Privacy Policy

Introduction:

The Health Families for Life (HFFL) support team (Ethos Health Pty Ltd and HFFL Health Solutions Pty Ltd) respects and upholds your rights to privacy protection and is committed to fulfilling the requirements of the thirteen Australian Privacy Principles (APPs) in respect of the collection, use, disclosure and handling of personal and sensitive information. This Policy details how HFFL meets its privacy obligations.

Terminology:

‘Personal Information’ is any information recorded about a person where their identity is known or could reasonably be worked out. When dealing with HFFL this information may include (but is not limited to):-

  • Date of birth
  • Sex
  • Postal address
  • Personal email address
  • Home phone number
  • Mobile phone number
  • Work email address
  • Work phone number
  • Emergency contacts
  • Private Health Insurance membership number

‘Health information’ is a particular kind of ‘personal information’ and attracts additional privacy protection because of its sensitivity. Health Information includes information about a person’s health, disability, use of health services, or other personal information collected from someone when delivering a health service. The only health information collected and recorded by HFFL is information for which you have provided your prior consent. HFFL will not collect any health information on any person without their specific consent.

Sensitive health information that you may choose to provide to HFFL may include (but is not limited to):-

  • Pathology test (blood tests)
  • Blood pressure results
  • Medications
  • Height, weight, waist circumference
  • Food allergies / other sensitivities
  • Diagnosed chronic diseases (eg. type 2 diabetes, cardiovascular disease)
  • Medical conditions (eg.coeliacs disease, allergies, nutritional deficiencies)
  • Names of nominated healthcare professionals
  • Health Status Questionnaires

 

When does HFFL collect personal information?

HFFL may collect personal information (as described above, excluding health information) from you when you:

  • make contact with us through our website
  • contact our Customer Service team to make a consumer enquiry or complaint about a particular HFFL product or service
  • participate in a HFFL product assessment panel
  • enrol in a Disease Management Program co-ordinated by HFFL
  • undertake a self-assessment questionnaire hosted by HFFL

Where it is practicable, information is only collected directly from the individual concerned or their family.

 

When does HFFL collect health information?

HFFL will only collect sensitive health information from you (as described above) under the following circumstances after you have provided your consent:

  • during Disease Management Programs co-ordinated by HFFL
  • when you contact our Customer Service team to make a consumer enquiry or complaint about a particular HFFL product or service.
  • when you have undertaken a HFFL self-assessment survey and have agreed that you would like to be contacted to discuss the outcomes further.

 

Why does HFFL collect health information?

HFFL will only collect health information that is necessary to provide a health service, respond to your enquiry, complaint or requests, provide self-assessment reports and to adequately co-ordinate and manage the provision of products, tools and services for your use (with ongoing supervision from your own healthcare professional) in specific Disease Management programs that you may be enrolled in.

 

How will health information be used?

HFFL will only use collected health information for the purposes of:

  • providing you with the service(s) that you have enrolled in
  • providing health information that may be relevant to you
  • analysing and reporting on the effectiveness and acceptability of the health services provided by HFFL.

HFFL will not use any collected health data for any purpose unrelated to the purpose for which you provided it. Only de-identified aggregate data will be used in reports; no individuals will be identifiable.

 

Who is collecting the health information?

Health information will be collected by HFFL staff directly or via an online database (data is entered directly by the individual concerned). HFFL staff who have access to your health information must sign and abide by the HFFL Privacy Policy Compliance Agreement. The operational functioning of the online database is managed by a company that subcontracts to HFFL however they have no access to, nor visibility of, your health information.

 

Who has access to collected health information?

Only HFFL staff i.e. those responsible for delivering or reporting on Disease Management programs will have access to your health information. No identifiable health information will be provided (loaned, sold or otherwise) by HFFL to any other company or unauthorised individual unless you provide your explicit consent to do so. HFFL will not provide any identifiable health information to your employer or private health insurance company or any other parties unless you provide your explicit consent to do so. You can request access to your health information held by HFFL at any time. Also, you can ask for information about you to be corrected if it is inaccurate, incomplete, irrelevant, misleading or out-of-date. HFFL will take all reasonable steps to correct your information. Under certain legislation we must disclose patient information when required by or under an Australian law or a court / tribunal order.

 

How is information collected and stored?

Information is collected either in paper, or electronic form. This data is collected and accessed only with the authorisation of patients. Documents, other than those covered by the Control of Records policy, are filed in restricted storage areas and are destroyed as soon as is possible.

Electronic records are held on secure password protected computers and are protected by firewalls. Electronic records are permanently purged from all computer systems within 3 months of the relevant program being finalised. Your identifiable health information will not be transferred out of Australia.

 

Complaints or concerns:

If you have any questions, concerns or complaints about your privacy, including alleged HFFL breaches of your privacy please contact the HFFL Privacy Officer:

Nicole Hedditch (BPharm, BApp Sc, MPS)
Prima Health Solutions Pty Ltd
PO Box 7468 Warringah Mall NSW 2100
e: nicole@HFFLhealth.com.au
p: 1800 226 180

Chris Morton
Ethos health Pty Ltd
8 Denison Street Newcastle West NSW 2302
e: cmorton@ethoshealth.com.au
p: (02) 4962 8700

If you are not satisfied with the HFFL response to your complaint or concern you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC). The process for lodging a complaint can be found at https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint