Privacy Policy

QOS takes your privacy seriously and is committed to protecting your privacy. QOS[ML1]  is bound by the Privacy Act and the APPs. This Privacy Policy describes how we treat your Personal Information.

QOS operates a serviced office arrangement and provides services and facilitates to assist the independent doctors to carry out their medical practice. 

By contacting QOS, scheduling an appointment for, and/or having a consultation with, an independent doctor  (whether the consult is completed by you or not), you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Privacy Policy.

This Privacy Policy may be amended from time to time. You will be notified of important changes and provided with a prominent link to those changes for a reasonable length of time following the changes. You consent to any amendments to this Privacy Policy by continuing to contact us, schedule an appointment for, or having a consultation with an independent doctor. Please ensure you regularly check our website for updates of this Privacy Policy.

If you have any questions about our use of your Personal Information or have any concerns about this Privacy Policy, please contact:

Name: The Practice Manager

Address: 205/32 Morrow St, Taringa Qld 4068

Tel: (07) 3062 2380

Personal Information collection and usage

This Privacy Policy relates to all information supplied by you to QOS or to independent doctors who engage QOS including:

  • Contact information: your name, position, role, company or organisation, telephone number email, postal address emergency contact details;

  • Communications: information provided in communications us including when you book (or enquire about booking) an appointment with an independent doctor;

  • Information from public sources: for example, from LinkedIn and similar professional networks, directories or internet publications;

  • Financial information: we may obtain your bank account details (or third party payer details) for example when taking payment for an appointment with an independent doctor (whether that appointment has occurred or not and including a deposit, or late or cancellation fees);

  • Medical information: we may collect information about your health and medical history for the purpose of your consultation and to process payment and rebates, for example through HICAPS and Medicare;

  • Social media: interactions with our social media presence including posts, likes, tweets;

  • Technical information: when you access our website and technology services being IP address, time zone setting, browser plug-in types and versions, operating system you are using, device type, hardware model, MAC address, unique identifiers and mobile network information;

  • Online data: when you access our website, app and technology services, information about your visit including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and other similar information and whether you click on particular links or open emails from us;

  • Medicare number: your Medicare number (in certain circumstances where it is necessary for us to liaise with Services Australia); and

  • Individual Healthcare Identifier (IHI): your IHI number (in certain circumstances for the purposes of communicating and managing health information including through the My Health Record in accordance with the Healthcare Identifiers Act 2010 (Cth)).

Personal Information may be received directly from you or third parties who assist us with our legal obligations. This information may be exchanged over the phone, by email, SMS, in person, or in any other form of written communication. Personal Information may also be obtained about you from a healthcare professional such as a specialist doctor.

If you send us an email containing Personal Information, we will use all reasonable endeavours to ensure the confidentiality of that information. Our internet host may monitor emails sent to us for maintenance, service provision, and fault detection purposes. We may also monitor emails to ensure compliance with our legal obligations. We may forward emails to third parties where the email contains feedback or complaints, or to assist us to respond to feedback and complaints and to otherwise assist with the management of our business. Email is not a secure method of communication. If you are concerned about sending your Personal Information us by email, you should consider contacting us in person, by alternative written means or by telephone.

Personal Information is not collected about your online activities across third party websites or online services.

The information you provide to us will not be made available to other doctors, staff of QOS or interested parties either: (a) without firstly obtaining your written consent (unless required or permitted by law); or (b) in accordance with this Privacy Policy.

If you do not wish to provide your Personal Information, then you do not have to do so, however it may affect your ability to book a consultation with an independent doctor whether via the website or otherwise.

Under the Privacy Act, you have the option of not identifying yourself or using a pseudonym unless identification is required or authorised by or under law or it would be impracticable to deal with individuals who have not identified themselves. If you do not wish to identify yourself, then you do not have to do so, however it may affect our ability to assist you to book a consultation with an independent doctor.

