Privacy Policy
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Objectives of Privacy Policy
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The objectives of Travel Medicine Alliance’s Privacy Policy is to:
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communicate its personal information handling practices;
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give its patients, clients and staff a better and more complete understanding of the personal information it holds, and the way in which it deals with this personal information;
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detail its collection, storage, access to, use and disclosure of “personal information”, within the meaning of Section 6 of the Privacy Act 1988 (Cth), and how individuals can access and seek correction of this personal information.
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Definitions
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3.1 Personal Information
(1) Section 6 of the Privacy Act 1988 (Cth) defines personal information as:
“information or an opinion about an identified individual, or an individual who is reasonably
identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.”
3.2 Sensitive Information
(1) Personal information includes “sensitive information”, within the meaning of Section 6 of the
Privacy Act 1988 (Cth), which is a particular category of personal information. While Dr Deb The
Travel Doctor recognises that maintaining the confidentiality of all personal information is
important, sensitive information is often afforded a higher level of protection.
(2) Section 6 of the Privacy Act 1988 (Cth) defines sensitive information as:
“(a) information or an opinion about an individual’s:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual orientation or practices; or
(ix) criminal record;
that is also personal information; or
(b) health information about an individual; or
(c) genetic information about an individual that is not otherwise health information; or
(d) biometric information that is to be used for the purpose of automated biometric verification or
biometric identification; or
(e) biometric templates.”
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4. Personal Information Handling Practices
4.1 Collection of Personal Information Generally
4.1.1 Guarantee
(1) Dr Deb The Travel Doctor collects personal information in a fair and lawful way and in a manner
that is not unreasonably intrusive. This means Dr Deb The Travel Doctor will not use any form of
deception or threat when it collects personal information. When Dr Deb The Travel Doctor
collects personal information, it takes all reasonable steps to keep any inconvenience or intrusion
to a minimum.
4.1.2 Sources of Personal Information
(1) Dr Deb The Travel Doctor only collects personal information it requires in order to perform its
functions and activities. Dr Deb The Travel Doctor collects personal information from:
(a) individuals directly;
(b) other persons acting on behalf of an individual;
(c) third parties; and/or
(d) publicly available sources.
4.2 Solicited Personal Information
(1) Unless it is impractical to do so, before or when, or if this is not practical as soon as possible
after, Dr Deb The Travel Doctor solicits personal information about an individual, Dr Deb The
Travel Doctor will inform this individual, or their lawfully authorised representative:
(a) of the identity and contact details of Dr Deb The Travel Doctor if this personal information is
to be, is being, or was collected from a person acting on behalf of this individual or a third
party, and the circumstances of this collection;
(b) if the collection of this personal information is or was required or authorised by or under an
Australian law or a court/tribunal order, in such a way that includes the name of the
Australian law, or details of the court/tribunal order, that requires or authorises the collection;
(c) the purposes for which Dr Deb The Travel Doctor collects or collected this personal
information;
(d) the main consequences (if any) if all or some of this personal information is not collected by
Dr Deb The Travel Doctor;
(e) of any other entities or individuals, or the types of entities or individuals, to which Dr Deb The
Travel Doctor usually discloses this personal information;
(f) that this Privacy Policy contains information about how this individual, or their lawfully
authorised representative, may access this personal information held by Dr Deb The Travel
Doctor and seek the correction of this personal information;
(g) that this Privacy Policy contains information about how this individual, or their lawfully
authorised representative, may complain about a breach of the Australian Privacy Principles
(Schedule 1 of the Privacy Act 1988 (Cth)) by Dr Deb The Travel Doctor, and how Dr Deb
The Travel Doctor will deal with such a complaint; and
(h) whether Dr Deb The Travel Doctor is likely to disclose this personal information to recipients
within foreign countries, and if so in what country or countries such recipients are likely to be
located if it is practicable to specify those countries in the notification or to otherwise make
this individual, or their lawfully authorised representative, aware of them.
