1. GENERAL

Connected Medical Solutions Limited (ACN 610 209 884) , including its subsidiaries and businesses, provide a range of telemedicine solutions to partner with hospitals and healthcare services in the Australian healthcare system. These services are provided under various names including My Emergency Doctor (ABN 54 610 209 884); GP2U (ACN 151 445 715) and PSYCH2U (ABN 58 151 445 715), collectively (“ConnectedMed”, “We” and “Our”). The previously mentioned services are provided by specialist doctors (emergency medicine and psychiatry), GPs and other health practitioners such as psychologists, all supported by our Patient Support Team. We are Australian owned and based in Sydney.

We own and operate the websites www.myemergencydr.com; med.com.au; drwaittimes.com.au; PSYCH2U.com.au and GP2U.com.au (“Websites”). We also maintain a presence on social media such as Facebook, Instagram, Twitter and LinkedIn (“Social Media”). This Privacy Policy is available through any of Our Websites. You may also ask for a copy to be emailed to you at any time email: info@myemergencydr.com.au

1. GENERAL
2. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT?
3. HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?
4. WHY DO WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?
5. HOW DO WE HOLD YOUR PERSONAL INFORMATION?
6. HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION?
7. PRIVACY RELATED QUESTIONS AND COMPLAINTS
8. ANONYMITY AND PSEUDONYMS
9. OVERSEAS DISCLOSURE
10. UPDATES TO THIS POLICY
11. WHERE TO FIND THIS PRIVACY POLICY
12. COOKIES
13. HCF MEMBERS

Information privacy is a key area of importance for ConnectedMed. We are committed to dealing with personal information responsibly whilst complying with the Privacy Act 1988 (Cth) (“Privacy Act”) and the associated Australian Privacy Principles (“APPs”). This Privacy Policy has been written to comply with Our obligations under the Privacy Act.

If you use any of our services (Services), access any of our Websites or Social Media, you agree to be bound by this Privacy Policy.

All issues regarding the collection, retention, use, storage and disclosure of your personal information (including medical information) will be governed by this Privacy Policy.

We have written this policy to inform you of:

• the kind of information that we collect and hold, which as a medical practice includes your confidential/sensitive health information
• how we collect and hold personal information
• the purposes for which we collect, hold, use and disclose personal information
• how do we hold your personal information
• how you may access your personal information and seek the correction of that information
• how you may complain about a breach of the Australian Privacy Principles and how we will deal with such a complaint
• whether we are likely to disclose your personal information to overseas recipients and, if so, the countries in which such recipients are likely to be located

2. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT?

We only collect information that is reasonably necessary and relevant to provide you with the requested Services including medical care, advice, treatment and to manage our medical practice. This information may include:

• Your name, address, date of birth, gender, email and contact details
• Contact details of your parent, carer or guardian where necessary or appropriate
• Medicare number, DVA number and other government identifiers
• Your medical insurance company
• Sensitive health information about you, including notes of your symptoms or diagnosis and the treatment given to you; previous appointments; your specialist reports and test results; medical history (including that of family members if a condition might be hereditary); current medications and allergies
• Enquiry or survey/feedback responses, service requests, information requests or complaints; referral source relating to your consultation; billing details and payment information
• Details of your use of our Websites, Social Media and details of any communications you have with Us
• If you apply to become a member of Our team, qualifications, employment history and other employee data in connection with your application
• Statistical non-identifiable information about visitors to our Website and our Social Media some of which may be collected using cookies.

Sometimes we may be required or permitted by law, court or tribunal order to collect other personal information about you. Where required to do so, we will notify you in accordance with relevant privacy legislation when we collect your personal information and for what purpose.

This Privacy Policy also applies if you are a staff member or other individual that we deal with in the course of running our business. In this case, most personal information we collect will be received directly from you however it may also be collected from third parties such as recruitment agencies, police, industry regulators, business partners and may include details such as your name and contact details, professional qualifications or skills and your employment history, financial information such as your bank account and credit card details used to transact with us, and other personal information you send or disclose to us including our records of any communication or interactions you have with us.

3. HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?

We will generally collect personal information:

• from you directly when you provide your details to us
• from a person responsible for your care, relatives and/or friends
• other health service providers such as but not limited to private health insurers, private and public hospitals, medical clinics, nursing homes and other aged care providers, interpreters and emergency service providers as well as other institutions responsible for your care
• from third parties where the Privacy Legislation or other law allows it: for example other members of your treating team, diagnostic centres, specialists, hospitals, the My Health Record system, electronic prescription services, Medicare, your health insurer, the Pharmaceutical Benefits Scheme.

Personal information may be collected via an online form, email, voice and/or video call or written forms.

We may be required by law to retain medical records for certain periods of time depending on your age at the time we provide services.

As required by some of the contracts which we have with our partner organisations, we may also be required to record consultations for quality assurance and confidential record keeping purposes. Please let us know if you do not want a consultation to be recorded.

If you don’t provide us with certain information, or if you request that we de-identify Personal Information we hold about you, we may be unable to provide you the information or Services you request.

4. WHY DO WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?

We will treat your personal information as strictly private and confidential. We will only use or disclose it for purposes directly related to your care and treatment, or if we are required by law to disclose it, or in ways that you have authorised us or would otherwise reasonably expect that we may use it for your ongoing care and treatment. For example, the disclosure of blood test results to your specialist or requests for x-rays. From time to time another of Our doctors may access your patient records for quality review and assurance purposes. Please also see ourTerms of Service
Link .

