RelationSpace Digital Services Pty Ltd and each of its related entities (together RelationSpace Online, we, us, our) understand our users’ concern about the privacy of their information when collected by us.
We are dedicated to protecting the confidentiality and security of the Personal Information which we collect about our users and do so in accordance with the Privacy Act 1988 (including the Australian Privacy Principles (APP’s)). This dedication extends to information or opinions that are collected about an individual in circumstances where their identity can reasonably be determined.
Any questions about the general privacy principles may be directed to the office of the Australian information Commissioner whose website details are: www.oaic.gov.au.
1. Types of Information
Personal Information means any information (or an opinion) about you from which your identity is apparent, or can be reasonably ascertained. This includes most information that is stored with or linked to your name, address, or other identifying features. Personal information may also include Sensitive Information.
Sensitive Information is a subset of Personal Information and includes (but not limited to) information relating to your race, religion, political opinions, sexual preferences, and health information.
2. Open and Transparent Policies (APP 1)
We have and will continue to take all reasonable steps to implement and maintain practices, procedures and systems to ensure that we comply with all our obligations under the Privacy Act. Do not hesitate to contact us if you have any questions about this policy or any matters arising from it.
3. Anonymity and Pseudonymity
You may not wish to identify yourself or you may wish to use a pseudonym and this is an option provided that this does not make it impractical for us to deal with you.
Please Note that it will generally be impractical for you to deal with us anonymously or under a pseudonym:
if you have agreed to obtain our services as part of a referral from a health professional, or a Court or Tribunal. The reason for this is because you (or us) may need to confirm your participation in our services and/or provide the health professional, Court or Tribunal with the information you provide to us, if it required by law that we do so, or
you wish to enter into a contract with us. The reason for this is because your identity is a relevant factor creating a legally binding arrangement. It is material to our decision of whether or not to enter into agreements with you.
4. Collection of Information (APP 3 & 4)
4.1. Personal Information (APP 3)
The sort of Personal Information we collect may include:-
your contact information; and
all other Personal Information that is necessary to provide you with adequate services.
We only collect Personal Information that is reasonably necessary for us to carry out the services that we offer to you, and to ensure that we comply with all laws in relation to the provision of our goods and services. This may include Sensitive information.
4.2. Sensitive Information
The sort of Sensitive Information we collect may include:-
your health/medical history;
your family health/medical history;
your ethnic background;
information about your current lifestyle;
any criminal convictions;
any religious or political affiliations; and
any other Sensitive Information that is necessary to provide you with adequate services.
Sensitive Information will only be collected where it is reasonably necessary to perform our functions and, if we choose to collect Sensitive Information, we will seek your express written consent in advance.
Collection of such Sensitive Information is done in accordance with the Australian Privacy Principles.
5. How We Collect Information (APP 5)
RelationSpace Online collects information:
directly from you when you provide information (such as an email address and personal details) on our website or input into any of our software programs, including, but not limited to, the information provided on your registration form;
information collected and collated from publicly available sources, including search engines, websites, social media, publicly available data bases, third party sources and referees, personal contacts and industry connections;
A cookie is a small file of letters and numbers downloaded on to a device when the user accesses certain websites. A cookie will allow a website to recognise a user’s device. A cookie will contain the name of internet location (the domain) from which the cookie has come and the lifetime of the cookie (a cookie will usually expire after a certain period of time).
Two types of cookies may be used on our website:
Session cookies which are temporary cookies that remain in the cookie file of your browser until you leave the site; and
Persistent cookies which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
We may use session cookies to allow you to carry information across pages of our site and avoid having to re-enter information.
We may use persistent cookies:
From time to time to help us recognise you as a unique visitor when you return to our website and to monitor your use of our website;
To allow us to link you to any of our Partners of Affiliates should you come to our website through a paid advert or banner on a website of an Affiliate or Partner.
Use of Web Beacons
Some of our web pages may contain web beacons which allow us to count users who have visited these pages. Web beacons collect only limited information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These beacons do not carry any personally identifiable information and are used to track the effectiveness of a particular marketing campaign.
6. Third Party Collection of Information (APP 5)
6.1. Types of Third Party Information
On occasion, we may need to collect information from a third party source to ensure that we are fully informed in relation to the issues that we need to address in order to provide you with our services. This may include:
any person or organisation that assesses health status or care requirements;
health providers or facilities;
your legal representative or a Court or Tribunal;
health practitioner of the client or resident; and
family members or next of kin.
6.2. Need for Consent for Collection of Third Party Information
Collection of information from a third party source will only be conducted if:
you have provided consent for RelationSpace Online to collect your information from a third party source; or
we are authorised by law to collect the information from someone else; or
it is not reasonable or practical for us to collect this information directly from you. This may include a situation where your health is at risk and your Personal Information is needed to provide you with emergency medical treatment.
Upon the engagement of our services, you should identify any parties to whom you do not wish to provide your Personal Information or from whom you do not wish your Personal Information to be accessed.
