PRIVACY POLICY

Purpose

This policy outlines how we collect, use, disclose, store, secure and dispose of your Personal Information, in accordance with the Australian Privacy Principles.

Scope

This policy applies to all Personal Information received, collected and held by Seekers regarding clients, staff, contractors, and other people who come into contact with the practice.

Policy

Personal Information We Collect

1. We collect Personal Information about:
   • Clients
   • Staff and contractors
   • Other people who come into contact with the practice (e.g. visitors, job applicants)

2. We will generally collect Personal Information held about an individual through forms filled out by clients, face-to-face and telehealth consultations, and telephone calls.
3. Third Parties: In some circumstances we may be provided with Personal Information about an individual from a third party, for example a referral or report provided by an Ophthalmologist or other medical professional.
4. Sensitive Information: We collect Sensitive Information, including health information, about patients to allow Seekers to provide clinical services for a client’s eye health.

How We Use Your Personal Information

5. We only use the Personal Information we collect from you for:
   • The primary purpose of collection
   • Secondary purposes that are related to the primary purpose and would be reasonably expected
   • Other purposes that you have consented to
6. Clients: Our primary purpose of collection is to enable Seekers to provide quality eyecare and related retail services to clients. The purposes for which we use Personal Information of clients include:
   • Scheduling appointments
   • Providing clinical services
   • Processing Medicare and private health insurance claims
   • Dispatching purchased eyewear and contact lenses
   • Keeping clients informed about our products, services and current offers (such as through our email newsletter which you can opt out of at any time)
   • Satisfying Seekers’ legal obligations
7. Job Applicants, Staff Members & Contractors: Our primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor.

Protecting Your Personal Information

8. Confidentiality: Our staff are required to respect the confidentiality of our clients’ Personal Information and are provided with privacy training. We typically seek Personal Information from you in private consultation rooms to prevent other clients from overhearing.
9. Access: We restrict access to Personal Information to staff that require this information to perform their role at Seekers.
10. Security: We have in place security controls to protect the Personal Information we hold from misuse, loss, unauthorised access, modification or disclosure through physical and electronic access controls, monitoring and technical controls, such as security alarms, privacy screens, encryption and multifactor authentication.
11. De-identification: Where possible, we de-identify data when meeting our internal and external reporting obligations.
12. Disposal: We securely destroy your Personal Information when we are legally permitted. Inactive individual patient medical records are kept until the patient has reached the age of 25 years or for a minimum of seven years from the time of last contact, whichever is longer.

Disclosing Your Personal Information

13. Seekers may disclose Personal Information, including Sensitive Information, held about an individual to:
    • medical practitioners (such as your GP, Pharmacist or Ophthalmologist)
    • government departments (where disclosure is required by law)
    • private health insurers (to submit claims on your behalf)
    • people providing services to Seekers, including IT specialists maintaining our systems
    • a client’s parent or guardian, where a child lacks maturity of understanding
    • anyone you authorise Seekers to disclose information to
14. Sensitive Information: Sensitive Information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the information is required by law.
15. Sending Information Overseas: We store your Sensitive Personal Information in secure systems located in Australia. We will not send Personal Information about an individual outside Australia without:
    • Obtaining the consent of the individual; or
    • Otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.

Accessing Your Personal Information

16. Right to Access: You have the right to access Personal Information Seekers holds about you or children you care for, and to advise us of any perceived inaccuracy.
17. Requests: To make a request to access any information Seekers holds, please contact the Seekers Optometrist in writing.
18. Identification: We may require you to verify your identity and specify what information you require.
19. Updates: We endeavour to ensure that the Personal Information we hold is accurate, complete and up-to-date. You may seek to update your Personal Information held by Seekers by contacting the Seekers Optometrist at any time.
20. Children: Children will generally have access to their Personal Information through their parents or guardians, however older children may seek access themselves. We may, at our discretion, grant a child with access to their Personal Information held by Seekers, or allow a child to give or withhold consent to the use of their Personal Information, independently of their parents or guardians. This would normally be done only when the maturity of the child and/or the child’s personal circumstances warranted it.
21. Parent or Guardian Consent: We respect every parent and guardian’s right to make decisions concerning their child’s health. Generally, we will refer any requests for consent and notices in relation to the Personal Information of a child to their parent or guardian. We will treat consent given by a parent or guardian as consent given on behalf of the child, and notice to them will act as notice given to the child.
22. Employment Records: Employee records are exempt under the Privacy Act. As a result, this Privacy Policy does not apply to Seekers’ treatment of an employee record, where the treatment is directly related to a current or former employment relationship between Seekers and employee. However, Seekers must provide access to health records and ensure compliance with the Health Privacy Principles under the Health Records Act.

Enquiries & Complaints

If you would like further information about the way Seekers manages the Personal Information it holds, or would like to make a privacy complaint, please contact:

Kye O’Donnell, Director
kye@seekersoptical.com.au
(03) 8456 8888
PO Box 4125, Fitzroy Victoria 3065

Definitions

Personal Information: Information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

Sensitive Information: Information relating to a person’s racial ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record, that is also personal information; and health information about an individual.

References

Privacy Act 1988 (Cth)

Health Records Act 2001 (Vic)

General Data Protection Regulation (EU)