Elanora Physiotherapy is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.

 This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

 In this Privacy Policy, “we” and “us” refers to the Elanora Physiotherapy group of companies and “you” refers to any individual about whom we collect personal information.

 About the Elanora Physiotherapy

 Elanora Physiotherapy comprises (Holdings) Pty Limited and its subsidiaries and controlled entities.  The Elanora Physiotherapy Group comprises a number of divisions including Elanora Physiotherapy and Private Care. Please contact us for a full list of companies comprising the Elanora Physiotherapy Group.

 What Information Does Elanora Physiotherapy Collect About You?

 Clients and prospective clients

 When you enquire about our services or when you become a client of Elanora Physiotherapy, a record is made which includes personal information such as your name, address, date of birth, contact details and emergency contact details.  When you become a client of Elanora Physiotherapy a photograph of you may also be kept on your file.  Personal information collected about you to provide, or in providing, healthcare services is considered health information and is treated as sensitive information.  Elanora Physiotherapy may also collect other personal information about you which is considered sensitive information (such as information about your racial/ethnic origin) where this is relevant to the services we provide.

 Generally, health information we collect about you includes:

 your previous and current medical history (including, where clinically relevant, a family medical history) and details of treatment and health services you have received your care plan medications you take information about other healthcare professionals and health service providers who are involved in your care information about your healthcare preferences and wishes information about your attorney, guardian or other person responsible for your healthcare decisions.

 Elanora Physiotherapy will also collect information relevant to administering your payment arrangements such as your banking details, your pension entitlements and arrangements, and information regarding your income and assets.  Where it is relevant to administering your payment arrangements, we will collect information such as your Medicare number, health care card number and your entitlement to benefits.  Where we have collected a government related identifier (such as your Medicare number), we will not adopt that identifier as our own identifier and we will only use or disclose that identifier as required or permitted by law.

 Elanora Physiotherapy will, where practicable, collect information directly from you (for example, when we have contact with you in person, over the phone or via the internet).  Elanora Physiotherapy may also collect personal information about you from third parties including: Other healthcare professionals and health service providers involved in your care the Aged Care Assessment Team or Regional Assessment Service which assessed your need for care government agencies responsible for administering relevant entitlements and benefits (such as Centrelink, Medicare, My Aged Care, Department of Social Services, National Disability Insurance Agency, Department of Veterans Affairs, and other government agencies responsible for home care services).

 We may also collect information about you from your family members, a carer, an attorney, a guardian or a person responsible for your healthcare decisions.

 Prospective employees/applicants

 We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history.  Generally, we will collect this information directly from you.  We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated).  Before offering you a position, we may collect additional details such as your tax file number, superannuation information and other information necessary to conduct police checks.

 This Privacy Policy does not apply to Elanora Physiotherapy’s employee records.

 Other individuals

 Elanora Physiotherapy may collect personal information about other individuals who are not clients of Elanora Physiotherapy.  This includes individual service providers and contractors to Elanora Physiotherapy; other individuals who interact with Elanora Physiotherapy on a commercial basis; and healthcare professionals who have referred clients to us or who are providing services to our clients.  The kinds of personal information we collect will depend on the capacity in which you are dealing with Elanora Physiotherapy. Generally, it would include your name, contact details, professional details and information regarding our interactions and transactions with you.

 Visitors to our website

 The way in which we handle the personal information of visitors to our website is discussed below under the heading How is your personal information handled on our websites.

 How does Elanora Physiotherapy hold and protect your personal information?

 Elanora Physiotherapy primarily collects and holds your personal information in electronic form.  Information held in electronic form is held securely on servers and computer systems located in Australia and on cloud servers located in the United States and Japan and can be accessed by Elanora Physiotherapy personnel, health professionals and clerical staff from time to time.

 Our staff are bound by a formal code of conduct.  We train and supervise our staff to ensure your information is treated with respect and care in accordance with privacy laws which apply to us.

 Certain information is collected and held in paper-based documents (such as administrative forms), which may be converted to electronic form and the original paper-based documents securely destroyed.  Information which is retained in paper-based form is held securely at our premises or in archive facilities in Australia.

 We maintain physical security over our paper and electronic data stores, such as locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

 Due to the nature of the services we provide, documents recording your personal information may be left with you in your home (such as your care plan or care records).  We cannot ensure the security of personal information which is left with you in your home.  However, we will work with you to minimise the opportunity for other individuals to access your personal information.