7. Why We Collect Information and How We Use Information (APP 5)
7.1. Use of Information
We collect and use information for business purposes with respect to our products and services and other business relations involving our users. We gather this information by lawful and fair means without being unreasonable or intrusive. We may use this information to:-
identify you and to assist you to access our relevant services more easily;
consider any application you may make and provide or change the services you require,
administer and manage those services, including charging, billing and collecting debts;
gain an understanding of your information and needs in order for us to provide you with better, more personalised services that are tailored to your requirements;
inform you of ways the services provided to you could be improved;
conduct appropriate checks for fraud and creditworthiness;
research and develop our services using third party services;
maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
inform you of matters about which we believe you may have an interest;
assist statistical, actuarial or research analysis as we consider is necessary for business, professional or academic purposes.
notify you of our service offerings from time to time; and
comply with legislative and regulatory requirements.
7.2 Disclosure of Information
Unless we are required to provide your Personal Information to others by law, by court order or to investigate suspected fraud or other unlawful activity, your information will only be seen or used by persons working in or for RelationSpace Online on a need to know basis. In saying that, we may disclose Personal Information (including Sensitive Information if necessary):
To your legal representative or a health professional with your consent;
To a Court or Tribunal who has referred or directed your participation in our services and where required by law;
De-identified information may be disclosed to researchers or academics for the purposes of statistical analysis or use in academic reports or papers
to our business affiliates to whom we will share aggregated demographic information. This is not linked to any Personal Information that can identify any individual person. We share users’ Personal Information within the RelationSpace Online network for the purposes of receiving services or information about our services. In these cases, the user identifies the location(s) within the RelationSpace Online network to which the Personal Information is to be sent; and
as required or permitted by law or with your prior consent;
companies within RelationSpace Digital Services Pty Ltd group when necessary and in connection with the purposes listed above.
8. Direct Marketing (APP 7)
By accepting our services you expressly permit us and RelationSpace Digital Services Pty Ltd group of companies to use your information for our direct marketing purposes and the purposes expressly set out in this policy. You consent to our use of your information to issue product and professional mail outs by email, fax, social media or letters and undertaking other marketing or service based activities.
If you do not wish to receive any of these materials, please contact us at firstname.lastname@example.org to opt out. Alternatively, all electronic communications contain an unsubscribe link which can be used to opt out.
You can change your mind about receiving materials or information about our products and services at any time by contacting us.
You may opt out of any direct marketing service at any time.
We will never sell, license, trade or provide your information to another for direct marketing purposes.
9. Cross-Border Disclosure of Personal Information (APP 8)
We may share your information within RelationSpace Digital Services Pty Ltd international group of companies who may be located outside Australia. We may use new technologies from time to time and Personal Information may be stored on servers outside Australia. We will not transfer Personal Information to a recipient in a foreign country unless we have appropriate protections in place as required by the relevant privacy laws. Your information will be stored on our data base for such period of time as required by law.
10. Identifiers (APP 9)
We will use our own identifiers and not those assigned by the government unless we are required to do so, or the Australian Privacy Principles or other another law legislates us to do so.
11. Accuracy of Personal Information (APP 10)
We will take all reasonable steps to ensure that the information we collect, use and disclose is accurate, up-to-date and complete. Please contact us if there is a change in your circumstances that requires an update to be made to our data or if you have an account with us, you may choose to modify your account details which can be accessed by logging in via www.relationspaceonline.com.au.
12. Security of Data (APP 11)
How We Protect Information
We will take all reasonable steps to protect the information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. When information is no longer needed we will destroy or de-identify it.
If a breach of security arises, we shall comply with the Mandatory Disclosure laws set out in the Privacy Act 1988.
13. Correction and Access to Information (APP 12)
You may request access to the information which we hold about you and request its correction if you believe it to be incorrect. We can also correct your information if we are satisfied that it is incorrect.
If your request is particularly complex or requires detailed searching of our records, there may be a reasonable cost to you in order for us to provide this information.
There are some circumstances where we can refuse to give access to information. These include where given access to the information would:
pose a serious threat to the life, health or safety of an individual or the public,
have an unreasonable impact on the privacy of others; or
be frivolous or vexatious.
Other exceptions are detailed the Australian Privacy Principles.
If you wish to access or correct your information, please contact RelationSpace Online at the address shown:
For security reasons, any request for details of information held by RelationSpace Online should be made in writing. You may be asked to provide proof of identify.
If you have a complaint regarding our management of your privacy you may access our internal dispute resolution (IDR) process by contacting us. The process will be as follows:
Upon receipt of any such complaint, RelationSpace Online will:
use a process that is accessible, flexible and timely and done in accordance with the principles set out in the Privacy Act;
focus on maximising the opportunity for the complainant and RelationSpace Online to work together to achieve a successful resolution to the complaint;
strive to identify and address any systemic issues that may arise through the lodgement of the complaint and rectify or deal with such issues to prevent their recurrence in the future.
The process referred to above will include the following steps:
At first instance you should contact us requesting a resolution. We will appoint a person to assist you with your complaint.
If the matter cannot be resolved you may ask him or her to refer it to the Clinical Director to engage the IDR process which may take up to 20 twenty business days to make a decision.
You will be notified of our decision. If you remain dissatisfied with the outcome, we will also inform you of your right to take this matter to the Office of the Australian Information Commissioner (OAIC).
You have 12 months from the date you became aware of your privacy issue to lodge your complaint with the OAIC. The contact details of the OAIC are:
Office of the Australian information Commissioner
Telephone: 1300 363 992
15. Update of Policy
16. Further Information
Catherine James, Practice Manager
If you have a concerns about how we deal with privacy issues you can contact our Privacy Officer or the Office of the Australian Information Commissioner: http://www.oaic.gov.au/privacy/privacy-complaints