You agree that we may also retain and use your personal information:

• To contact you about our Services and business, and about other content (for example information about our doctors, tele-health related educational material such as video examples of how our doctors work and information from tele-health data and studies), that we think may be of interest to you as well as following up with you about such matters by phone, post, email or other means. You can opt out of receiving such content and communications by sending an email to info@myemergencydr.com.au

and typing “unsubscribe” in the subject line of your email. Please note that even if you opt out of receiving such marketing and promotional material, we will still contact you in future regarding your actual use of our Services

• To contact you regarding customer assistance matters regarding your use of our Services, billing, account management and other administrative matters, sending you information about changes to our organisation, policies and terms and conditions or other legal matters.
• For our research purposes including improving your browsing experience and personalising your user experience, and developing and improving our business and Services.

There are circumstances where we may be permitted or required by law or are requested to disclose your personal information to third parties such as, to statutory authorities, public health authorities for infectious disease notification, Medicare, Police, insurers, government regulatory bodies, tribunals, courts of law or hospitals. In these cases, you authorise us to disclose your personal information where we are requested or required to do so. If you bring a legal action again Us or if you owe us money, we also reserve the right to provide your Personal Information to our solicitors or debt collection agent.

We may also disclose your personal information to other health service entities such as but not limited to other health service providers, private health insurers, private and public hospitals, government, state or territory funding bodies or area health services (and their related entities), nursing homes and other aged care providers, allied health providers, interpreters and emergency service providers. If the patient is a student and the student is using our Service through his/her school, we may need to disclose the student’s personal information to the relevant school.

If you contacted us from a facility or where a third party has agreed to fund the cost of your consultation, depending on the legal contract which we have in place, We may be required to disclose certain information about you and your consultation back to that funding party for reporting and invoicing purposes.

We may also provide statistical data to third parties for research purposes. This will be de-identified.

5. HOW DO WE HOLD YOUR PERSONAL INFORMATION?

As We are a telehealth company, many of our systems are reliant on IT and software which is mostly provided to Us by our trusted IT vendors on a SAAS (software as a service) basis. We take great care to ensure that our IT partners and SAAS providers have secure, robust systems in place and that personal data is encrypted to minimise unauthorised access. Furthermore, services are hosted on Australian based servers. In order to ensure that your personal data is accurate and complete, we may ask you from to time to confirm that your contact details are correct. We may also request that you let us know if any of the information we hold about you is incorrect or out of date.

Personal information that we hold is protected by:

• Encryption wherever possible
• placing passwords and varying access levels on databases to limit access and protect electronic information from unauthorised interference, access, modification and disclosure.
• providing locked cabinets and rooms for the storage of physical records.

6. HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION?

You have a right to seek access at any time, and to correct, the personal information which we hold about you. For details on how to access and correct your health record, please send an email to our practice as noted below. We will normally respond to your request within 30 days.

We may deny access to your medical records in certain circumstances permitted by law, for example, if disclosure may cause a serious threat to your health or safety. We will always tell you why access is denied and the options you have to respond to our decision.

If there are any unusual circumstances, we reserve the right to charge you a reasonable fee to access or correct your personal information.

7. PRIVACY RELATED QUESTIONS AND COMPLAINTS

If you have any questions about privacy-related issues or wish to complain about a breach of the Australian Privacy Principles or the handling of your personal information by us, please send us an email in the first instance. If the matter is urgent, please call the number below. Non-urgent matters will normally be responded to within 30 days:

Privacy Officer

My Emergency Doctor

Email: info@myemergencydr.com.au

If you are dissatisfied with our response, you may refer the matter to the OAIC:

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Fax: +61 2 9284 9666

Post: GPO Box 5218

Sydney NSW 2001

Website: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint

You may also contact the NSW Health Care Complaints Commission:

Phone: 1800 043 159

Email: hccc@hccc.nsw.gov.au

Address: Level 13, 323 Castlereagh Street (corner of Hay St), Sydney NSW 2000

8. ANONYMITY AND PSEUDONYMS

The Privacy Act provides that individuals have the option of not identifying themselves, or of using a pseudonym, when dealing with Us, except in certain circumstances, such as where it is impracticable for Us to deal with you if you have not identified yourself. Because we usually require either prior payment or that you provide sufficient personal information so that you can identify you as a permitted user under one of our client contracts, it is likely to be impracticable for us to do consultations on an anonymous basis.

9. OVERSEAS DISCLOSURE

We may disclose your personal information to the following overseas recipients:

• any practice or individual who assists us in providing services (for example if you have come from overseas and your original health records are overseas, or your treatment is being given by an overseas based provider)

• overseas transcription / administration services

• anyone else to whom you might direct or authorise us to disclose.

Even though all of Our doctors are Australian registered, some of our doctors, health practitioners and administrative staff are based overseas (eg. United Kingdom and Philippines).

10. UPDATES TO THIS POLICY

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and other necessary developments. Updates will be published on our website.

11. WHERE TO FIND THIS PRIVACY POLICY

This Privacy Policy will be made available through any of our Websites. It may also be, referred to on our Social Media, in our communications and marketing material.

12. COOKIES

Our Websites and Social Media may employ the use of analytical tools and cookies to collect and track personal information. By using our Services, the Websites or our Social Media, you agree to the use of such technologies and cookies. You may block or restrict any cookies by adjusting your internet browser settings but if you do so, our Websites and Social Media may not function properly and you may not be able to access some or all of the Services.

13. HCF MEMBERS

If you are an HCF Member, have Overseas Visitors Health Cover or are participating in an HCF program, please click here to view how we collect, store and protect your data : HCF.