Privacy Policy

  1. Purpose

BEDPOST Sleep Collective and its related bodies corporate (collectively “BSC”) respects your right to privacy. This policy sets out how we collect and manage your Personal Information.

BSC’s privacy obligations are governed by the Privacy Act 1988 (Cth) as amended from time to time (the Privacy Act) and the Australian Privacy Principles.

The purpose of this policy is to ensure that:

  1. the privacy of Personal Information, including Sensitive Information and Health Information is protected managed in an open and transparent way;

  2. information collected in accordance with this policy is used and disclosed only for relevant purposes; and

  3. access to and correction of Personal Information is appropriately regulated.

Terms that are capitalised in this policy have the meaning given to them in the Definitions in section 6 of this policy.

This policy is accessible at www.bedpostsc.com.au. If you provide information to us either via the BSC website or by any other means, whether verbal, written or electronic, you agree to our collection, handling, use and disclosure of that information in accordance with this policy.

  1. Scope

This policy applies to all BSC consultants, employees, clients and, to the extent relevant, a client’s attorney, guardian, personal and/or legal representative (described in this policy as the ‘person responsible’).

  1. Policy

3.1 Details of the Personal Information that BSC may collect

The Personal Information we collect, hold, use and disclose will depend on the relationship you have with us. The table below describes the types of Personal Information collected and held by BSC and the main ways in which we may use that information.

Information collected

Main use by BSC

For Clients receiving services from BSC 

Client’s name, address, contact details, medical history, medical diagnoses, previous assessments and advice, any information required to complete and update recommendations to medical professionals, family history, information pertaining to guardianship, attorney or person responsible, personal and religious preferences, financial details.

To ensure provision of services to all clients by BSC’s Clinical Physiologists. 

For medical practitioners and other health professionals

Name, business contact details, professional or practice details, historical record of business relationship, financial details, Medicare provider number details, other professional association membership details.

To ensure that details contained in Client’s records are accurate and up to date and to enable medical practitioners and allied health professionals to receive reports and information from the services delivered by BSC to clients. 

For applicants for employment with and employees of BSC

Name and contact details, professional qualifications and education, applicable licenses or certificates, prior employment history, references, and any other information that applicant chooses to provide.

To assess suitability of an applicant for employment with BSC and to create, update and maintain any employee records. 

For suppliers and other BSC business partners

Name and contact details, current and prior business history and dealings, internal governance information and such other information as BSC may obtain on request.

To comply with contractual and legislative obligations and ensuring timely payments to service providers and contractors. 

3.2 Methods of collection

BSC collects certain Personal Information, Sensitive Information and Health Information in a variety of ways, including:

  1. from our website; in person from Clients and from persons responsible where Clients do not have the capacity to provide the requested information;

  2. from medical professionals and allied health professionals to ensure consistent quality in the services provided to Clients;

  3. when you access the BSC website or from public sources and from private sources where it is necessary; and

  4. from any other person where we are required or authorised by law to collect the information from someone else.

BSC will own any Personal Information collected, whether directly, indirectly or via our website.

3.2.1 BSC website, webforms and analytics 

When you visit the BSC website, we may collect information such as browser type, operating system, website visited immediately before coming to our site. This information is used in an aggregated manner to assess how people use our site, so that we can improve our service. 

The BSC website allows you to complete web forms to, for example, request a consultation or sleep study. We collect Personal Information in the web forms you complete online. Web Forms are hosted under CLINIKO (Red Guava Pty Ltd ACN 147311466) on behalf of BSC.

In addition, like many companies, BSC uses “cookies” on its website to help us serve you better on future visits and to help us evaluate and improve the content and functions of our site/s. Cookies are very small files that a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. We use cookies to improve the experience of people using our websites. If you prefer, you can set your browser to refuse cookies from this and other websites that you may visit.

3.2.2 Links to Other Websites

The BSC website may contain links to other websites that are not owned or operated by BSC. You should carefully review the privacy policies and practices of other websites before providing any Personal Information through them, as we cannot control and are not responsible for the privacy policies or practices of third party websites that are not ours.

3.2.3 Google Analytics

BSC uses Google Analytics as a website analytics tool to collect data about how you interact with the BSC website, including:

  • device IP address (collected and stored in an anonymized format);

  • search terms and pages visited on the BSC website;

  • date and time when pages were accessed;

  • downloads, time spent on page and bounce rate;

  • referring domain and out link if applicable;

  • device type, operating system and browser information;

  • device screen size; and

  • geographic location (city).

This information will not ordinarily be personal information, because you will not be identified, or reasonably identifiable from it.

