VIVIR Healthcare Group Policy Document
VIVIR Healthcare Pty Ltd (referred to as “VIVIR, “us”, “we” or “our”) is committed to protecting the privacy of the personal information that we collect from you, respecting your rights to privacy and complying with the Privacy Act 1988 (Cth) (the “Privacy Act”) and other applicable laws protecting privacy including State and Territory legislation.
The Privacy Act provides you with a number of rights, including the right:
- to know why your personal information is being collected, how it will be used and whether it can be given to anyone else;
- to see what information is held about you and have it corrected if it is incorrect, out of date or incomplete;
- to have your personal information stored securely and protected from unauthorised access or misuse; and
- to know the complaints procedure if you believe your privacy has been infringed.
1. What is your personal information?
When used in this policy, the term “personal information” has the meaning given to it in the Privacy Act. Personal information means 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.
2. What personal information do we collect and hold?
In relation to us providing managed allied health services to aged and community providers, the personal information collected may consist of your name, address, telephone number, photo, email address, age or birthdate, a unique site access ID, company or educational affiliations, profession or occupation, qualifications, titles, contact information, information from your CV, employment records, details of our services you have used or enquired about and other information about you.
Sensitive information is a specific category of personal information, and, when used in this policy the term “sensitive information” has meaning given to it in the Privacy Act. Such information includes membership of a profession or trade association or of a trade union, health information, criminal record, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs and the like. We may need to collect, hold and disclose limited sensitive information about you, such as your criminal record, in relation to the specific requirements of your placement with our clients or direct engagement by us or to provide you with services.
In providing health services we may also collect some sensitive information/health information which is required to provide those services.
We may collect some de-identified information that is not personal information. This may include aggregated information about how users use the VIVIR Site, and anonymous answers to surveys.
3. How do we collect and hold your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. We can also collect personal information in a variety of ways, including via the VIVIR Site (such as when users register or apply for employment), when you respond to e-mail questionnaires or when you provide personal information to us by other means, such as in-person during conversations with our representatives, via your employer for the purposes of providing services to your employer, providing a business card, over the phone or by email.
We may also collect personal information from third parties including:
- our service providers;
- other service providers to you;
- business affiliates;
- clients; and
- other third parties such as employers and persons nominated by you as referees, credit agencies or government agencies.
Personal information is held by us in secure physical and electronic data systems.
4. For what purposes do we collect, hold and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality services.
In relation to the provision of managed allied services to aged and community providers, we collect, hold and disclose your personal information for the following purposes (in some cases we may only disclose information with your consent):
- to provide our services to you, including to fulfil your requests for information and employment opportunities and to manage the recruitment process for third parties and ourselves;
- to manage our client and business relationships;
- to provide assessment and other consulting services;
- to provide you important work related information including workplace health and safety, work rosters and other information relating to your engagement by VIVIR;
- to undertake psychometric testing;
- to perform statistical analyses of user behaviour in order to measure interest in specific areas and articles posted on the VIVIR Site. The e-mail addresses provided at registration allow us to send e-mails to individuals based on the areas of interest that they may indicate during the employment registration process.
In relation to the provision of services directly to aged and community clients, we collect, hold and disclose your sensitive information/health information in order to provide health and other services to you, with your consent or otherwise only as permitted by law.
In general, we also collect, hold and disclose personal information for the following purposes:
- to send communications requested by you, answer enquiries and provide information about existing or new services;
- to provide your updated personal information to related bodies corporate, our customers, contractors or service providers if such disclosure is required to administer our business functions or to provide our products and services to you;
- to update our records and keep your records up to date;
- to process and respond to any complaint made by you; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority of any country.
We will not intentionally disclose (and will take commercially reasonable steps to prevent the accidental disclosure of) your personal information to third parties, whether for such third parties’ marketing purposes or otherwise, except when we believe we are under a legal duty to do so.
If we are unable to collect your personal information, we may be unable to fulfil some or all of the purposes listed above. In particular, we may be unable to provide our services to you or provide you with full access to the VIVIR Site.
5. To whom do we disclose your information
We may disclose your personal information to:
- our customers;
- contractors or service providers if such disclosure is required to administer our business functions or to provide our products and services;
- our employees, related bodies corporate, contractors or service providers for purposes of operation of our website and to fulfil your requests including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors and professional advisors such as accountants, solicitors, business advisors and consultants;
- any organisation for any authorized purpose with your express consent;
- should we intend to merge with, or sell the majority of our assets or equity to a third party, personal information may be disclosed to that third party; and
- as required or permitted by law.
6. Are cookies and IP addresses used?
The VIVIR Site use “cookies” to identify you and your interests and to track usage of the VIVIR Site in order to help personalise your browsing experience. Cookies are small pieces of text stored on your computer that help us know which browser you are using and where you have been on the VIVIR Site and on website to which you may link in order to use some of our features. Cookies also let us know whether you have registered with us and otherwise enable us to relate your current usage of the VIVIR Site to your prior usage. If you do not wish to receive cookies, you can set your browser to refuse them. However, a user who does not accept the cookie from the VIVIR Site may not be able to access certain areas and may limit your use of the VIVIR Site and some of our services. In administering the VIVIR Site and diagnosing potential system problems, we also log all IP addresses which access the VIVIR Site.
7. Direct Marketing Materials
We may send you direct marketing communications and information about our products and services that we consider might be of interest to you. We will not use sensitive information for direct marketing without your prior written consent. These communications may be sent in various forms, including mail, SMS, fax and email in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method wherever practicable to do so. You consent to receiving direct marketing communications and information from us. However, at any time you may opt out of receiving marketing communications for us by contacting us (see details below) or by using opt out facilities provided in the marketing communications and then we will ensure that your name is removed from our mailing list.
We do not provide your personal information to other organizations for the purposes of direct marketing without your prior consent.
8. Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate, customers and third party service providers and suppliers located overseas for some of the purposes listed above. Those overseas entities may be located in the United Kingdom, New Zealand, Singapore, Hong Kong, Indonesia, India and China. If we disclosure your personal information to persons located overseas we will comply with the Privacy Act 1988 (Cth).
9. How can you access, change, and/or delete information?
You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for making the request or for making any corrections to your personal information. To do so, please contact your VIVIR representative or our Privacy Officer by the means set out in paragraph 12. We will then contact you to request sufficient information to allow us to confirm your identity. As soon as practicable after your request is received, we will give you access to your personal information.
There may be times when we cannot grant you access to the personal information we hold. For example, if access would interfere with the privacy of others or if it would result in a breach of confidentiality or law, we will not be required to grant you access. We will let you know if this is the case.
If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, you may request us to amend it by contacting our Privacy Officer. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it. You may also have your personal information deleted. You should be aware that we are required by law to retain certain personal information (such as payroll records); such information will not be deleted. We will let you know if we cannot delete your personal information for legal or other reasons.
Of course, if your personal information has been deleted and you wish to apply for another position through us, you will need to repeat the application process.
As the VIVIR Site is linked to the internet and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any information which you transmit to us online is transmitted at your own risk.
11. Links to third party websites
The VIVIR Site may contain links to third party websites as a service to our users. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. We encourage you to review and understand the privacy policies of the relevant third parties before providing any information to them.
12. Contact our Privacy Officer