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4.3 Unsolicited Personal Information
(1) In some circumstances, individuals or entities provide unsolicited personal information to Dr Deb
The Travel Doctor. If this personal information could have been acquired via solicited means and
there is a need for this information, Dr Deb The Travel Doctor will retain this information and
advise the individual, or their lawfully authorised representative, of this in accordance with
Section 4.2 of this Privacy Policy. If Dr Deb The Travel Doctor does not require this personal
information, it will be de-identified, securely deleted or securely destroyed.
4.4 Personal Information Collection Channels
(1) Dr Deb The Travel Doctor collects personal information through a range of different channels
including:
(a) face to face meetings and consultations;
(b) telephone, email, and facsimile communications;
(c) paper-based and electronic forms (including online forms);
(d) Dr Deb The Travel Doctor’s websites (including online portals); and
(e) social media websites and accounts.
4.5 Kinds of Personal Information Collected and Held
(1) Dr Deb The Travel Doctor collects and holds various kinds of personal information including:
(a) patient records, reports and results;
(b) correspondence and other documents relating to requests for medical information and/or
advice;
(c) requests for access to documents held by Dr Deb The Travel Doctor and related
correspondence;
(d) correspondence from individuals and third parties;
(e) correspondence and other documents relating to complaints and other feedback provided to
Dr Deb The Travel Doctor;
(f) distribution and mailing lists relating to the dissemination of Dr Deb The Travel Doctor’s
publications, reports, newsletters and other information of interest to individuals;
(g) records relating to the performance of Dr Deb The Travel Doctor’s administrative functions
and activities;
(h) correspondence, invoices, receipts and other records relating to goods and services supplied
to Dr Deb The Travel Doctor;
(i) correspondence, invoices, receipts and other records relating to goods and services provided
by Dr Deb The Travel Doctor;
(j) correspondence and other documents relating to contracts, requests for tenders and other
procurement processes;
(k) records relating to personnel, payroll matters, recruitment, disciplinary and counselling
matters for Dr Deb The Travel Doctor’s staff, contractors and job applicants, including
security clearances and police record checks;
(l) records relating to occupational health and safety matters including accident and injury
records, compensation and rehabilitation case files;
(m) correspondence, curricula vitae, remuneration and travel records; and
(n) correspondence, reports and other records relating to internal and external audits and
compliance investigations.
4.6 How Personal Information is Held
(1) Dr Deb The Travel Doctor takes steps to ensure the personal information it has collected and
holds is accurate, up-to-date and complete. These steps include updating personal information
when Dr Deb The Travel Doctor is informed by the individual to whom the personal information
relates, or their lawfully authorised representative, this individual’s personal information has
changed, and at other times as necessary.
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(2) Dr Deb The Travel Doctor holds personal information it has collected for so long as is necessary,
provided it is practical for Dr Deb The Travel Doctor to hold this personal information. Personal
information held by Dr Deb The Travel Doctor, that Dr Deb The Travel Doctor has deemed is no
longer necessary or practical to hold will be de-identified, securely deleted or securely destroyed.
(3) Dr Deb The Travel Doctor’s staff may not access personal information unless they are doing so:
(a) in the course of performing their functions or activities; or
(b) in accordance with the processes of a court or tribunal.
(4) Dr Deb The Travel Doctor take steps to protect the personal information it has collected and
holds against loss, unauthorised access, use, modification or disclosure, and other misuse.
These steps include password-protecting access to its electronic information technology and
communications systems and holding paper files and charts in secure cabinets.
(5) Dr Deb The Travel Doctor may hold personal information electronically and physically with third
parties provided these third parties do not use or disclose this personal information unless
required by law.
4.7 Purposes for Which Personal Information Is Collected, Held, Used and
Disclosed
(1) In order to provide travel health goods and services it is necessary that Dr Deb The Travel Doctor
collects and holds a wide range of personal information.
