Nabenet is committed to protecting the privacy of clients’ personal, sensitive and health information. This policy outlines our obligations in regards to how we collect, use, disclose, store, secure and dispose of personal, sensitive and health information.
In Victoria we are bound by the Privacy Act 1988 (Cth), Privacy and Data Protection Act (2014) and the Health Records Act 2001 (Vic) regarding the manner in which we handle personal, sensitive and health information.
What is personal and sensitive information and why do we collect it?
Personal information is information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Examples of personal information we collect include names, addresses, email addresses, phone and facsimile numbers. This personal information may be obtained in many ways, including via written referral from WorkSafe Agent, Comcare or employer, or their insurers, or at the time of assessment interview, worksite meetings or subsequent meetings, as well as by correspondence, telephone, facsimile or email.
Nabenet also collects sensitive information as defined in the Privacy Act (1988) and the Health Records Act (2001). This includes health information and medical opinions, fitness for work assessments, details of such things as an individual’s primary language, racial or ethnic origin, and membership of a trade union.
Nabenet collects personal, sensitive and health information for the primary purpose of providing occupational rehabilitation services and to provide information to stakeholders including the employer, WorkSafe agent or Comcare, insurers and treating health practitioners. We may also use personal, sensitive and health information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
We also routinely use and disclose your personal, sensitive and health information (both in raw and aggregated form) for research purposes and the compilation of statistics.
If we do not collect your personal, sensitive and health information, we may not be able to provide our services, or our full range of services, to you and other stakeholders.
When we collect personal, sensitive and health information we will, where appropriate and where possible, explain why the information is being collected and how we plan to use it.
We collect personal, sensitive and health information lawfully, fairly and not in an unreasonably intrusive way.
If we become aware of an actual or suspected privacy breach, we will inform the party whose privacy is impacted and the process Nabenet has followed or will follow to remedy the breach and prevent a similar recurrence. If applicable, the relevant regulator would also be informed.
Type of information held
Personal, sensitive and health information is held about a person if it is relevant to effectively provide occupational rehabilitation services.
Prior to assessment by Nabenet, information may be forwarded to us by the WorkSafe agent, employer, or their insurers, including:
- The worker’s name, address, phone number, email address, date of birth, date of injury, nature of injury/condition, and employment details
- Relevant medical information, reports or opinion regarding the relevant injury/condition
- Information regarding any issues/difficulties concerning recovery, employment status or return to work
At the time of assessment, Nabenet will obtain additional information and confirm personal, sensitive and health information including health information from the worker as required to provide occupational rehabilitation services. Subsequent to the initial assessment, further details of health information pertaining to the relevant injury/condition may be collected from treating health practitioners.
Further information may be sought from all relevant parties, including the worker, employer, treating health practitioners, independent medical examiners and the WorkSafe agent for the duration of Nabenet’s involvement in relation to the relevant injury unless specifically advised by the worker not to do so at which time we will advise the Agent.
How we hold your information
Nabenet holds personal and sensitive information in either hardcopy or electronic form, or both. At case completion all hard copy information is stored electronically and then securely destroyed.
How we secure your information
We hold all hardcopy and electronic records of personal, sensitive and health information in a secure manner to protect it from unauthorised access, modification or disclosure. Our staff follow strict information handling procedures and we only permit those staff whose tasks require use of your information to access it. In circumstances where hard copies of information are taken offsite, staff maintain this file on their person, or in a locked residence or vehicle. Only Nabenet staff have access to the electronic database, as protected by a secure password login.
We hold your personal, sensitive and health information for as long as it is required for our business functions, or as otherwise permitted or required by law.
How we disclose your information
Personal information may be disclosed to the WorkSafe agent, the employer and to insurers. Sensitive information including health information may be disclosed to parties including the employer, WorkSafe agent, insurers, treating health practitioners and regulator where you have consented to the use or disclosure, or where we are required or authorised by law. Personal, sensitive and health information may be disclosed to our research partners; however we require them to follow privacy procedures.
Your right to lodge a complaint
If you are not satisfied with how we have handled your personal, sensitive or health information, you are entitled to lodge a complaint with (as appropriate):
- the Office of the Australian Information Commissioner (website oaic.gov.au, telephone 1300 363 992); or
- the Victorian Health Services Commissioner (website health.vic.gov.au/hsc, telephone 1300 582 113).
However, before investigating a complaint, the Commissioners are legally required to be satisfied that you have first expressed your concern to us to afford us an opportunity to resolve the complaint directly, unless it is inappropriate for you to do so. You may lodge a complaint with our Privacy Officer at the contact details below. We will inform you of who will handle your complaint and you may contact our Privacy Officer to enquire about its stage of progress at any time. We will endeavour to ensure that your complaint is resolved to your satisfaction.
Your right of access
You may request access to your personal information at any time by sending a written request to our Privacy Officer at the contact details below. In your request, please state you would like to obtain access. You do not need to provide a reason for your request. Once our Privacy Officer has verified your identity, your request will be processed to enable access to be provided to you in an appropriate manner. We may charge a fee for providing access if it requires a significant amount of time to locate your information or to collate or present it in an appropriate form. Our Privacy Officer will follow up your request to ensure that the level of access with which you have been provided is to your satisfaction.
You may correct your information
Nabenet takes reasonable steps to ensure that the personal, sensitive and health information it collects, uses, holds or discloses is accurate, complete, up to date and relevant to its functions.
If your personal, sensitive or health information is out of date or incorrect, you may inform us of this and we will endeavour to correct it for you. In the unlikely event that we disagree about the accuracy of the information and are unable to change it, you may provide us with a statement indicating that you dispute its accuracy and we will associate the statement with your information/ report in such a manner that it will be brought to the attention of each person who uses the information.
Marketing information
In relation to employers, we may send promotional information about other services we believe may be of interest. However, should you not wish to receive such material, please inform our Relationship Manager by either mail at Level 2, 108 Power Street, Hawthorn, Victoria, 3122, by telephone on (03) 9981 9888 or by email to vanessacariss@nabenet.com.au and we will ensure that your name is removed from our mailing list. Opt out procedures are also included on our marketing communications.
Disclosure of information outside of Australia
Your personal, sensitive and health information is securely stored within Australia, however Nabenet employees can access this information remotely from outside Australia.
We may need to change our privacy policy from time to time
Due to changing business circumstances, we may need to change our privacy policy from time to time. If we do, we will endeavour to ensure that your overall level of privacy protection is not diminished and will publish the changes on our website. Any actions that we have taken before the change will continue to be regulated by the privacy policy that existed before the changes were made.
Further information
We are happy to provide you with further information regarding your privacy. If you have any queries or requests in this respect, please contact our Privacy Officer on the contact details below.
Contact
Audrey Lim (Quality Manager)
Innovative Physiotherapy Services Pty Ltd t/a Nabenet
Level 2, 108 Power Street, Hawthorn, Victoria, 3122
T: (03) 9981 9888
References
- Privacy Act 1988 (Cth)
- Health Records Act 2001 (Vic)
- Privacy and Data Protection Act (2014)
- ISO 9001:2015 (E) 5.3 Property belonging to customers or external providers
- WorkSafe Privacy Register