 Why does Elanora Physiotherapy collect your personal information?

 Elanora Physiotherapy collects personal information about clients in order to assess and manage your needs when we are providing our services to you.  For example, we collect information about your health to ensure that our services respond to your healthcare needs; to determine your eligibility to entitlements under the Aged Care Act 1997 (Cth) or other legislation relating to the services you may receive; to ensure that our services are consistent with other healthcare services you receive; and to minimise the need for you to provide the same information on multiple occasions.

 Further information about the way in which Elanora Physiotherapy uses and discloses your personal information is set out in the next section.

 Providing accurate and complete information is important for the safety, quality and effectiveness of the services we provide.  It is also important to ensure you receive the correct entitlements to benefits and funding for the services we provide.  If you provide incomplete or inaccurate information, we may not be able to provide you with the services you seek.  If you have any concerns about personal information we have asked you to provide, please let us know.

 You have the option of not identifying yourself, or using a pseudonym, when dealing with Elanora Physiotherapy (for example, when making a general enquiry).  However, it is usually not practicable for Elanora Physiotherapy to deal with you anonymously or pseudonymously on an ongoing basis (for example, as a client of Elanora Physiotherapy).

 How does Elanora Physiotherapy use and disclose your personal information?

 Your personal information will usually be shared with other persons involved in your care. Generally, this will only happen in ways you would reasonably expect or otherwise with your consent.  For example, Elanora Physiotherapy may disclose your personal information to your GP or to a medical specialist involved in your care; to your attorney, guardian or family members (where you have provided consent to do so); to a hospital or aged care facility if you are referred for respite or higher levels of care; or to other healthcare professionals who are involved in your care such as nurses, occupational therapists, pharmacists, physiotherapists, podiatrists, dentists and the ambulance service.

 In an emergency, we may provide personal information to other healthcare professionals and health services without your consent.

 Contractors and other service providers

 Elanora Physiotherapy sometimes engages third parties to perform services on our behalf and we may use and disclose personal information to facilitate these arrangements.  This may include specialist care services, allied health services, and general domestic and personal care services.  We may also contract other organisations to perform services on our behalf, for example, to undertake customer satisfaction surveys.

 Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

 Administration and management

 Elanora Physiotherapy will also use and disclose your personal information for a range of administrative, management and operational purposes.  This includes: administering billing and payments and debt recovery liaising with, and reporting to, government agencies in the administration of particular funding programs administering subsidies and benefits to which you may be entitled from government agencies and other third-party payers (such as My Aged Care, Centrelink, Medicare, Department of Social Services, National Disability Insurance Agency, Department of Veterans Affairs, and other government agencies responsible for home care services)

 Planning, managing, monitoring and evaluating our services safety and quality assurance and improvement activities, statistical analysis and reporting, training staff, contractors and other workers risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives) responding to enquiries and complaints regarding services provided to clients (including external bodies, such as the Australian Aged Care Quality Agency and the Aged Care Complaints Commissioner) obtaining advice from consultants and other professional advisers responding to subpoenas and other legal orders and obligations.

 Does Elanora Physiotherapy use or disclose your personal information for direct marketing?

 If you are a client, we will only use or disclose your personal information for direct marketing purposes with your consent.  If you do provide your consent to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.  We will provide this information to you by post, email, telephone and/or text message, using the details you have provided.

 For other individuals, Elanora Physiotherapy may use or disclose your personal information for the purpose of informing you about products or services, promotions or other opportunities that may interest you.  If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.

 Does Elanora Physiotherapy disclose your personal information overseas?

 Elanora Physiotherapy does not typically or routinely disclose personal information to overseas recipients.

 Unless we have your consent, or an exception under the Australian Privacy Principles applies, we 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 Australian Privacy Principles in relation to your personal information.

 How can you access or seek correction of your personal information?

 Generally, if you would like further information about the care or services you have received from Elanora Physiotherapy you may simply ask your nurse or carer.

 However, you have the right to request access to personal information Elanora Physiotherapy holds about you at any time.  To request access to your personal information, please contact us using the contact details below.

