Privacy Policy

1. Introduction
Your privacy and maintaining the confidentiality of your personal information is important to Us. We are committed to safeguarding Your personal information. This privacy statement explains what information We collect, how information is collected, used and handled, when information may be disclosed to third parties with Your consent, Your rights for requesting access to or amending Your personal information, as well as how you can provide Us with feedback or make a complaint. This document may be amended by Us from time to time.

2. Definitions
Consent means Your permission. Your consent can be express or implied. Express consent can be written (e.g. when you sign a form or send us correspondence) or verbal (e.g. when you give us your permission over the phone or in face-to-face conversations). Your consent will be implied when we can reasonably form a conclusion from our pre-established relationship with You that You have given consent by either taking action or deciding not to take action.

Personal information has the same meaning that it has under the Privacy Act 1988 (Cth), namely information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

3. Information We Collect
We will only collect information that is necessary for providing our services to You. We will only collect information that is necessary for the purposes for which it will be used. The amount and type of personal information We collect from You and hold about You will vary depending on whether You are an existing patient or customer of Us or another Dental Care Network practice, have made enquiries about Our products and services and also the extent to which You have used Our products and services. If You apply to be, are currently or have in the past been a patient or customer of a Dental Care Network practice, the personal, or individually identifiable information that We hold about You may include:

• Name, address, telephone and email contact details;
• personal details such as age and gender;
• details of previous dentists you’ve been a patient of;
• your Medicare number;
• records of service contacts such as system notes and voice recordings of telephone conversation you’ve had with our employees;
• census and statistical information for purposes including product development and risk assessment;
• financial information (for example, credit card numbers to assist in the administration of payments for dental services);
• details of purchases made and professional services used, including the date; and

sensitive information including:

• medical history;

family medical history;
current health and dental assessment; and
health insurance details.

4. How Information May Be Collected
We may collect personal information directly from you in a number of ways, including:

• you choose to provide it directly to Us in order for Us to provide dental services to you;
• you may complete forms, send Us an email, provide information during a visit to Our Dental practice;
• you may choose to provide information through the contact forms housed on www.dentalcarenetwork.com;
• when you subscribe to newsletters or other direct marketing materials;
• when you use Our services or purchase goods from Us.

We may also collect information from Dental Corporation Pty Ltd or other third parties if You have provided them with consent under their own privacy policies:

• we may collect information from third parties such as your health insurance provider or Medicare; or

we may collect information from dentists, dental specialists or other health practitioners (for example if you were referred to us by another dentist).

5. Use and disclosure of Your Personal Information
We use Your personal information primarily to provide, manage and administer dental services and products to You and operate an efficient and sustainable business. As a part of these processes, We may disclose Your personal information on a confidential basis to Dental Corporation Pty Ltd and its related entities within the Bupa Australia Group of companies. In addition, We may use Your personal information for a number of purposes, including:

• to provide dental and related services to You;
• to maintain and administer Your patient file(s) at Our dental practice;
• to contact You in relation to any matter relating to You or the dental services or products provided to You;
• to answer Your enquiries and deliver dental services to You;
• to carry out internal functions such as administration, accounting, quality assurance and information technology;
• to resolve complaints;
• to monitor price and evaluate products and services;
• to conduct marketing surveys, research and statistical analysis;
• to fulfil marketing promotions;
• to administer Your invoicing for dental services, credit card payments, or to collect unpaid invoices;
• to process Your health insurance claims;
• to follow You up regarding further dental examinations or treatments required;
• to send information to You about Us;
• to comply with any laws or regulations.

In order to allow Us to manage and administer Our dental services and products to You and to operate an efficient and sustainable business, We may be required to disclose Your information to third parties. This may include disclosure in the following circumstances:

• to Your nominated relatives in an emergency;
• to government and regulatory bodies, e.g. Medicare;
• to auditors and other service providers We may appoint to ensure the integrity of Our operations and services;
• to any person or entity acting on Our behalf;
• to dentists, dental specialists and other healthcare professionals, for the purpose of seeking a second opinion or a referral, where You have consented to Us obtaining the second opinion or the referral;
• to third party health benefit providers and insurance companies (contact information only) to assist in the processing of a claim for reimbursement or payment of all or part of the cost of dental treatment submitted by You or on Your behalf;
• to carry out a review of the practice for the purposes of improving the quality of care provided;
• where disclosure is required by law, e.g. compulsory notices from courts of law, tribunals or government agencies.

