UFS Medical Privacy Policy
UFS Privacy Policy
Effective 30 November, 2024
UFS Healthcare Limited (UFS) provides a range of healthcare products and services and includes (but is not limited to) the following:
• UFS Pharmacy
• UFS Medical
• UFS Eye Care
UFS recognises the importance of your privacy. This Privacy Policy explains how UFS manages the personal information that we collect, store, use and disclose and how to contact us if you have any further queries about our management of your personal information.
UFS is required to ensure that all personal information pertaining to our customers, emergency contacts (including next-of-kin/guardians/carers of our customers), healthcare professionals, employees and contractors is treated in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Health Records Act 2001 (Vic) (Health Records Act).
This Privacy Policy applies to you only to the extent that the collection and handling of personal information by UFS is subject to the Privacy Act and Health Records Act.
1. Background
Where the collection or handling of your personal information by UFS is subject to the Privacy Act, UFS must comply with the requirements of the Privacy Act. The Privacy Act regulates the manner in which personal information is handled throughout its life cycle, from collection to use, disclosure, storage, accessibility and disposal.
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Special provisions apply to the collection of personal information which is sensitive. This includes health information and information about a person’s race, ethnic origin, political opinions, membership of political parties, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.
Where UFS collects your health information, the collection or handling of that information is also subject to the Health Records Act.
In this Privacy Policy, all references to personal information include sensitive information unless indicated otherwise.
2. What personal information does UFS collect?
In the course of our business, UFS may collect personal information about you that is necessary for us to perform our functions and activities. UFS will only collect personal information about you by lawful and fair means and not in an unreasonably intrusive manner.
2.1 What type of personal information do we collect?
The types of personal information we may collect and hold will vary depending on the nature of our interaction with you and may include:
· identifying and contact information (such as your name, postal address, email address and telephone phone number);
· information about your family members, next of kin, medical power of attorney, guardian or preferred/emergency contact person (Representative);
· health information such as medical history, medications, allergies, adverse events, immunisations, social history, family history, risk factors, prescriptions, optical test results and information relating to any glasses or lenses we supply to you;
· credit card and payment details;
· Commonwealth and Victorian government identifiers (such as Medicare numbers, healthcare identifiers and Veterans’ Affairs numbers);
· details about your health fund; and
· qualifications, education and employment history.
2.2 Who do we collect personal information from?
UFS may collect personal information about a range of individuals including:
· customers who purchase our healthcare and personal care- products and services;
· healthcare professionals;
· job applicants, employees and contractors of UFS;
· Representatives; and
· third parties providing a product or service to UFS, including personnel of those third parties.
3. How does UFS typically collect personal information?
Depending on the nature of your interaction with UFS, we may collect your personal information in a number of ways including in-person when you attend at our stores or during pharmacy professional services or a medical or optical consultation, through our websites (such as when you make an online appointment with us), through application forms (such as when you apply to become a UFS member) and when you communicate with us (including via social media).
If you are a customer, we usually collect your personal information directly from you wherever reasonably possible. We may also receive or collect personal information about you, from third parties such as:
• healthcare providers: your general practitioner, specialists, allied health professionals, hospitals, community health services, residential aged care facility, pathology and diagnostic imaging service providers and other healthcare professionals involved in your care. We may also collect your personal information via electronic medical platforms such as Electronic Transfer of Prescriptions (eTP), SafeScript and the My Health Records system;
• your Representatives: your family members, next of kin, medical power of attorney, guardian or your preferred/emergency contact person (Representatives);
• Funding Organisations: the organisation that is funding the provision of our products and services to you such as your Medicare Australia, the Department of Veterans Affairs, the Transport Accident Commission, WorkSafe Victoria appointed WorkCover agents, the National Disability Insurance Agency, your insurer and/or your employer (Funding Organisation);
• pharmacy owners: organisations who engage us to manage their pharmacies, such as Western Victorian UFS Dispensaries Ltd; and
• third party service providers: persons or organisations engaged by us to assist us in carrying out the above purposes such as our online appointment booking system provider.
If you are a healthcare professional or Representative, we typically collect your personal information directly from you or from our customers.
If you are an employee, contractor or third party service provider, we typically collect your personal information directly from you. If you are a prospective employee or contractor, we may also collect your personal information from third parties such as recruitment agencies and your referees.
