Privacy Policy

Hear and Say Privacy Policy

Hear and Say Limited ACN 058 430 069 (referred to in this document as Hear and Say, we, us or our) recognises that your privacy is very important. You have trusted us to take care of your hearing, speech and other related health needs and we are equally committed to protecting the personal information we collect from you.

When we refer to you, we mean the person whose personal information we collect, including but not limited to visitors to our website, and users of our services.

The Privacy Act 1988 (Cth) (Privacy Act), and the Australian Privacy Principles (APPs) govern the way in which we must manage your personal information and this policy sets out how we collect, use, disclose, and otherwise manage personal information about you.

Definitions

“Health information” has the same meaning that it has under section 6FA of the Privacy Act.

“Personal Information” has the same meaning that it has under section 6 of the Privacy Act, namely information or an opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual.

“Sensitive Information” is a subset of personal information that includes, among other things, health information, and has the same meaning that it has under section 6 of the Privacy Act.

Terms not otherwise defined in this Privacy Policy have the same meanings provided for in the Privacy Act.

What type of personal information does Hear and Say collect?

To provide the best possible experience, Hear and Say may ask you to provide personal information. We may collect the following information about you, among other things:

your full name, date of birth, gender, health fund details, Medicare number, and relevant information from government agencies (such as Centrelink, Department of Veterans Affairs, Hearing Australia and/or Queensland Health);
contact details, including address, phone number, facsimile number and email address;
health information, including but not limited to hearing test results, speech and language assessments or results, diagnostic information, past and present health conditions, prescribed medication and treatments, hearing technology utilised, family history, and any other health information provided by you or your healthcare provider;
demographic information, such as cultural heritage and first language;
your bank account and payment details;
information about your lifestyle, occupation/employment and hobbies;
details of your visit to our website and any transactions you carry out or forms you fill in on the website;
information collected for employment purposes or if you apply for a position with Hear and Say; and
any other information you have voluntarily provided to us.

For certain services, Hear and Say is required to collect specific information as part of our legal and regulatory obligations, including without limitation, under the Health Practitioner Regulation National Law (Queensland) as enacted in the National Code of Conduct for Health Care Workers (Queensland). If you refuse to provide us with this information, we may not be able to provide health services to you.

Some personal information we collect is sensitive information. Sensitive information extends to health information including things like medical history, and health conditions. Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out further below.

How does Hear and Say collect information

Hear and Say will generally collect personal information directly from you in various ways, including but not limited to:

when you visit a Hear and Say Centre for a service or to purchase or enquire about products;
when you visit the Hear and Say website or subsite;
when you register for or attend a Hear and Say event, pop-up, or privately arranged service;
when you book a service or make an enquiry over the phone, through our website, or other electronic means;
when you make a gift, donation or award a grant, over the phone, through our website, or other electronic means;
when you enter our competitions and promotions;
when you apply for a position with us;
when you provide customer feedback surveys, lodge a complaint, and communicate with our Business Support Team;
when authorised people provide us with your personal information on your behalf; and
otherwise through the use of any of our standard forms, over the internet, via email, or through a telephone conversation with you.

Your personal information may also be collected on occasions through third parties (however, we will seek your consent prior to doing so, unless authorised or required to collect the information by law) including but not limited from:

employment recruitment agencies;
health insurers or Government agencies (for instance, to receive advice about your eligibility for rebates on Hear and Say services);
schools or other education providers; or
other professionals such as, audiology professionals, speech professionals, and health practitioners.

There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.

Information collected from visitors to our website

When you use our website, Hear and Say may collect information about our website users collectively, which may include data about your location (i.e. city and country through your device’s IP address), internet browser type, domain name, language, operating system, service provider, screen resolution and whether you are visiting for the first time or revisiting our website. This data is anonymously collected and only used in aggregate, and as such no identifying information is collected. Hear and Say uses this information to help improve our website and its usability and to help us determine what is most beneficial to our users so that we can provide you with the best possible experience.

Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites, and linked websites are not subject to our privacy policies and procedures.

Our website uses cookies. The main purpose of cookies is to identify users and to prepare customised web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve you more effectively.

How and why does Hear and Say use your personal information?

