CALL TO MIND PRIVACY POLICY

1. ABOUT THIS POLICY

This section explains how to read this policy and describes its purpose.

1.1 Interpretation of this document and general overview

Defining specific terms:

1.1.1 “APPs” refer to the Australian Privacy Principles in the Privacy Act 1988 (Cth).

1.1.2 “Call to Mind”, “we”, “us”, “our” means Call to Mind Pty Ltd ABN [93254104171].

1.1.3 “Call to Mind Services” means the technology, communication and administration services provided by Call to Mind when you access the Call to Mind online platform.

1.1.4 “Health Information” means information about the physical, mental or psychological health or disability of an individual or an individual’s wishes about the provision of health services.

1.1.5 “Personal Information” means information that is capable of identifying an individual such as name, address and date of birth.

1.1.6 “Privacy Information” means Personal Information and Sensitive Information.

1.1.7 “Psychiatry Services” means the health and psychiatry services provided using the Call to Mind online platform and other related services provided now or in the future by us.

1.1.8 “Sensitive Information” includes information relating to religion, racial or ethnic origin.

1.1.9 “You”, “your” means any person who accesses the Call to Mind Services or Psychiatry Services.
Call to Mind is subject to the Australian Privacy Principles as laid out in the Privacy Act 1988.

1.2 Purpose of this policy

The Call to Mind Privacy Policy explains how our organisation protects your Privacy Information. Our Privacy Policy lays down the principles by which we collect, store, use and disclose any Personal Information you provide to us or we collect from other sources.
Our Privacy Policy also informs clients, prospective clients, health providers and anyone else whose Privacy Information is protected in dealing with Call to Mind, about how they can access their Privacy Information, correct Privacy Information held by us, lodge complaints or make any related enquiry.

2. TYPE OF INFORMATION WE COLLECT AND HOLD

Call to Mind collects information about you in order to provide Call to Mind Services and facilitate the Psychiatry Services.

Types of Personal Information we collect:

2.1 Health providers

We may collect Personal Information regarding health providers (for example, general practices, independent psychiatrists), and their employees to facilitate the provision of Psychiatry Services. The type of information can include:

2.1.1 Name

2.1.2 Contact details

2.1.3 Role/health services provided

2.1.4 Connection with Call to Mind

2.2 Clients

Call to Mind generally collects information about clients for the provision of Psychiatry Services. Call to Mind collects personal details to facilitate or arrange health services, maintain client records, manage service demand and in some cases, provide health services.
Where Call to Mind provides a health service, Call to Mind will collect Health Information and Sensitive Information. This information is needed to co-ordinate referrals for the Psychiatry Services and ensure deliver of the appropriate services.

The types of information collected can typically include (this list is not exhaustive):

2.2.1 Contact details (name, address, telephone number, email address, next of kin)

2.2.2 Age, date of birth, gender, marital status

2.2.3 Driver’s licence number, Medicare number

2.2.4 Medical history, treatment records, images, photographs, family medical histories

2.2.5 Referrals to and from other practitioners and their reports

2.2.6 Ethnic origin (for example, to assess your eligibility for free health services)

2.2.7 If payments or co-payments are required, banking/credit card details

2.3 Website visitors

For our website visitors, we collect information such as your IP address, internet service provider, the web page directing you to our website and your activity on our website. This information is usually anonymous and we do not use it to identify individuals. However, due to the nature of internet protocols, such information might contain details that identify you. This information is collected to ensure that our information has reached its target audience.

2.4 Prospective employees and directors

We collect Personal Information regarding prospective employees, regarding their skills, interests, qualifications and experience to:

2.4.1 Assess their suitability for potential employment with us; and

2.4.2 Match them to suitable projects or roles.

3. HOW WE COLLECT YOUR INFORMATION

We may collect Personal Information (not including sensitive information) from people through our marketing, business development, operational, human resources, research or other activities.

We have a general policy to collect Personal Information directly from you, unless it is unreasonable or impracticable to do so.
We will need your written consent to collect Sensitive Information (which includes health information) about you.

3.1 Health providers

We generally collect Personal Information directly from individuals. However, for some health providers, we may collect your Personal Information from colleagues or other health providers and stakeholders, or clients.
In some cases, we collect your Personal Information from public sources (for example national health practitioner register, internet) or through your memberships (for example with peak bodies).

3.2 Clients

Call to Mind usually collect Personal Information directly from individuals and their referring clinican unless it is unreasonable or impracticable to do so. We collect Health and Sensitive Information with your consent in a fair and unobtrusive way.

We also collect information about clients from:

3.2.1 Clients and their representatives through forms, agreements, mail, email, telephone, in-person inquiries and website inquiries

3.2.2 Referrers and third parties (eg specialists or providers outside the clinics or the programs)

3.2.3 Publicly available sources of information

3.3 Website visitors

We analyse how our site is used to help us make it better. We do this by obtaining reports on usage from Google Analytics. These tell us which pages are visited, for how long, on what operating systems and browsers and from what areas. This works by using cookies. A cookie is a text file that our website sends to your browser which is stored on your computer as a tag identifying your computer to us. You can set your browser to disable cookies. However, some parts of our website may not function properly (or at all) if cookies are disabled. Our employees are required to protect any personal information we collect. Our technology and work policies are designed to protect this information. However, if you send information over the Internet it may not be completely secure.

3.4 Prospective employees

We generally collect Personal Information directly from the prospective candidate, but may also do so from recruitment agents, recruiters, referrers, referees, Call to Mind officers/employees or other knowledgeable parties where relevant to the recruitment process.

3.5 Others

We collect information about employees and others directly from those persons.