However, if We do send your personal information outside of Australia We will require that the recipient of the information complies with privacy laws and contractual obligations to maintain the security of the data.

5.1. Direct marketing

From time to time, We may contact You to provide You with information about other products and services offered by Us, our related entities and our business partners that may be of benefit to You and Your family. When We contact You it may be via mail, phone, email or SMS. We may share Your personal information on a confidential basis with Dental Corporation Pty Ltd and third parties engaged by Us so that they can offer you products and services and fulfil offers to You. When You become our patient, You consent to Us using your personal information for direct marketing purposes (as described in this document), unless You have contacted us to withdraw Your consent. If You do not wish to receive marketing material from Us You can contact Us at any time to let Us know. Our contact details are at the end of this policy. When You contact Us to make this request, We will action your request within 5 working days.

If You request not to receive marketing material, please note that We will still contact You in relation to Our on-going relationship with You. For example, We will still send You any bills, statements and notices that are relevant to the products and services You have purchased from Us.

6. Handling and storage of Personal Information
We will take reasonable steps to ensure that Your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure. We will take reasonable steps to ensure that personal information provided by You will be handled in accordance with Australian privacy laws including the Australian Privacy Principles. We maintain strict data security standards and procedures with a view to preventing unauthorised access to your data by anyone other than Us.

Your personal information may be handled by Our employees. Information may be used by staff at Our practice for the provision of dental services to You. We keep your personal information for as long as it is required to provide You with the services and products You requested from Us and to comply with legal requirements.

If We no longer require Your personal information for any purpose, including legal purposes, We will take reasonable steps to securely destroy or de-identify your personal information except in circumstances permitted or required by law.

7. Accessing, Amending, Updating and Correcting Your Information
7.1 Access to personal information

You have the right to access personal information that is held about you. You can ask Us for access to the information that We hold about you at any time. Simply contact Us (Our contact details are listed below) to make your request. We will always endeavour to meet Your request for access within a reasonable time and in the manner requested by You if it is reasonable to do so. However, in some circumstances, access to certain information may be declined. This includes the following circumstances:

• We no longer hold or use the information;
• providing access would have an unreasonable impact on the privacy of others;
• the request is frivolous or vexatious;
• the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
• providing access would be unlawful;
• denying access is required by law;
• providing access would be likely to prejudice the prevention, detection, investigation and prosecution of possible unlawful activity;
• the information would reveal our commercially sensitive decision-making process;
• where access would pose a threat to the life or health of any individual;

If We are unable to give You access to the information you have requested, We will give You written reasons for this decision when we respond to Your request. If You have any concerns about the refusal, please see section 9 of this Policy for further information.

We may charge You a reasonable fee for access to some types of information. This charge will be limited to the cost of recouping Our costs for providing You with the information. For example, document retrieval, photocopy, labour and delivery to You. We will not charge You to make a request to access Your information.

You may request access to your personal information by contacting Us as per the contact details at the end of this document.

7.2 Correcting your personal information

To enable Us to provide you with the best possible service, it is important that the information We hold about You is accurate. We will take reasonable steps to ensure that Your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it. If You believe any information We hold about you is inaccurate, incomplete or out-of-date, You should contact Us to let Us know. We will respond to Your request within a reasonable period and will take reasonable steps to amend Your records.

8. Changes to the Privacy Statement
We may change the content or services found on Our website at any time without notice. Consequently Our Privacy Statement may change at any time also without notice.

9. Our Contact Information and Resolving your Concerns
You can contact Us at any time if You have any questions or concerns about this document or about how Your personal information has been handled.

You can contact Us and ask to speak to Our Privacy Officer. Upon request, We can refer you to a representative from Dental Corporation.

If You are not happy with Our response, or if You do not feel Your complaint has been resolved, You are able to seek advice from the Office of the Australian Information Commissioner by calling 1300 363 992.

Last Revised in 2014