1. ABOUT THIS POLICY
1.2 MySmile Orthodontics is a specialist provider of orthodontic services and treatments.
1.3 We are committed to protecting your privacy and understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure and how individuals can seek to access and correct their personal information or make a complaint.
1.4 We will handle your personal information in accordance with this Policy, legislation including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) contained in the Privacy Act, as well as the Health Records and Information Privacy Act 2002 (NSW)].
1.5 In this Policy:
(a) personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.
(b) sensitive information is personal information that is about an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, or health, genetic or biometric information.
(c) health information is personal information that is about the physical, mental or psychological health of an individual, a disability of an individual, a health service provided to an individual (including information about the individua's expressed wishes about health care and any information collected to provide a health service), a donation of human tissue by the individual or genetic information which is or could be predictive of health of the individual.
1.6 This Policy does not apply to the personal information of our employees.
2. TYPES OF PERSONAL INFORMATION WE COLLECT
2.1 The types of personal information we collect about you depends on the dealings you have with us, and may include:
(a) name, address, email address and phone number;
(b) the name of the organisation you work for and your professional title;
(c) demographic information such as your location, age and gender; and
(d) your interests and preferences.
2.2 If you receive orthodontic treatment from us, we may also collect your:
(a) health information, such as referral and procedure details, dental and medical history, including that of your family where relevant, and information about consultations, examinations, tests, treatments and advice;
(b) Medicare and health fund details; and
(c) billing and account details.
2.3 If you are applying for a job with us, we may also collect your:
(a) employment history and qualifications;
(b) academic records;
(d) medical information;
(e) personal alternative contact details;
(f) superannuation fund details; and
(g) criminal history record.
3. DEALING WITH US ANONYMOUSLY OR USING A PSEUDONYM
3.1 Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question we will not record your name unless we need it to adequately handle your question.
3.2 However, for many of our functions and activities we usually need your name, contact information and other details to enable us to provide our services or products to you.
4. WAYS WE COLLECT YOUR PERSONAL INFORMATION
4.1 We may collect personal information from or about you in different ways, including:
(a) from you directly when you interact with us, eg from our discussions with you, when you complete a form, your emails and your interaction with our website;
(b) through third parties with whom we interact in order to provide our services, including referring and other practitioners involved in your care and treatment; and
(c) publicly available sources, including social media.
4.2 If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including:
(b) government departments to verify your entitlement to work in Australia;
(c) police agencies to obtain your criminal history record;
(d) academic institutions;
(e) superannuation fund provider;
(f) your current or previous employers; or
(g) your referees.
5. COLLECTION OF INFORMATION VIA OUR WEBSITE – COOKIES
5.1 A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
5.2 We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
5.3 Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
5.4 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
6. PURPOSES FOR WHICH WE COLLECT, USE & DISCLOSE PERSONAL INFORMATION
6.1 We collect your personal information for the following purposes:
(a) to provide our services and treatments;
(b) to manage and conduct our practice;
(c) to offer or promote our services and treatments, including through social media;
(d) to obtain feedback;
(e) to help us manage, develop and enhance our services and treatments;
(f) for research purposes in a manner which does not identify you;
(g) to consider your suitability for employment; and
(h) to comply with our legal obligations, resolve any disputes and enforce our agreements and rights with third parties.
6.2 We will use and disclosure your personal information for the above purposes, or otherwise with your consent or in accordance with relevant privacy laws.
7. DISCLOSING YOUR PERSONAL INFORMATION
7.1 In the course of providing our services and treatments to you, we may disclose your personal information to the following:
(a) our staff, consultants and contractors involved in the provision of services and treatments;
(b) organisations we contract to provide services to our practice or on our behalf such as software suppliers and marketing agents;
(c) anyone to whom part of all of our assets or businesses are transferred or sold;
(d) our professional advisers, including lawyers, accountants and auditors; and
(e) government agencies, regulatory bodies and law enforcement agencies, or other similar entities.
7.2 Some of these organisations may be located overseas.
8. DIRECT MARKETING
8.1 We may use your personal information to identify a product or service that you may be interested in or to contact you about a service, treatment or product. We may, with your consent, use the personal information we have collected about you to contact you from time to time whether by phone, email, SMS or through social media to tell you about new products or services and special offers that we believe may be of interest to you.
8.2 You can withdraw your consent to receiving direct marketing communications from us at any time by unsubscribing from the mailing list by clicking on the link in the marketing communication.
9. SECURITY AND STORAGE
9.1 We store your personal information in hard copy and electronically.
9.2 We take all reasonable and appropriate steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
9.3 We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.
10. ACCESS TO AND CORRECTION OF YOUR INFORMATION
10.1 We will endeavour to ensure that the personal information collected from you is up to date, accurate and complete.
10.2 You may request access to, or correction of, the personal information we hold about you at any time by contacting our reception team on (02) 9540 5888 or by emailing us at firstname.lastname@example.org. We will need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, we will provide you with access to the personal information you request within a reasonable time and usually within 28 days. If we decide to refuse your request, we will tell you why in writing and how to complain.
11.1 You can make a complaint in writing to email@example.com using the details set out in this Policy. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
11.2 If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.
12. CONTACT US
12.1 If you have a question or comment regarding this Policy or wish to make a complaint or exercise your privacy rights, please contact our reception team on the following details:
Dated: April 2021