 Where the person requesting access is an authorised representative of the person about whom the information relates (such as an attorney or guardian) we will ask the representative to provide evidence of their authority (such as a copy of an Enduring Power of Attorney) where we do not already hold that information.

 In certain circumstances, your request to access your personal information may be declined in accordance with privacy laws (for example, where giving access would put you or another person at risk of harm).

 Elanora Physiotherapy will endeavour to acknowledge your request to access within 14 days of its receipt and provide you with access to the information requested within 30 days.  If we decline your request for access, we will tell you the reasons for declining your request and inform you of your right to make a complaint.  We may recover reasonable charges to provide you with access.

 We take reasonable steps to ensure that your personal information is accurate, up-to-date and complete.  You can help us do this by letting us know if you notice errors or discrepancies in information we hold about you and also letting us know if any of your personal details change.

 If you consider personal information we hold about you is inaccurate, out-of-date, incomplete or irrelevant, you have a right to request we correct the information.  It is sometimes not possible for us to make changes to personal information we hold about you (such as your healthcare records).  In that circumstance, you may be entitled to request that we associate a statement with your information and you may have a right to make a complaint.

 How long will Elanora Physiotherapy hold your personal information?

 Elanora Physiotherapy will hold your personal information until it is no longer needed.  Generally, if you are a client, your personal information will be held for a minimum of 7 years from the date of last entry in your record (in the case of children, the record is kept until the client attains or would have attained 25 years of age).  This complies with Elanora Physiotherapy's legal requirements to maintain such records.

 Information that is no longer needed will be securely destroyed or de-identified.

 How is your personal information handled on our website?

 You may visit our website (www.elanoraphysiotherapy.com.au) without identifying yourself.  If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to Elanora Physiotherapy will be managed in accordance with this Privacy Policy.

 Elanora Physiotherapy's website uses cookies.  A cookie is a small file which is placed on your computer or device when you visit our website.  Cookies allow us to recognise your computer or device and are required to enable our website to function correctly.

 When you visit our website, we use cookies to collect certain information such as your device type, browser type, IP address, date and time of your visits, pages you accessed on our website and on third-party websites.  In general, this information will only identify your device and will not identify you personally.

 We may also place cookies (called persistent cookies) on your computer or device.  We use, and third-parties use, these cookies to display personalised advertisements (or targeted advertisements) on websites you visit or social media platforms you use.  For example, if you visit our website you may see advertisements for Elanora Physiotherapy on other websites you visit.  Advertisers can use these cookies to build up a profile of your behaviour online (including websites you visit).

 We also use cookies to allow our service providers such as Google Analytics to monitor and analyse how users interact with our website.  Details about how Google uses information is available at http://policies.google.com/technologies/partner-sites.

 You can change the settings on your computer or device to disable cookies (or certain kinds of cookies).  This may affect how our website, and other websites you visit, function.

 You can also opt-out of personalised advertisements by visiting Googles Ad Settings at http://www.google.com/settings/ads.  Websites such as youronlinechoices.com.au also allow you to opt-out of personalised advertisements.  You may also be able to change your settings on websites or social media platforms where you are seeing personalised advertisements.

 Our website includes secure payment facilities to process certain transactions online.  Those secure payment facilities are encrypted and maintained by third-party providers.

 Except for our secure payment facilities, our websites do not use encryption or other technologies to ensure the secure transmission of information via the internet.  Users of our website are encouraged to exercise care in sending personal information via the internet.

Our website may contain links to third-party websites.  Elanora Physiotherapy is not responsible for the content or privacy practices employed by websites that are linked from our website.

 How can you make a complaint about the handling of your personal information?

 You may contact Elanora Physiotherapy at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

 You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

 The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within 14 days.

 If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within 14 days and endeavour to complete our investigation into your complaint promptly.  If something is not clear, we may ask you to provide further information about your complaint and the outcome you are seeking.  We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

 In most cases, we will investigate and respond to a complaint within 30 days.  If the matter is more complex or our investigation may take longer, we will let you know.

 If you are not satisfied with our response to your complaint, or you think we may have breached the Australian privacy laws, you are entitled to make a complaint to the Office of the Australian Information Commissioner.  The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992.  Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

 How are changes to this Privacy Policy made?

 This Privacy Policy may be reviewed or amended from time to time. You can access the most up to date copy of this policy by visiting our website (www.elanoraphysiotherapy.com.au)