How your Personal Information is used

We use your Personal Information for the following purposes:

  • to enable the independent doctor who uses our services and facilities to provide medical services to you;

  • to process Medicare and private health fund claims on behalf of the independent doctor who provides you with medical services;

  • to communicate with you including for example sending appointment reminders and confirmations, or sending you your invoice or bill;

  • receiving or responding to feedback, enquiries or concerns you may have;

  • compliance with law, including circumstances where disclosure is required without your consent for example where a serious threat to life, health or safety exists. We may obtain further information from you to comply with the law if required;

  • to monitor our website and our other technology services, to ensure they are used appropriately and working as intended, including as tracking outages, unauthorised use, or troubleshooting issues that you report to us;

  • protecting our information and technology platforms from hacks, or identifying and addressing malware and other security threats; and

  • for quality assurance and improvement of processes purposes for example risk management.

Why your Personal Information is used

Your Personal Information may be collected, held, used or disclosed for a number of reasons including:

  • with your consent for example you share details for particular purposes including relating to scheduling an appointment with an independent doctor;

  • to contact you (including on behalf of the independent doctor), for example, sending your appointment reminders, to respond to your queries, or to tell you something important;

  • to comply with legal, regulatory and licencing requirements; and

  • where processing is necessary for our legitimate business interests or those of a third party, provided this does not override any interests or rights that you have as an individual.

Our legitimate interests include understanding and responding to feedback and enquiries, and providing the appropriate facilities and services to enable the independent doctors to service their patients.

Why Sensitive Information may be used

Sensitive Information is only used if:

  • it is not otherwise permitted under this Privacy Policy, but you have provided express and informed consent for the particular processing; 

  • it is necessary to protect your vital interests or those of another person for example, in medical emergencies;

  • you have manifestly made the data public for example, where you have published it on social media;

  • it is necessary to deal with legal claims for example, involving court proceedings;

  • it is necessary for substantial public interest for example, to prevent or detect unlawful acts; or

  • it is permitted by applicable law.

Who your Personal Information is shared with

There are instances where we will disclose your Personal Information including where it is permitted or required by law, or as follows:

  • To doctors: that have engaged QOS to assist the independent doctor to provide you with medical services, manage its files, bookings, process payments and otherwise conduct its business;

  • Shared service centres: that we or third parties operate including for IT services, marketing, risk management and office support services;

  • Financial institutions: for payment processing;

  • Law enforcement bodies and our regulators: or authorities in accordance with law or good practice for example by order of a court or otherwise required by law;

  • Healthcare professionals: including hospitals and specialists for example in connection with your referrals and scripts;

  • Family or representative: any person, family member, representatives or other organisations that you have consented or where we are required, permitted, authorised or otherwise directed to by law;

  • Appropriate parties in the event of emergencies: in particular to protect health and safety of you and others including where it is required to prevent serious risk to the health, safety or life of you or another;

  • You consent: in instances where you consent for example to provide a report to another medical professional, lawyer, or advisor, to discuss with another person connected with your treatment (including a spouse, parent or employer);

  • Third parties: in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation;

  • Independent contractors: including website designers, mailing and courier services, printers and distributors of direct marketing material and external advisors such as auditors, lawyers and debt collectors; and

  • Government related third parties: including Services Australia in connection with the payment and claim processing on behalf of the independent doctor.

How your Personal Information is stored

We may keep your Personal Information in physical and electronic form (or a combination) in accordance with the Privacy Act (subject to legal obligations). We will store and process your information securely using good practice physical, technical and administrative security measures.

Where your Personal Information is also kept by an independent doctor, how your information is dealt with is provided for under the doctor's privacy policy. We encourage you to read their privacy policy.  

Exchanging information, including Personal Information, by the internet is not completely secure. Although we will take reasonable measures to protect your Personal Information, we cannot guarantee the security of information you transmit, so any transmission is at your own risk.

