Introduction

Fremantle Skin Cancer Clinic and its related corporate bodies (collectively, Fremantle Skin Cancer Clinic, we, us or our) recognise that your privacy is very important, and we are committed to and understand the importance of protecting the personal information we collect from you.

In handling your personal information, we are required to comply with the Privacy Act 1988 (Cth) (Privacy Act) and the 13 Australian Privacy Principles (APPs) under the Privacy Act. Further, as a health services provider, Fremantle Skin Cancer Clinic is required to comply with the Health Records and Information Privacy Act 2002 (NSW), Health Records Act 2001 (Vic) and Health Records (Privacy and Access) Act 1997 (ACT) (collectively, Health Acts) and the Health Privacy Principles (HPP) of the Health Acts.

This privacy policy sets out how we aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us, and how we collect, hold, use and disclose your personal information.

We regularly review our practices and procedures regarding how we manage personal information. As a result, this policy may be updated from time to time. When we update this policy, we will make the updated policy available, including on our website.

What kinds of personal information do we collect?

Personal information is information or an opinion about an identified or reasonably identifiable individual. During the provision of our services, we may collect your personal information.

The kinds of personal information we collect will vary depending on the dealings we have with you and how you interact with us.

For example, if you have an appointment with us, the kinds of personal information we may collect include:

• your contact information, such as your name, address, telephone number and email address;
• your gender and date of birth;
• your payment details and health insurance details;
• sensitive information such as your medical history and personal health;

Where we collect sensitive information about you, we will only do so with your consent or where we are required to do so by law. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all sensitive.

How do we collect personal information?

We will collect personal information for the primary purpose of providing healthcare to you. To enable us to provide our healthcare services to you, we collect the information necessary to ensure appropriate and relevant healthcare is provided to you.

There are several circumstances in which Fremantle Skin Cancer Clinic will collect personal information from you. For example, Fremantle Skin Cancer Clinic may collect personal information:

• where you request information from Fremantle Skin Cancer Clinic regarding our services;
• where you attend a Fremantle Skin Cancer Clinic clinic for an appointment; or
• as part of Fremantle Skin Cancer Clinic providing our services to you.

Generally, we only collect personal information directly from you:

• in person;
• through the use of any of our standard forms;
• via email; or

through telephone conversations or other direct communications with you.

Why do we need your personal information?

Fremantle Skin Cancer Clinic collects, holds, uses and discloses your personal information where it is reasonably necessary for:

• Providing you with healthcare and associated services, including:
  • providing you with an assessment of your health;
  • administering a course of treatment to you;
  • establishing a prevention strategy for you;
• accounting, billing and other internal administrative purposes;
• developing and facilitating our relationship with you;
• providing you with promotional information about us, our related entities and other organisations that we have affiliations with; and
• analysing our products and services and customer needs to develop new and/or improved products and services.

We may also collect, hold, use and disclose personal information to undertake identification and verification processes by the Anti-Money Laundering and Counter-Terrorism Financing Act or any other relevant laws. For certain investors, we may also be required to collect and disclose personal information to the Australian Taxation Office to comply with the Foreign Account Tax Compliance Act (FATCA).

You are under no obligation to provide your personal information to us. However, without receiving certain information from you, we may not be able to provide our products or services to you. We may be unable to process your application for investment in our funds or other financial products or services.

Who do we disclose your personal information to?

Generally, we will only disclose your personal information to third parties for a purpose related to providing our healthcare services or any related purposes within your reasonable expectations. We may also disclose your personal information to third parties for other purposes with your consent or if the disclosure is required or authorised by law.