View https://policies.google.com/technologies/partner-sites

3.3 Use and Sharing of Your Personal Information

BSC uses Personal Information in accordance with the table above and generally also for the following purposes:

  1. to provide services to Clients;

  2. to enable medical consultants, allied health professionals and other consultants to provide streamlined services to Clients;

  3. to improve our services to Clients;

  4. to consider applications for employment; 

  5. to perform our obligations to employees;

  6. to perform our obligations under agreements with suppliers and consultants; and

  7. to comply with our legal obligations and to ensure that BSC meets any applicable governance requirements.

BSC may share your information with its related companies for the same purposes as set out above. BSC does not sell any Personal Information that you provide to us, to any third party and/or for any separate use by a third party.

BSC will not disclose your Personal Information, Sensitive Information or Health Information to other third parties except in the following circumstances:

  1. the third party was the original discloser of the Personal Information to BSC;

  2. to medical and allied health professionals as detailed in this policy;

  3. to regulatory bodies or agencies where BSC is legally obliged to do so;

  4. to law enforcement agencies, government agencies, courts or external advisers, where permitted or required by law;

  5. to third parties that assist us in providing services to Clients;

  6. if a Client is unable to consent to necessary treatment, to the person responsible in accordance with the Privacy Law; or

  7. with your express consent or as otherwise authorised by you.

3.4 Disclosure of Your Personal Information Overseas

BSC does not operate overseas however if we do disclose Personal Information to an overseas recipient, we will take all reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles unless:

  1. the overseas recipient is subject to similar laws to the Australian Privacy Principles and the individual has mechanisms to take action against the overseas recipient;

  2. we reasonably believe the disclosure is necessary or authorised by Australian Law; or

  3. you have provided express consent to the disclosure.

3.5 Security of Your Personal Information

BSC has implemented appropriate physical, electronic and administrative safeguards to protect your Personal Information from loss, misuse, alteration, theft, unauthorised access, or unauthorised disclosure. We evaluate our safeguards on an ongoing basis to help minimise risks from new security threats as they become known. However, we unfortunately cannot guarantee 100% security for Personal Information collected.

We expect our employees and contractors who handle Personal Information to comply with the Privacy Law and will take appropriate action in response to breaches of the obligations imposed by the Privacy Law and/or the Privacy Principles. 

3.6 Access to Your Personal Information

3.6.1 Right of access

Under the Privacy Principles, you have the right to obtain a copy of any Personal Information that BSC holds about you and to let us know of any error or inaccuracy in that information. In certain circumstances that are clearly defined in the Privacy Law, a person responsible may also obtain a copy of a Client’s Personal Information. We must be able to establish the identity of the individual seeking access to the Personal Information and, in the case of a person responsible, that the Client has consented to the person responsible obtaining access to the information on your behalf.

We will consider any recommendation by you or your person responsible to change or correct Personal Information and advise you or your person responsible of the action taken. You or the person responsible can access and update your Personal Information by contacting us in the manner set out in this policy.  We may charge a reasonable administration fee for this access.

3.6.2 Declining access

Please note that in circumstances prescribed by the Privacy Law, you or your person responsible may be refused access to your Personal Information.

As noted above, an individual’s identity must be established prior to allowing access to the requested information. If we are dissatisfied with the individual’s identity or access is requested from an unauthorised party, we can decline access to the information.

We can also decline access to information if:

  1. there is a serious threat to life or health of any individual;

  2. the privacy of others may be affected;

  3. the request is frivolous or vexatious;

  4. the information relates to existing or anticipated legal proceedings; or

  5. the access would be unlawful.

In these cases, we will provide you or, as appropriate, the person responsible for the Client with a written explanation for our refusal to provide access.

3.7 Complaints About Privacy

If you consider that any action taken by BSC breaches this policy or the Privacy Principles, you can make a complaint by contacting us by one of the methods set out in Section 3.8 of this policy. We take privacy complaints very seriously and will act promptly in response to a complaint.

3.8 How to contact us to make a comment or complaint about this policy

3.8.1 BSC contact details

You can contact BSC about a privacy related issue by phone, or email as follows:

Email: admin@bedpostsc.com.au

Phone: 04807120532

3.8.2 Office of the Australian Information Commissioner

The Office of the Australian Information Commissioner receives complaints under the Act. Complaints can be made:

Online: Lodge a privacy complaint with us | OAIC

http://www.oaic.gov.au/privacy/making-a-privacy-complaint

By phone: on 1300 363 992

In writing:

Address your letter to the Australian Information Commissioner at the:

Office of the Australian Information Commissioner

GPO Box 5288

Sydney NSW 2001

3.9 Updates to this policy

As we continue to provide additional services and as the Privacy Law and other laws change, it may be necessary to revise or update this policy. We encourage you to review this policy from time to time so that you are familiar with any changes. You may contact us to obtain the latest copy of this policy at any time.

  1. Measures

 

Outcomes of this policy will be measured through review of feedback from people to whom this policy relates.