(2) The purpose for which Dr Deb The Travel Doctor collects, holds, uses and discloses personal
information varies depending upon the function or activity being undertaken. The aforementioned
functions and activities include:
(a) providing medical goods and services;
(b) enabling third parties to provide goods and services for or on behalf of Dr Deb The Travel
Doctor, including but not limited to other medical practitioners and pathology providers;
(c) managing and responding to correspondence and enquiries from individuals and entities;
(d) undertaking health promotion activities and campaigns;
(e) assessing satisfaction with service provision;
(f) researching and evaluating programs and activities;
(g) conducting medical research or analysis relevant to public health or public safety;
(h) auditing Dr Deb The Travel Doctor’s programs and activities;
(i) informing the design and development of Dr Deb The Travel Doctor’s policies and programs;
(j) undertaking compliance with legal obligations;
(k) performing personnel functions including work health and safety obligations in relation to
Dr Deb The Travel Doctor’s staff;
(l) recruiting and engaging staff;
(m) investigating and responding to complaints about service provision; and
(n) lessening or preventing a serious threat to the life, health or safety of an individual, or to
public health or safety.
4.8 Contact between Individuals and Dr Deb The Travel Doctor
4.8.1 Contact by Individual
(1) Dr Deb The Travel Doctor must be certain of an individual’s identity before it can disclose their
personal information to this individual or their lawfully authorised representative. If an individual
contacts Dr Deb The Travel Doctor to discuss a matter that requires the disclosure of personal
information, this individual must be able to prove their identity. This ensures Dr Deb The Travel
Doctor is able to protect an individual’s personal information by only disclosing it to the respective
individual or someone who can prove they are lawfully authorised to act on this individual’s
behalf.
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(a) For example, if an individual telephones Dr Deb The Travel Doctor to discuss a matter that
requires the disclosure of their personal information, this individual can prove their identity by
providing their:
(i) full name;
(ii) date of birth; and
(iii) address (as notified to Dr Deb The Travel Doctor previously).
Other information can be used as proof of identity, depending upon the circumstances.
(2) If an individual has a general enquiry that does not involve discussing personal information, then
this individual does not have to provide identification.
4.8.2 Contact by Dr Deb The Travel Doctor
(1) If Dr Deb The Travel Doctor requests that an individual provide personal information to Dr Deb
The Travel Doctor this individual has the right to know why Dr Deb The Travel Doctor is
requesting this personal information.
(2) Generally, when Dr Deb The Travel Doctor collects personal information about an individual,
Dr Deb The Travel Doctor will inform this individual, or their lawfully authorised representative:
(a) if the collection of this personal information is required or authorised by or under an
Australian law or a court/tribunal order, in such a way that includes the name of the
Australian law, or details of the court/tribunal order, that requires or authorises the collection;
(b) the purposes for which Dr Deb The Travel Doctor collects this personal information;
(c) the main consequences (if any) if all or some of this personal information is not collected by
Dr Deb The Travel Doctor;
(d) of any other entities or individuals, or the types of entities or individuals, to which Dr Deb The
Travel Doctor usually discloses this personal information;
(e) that this Privacy Policy contains information about how this individual, or their lawfully
authorised representative, may access this personal information held by Dr Deb The Travel
Doctor and seek the correction of this personal information;
(f) that this Privacy Policy contains information about how this individual, or their lawfully
authorised representative, may complain about a breach of the Australian Privacy Principles
(Schedule 1 of the Privacy Act 1988 (Cth)) by Dr Deb The Travel Doctor, and how Dr Deb
The Travel Doctor will deal with such a complaint; and
(g) whether Dr Deb The Travel Doctor is likely to disclose this personal information to recipients
within foreign countries, and if so in what country or countries such recipients are likely to be
located if it is practicable to specify those countries in the notification or to otherwise make
this individual, or their lawfully authorised representative, aware of them.
4.9 Website Browsing Records
(1) When an individual visits Dr Deb The Travel Doctor’s website (www.thetraveldoctor.com.au),
Dr Deb The Travel Doctor will collect information from this individual’s website browser relating
to:
(a) their server address, operating system and top level domain name; and
(b) the date and time of their visit, the pages they accessed and documents they downloaded,
the previous site they visited, and the type of website browser they used.
(2) No attempt is made to identify individuals or their browsing activities except in the event of an
investigation where a law enforcement agency may exercise a warrant to inspect Dr Deb The
Travel Doctor’s internet web server logs.