The types of organisations we may disclose your personal information include:

• third-party medical consultants;
• government authorities were required to by law, such as under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• third-party service providers we engage to assist us in providing our healthcare services or other healthcare products or services, including such service providers we may engage to provide custody,
• administration, identity verification, technology, auditing, mailing, printing or other relevant services;
• related bodies corporate of Fremantle Skin Cancer Clinic (such as subsidiaries or holding companies of Fremantle Skin Cancer Clinic) or other third parties that Fremantle Skin Cancer Clinic has a commercial arrangement with, to advise you of special offers or promotions or otherwise notify you of other products or services that we believe may be of interest to you;
• our professional advisors (including legal, financial or insurance advisors); or
• any entity that acquires our business or assets or any entity that may wish to acquire, or has acquired, an interest in our business, the benefit of any contracts entered into by us or any rights under an account or agreement you have entered into with us.

Overseas disclosure

We do not disclose your personal information to recipients located overseas (i.e. outside Australian borders).

If, in the future, we decide to disclose personal information to an overseas recipient, we will update this privacy policy regarding the likely disclosures (including, if it is practical to do so, the countries in which such overseas recipients are likely to be located).

Direct marketing

We may collect, use and disclose your personal information to inform you of products, services or offers of Fremantle Skin Cancer Clinic, our related corporate bodies or other parties that we have a commercial arrangement with which we consider may be of interest to you.

Suppose you do not want to receive this information or do not want us to use or disclose your personal information for direct marketing purposes. In that case, you can opt-out by letting us know that you wish to opt out of receiving this information and/or Fremantle Skin Cancer Clinic using or disclosing your personal information for direct marketing purposes.

Security of your personal information

We take reasonable steps to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We store your personal information in different ways, including paper and electronic forms.

Personal information is stored on secured servers or in controlled, access-restricted environments. Our employees are obligated to maintain the confidentiality of any personal information held by us.

In certain circumstances, Personal information may also be held on Fremantle Skin Cancer Clinic’s behalf in hard copy or electronic forms by Fremantle Skin Cancer Clinic’s service providers (such as offsite document storage providers or electronic data storage providers). Fremantle Skin Cancer Clinic enters into agreements with such service providers, which impose confidentiality and privacy obligations on the service provider.

Fremantle Skin Cancer Clinic will destroy or de-identify personal information when it is no longer required unless we are otherwise required or authorised by law to retain it.

Correcting, accessing or updating your personal information

Fremantle Skin Cancer Clinic takes reasonable steps to ensure the personal information we collect is up-to-date, accurate and complete.

If your personal information changes (such as your name or address), you can contact us and inform us of the change. Please contact the Practice Manager at the clinic you attended.

You have a right to request the following:

• Access to personal information we hold about you; and
• Correction to the personal information we hold about you that is incorrect, inaccurate, outdated, incomplete, irrelevant or misleading.

Suppose you are in a State or Territory where the Health Privacy Principles apply. In that case, there are additional requirements that Fremantle Skin Cancer Clinic must consider when correcting, accessing or updating your health information.

We require you to put this request in writing and give this attention to the Practice Manager, and our clinic will respond to your request within 30 days. You will not be charged for making a request however, if results are required to be printed or photocopied, an administration fee will be charged. This fee is in line with the AMA rates and is charged at $33 for 30 pages, then $1 for each page after. This fee is payable before medical records can be released.

Our clinic will take reasonable steps to correct your personal information where the information is not accurate or up-to-date. From time to time, we will ask you to verify that your personal information held by us is correct and up-to-date.

Where you dispute the accuracy of the information Fremantle Skin Cancer Clinic has recorded, you are entitled to submit a written request for the Doctor to correct that information. Please be advised that the request and a note will be placed on your file, but Fremantle Skin Cancer Clinic will not erase the original record. You will be notified once this correction has been made.

To protect your privacy and the privacy of others, we will need to verify your identity before granting access or making corrections to your personal information.

Links to other websites

Our websites may contain links to other sites. We are not responsible for the privacy practices or content of other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each website that we may provide a link to on our website.

Also, our website may use cookies. The main purpose of cookies is to prepare customised web pages or content for users. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor the usage of our website and to create records of when users visit our website and what pages users view so that we may provide information, content and services tailored for that user. We cannot identify any particular individual from the information we collect due to our use of cookies.