To provide you with the best possible experience, Hear and Say may use the personal information collected from you. Generally, we will collect, use and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the following purposes:

to contact you, manage our relationship with you, respond to your enquiries, or verify your identity;
to book, confirm, and remind you of your appointments;
to perform examinations, assessments, and other related allied health services;
to provide other products and services you have requested;
to deliver goods and services to you via our website;
to process credit and debit card payments via third-party payment card processors such as Stripe and PayPal (we do not hold this information);
to respond to your requests, complaints, or enquiries and other customer care related activities;
to evaluate, develop, and enhance our websites, services and our operations;
to conduct surveys, market research, and send out feedback requests to help us improve our service to you;
to conduct research activities which may include publications;
to conduct website and system administration, such as for the technical support of our websites and computer systems;
to undertake direct marketing such as providing information to you about offers, services, products, events, and fundraisers that we think may be of interest to you or conducting surveys including by mail, email, SMS, social media, or other forms of communication. You can unsubscribe from these communications at any time;
to manage our obligations with funding bodies as part of our funding agreements, including reporting and updates on how gifts or donations are helping;
to contact you about changes to our service that could affect or inconvenience you;
to comply with a legal or regulatory requirement or in connection with legal proceedings or at the request of a regulatory body; and
to carry out general administrative requirements and other activities connected with the running of our business, including fraud prevention and detection and health and safety matters.

We may disclose your name and contact details, to third-party providers (such as Facebook and Google) to enable us to display marketing to you via such platforms, to allow us to monitor how effective our advertisements are, and to help us target our advertisements more effectively.

Where we do this, we require social media providers only to use your information for the purposes of enabling us to display marketing to you through their site and to monitor how effective our adverts are and ensure that our adverts are targeted at the correct people or types of people - not for any of their own purposes. You can update your social media privacy preferences within each of your personal social media accounts.

Research, analysis and management, funding, and monitoring of our services
We are permitted to collect health information for research that is relevant to public health or safety, analysis of statistics, or the management, funding, or monitoring of our health service. We undertake these types of activities to improve hearing health, educate, promote listening and spoken language development, set clinical benchmarks, and prevent and manage hearing loss and/or diseases.

Sensitive information
We collect sensitive information for the primary purpose to provide health services to you. Sensitive information will be used and disclosed only for the primary purpose for which it was provided, or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (for example, where required by law, necessary for the protection of a person/persons, or one or more enforcement related activities conducted by, or on behalf of, an enforcement body).

Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking.

Anonymity/Pseudonym

Where possible and to accommodate your preference, Hear and Say will give you the option of not identifying yourself or of using a pseudonym. Hear and Say may not always be able to interact with you in this manner, especially where it is impractical or required by law to identify you before providing certain information (including to provide health services to you).

How and with whom might Hear and Say disclose personal information?

There may be times when we need to disclose your personal information to third parties for the purposes as set out above. Where appropriate, Hear and Say shall take such steps as are reasonable in the circumstances to de-identify the information prior to disclosure.

Hear and Say may disclose your personal information to third parties including but not limited to:

medical and other healthcare practitioners, including doctors, specialists, audiologists, and audiometrists and specific health bodies (such as Hearing Australia) who are providing or may provide services to you in the future;
health insurers, health authorities and regulators as permitted or required by law;
the Police and other law-enforcement agencies to prevent and detect fraud and criminal activities;
our insurers, Workcover, external auditors and investigators, and other persons assisting Hear and Say to protect and defend the rights and safety of Hear and Say, its customers, and the public;
your employer, if you have been referred to us as a hearing care customer;
our service providers, volunteers, and contractors who provide services to us including data processing, data washing, data hosting/storage, technical support, customer satisfaction surveys, appointment booking, printing, and fulfilment operations such as mail houses and other services that enable us to provide products and services to you;
our related entities or entities for whom we are acting as an agent or partner with, and anyone authorised specifically by you; or
to another organisation, if Hear and Say or its assets are acquired by that organisation.

Sometimes, third parties with which we may share personal information for the above purposes may be located in other countries, including but not limited to the United States of America, and Ireland.

If you are accessing our website from a country outside Australia, your information may be transferred outside Australia to that country. If we transfer your information outside Australia in this way, we will take reasonable steps to ensure that your privacy continues to be protected in a manner that is consistent with the laws of Australia.

Management and security of personal information

All personal information collected by Hear and Say is handled with utmost care. We take reasonable precautions to protect the security and integrity of your personal information. We regularly evaluate the risk of misuse, interference, loss, unauthorised access to, modification of, disclosure of, or disposal of that information. Accordingly, we take measures to minimise these risks to safeguard your personal information.

These measures include, but are not limited to:

holding all records (whether physical and/or digital) securely in accordance with Australian legislation and standards (as applicable);
storing electronic records of personal information in secure data storage facilities;
only allowing those with a reasonable need to access personal information to do so;
ensuring that each of our premises are appropriately secured to restrict access to personal information stored on-site; and
ensuring that our personnel are regularly trained on information security matters, the importance of protecting your personal information and what to do if something goes wrong in relation to personal information.

Although we take reasonable steps to maintain the security of our internet connections and safeguard your personal information, for reasons outside of our control, information transmitted to us over the internet may not be secure and we cannot guarantee that your information will be protected against unauthorised access, misuse or disclosure.

We do not accept any liability for disclosure of data due to errors in transmission, or improper actions or misuse of personal information by third parties to the maximum extent permitted by law.

Hear and Say accepts no responsibility or liability for third parties such as payment card processors, advertisers or other entities who utilise banner ads and links from our website. As mentioned above, if you click through a banner advertisement or link and submit your information to an advertiser or other third party, you will be subject to the privacy policies of that third party (if any).

Hear and Say ensures that all employees and contractors are bound to keep your personal information confidential and to not use or disclose your personal information in a manner contrary to this Privacy Policy.

We retain your personal information in line with relevant legislation.

Hear and Say has procedures in place to ensure that any document or record containing your personal or health information is disposed of in a manner that preserves your privacy.

Accessing and updating your personal information

You have a right to request access to and correction of personal information held about you. You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access). We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

Hear and Say endeavours to ensure that the personal information it holds about individuals is accurate, complete up-to-date, and not misleading. If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please contact your local Hear and Say centre or our Privacy Officer via the below details if the information we hold about you is incomplete or inaccurate, or if you would like to request access. We will take reasonable steps to correct the information so that it is accurate, complete, and up to date.

If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

Privacy protocols

In protecting the privacy of our families and donors, we ensure they are well-informed about their rights and that we take our responsibilities seriously. In particular, we have implemented the following measures:

Privacy and confidential forms are part of all enrolment packs for families;
All forms of direct marketing have the option to ‘opt-out’;
The Privacy Policy is available through the Hear and Say website;
All individual clinical services are provided in a private room;
Paper files are stored in staff-only access rooms; and
Access by staff to personal or sensitive information is strictly controlled through passwords and documented procedures.

In addition to the above, we pay attention to the physical layout of our premises regarding privacy. We make the following provision for private interview space when interviewing clients or talking with them about matters of a sensitive or personal nature:

Clinical areas are locked with swipe access by staff members only;
Administration areas are secure; and
Alternative meeting rooms are available for face to face or phone calls that may contain sensitive conversations.

How to contact the Privacy Officer

If you would like to make an enquiry about this Privacy Policy, or a request to access and update your personal information, or believe that Hear and Say has not adhered to this Privacy Policy at any time and would like to provide feedback with this respect, please contact your local centre or our Privacy Officer in writing. Our Privacy Officer will endeavour to respond to your email within 48 hours.

The Privacy Officer
Hear and Say Limited
PO Box 930
Toowong QLD Australia 4066
Email: privacy@hearandsay.com.au

How to make a Complaint

If you wish to make a complaint about a breach of the Privacy Act, the APPs or a privacy code that applies to us, please contact us using the above details and we will take reasonable steps to investigate the complaint and respond to you.

If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Australian Information Commissioner (OAIC). To lodge a complaint, visit the ‘Complaints’ section of the OAIC’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the OAIC's office.

For more information about privacy in general, please contact the OAIC on 1300 363 992 or visit the OAIC’s website at www.oaic.gov.au.

All information which is held by Hear and Say is governed by the latest version of this Privacy Policy at all times. Hear and Say may change this Privacy Policy at any time without notice. We encourage you to check our Privacy Policy regularly so that you are aware of any changes.

Last updated September 2023. Version 4.1.

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Hear and Say Privacy Policy

Definitions

What type of personal information does Hear and Say collect?

How does Hear and Say collect information

Information collected from visitors to our website

How and why does Hear and Say use your personal information?

Anonymity/Pseudonym

How and with whom might Hear and Say disclose personal information?

Management and security of personal information

Accessing and updating your personal information

Privacy protocols

How to contact the Privacy Officer

How to make a Complaint

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