you proceed to make a booking, will be made available to your Service Provider.
NOTICES
We may provide notices or other communications to you regarding this agreement or any aspect of the website, by Text to the Text number that we have on record, by Email to the email address that we have on record or via the client portal in the Gullucks Pty ltd t/a IndiDoc platform. The date of receipt shall be deemed the date on which such notice is given.
COMPLAINTS
If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy Policy, the APPs and/or the Privacy Act in respect of your personal information, or for any other queries, problems, complaints or communication in relation to this Privacy Policy, please send your complaint to the Gullucks Pty ltd t/a IndiDoc at the address below. The complaint will be investigated, and a response will be sent to you as quickly as possible (generally within 30 days of our receipt of your complaint). If you are not satisfied with the response, you can contact the Office of the Australian Information Commissioner (OAIC).
CHANGES TO THE POLICY
- From time to time, we may need to change this Privacy Policy, without notice. If we do, we will post the updated Privacy Policy on our website.
- You should review this Privacy Policy from time to time to review any changes. Any revised Privacy Policy, once published on our website, will apply to all Personal Information that is handled by us.