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4.10 How to Seek Access To and Correction Of Personal Information
(1) An individual, or their lawfully authorised representative, has a right under the Privacy Act 1988
(Cth) to access the personal information that Dr Deb The Travel Doctor holds about this
individual. This right of access is subject to the ability of Dr Deb The Travel Doctor to refuse
access.
(2) An individual, or their lawfully authorised representative, can seek access to the personal
information that Dr Deb The Travel Doctor holds about this individual by emailing Dr Deb The
Travel Doctor at clinic@thetraveldoctor.com.au. There is no charge for making a request for the
provision of an individual’s personal information. For each distinct document to which access is
provided there is a charge of $38.50, this charge includes Australian Goods and Services Tax but
does not include any additional charges for printing or postage, if applicable. More information
about requesting access to personal information is available by telephoning +61 7 3221 9066.
(3) An individual, or their lawfully authorised representative, also has a right under the Privacy Act
1988 (Cth) to request the correction of the personal information that Dr Deb The Travel Doctor
holds about this individual. If an individual, or their lawfully authorised representative, seeks to
correct their personal information, they should contact Dr Deb The Travel Doctor via the contact
details provided in Section 4.10(2) of this Privacy Policy. Dr Deb The Travel Doctor will deal
promptly with this request in accordance with the Privacy Act 1988 (Cth).
(4) If an individual, or their lawfully authorised representative, requests access to, or the correction
of, the personal information that Dr Deb The Travel Doctor holds about this individual Dr Deb The
Travel Doctor will:
(a) respond to the request for access or correction within 30 days; and
(b) allow access or make the requested changes to this personal information unless Dr Deb The
Travel Doctor considers there is a sound reason under the Privacy Act 1988 (Cth) to refuse
the request for access, amendment or annotation of this personal information.
(5) If Dr Deb The Travel Doctor refuses to provide access, amend or annotate the personal
information that Dr Deb The Travel Doctor holds about an individual, the individual to whom the
personal information relates, or their lawfully authorised representative, may:
(a) seek a review of Dr Deb The Travel Doctor’s decision; or
(b) make a statement about the requested access, amendment or annotation and Dr Deb The
Travel Doctor will attach this to the record.
4.11 Disclosure of Personal Information to Recipients in Foreign Countries
(1) Dr Deb The Travel Doctor may disclose personal information to recipients in foreign countries. If
Dr Deb The Travel Doctor discloses an individual’s personal information to a recipient in a foreign
country Dr Deb The Travel Doctor will:
(a) take all reasonable steps to ensure the recipient does not breach the Australian Privacy
Principles (Schedule 1 of the Privacy Act 1988 (Cth)); or
(b) ensure the recipient is subject to a law, or binding scheme, that has the effect of protecting
this personal information in a way that, overall, is at least substantially similar to the way in
which the Australian Privacy Principles (Schedule 1 of the Privacy Act 1988 (Cth)) protect this
personal information, and there is a mechanism that the individual to whom this personal
information relates, or their lawfully authorised representative, can access to take action to
enforce the protection of such a law or binding scheme; or
(c) inform the individual to whom this personal information relates, or their lawfully authorised
representative, that neither Section 4.11(1)(a) or Section 4.11(1)(b) of this Privacy Policy
would apply if this individual’s personal information were disclosed to the recipient, and
subsequently obtain the consent of this individual, or their lawfully authorised representative,
for the disclosure of this personal information to the recipient.
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5. Complaints
(1) If an individual believes Dr Deb The Travel Doctor has breached the privacy rights of an
individual, they may contact Dr Deb The Travel Doctor and complain via the contact details
provided in Section 4.10(2) of this Privacy Policy.
(2) Dr Deb The Travel Doctor treats all complaints seriously, endeavours to resolve complaints fairly
and quickly, and will work with the complainant to resolve the complaint and keep them informed
of its progress. If an individual makes a complaint, we aim to contact this individual within five
working days.
(3) If an individual wishes to make a privacy complaint against Dr Deb The Travel Doctor, they also
have the option of complaining directly to the Office of the Australian Information Commissioner.
The Office of the Australian Information Commissioner’s details are:
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Post: Office of the Australian Information Commissioner
GPO Box 5218
Sydney, New South Wales, Australia, 2001
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