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Privacy Policy

HCB Australia Privacy Policy

March 2024
Owner: The Board

In this Privacy Policy, the expressions ‘HCB’, ‘we’, ‘us’ and ‘our’ are a reference to HEALTH CLAIMS BUREAU (AUSTRALIA) PTY LTD (can 647 711 555).

This Privacy Policy applies to personal information collected by us. We are bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth) which govern the way private sector organisations collect, use, keep secure and disclose personal information.

The purpose of this Privacy Policy is to generally inform people of:

  • how and when we collect personal information.
  • how we use and disclose personal information.
  • how we keep personal information secure, accurate and up to date.
  • how an individual can access and correct their personal information; and
  • how we will facilitate or resolve a privacy complaint.

If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, we have put in place mechanisms and procedures for you to contact us so that we can attempt to resolve the issue or complaint. Please see Section 19 below for further details.

If you have any concerns or questions, please contact us and our privacy officer at https://www.hcbgroup.com.au/contact/ or write to us at 207 Richmond Road, Richmond, South Australia 5033 and our privacy officer will then attempt to resolve the issue.

We recommend that you keep this information for future reference.

What is personal information?

The Australian Privacy Act 1988 (Cth) (Privacy Act) defines ‘personal information’ to mean any 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.

The kind of personal information collected, used and disclosed by HCB

We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you unless an exception under the Privacy Act applies to that disclosure or use.

At or around the time we collect personal information from you, we will require your consent to us gathering the information and we will endeavour to provide you with details of how we will use and disclose that specific information. We set out some common collection, use and disclosure instances below.

Purpose of HCB collecting your data

General information we will collect

Personal and Contact information: Such as your name, residential address, communication address (if required and different to your residential address), email address and/or phone numbers, date of birth, medical history.

The uses we will make of the personal information collected include:

  • Identity verification: if required, the verification of your identity.
  • Services: the provision of our services to you or your Insurer or Employer, including:
    • using your personal information in order to provide the services.
    • to provide customer service functions, including handling customer enquiries and complaints.
  • General administrative and security use:
    • To protect HCB’s websites from security threats, fraud, or other criminal activities.
    • The use for the administration and management of HCB Australia and HCB Group.

The types of disclosures we will make of personal information collected include, but are not limited to:

  • Your Insurer or Employer in line with your consent and the services HCB provide.
  • HCB Service providers (including Doctors and Medical Practitioners and Consultants) who assist HCB in providing our products and services.
  • As required or authorised by Law.
  • Anonymised data may be used for data analysis by HCB.

Specific Purposes of HCB collecting your data

  1. Provision of our health and assessment services
  • Contact and identifying information:
    • Your name, address, billing address (if required), email address, phone numbers, marital status.
    • Alternative and emergency contact details (name, address, and phone number).
    • Details of required primary identification information (such as a current Australian driving licence).
    • Occupation and employment details.
    • Medical and employment information relating to the services we offer to you.
    • Your medical history, and current prescription medicines.
    • Any relevant history of past accidents or injuries.
    • The results of any assessment or test, or any diagnosis resulting from the provision of our services, as well as any medical or health related observations we make about you during the provision of our services.
    • Where applicable to the services we provide, details of your employment, your work environment, and daily duties.
  • Provision of our services: the provision of our health services to you, your employer, or your (or your employer’s) insurer (as may be applicable).

HCB try to limit any disclosure of sensitive information (explained in Section 10 below) we collect from you to circumstances where disclosure is required to effectively perform the services we provide, however we may disclose your personal information (including sensitive information):

