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Reimbursement.org.au Privacy Policy

This website, Reimbursement.org.au (the Website) is owned and operated by Wellspect HealthCare ("Wellspect"). The purpose of this Website is to (collectively the Services):

(a)  Provide general guidance as to the potential availability of certain medical funding schemes (the Information Services); and

(b)  Collect names for petitions to secure adequate reimbursement for clean intermittent catheters (the Petition Services).

Wellspect respects the privacy of individuals and is committed to protecting personal information that individuals provide. Wellspect is further committed to complying with the obligations of the Australian Privacy Principles (APP) as set out in the Privacy Act 1988 (Cth) (the Act). This document sets out when and how Wellspect will collect, hold, use and disclose an individual's personal information, which has been provided through this Website, as well as how an individual may contact Wellspect in relation to their personal information or in order to make a complaint about a breach of privacy.

1. What personal information may be collected.

1.1 Personal information is defined by the Act as 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. Examples of personal information might include an individuals name, address, phone number, email address, medical records, family details or any other information from which an individual could reasonably be identified.

1.2 The type of personal information which Wellspect might collect through this website can be split into two categories, as follows:

(a) The Information Services, which might include collection of personal information such as:

(i)     name;

(ii)    address;

(ii)    email address, or other appropriate contact details;

(iv)   gender;

(v)    family details, including personal information relating to, or about, an individuals next of kin;

(vi)   medical/dental records, including past and present illnesses;

(vii)  general financial details;

(viii) Other personal information which might be relevant for the purposes of a particular funding scheme provider.

(b) The Petition Services, which might include collection of personal information such as;

(i) name;

(ii) address; and

(iii) email address, or other appropriate contact details.

1.3 In addition to the above, Wellspect may collect sensitive information about individuals. Sensitive information is defined in the Act and includes information about an individual's health, amongst other information. Wellspect will generally only collect sensitive information when it is directly relevant to providing the services offers by this Website.

2 Collection of Personal Information

2.1 Wellspect will generally only collect personal information which relates to the provision of the Services. Generally Wellspect requires that personal information is only provided by the person to whom it relates, however in some circumstances it may be provided by a third party, for example a carer or guardian of the relevant person.

2.2 In circumstances where you are providing personal information to Wellspect which relates to a third party, you warrant that you have that third party's permission to provide their personal information.

2.3 When necessary, if an individual is required to register in order to use Wellspect's website or to otherwise complete an online application form (e.g. to obtain e-mail updates) then Wellspect will collect personally identifiable information about the individual, such as their name, e-mail address, country of residence and other information which they voluntarily submit.

2.4 While an individual may choose not to provide personal information to Wellspect, failure to do so may hamper the provision of the Services. Generally failure to provide personal information will result in Wellspect being incapable of providing Services, or may result in incorrect information being provided to the relevant individual.

3. Use of Third Party Services in Collection

3.1 In order to collect personal information we may, from time to time, use the services of third party software providers. This includes the use of services provided by Google Inc. to collect and collate personal information provided on this website.

3.2 Such services may, and often do, result in copies of your personal information being collected and stored by such third parties. This may involve storage in servers located in Australia, or internationally. Given the nature of the services provided it is not possible to determine accurately which countries will contain the relevant servers.

3.3 Any personal information collected using such third party services will be subject to the privacy policy of the relevant third party provider. While Wellspect will take all reasonable steps to ensure that your personal information is used in accordance with this Privacy Policy, it cannot control all information collected or stored by third parties pursuant to this Clause.

3.4 If you have any concerns regarding the collection of your personal information by third parties, in accordance with this clause, you should not provide any personal information by using this website. This may result in Wellspect being incapable of providing Services to you.

4. Use and Disclosure of Personal information.

4.1 Wellspect uses and discloses personal information for the purpose of, or in relation to, providing the Services. In particular, personal information collected for the purposes of providing the Petition Information may be disclosed to third parties who do or might provide funding referred to in the relevant Petition.

4.2 Wellspect may also use or disclose personal information in the following circumstances:

(a) where an individual has given consent; or

(b) where use or disclosure is required or authorised by law.

4.3 Wellspect is committed to the appropriate use of sensitive information about an individual. Unless otherwise consented to by the relevant individual, any sensitive information will only be used for the purposes of providing the Information Services.

4.4 From time to time Wellspect may disclose personal information to a variety of third parties in relation to the provision of products to individuals. Potential third party recipients may include:

(a)    Wellspect's legal and financial advisers;

(b)    Wellspect's Insurers;

(c)    Government agencies, for the purposes of providing the Petition Services;

(d)    Any third party with a lawful entitlement to the information.

Whenever Wellspect discloses personal information to a third party it will take steps that are reasonable and practicable in the circumstances to either:

(e)    limit the disclosed personal information to the minimum required to fulfil the purpose of the disclosure; or

(f)     where appropriate, de-identify the personal information prior to disclosing it to a third party.

4.5 An individual may agree to provide their personal information directly to third parties in connection with the Services, in order to access and/or use the third party's products and/or services. If an individual agrees to provide such information to these third parties, then their personal information will be subject to the third party's privacy policies.

5. Overseas Recipients

5.1 Wellspect is a part of Dentsply International, which operates in the following countries:

(a)  Australia;

(b)  Austria;

(c)  Belgium;

(d)  Denmark;

(e)  Finland;

(f)   France;

(g)  Germany;

(h)  Italy;

(i)    Netherlands;

(j)    Norway;

(k)  Spain;

(l)    Sweden;

(m) Switzerland;

(n)  The United Kingdom; and

(o)  The United States Of America.

