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Choosewell Privacy Policy

Our commitment

Choosewell recognises your privacy is very important to you. We handle personal information provided by and about people every day. By personal information we mean information or an opinion about a person whose identity is apparent or can reasonably be ascertained.

We are bound by, and committed to supporting, the Australian Privacy Principles (APPs) set out in the Privacy Act 1988. Our aim is to both support, and ensure that we comply with the APPs that form the basis of laws introduced to strengthen privacy protection for the general public. The information set out below is largely a summary of our obligations under the APPs.

This statement provides information about how personal information you provide to Choosewell is collected, held, used, corrected, disclosed and transferred. You can obtain more information on request about the way we manage the personal information we hold. If you require any further information please contact us in one of the ways set out below.

Collection

In the course of our activities we may collect and hold personal information from our website users, prospective customers and customers. Our main purpose for collecting personal information is to provide relevant health insurance information and referrals.

We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.

Generally, collection of your personal information will be effected over the telephone or online. From time to time additional and/or updated personal information may be collected through one or more of those methods.

We will only collect personal information from you that is necessary for one or more of our functions and activities. The types of personal information we collect may include:

  • identifying and contact information, such as name, date of birth, residential address, email address and contact telephone numbers,
  • information about you and your partner/family members such as date of birth, employment (where applicable), claims history and insurance coverage status,
  • financial information, such as credit card details (we will not store credit card details),
  • where applicable, sensitive information such as information about your health and that of your partner/family members and whether there are any medical conditions and/or family medical history; and
  • information about your activities, including but not limited to sporting and other lifestyle interests.

We will only collect personal information from you by lawful and fair means, without being unreasonably intrusive.

At or before the time we collect personal information from you we will take reasonable steps to inform you of who we are, why we are collecting that personal information, who else we might disclose that personal information to and what will happen if you do not provide personal information to us. Failure to provide full and complete information we request may mean that we are unable to provide our services to you fully and properly.

Where reasonable and practicable, we will only collect personal information about you, from you. Once we hold personal information we will take reasonable steps to keep it accurate, complete and up-to-date.

Where we receive unsolicited personal information about you and we determine that we would not normally have collected the information had we solicited that information from you, we will, as soon as practicable but only if it is lawful and reasonable to do so, destroy or de-identify the information.

Use and disclosure

We will not use or disclose personal information collected by us for any purpose other than:

a) the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or

b) where you have consented to such disclosure; or

c) where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

We may use the personal information collected from you by Choosewell or a third party for the purpose of providing you with direct marketing material such as articles that may be of interest to you. You may, by contacting us by any of the methods detailed below, request the source of the personal information and/or not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned.

We may disclose your personal information to external contractors in the following circumstances:

  • Prosecuting or defending legal proceedings in which we are involved. eg. Common Law actions, Trade Practices, Australian Prudential Regulation Authority (APRA), Australian Taxation Office (ATO), Australian Competition and Consumer Commission (ACCC) etc.
  • Mail distribution and call centre facilities and the like who may be contracted by Choosewell to assist with the distribution of information to Choosewell clients.
  • Organisations conducting promotional, research or marketing activities to assist Choosewell to provide health insurance services and advice.
  • Contracted Affiliates who are required to fulfil an offer or promotion.
  • Health Funds which may provide services and advice directly to you.

Importantly, all companies to whom we disclose data can use the data only for these contractually agreed purposes and must handle the data in a confidential and secure manner in accordance with Australian privacy legislation. Currently, we use specialist services from suppliers located in the Philippines and India.

If you have any concerns about disclosure, you should contact us by any of the methods detailed below.

In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business.

Data quality

We may need to collect sufficient information to ensure appropriate and relevant health insurance information and advice can be provided to you. If you elect not to provide us with this personal information you may affect the adequacy or appropriateness of the information given to you.

Data Correctness

We will endeavour to ensure that, at all times, the personal information we hold about you is up to date and accurate. In the event that you become aware, or believe, that any Personal Information we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or out-datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information. If we refuse to correct the personal information we hold about you we will provide you with a written explanation for that refusal and the mechanisms available to you to complain about the refusal.

Data security

Your personal information is generally held in a computer database.

We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. All paper files are stored in cabinets, which are locked out of hours. Access to our premises is controlled, and after-hours access is allowed only to personnel with authorisation to access the premises. All computer based information is protected through the use of access passwords on each computer. Data is backed up and stored securely.

In the event that you cease to be a customer of this organisation, any personal information which we hold about you will be maintained in secure storage for a period of at least 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.

Access

You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity. In most cases the requested information will be provided to you without charge.

We will endeavour to respond to any request for access within 30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.

We will not provide you with access to your personal information if:

  • providing access would pose a serious threat to the life, health or safety of a person;
  • providing access would have an unreasonable impact on the privacy of others;
  • the request for access is frivolous or vexatious;
  • the information relates to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
  • providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
  • providing access would be unlawful;
  • denying access is required or authorised by or under law or a court/tribunal order;
  • we have reason to suspect the unlawful activity, or misconduct of a serious nature that relates to Choosewell’s functions or activities has been or is being engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter
  • providing access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body
  • providing access would reveal evaluative information generated within Choosewell in connection with a commercially sensitive decision making process.

In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal.

Privacy complaints

If you wish to complain about any breach or potential breach of this privacy policy or the Australian Privacy Principles, you should contact us by any of the methods detailed below. Your complaint will be considered within 14 days and responded to. It is our intention to use our best endeavours to resolve any complaint to your satisfaction; however, if you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner who may investigate your complaint further.

Website

Choosewell’s website may contain links to other (third party) websites whose operator may or may not adhere to a privacy policy or be governed by the Australian Privacy Principles. We are not responsible for the content or practices of third party websites linked from our site. These links are provided for your convenience only. We do not endorse any linked third party website and recommend that you check the privacy policies of these third party websites.

Our website may use cookies which allow us to identify your browser while you are using our site. Cookies do not identify you; they simply allow us to track usage patterns so that we can measure the level of interest in various areas of our site. All browsers allow you to be notified when you receive a cookie and elect to either accept it or not. Your Internet service provider should be able to assist you to set your preferences.

You need to be aware that there are risks associated with transmitting information via the Internet.

If you have registered with us through our website or a third party website and decide, at any time, that you do not wish to receive any further information from us, you can send an e-mail to the e-mail address noted below requesting to be removed from our database. Please allow 2 weeks for your request to be actioned.

You may amend or update your registration details by sending an e-mail to the e-mail address noted below providing your amended details. Please allow 2 weeks for your request to be actioned.

Where to go for more information

Choosewell
Email: privacy@choosewell.com.au
Telephone: 1300 421 154
Post: Privacy Officer
Choosewell Pty Ltd
PO Box 6793
Melbourne Vic 3004

Office of the Australian Information Commissioner (OAIC)
Email: enquiries@oaic.gov.au
Telephone: 1300 363 992
Facsimile: 02 9284 9666
Post: OAIC
GPO Box 2999
Canberra ACT 2601
Web: http://www.oaic.gov.au

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