How long your Personal Information is stored for

We retain the date we collect for different periods of time depending on what it is and how we use it. We generally keep you information for as long as needed to provide our services to the independent doctors, or as requested by the independent doctor, comply with legal, accounting or regulatory requirements or to deal with claims. We have a legal requirement to store your information for at least seven years from the time you had last contact with an independent doctor, or if you are a minor, until you turn 25 years of age.

Once your Personal Information is no longer needed (for example you no longer see an independent doctor at our premises), it will be destroyed (either by shredding physical documents or deleting electronic information from all servers, subject to any back-up records).

How you can correct your Personal Information

If you believe that any Personal Information that we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us in writing. It is your responsibility to advise of any changes to your Personal Information (for example change of residential address, email address or phone number). We will respond within a reasonable time (but being no more than 30 days after your request) and will endeavour to correct any Personal Information. You may request that you be provided with your Personal Information or it be deleted. Any written request by you cannot be unreasonably withheld. However, in some limited circumstances the requested corrections to Personal Information may be refused, in which case you will be provided with written reasons for this decision.

Access to your Personal Information

All individuals have a right to request access to their Personal Information. Please contact us if you would like to access your Personal Information. We will generally provide you with access to your Personal Information within a reasonable period (but being no more than 30 days after your request). Depending on the amount of information requested, we may charge an administration fee to cover the cost of retrieving the information and supplying it to you.

Access to Personal Information may be refused in a number of circumstances, such as where the information relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, you will be provided with a written explanation.

If you have any concerns about the way your Personal Information is stored, disclosed or otherwise managed, or believe that a breach of your privacy has occurred, please contact us in writing. We will respond to your concerns as soon as reasonably practicable (and no more than 30 days after your request). If you are for whatever reason not satisfied with the response or resolution of your concerns or complaint, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or by visiting www.oaic.gov.au.

Use of Commonwealth government identifiers

We will not use Commonwealth government identifiers (Identifiers) (for example, Medicare numbers) as an identifier of individuals. Identifiers will only be used or disclosed in the circumstances permitted by the Privacy Act.

Where your information will be held

Your data may be stored in different parts of the world, and your information may be transferred out of Australia]. Data protection laws vary by country. In the event that data is stored in another country, all reasonable steps will be taken to protect your information in line with locally applicable data protection requirements.

Cookies and Google Analytics

Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and which allow us to provide you with customised services. We use cookies and Google Analytics on our online services.

Google Analytics collects and processes data by using the website's cookies to analyse the use of the website including, for example, how long users spend on each webpage and collect other 'Online data' described above. This information is used mainly for the optimisation of the website to enhance the user experience, and to allow us to better deliver our services. The data collected by Google is transmitted to a server in the United States (or other countries outside of Australia).

You can review how Google uses data by clicking on the following link: https://policies.google.com/technologies/partner-sites

Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to refuse cookies. However, if you do so, you may not be able to take full advantage of our website.

Links to third party websites

Our website, email updates and other communications may, from time to time, contain links to and from the websites of others. The Personal Information that you provide through these websites is not subject to this Privacy Policy and the treatment of your Personal Information by such websites is not our responsibility. 

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

Definitions

In this Privacy Policy, the following terms have the meaning given to them below unless the context requires otherwise:

(a)   APPs: means the Australian Privacy Principles;

(b)   Personal Information: has the meaning given to it in the Privacy Act, which includes information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not or in a material form or not;

(c)   Privacy Policy: means this privacy policy as amended from time to time made available on the QOC website and available in physical copy upon request;

(d)   Privacy Act: means the Privacy Act 1988 (Cth) as amended from time to time;

(e)  Sensitive Information: has the meaning given to it in the Privacy Act, which includes information or an opinion about an individual's racial or ethnic origin, political opinions, religious beliefs, sexual orientation or criminal record;

(f)    QOS: Sharwood & Stewart Ophthalmology Services Pty Ltd ACN 629 565 644 trading as Queensland Ophthalmic Specialists; and

(g)   You/Your: means the individual who we collect the Personal Information from and about.