  • To your Employer – Where we have provided our services to your employer.
  • To your Insurer – Where we have provided our services to your or your Employers insurer.
  • To third party providers who assist us in providing our services to you.
  • If required due to an emergency, immediate threat to life, health, or safety, or under a lawful order or similar authority, to a court, tribunal, medical institution or professional, or enforcement agency.
  • In the case of an emergency or if you do not have the capacity to make decisions about your own care, to a ‘responsible person’, generally your guardian, emergency contact.
  • Where our services relate to a claim, or potential claim, with a workers’ compensation organisation, that organisation (e.g. WorkCover etc).
  • As otherwise required by law.
  1. Human resources
  • Contact information: Such as name, e-mail address, current postal and residential address, phone numbers, country of residence, next of kin contact details.
  • Employee record information
  • Identifying information: Such as your photo, passport and residency details, date of birth.
  • Tax, superannuation and payroll information: Such as your Tax File Number and ATO Declaration, Superannuation details and financial institution details.
  • Background check information: Information obtained from you or third parties to perform background checks.
  • Medical or health information which you voluntarily provide to us as part of pre-employment medicals, random drug and alcohol testing or such other information which may be related to an incident which has occurred during your employment.
  • Performance related information: Pre-employment testing and other information collected by HCB’s systems during the employee or contractor’s engagement with HCB. Information collected from referees.
  • Background checks: Where deemed appropriate by us, providing the information collected to our service providers for the purpose of assessing candidate suitability for role, including by obtaining:
    • Verification of your identity and age.
    • Criminal history background checks including publicly available information including Facebook, Twitter, Instagram, YouTube.
    • Confirmation of eligibility to work in Australia.
    • Confirmation of education and qualifications.
    • Confirmation of previous employment.
    • Consideration regarding medical leave.
  • Administration and performance monitoring use: Utilising the information collected for the purpose of:
    • Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be).
    • Use of such information whether or not the employment or contractor relationship is prospective, current or past.
    • The use of your personal information collected in the administration and management of HCB.
    • In connection with the sale of any part of HCB’s business or a company owned by an HCB entity.
  • We may disclose your personal information to:
    • Relevant superannuation company.
    • Government agencies, including but not limited to The Australian Taxation Office, Centrelink, and Child Support Agency.
    • Relevant Worker’s Compensation organisation (e.g. WorkCover etc).
    • Third party referees provided by you in connection with an application made to HCB.
    • Service providers (including medical service providers
    • Third parties in connection with the sale of any part of HCB’s business or a company owned by a HCB’s entity.
    • Third party parties in connection with obtaining any background checks, pre-employment screening.
    • Financial institutions for payroll purposes.
    • As required or authorised by law.

How HCB Collects and holds Personal Information

  1. Collection Generally

As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your personal information directly from you. Depending on the circumstances and the nature of the services we are providing in respect of you, we may collect your personal information from:

  1. a referring medical provider, and independent medical services provider (such as an IME), or other health or medical third party in order to provide our services effectively; and
  2. an insurer of you or your employer (such as Workcover).

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information, or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.

  1. Other Data Collection Methods

We may also collect personal information about you from other sources. Some examples of these alternative collection events are:

  1. when we have been engaged by your current or prospective employer to conduct health, medical, or drug or alcohol screening or training, some details about you may be provided by the employer.
  2. where your background health information is collected from another individual to assist you during a medical emergency; or
  3. when we collect personal information about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, the White Pages directory, online search engines and social media platforms (such as Facebook, Twitter, Instagram etc).

Where medical service providers, HCB Case Managers and Employers use our HCB IT platform as part of their business dealings with HCB, they may collect your personal information and input it into the HCB IT platform. These parties   may have access to your personal information for administrative purposes in connection with the services they provide to HCB.

  1. Notification of Data Collection

You will be advised of the data collected and its use as part of the Consent you provide to HCB to provide the relevant services.  Generally speaking, and after you have provided Consent to HCB to collect your personal data, we will not tell you when we collect additional personal information about you for example in the following circumstances:

  1. where we are engaged by a third party to perform our services, such as your employer or an insurer (such as Workcover).
  2. where information is collected from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc), or
  3. as otherwise required or authorised by Law.
  1. Unsolicited Personal Information

In the event we collect personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by HCB that the personal information is not required, we will destroy the information or ensure that the information is deidentified.

If the unsolicited personal information collected is in relation to potential future employment with HCB, such as your CV, resume or candidacy related information, and it is determined by HCB (in its absolute discretion) that it may consider you for potential future employment, HCB may keep the personal information on its human resource records.

  1. How we hold your Personal Information

Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third-party service provider who have taken reasonable steps to ensure they comply with the Privacy Act 1988 (Cth). We provide some more general information on our security measures in Section 18 below (‘Data Security and Quality’).

  1. Cookies and IP Addresses

If you use our website, we may utilise ‘cookies’ which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.

We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.

However, in some cases, cookies may enable us to aggregate certain information with other personal information we collect and hold about you. HCB extends the same privacy protection to your personal information, whether gathered via cookies or from other sources, as detailed in this Privacy Policy.

You can set your browser to notify you when you receive a cookie, and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved web site experience that cookies offer.

  1. Uses and disclosure of Personal Information

 Use and disclosure details

We provide a detailed list above of some common uses and disclosures we make regarding the personal information we collect.

Other Uses and Disclosures

We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:

  1. when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose.
  2. if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health, or safety or to lessen or prevent a threat to public health or safety.
  3. if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
  4. if it is required or authorised by law.

Please be aware that, where you do not have capacity to make decisions about your medical care, we do not need your consent to disclose your personal information relating to your health to the person who is responsible for your care, usually your legal guardian or doctor.

  1. Use and Disclosure Procedures

In the event we propose to use or disclose such personal information other than for reasons set out in the above table or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

Your personal information is disclosed to these organisations or parties only in relation to the products or services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your personal information.