Other companies may occasionally place advertising or links on our website and collect information about you when you view or click on their advertising or content through the use of cookies. Due to the technical operation of the internet, we cannot control this information collection and are not responsible for this collection, use or disclosure. You should contact these advertisers or content providers if you have any questions about their use of the information they collect.

Privacy Complaints

Please direct all privacy complaints to our Privacy Manager, info@fremantleskincancerclinic.com.au, or post to:

Privacy Officer
Unit 6, 87 South Terrace,Fremantle

A privacy complaint may relate to any concern or dispute you may have with our privacy practices. This could include matters such as:

• how your personal information is collected;
• how your personal information is stored;
• how your personal information is used or disclosed; or
• how access to your personal information is provided.

You can also make a privacy complaint if we have breached the Privacy Act, the APPs or any relevant APP Code.

At all times, privacy complaints will:

• be treated seriously;
• be dealt with promptly;
• be dealt with confidentially; and

not affect your existing obligations or commercial arrangements between you and us.

Our Privacy Officer will promptly investigate your complaint; all received letters will be acknowledged, and a response will be sent to you within 30 days. You will be informed of the outcome of your complaint after completing the investigation. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au or call OAIC on 1300 336 002.

Privacy Collection Notice

Fremantle Skin Cancer Clinic (we, our or us) may collect personal information (which may include sensitive information and health information) you provide directly to us by way of forms and other documents, in person or online, correspondence you provide to us, and telephone calls/meetings we have with you.

We may also collect personal information from third parties, such as medical practitioners who engage us to provide services to them or you, and from companies we hire to provide services to you on our behalf, including but not limited to third parties handling customer support enquiries, marketing or recruitment.

We will use personal information (except sensitive information, see below) for the following purposes unless otherwise required or permitted by law or by your express consent:

• Your medical treatment;
• to enable us to conduct our business generally and to facilitate the provision of health, lifestyle or other services to you;
• to provide you with marketing materials concerning offers, specials, products and services we or other companies have available from time to time which might better service your healthcare or lifestyle requirements or other opportunities in which you may be interested;
• if you are a job applicant or a potential contractor, to assess your suitability and (if successful) engage you and to assist with administering your employment or contract;
• for our internal management purposes, to manage our relationship with you and to manage the payment and recovery of amounts payable to us or your treating doctor by you; and
• for other reasonably necessary purposes in connection with any of the above uses.

We will only use sensitive information for the purposes for which it was provided or for a purpose directly related to it unless you agree otherwise or the use of such sensitive information is required or authorised by law.

If we cannot collect personal information relating to you in whole or in part, we cannot provide you with the goods or services you require or continue our relationship with you.

We may disclose personal information about you to the following types of entities if required in connection with the purposes listed above:

• your treating doctor or regular general practitioner;
• Medicare;
• your Health Fund;
• our contractors, consultants, advisers, associates and of our associated companies;
• any industry body, tribunal, court or otherwise in connection with any complaint made by you about us;
• any entity included in a transfer of all or part of our assets or businesses;
• if you have provided us with referees to assist with a job application or the assessment of a potential contract between you and us, the referees you have provided; and
• other entities with your consent or as permitted or required by law.

We may disclose the kinds of personal information mentioned above to overseas recipients such as associated companies or contractors who provide us with services.

Our Privacy Policy contains information about how you can obtain access to or correction of, personal information we hold about you and about how you can make a complaint if you are of the view we have breached the APPs, the Privacy Act, or any related privacy code in dealing with your personal information. Our Privacy Policy is available on our website or by contacting us at the contact details specified below.

Please direct all queries or complaints concerning your privacy to Privacy Officer, Fremantle Skin Cancer Clinic, Unit 6,87 South Terrace, Fremantle. (e-mail address: info@fremantleskincancerclinic.com.au).