In some cases, we collect information about such persons:

3.5.1 Through forms, agreements, general inquiries

3.5.2 From researchers or contractors engaged by Call to Mind

3.5.3 Public sources (for example national health practitioner register)

4. DIRECT MARKETING

4.1 Collecting information indirectly about an individual for marketing to that individual

If Call to Mind plans to engage in direct marketing using or disclosing information collected:

4.1.1 Indirectly about that individual, or

4.1.2 From the individual and the individual would not reasonably expect us to use or disclose the information for marketing purposes,
Call to Mind must first obtain consent, unless an exception set out in the APPs applies.

All subsequent direct marketing you receive will include an easy opt-out procedure if at any time you wish us to cease sending you information.

4.2 Collecting information directly about an individual for marketing to that individual

If we collect information about you and you would reasonably expect us to use or disclose the information for the purpose of marketing, we will use an opt-out procedure in all our marketing communications. This means you will be able to easily unsubscribe from all future marketing communications.

5. PURPOSE FOR WHICH WE COLLECT AND DEAL WITH YOUR INFORMATION

As a general principle, we only use Privacy Information for the primary purpose for which we collect the information or a secondary purpose related to the primary purpose for which you would reasonably expect us to use the collected information. All the information collected by Call to Mind will be used only for the purpose providing the Call to Mind Services or facilitating the Psychiatry Services.

We will make you aware of the purpose for which we collect your information by notifying you about all the relevant matters of that collection.
We will not use your information for an unrelated secondary purpose unless we obtain your written consent or an exception applies, such as it is impracticable to obtain your consent and we believe that collecting, using or disclosing your information is necessary to lessen a serious threat to the life, health or safety of any individual.

5.1 Health providers

We collect Personal Information regarding individual health practitioners and the employees, volunteers and officers of our health providers:

5.1.1 To facilitate referrals for clients accessing Psychiatry Services

5.1.2 In the course of contracting with them or arranging for the delivery of health services for clients

5.1.3 To distribute information about our activities and publications by way of direct communications/marketing to improve our health system and the health of our clients

We may collect Personal Information regarding your interests to personalise your interactions with us.

5.2 Clients

We collect and use Personal and Health Information for the purpose of:

5.2.1 Providing Call to Mind Services

5.2.2 Facilitating access to Psychiatry Services;

5.2.3 Managing service demands for the services we provide

The following are specific examples of when we collect and use your Personal Information:

5.2.4 To make appointments and send reminder notices

5.2.5 To communicate with other health practitioners as part of a multidisciplinary team or a referral

5.2.6 To maintain your personal information, our client records and other medical registers

5.2.7 To inform your nominated emergency contacts (next of kin) of a medical condition

5.2.8 To disclose your health information to paramedics and health professionals in a medical emergency

5.2.9 To use de-identified information to model or forecast service demand]

5.2.10 To liaise with a person’s nominated representative or family members where needed

5.2.11 To improve our services through quality improvement activities, audits, surveys and program evaluations

5.3 Prospective employees

We use Personal Information about our prospective employees predominately to consider the application.

5.4 Website visitors

We use information regarding website visits for the purpose personalising of your website visit or to enable remarketing website functionality.

5.5 Others

Call to Mind may also collect and use Personal Information from others for our operational, human resources, research referral or other corporate activities.

6. CROSS BORDER TRANSFER OR DISCLOSURE OF INFORMATION

In the event we engage in cross border transfer of information, such as routing or storing information on cloud servers located overseas or transferring information to an office of our company overseas, we will ensure that adequate security mechanisms are in place to protect your information. For example, we will enter into a contract with the cloud server that complies with the APPs and ensures the information is for the limited purpose of storing and managing the Personal Information.

7. MAINTAINING THE INTEGRITY, CURRENCY AND SAFETY OF YOUR PRIVACY INFORMATION

This section explains how Call to Mind holds your Privacy Information, how you can access your Privacy Information, update your Privacy Information, complain about an alleged breach of the APPs or make any related enquiry.

7.1 Maintaining currency of your information

Call to Mind relies on accurate and reliable information to deliver its services. If we are satisfied that any of the information we have about you is inaccurate, out-of-date, irrelevant, incomplete or misleading, or you request we correct any information, we will take reasonable steps to ensure the information held by us is accurate, up-to-date, complete, relevant and not misleading.
If we disclose your Privacy Information that is later corrected, we will, or else you may ask us to, notify the entity that received the incorrect information about that correction.

Should we refuse to correct the information, we will explain the reasons for refusal. We will also show you the complaint procedure if you wish to lodge a formal complaint about our refusal.

7.2 Safety of your information

All Privacy Information is securely stored using appropriate physical and/or electronic security technology, settings and applications, and by ensuring staff dealing with privacy information is trained in our privacy policies and procedures.
This policy are designed to protect Privacy Information from unauthorised access, modification or disclosure; and from misuse, interference and loss.

8. ACCESSING YOUR INFORMATION OR LODGING A COMPLAINT

8.1 Accessing and correcting information

You are entitled at any time, upon request, to access your Privacy Information held by us. We will respond within a reasonable time after the request is made and give access to the information in the manner requested by you, unless it is impracticable to do so. We are entitled to charge you a reasonable administrative fee for giving you access to the information requested.
Should you be refused access to your information, we will explain the reasons for refusal – any exceptions under the Privacy Act or other legal basis relied upon as the basis for such refusal – and, if you wish to lodge a formal complaint about our refusal, we will explain the complaint procedure.

8.2 Lodging a complaint

Should you wish to complain about a potential breach of this Privacy Policy or the Australian Privacy Principles please contact our Privacy Officer.
The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.

8.3 Contact details

Privacy Officer
Dr David Carmody
Call to Mind
Phone: 0438 643 217
Email: info@calltomind.com.au