4. For what purposes does UFS collect, hold, use and disclose your personal information?
UFS may collect, hold, use and disclose personal information for a range of purposes which may include the following:
• health, optical, pharmacy, oral health and personal care products and services: to assess and manage your health and provide you with advice, products and services to help address your health, optical, pharmacy, oral health and personal care needs (and those of any other health related businesses we may become involved with), such as prescribing and dispensing medication, providing glasses and lenses and providing other healthcare services to you;
• communication: to send communications to you, manage our ongoing relationship with you and provide advice on your healthcare needs, including appointment reminders and appointment follow ups regarding further examinations or treatments you may require;
• invoicing and payment processing: to manage billing and process payments in relation to products and services rendered by us, including handling claims with Medicare, the Transport Accident Commission, the National Disability Insurance Agency, WorkSafe Victoria appointed WorkCover agents and the Department of Veterans Affairs (amongst others);
• improvement of products and services: to review, develop and improve our products and services, including our customer service provided to you ;
• business processes: to undertake quality assurance, practice audits, accreditation, service planning, market research, statistical analysis, risk assessment and management activities;
• changes to our business: to advise you if we or one of our healthcare providers relocate or if any of our stores merge, rebrand, relocate or close;
• training: to train and educate our personnel;
• data quality: to verify and update Information held by us;
• marketing (with consent): with your consent, to market our products and services or of other third parties who have a relationship with us, including the running of promotions and competitions;
• legal compliance: to comply with legal or regulatory obligations (such as medication dispensing requirements);
• complaints: to resolve any complaints, disputes or claims or follow up on incidents;
• membership management: if you choose to purchase a UFS membership, to provide you with and manage your UFS membership, including processing applications, handling renewals and administering benefits; and
• other purposes: for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.
5. To whom may UFS disclose your personal information?
We may share your personal information with other third parties as reasonably necessary to provide you with our products and services, and for the above purposes. This includes:
• healthcare providers: to healthcare providers including:
o healthcare providers UFS employ or engage to provide healthcare services;
o your treating healthcare providers such as your general practitioner, specialists, allied health professionals, hospitals, community health services, residential aged care facility, pathology and diagnostic imaging service providers and other healthcare professionals involved in your care;
o via electronic medical platforms such as Electronic Transfer of Prescriptions (eTP), SafeScript and the My Health Records system;
• your Representatives: to your Representatives;
• Funding Organisations: to the Funding Organisations that are funding the provision of our products and services to you;
• persons authorised by you: to other persons or organisations authorised by you such as the National Diabetes Service Scheme (if you have diabetes and are registered with that Scheme);
• auditors: to auditors, accreditation agencies and other service providers who we may appoint to ensure the integrity of our operations and services;
• automated transcription providers: with your consent, to providers of automated transcription services to assist with recording and generating clinical notes in real-time;
• third party service providers: to other persons or organisations engaged by us to assist us in carrying out the above purposes such as data storage service providers (such as Fred IT Group Pty Ltd in the case of UFS Pharmacies), patient management system / health software providers, product suppliers (such as suppliers of glasses and lenses in the case of UFS Eye Care), IT support providers, medication packing service providers, payment system operators (such as HICAPS), insurers, mail houses and professional advisors;
• government and regulatory authorities: to government and regulatory authorities such as Medicare Australia, the Commonwealth Department of Health and the Victorian Department of Human Services, including to comply with legal requirements such as mandatory health notifications;
• pharmacy owners: to organisations who engage us to manage their pharmacies, such as Western Victorian UFS Dispensaries Ltd;
• purchasers: to prospective or actual purchasers of parts or all of our assets or business;
• fraud: to other companies and organisations if we are concerned there is a risk of fraud; and
• other third parties: to other third parties required or authorised by or under law, such as to comply with court orders or subpoenas served on us, where disclosure is required for the management or funding of a health service, and where disclosure is necessary to lessen or prevent a serious threat to a patient’s life, health or safety.
UFS may also share your personal information between its various healthcare businesses so we have an integrated and complete view of our customers and to provide you with a better and more personalised service.