5.2 While it is not Wellspect's ordinary practice to do so, from time to time Wellspect may provide personal information to other companies, located in one or more of the above countries, which form a part of Dentsply International for the purposes of product development and/or quality control.

5.3 Prior to disclosing personal information to an overseas recipient Wellspect will generally either seek your consent, ensure that the recipient abides by the APP or ensure that the entity is bounds by restrictions on the use of personal information that are substantially similar to the APP. In addition wherever reasonable and practicable Wellspect will either limit the personal information disclosed to that which is absolutely necessary or will undertake to de-identify the information prior to its disclosure.

6. Direct Marketing

6.1 Wellspect does not sell, trade or transfer personal information to third parties for the purposes of direct marketing.

6.2 Wellspect may from time to time use personal information, including sensitive information, to notify individuals of changes to the Services, or to bring to that individual's attention new or additional information which may be beneficial to them. All such communications will include an option for the recipient to opt out of receiving any future direct marketing.

7. Security.

7.1 Wellspect is concerned with the security of your Personal information and is committed to taking reasonable steps to protect it from unauthorized access and use. To that end, Wellspect has put in place appropriate physical, electronic and managerial policies and procedures to secure personal information. These policies and procedures include, but are not limited to:

(a)    storing any electronic information on password protected and secure servers;

(b)    ensuring any physical copies of personal information are kept in a secure area which is not open to unauthorised access;

(c)    requiring Wellspect employees to enter into confidentiality agreements requiring they ensure the security of personal information; and

(d)    ensuring that any access to personal information by Wellspect employees is limited to those employees with a need to know that information for the provision of products to the relevant individual;

7.2 Personal information may be retained for 7 years or such other period as required by taxation or other laws.

8. Accuracy of Personal Information

Wellspect is committed to ensuring that all personal information held is accurate, complete and up-to-date. To that end Wellspect may from time to time contact individuals directly for the purposes of verifying their information.

9. Access to and Correction of Personal information

9.1 Individuals have a right to know what of their personal information Wellspect holds. Individuals may request this by contacting Wellspect's Privacy Officer by the following methods:

Phone: 1800 622 492,

Email: nurse-au@wellspect.com

Mail addressed to:

Privacy Officer
Wellspect HealthCare
PO Box 6071
Pymble NSW 2073
Australia

9.2 When requesting access or correction of personal information Wellspect will require an individual to verify their identity by reference to their personal information. In some circumstances it may be necessary for an individual to visit Wellspect's location to properly verify their identity before access to personal information can be granted.

9.3 While Wellspect will attempt to respond to a request for access to personal information in a timely manner, given the wide array of Wellspect's products provided, it may take some time to collect an individual's personal information and make it available. Individuals can help to minimise delays by providing details of what information they require access to, how and when they have provided information to Wellspect in the past and the general nature of any dealings between them.

9.4 When a request for information is received, Wellspect will endeavour to provide an accurate estimate of the time it may take to comply with the request, however, compliance with this timeframe is not guaranteed.

9.5 While Wellspect will generally comply with an individual's request for access to personal information about them, Wellspect does have the right under the APP to refuse access in certain circumstances. In the event that access is refused Wellspect will, where reasonable, provide reasons for the refusal, along with alternative methods which may allow access.

9.6 In addition to requesting access to personal information individuals may request that Wellspect correct any personal information held about the individual. Once the individual's identity has been verified Wellspect will take reasonable steps to correct their personal information.

10. Anonymity and Pseudonymity

While the APP does allow individuals to deal with an entity anonymously or by use of a pseudonym, Wellspect may be unable to provide the Services to a particular individual without confirming their identity. In particular, the Petition Services require that an individual provide their actual name and some form of contact details.

11. Complaints

11.1 If an individual wishes to make a complaint about Wellspect's collection, use or disclosure of any personal information, or about any potential breach of an APP, the individual may contact the Privacy Officer by use of the contact details at the end of this document.

11.2 When making a complaint an individual should include as many details as possible, including the nature of the personal information concerned, how it is believed to have been misused, which APP is believed to have been breached (if relevant), the details of any Wellspect employee or representative involved and any other information which may be relevant. The Privacy Officer may request additional information to enable the Privacy Officer to properly investigate the complaint and take such reparatory action as necessary.

11.3 Once a complaint is received the Privacy Officer will investigate the circumstances of the complaint and determine whether a misuse of personal information has occurred and if so how it may be rectified and whether/what action should be taken in relation to any Wellspect employee or representative involved. Wellspect will endeavour to keep the individual informed regarding the process of their complaint and any action taken.

11.4 Should an individual not be satisfied with Wellspect's handling of their complaint then Wellspect will generally agree to the complaint being referred to mediation and/or arbitration. Should the matter remain unresolved then an individual is entitled to refer their matter to the Office of the Australian Information Commissioner.

12. Use of Cookies

Cookies are small files which are sent to an individual's web browser and stored on their computer's hard disk. If an individual is required to register to use Wellspect's website, then cookies will be created and transferred to their hard disk upon first registration. Cookies are subsequently used to identify the individual's computer and allow repeated access to the website without having to re-register each time. The cookie is used purely to speed up an individual's access to the website and the information they wish to see. The majority of web browsers accept cookies, but individuals can usually change the browser settings to prevent the transfer, though some functionality may be lost.

13. General.

If you have questions regarding this Privacy Policy, please contact Wellspect's Privacy Officer by the following methods:

Phone: 1800 622 492,

Email: nurse-au@wellspect.com

Mail addressed to:

Privacy Officer
Wellspect HealthCare
PO Box 6071
Pymble NSW 2073
Australia