  1. Communications Opt-out

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the top of this document and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.

  1. Sensitive information

Sensitive information generally

Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, and health information about an individual. HCB treats all personal information as sensitive personal information.

  1. Collection and use of Sensitive Information

Given the services HCB provide, it is likely we will collect sensitive information from you or others in order to carry out the services provided to you. However, any sensitive information is provided to HC with your Consent,

The type of sensitive information we may collect about you is dependent on the services provided to you by HCB will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you in the table at above.

We do not use sensitive information to send you Direct Marketing Communications without your express consent.

  1. Consent

We will require your Consent prior to HCB collecting processing and storing your personal and sensitive information.

  1. Storage and Access.

We will store any information you provide us, or which we obtain about you, with any other personal information we may hold about you.

Data will be gathered, processed and stored in Australia (see 16 below).

You may request to access or correct your information.

  1. Complaints

If you wish to make a complaint, please contact us at https://www.hcbgroup.com.au/contact/

  1. Anonymity and pseudo-anonymity

Given the sort of services we provide, it is generally not practical for HCB to correspond with you, or provide our services to you, in an anonymous manner or when you use a pseudonym. Your personal information may be required in order to provide you with our services or to resolve any issue you may have.

  1. Cross Border Disclosure

Personal information will be processed in and stored in Australia.

Any personal information collected and held by HCB Australia may be disclosed to HCB Group UK, where our parent company is located.  Any personal information shared with HCB UK will be subject to the same Privacy Principles as apply to HCB Australia.

All your personal information will be processed and stored in Australia.

  1. Provision of Informed Consent

Prior to providing personal information to HCB, you will be asked to provide your Consent to HCB for HCB collecting, processing, storing, and transmitting your data.

The Australian Privacy Act 1988 requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act 1988. By providing your consent, under the Privacy Act 1988, we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information when being collected by HCB or transmitted to or received from relevant third parties is handled securely and in accordance with the terms of this Privacy Policy.

  1. Data Security and Quality

HCB’s security generally

We have taken steps to ensure your personal information is gathered, transmitted, and stored securely. Your personal information is processed and stored in Australia but may be shared with HCB Group UK for the purposes of analysis or service support.

Notwithstanding the above, we will take reasonable steps to:

  1. make sure that the personal information we collect, use or disclose is accurate, and complete at the date it is provided to us.
  2. protect your personal information from misuse, loss, and unauthorised access.
  3. destroy or permanently de-identify personal information if it is no longer needed for the provision of services or if requested by you, your Insurer or Employer accuracy.

The accuracy of personal information depends l on the information provided to us at the point in time where we provide services, so we recommend that you:

  1. let us know if you feel that there are any errors in your personal information you have provided to us or that we hold, and
  2. we provide information about how you can access and correct your information below.

Access to and Correction of your Personal Information

You are entitled to have access to any personal information relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act 1988 (Cth)). You are also entitled to ask HCB to edit and correct such information if the information is inaccurate, incomplete, irrelevant, or misleading.

If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via https://www.hcbgroup.com.au/contact/

Where accessing your personal information is particularly difficult, we may charge you a fee for providing that information to you equal to our costs in procuring what you have requested.

  1. Resolving Privacy Complaints

Complaints generally

We have put in place a mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously.

Contacting HCB regarding complaints

If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us:

Telephone: (08) 8352 6392

email: https://www.hcbgroup.com.au/contact/

Address: 207 Richmond Road, Richmond SA 5033

Please mark your correspondence to the attention of the Privacy Officer.

Steps we take to Resolve a Complaint

In order to resolve a complaint, we:

  1. will liaise with you to identify and define the nature and cause of the complaint.
  2. may request that you provide the details of the complaint in writing.
  3. will keep you informed of the likely time within which we will respond to your complaint, and
  4. will inform you of the legislative basis (if any) of our decision in resolving such complaint.

Register of complaints

We will keep a record of the complaint and any action taken will be recorded in a Register of Complaints.

  1. Consent, modifications, and updates

Interaction of this Policy with contracts

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such instances, HCB may incorporate the terms of this policy such that:

  • certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto HCB, but do create contractual obligations on the other party to the contract, and
  • Your Consent will be required to provide the services and if so, will form part of your, Insurers or Employers contract with HCB.
  1. Acknowledgement

Prior to HCB providing our services, you will be advised of our Privacy Policy as part of the Consent you provide to HCB.

Details of our Privacy Policy are available on our website.

  1. Modifications and updates

We reserve the right to modify our Privacy Policy as our business needs require.  Updates to the Privacy Policy are provided on our website.