6. What happens if you don’t provide UFS with personal information about you?
While in some circumstances you may not need to provide UFS with your personal information, or you may use a pseudonym to interact with UFS, there are some circumstances when dealing with UFS -where you must provide your personal information to us, otherwise we may be unable to provide you with the products and services requested or otherwise work or transact with you. For example, we are unable to process any prescriptions without the provision of your personal details, including your name and address and, in some circumstances, your Medicare number or date of birth.
7. How does UFS hold personal information and manage the data quality and security of personal information?
Your personal information may be stored by UFS in various forms (for example, electronically, in paper form, x-ray films and/or disc). To the extent your personal information is stored electronically, it is generally stored either at the site where it was collected on secured servers, or within the software vendor’s cloud storage environment and/or hosted servers.
To the extent required by the Privacy Act, UFS will take reasonable steps to:
· make sure that the personal information we collect, hold, use and disclose is accurate, complete and up to date; and
· protect the personal information we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
Subject to the requirements of the Privacy Act and the Health Records Act, UFS will take reasonable steps to ensure that personal information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner.
8. Does UFS transfer personal information outside of Australia?
From time to time, UFS may need to disclose your personal information to organisations located outside of Australia in the course of everyday business (for example, we use an organisation located in the United States of America to facilitate the sending of emails and SMS). If we do so, we will take reasonable steps to ensure the overseas organisations comply with Australian privacy laws.
The countries to which we may disclose your personal information in the course of our functions and activities may be updated from time to time. To obtain a copy of the latest list of countries at any time, you should visit the latest Privacy Policy on our website as at 30 November, 2024.
9. Communicating with you and direct marketing
If you consent to receiving marketing communications from us, UFS may use your personal information (including sensitive/health information) to contact you in relation to products, services or other offers we think may be of interest to you. This may include products, services or other offers of UFS (including any healthcare services offered by UFS such as eye care, pharmacy, oral health and medical) or third parties with whom we have a relationship. We may do this through various channels (for example, by mail, SMS, phone, email and MMS messages, through targeted marketing on social media platforms and in app and push notifications). You may opt-out of receiving marketing communications from UFS at any time by:
• submitting an ‘unsubscribe’ request via the link in our communications; or
• contacting us using the contact details below.
If you do not wish to receive marketing material from UFS, please note that UFS may still contact you in relation to our ongoing relationship with you relating to the healthcare products and services we have already provided you while you remain our customer (for example, in relation to invoices and appointment reminders).
10. How can you access or correct your personal information and contact UFS?
Please contact the UFS Privacy Officer if you would like to seek access to, or request that we correct, the personal information we hold about you:
· by mail: Privacy Officer, UFS Healthcare Limited, 206 Armstrong Street North, Ballarat, VIC 3350; or
· by telephone: (03) 5327 7777; or
· by email: [email protected].
UFS will generally provide you with access to your personal information if practicable, and will take reasonable steps to amend any personal information about you which is inaccurate or out of date.
UFS may charge a reasonable fee for providing your personal information. We will let you know in advance of charging any fee to confirm that you still wish to proceed with your request. In some circumstances, and in accordance with the Privacy Act and the Health Records Act, UFS may not permit access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision.
11. How UFS handles complaints
If you have any concerns or complaints about the manner in which your personal information has been collected or handled by UFS, please advise us of the concern or complaint in writing and send it to the UFS Privacy Officer using the contact details set out in Section 10 above. The concern or complaint will be considered or investigated and we will respond to the complaint as soon as practicable.
If you remain dissatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) who responds to complaints about the misuse of personal information.
To lodge a complaint with the OAIC:
· fill out a complaint form online at https://www.oaic.gov.au/; or
· send the complaint form by:
» email at [email protected]; or
» mail to GPO Box 5218, Sydney NSW 2001; or
» fax to 02 9284 9666.
12. Further information
Further information about the application of the Privacy Act can be found at the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
Further information about the application of the Health Records Act 2001 (Vic) can be found at the website of the Health Complaints Commissioner at www.hcc.vic.gov.au.
13. Changes to our Privacy Policy
This Privacy Policy is effective from 30 November, 2024. As this Privacy Policy is updated from time to time, to obtain a copy of the latest version at any time, you should visit our website at www.ufs.com.au/privacy.