This privacy policy

This privacy policy is issued by Telstra Health Pty Ltd ABN 38 163 077 236 and its related entities, trading in their own capacities and also previously as ReadyCare and Anywhere HealthCare (‘we’, ‘our’ or ‘us’). It sets out how we collected, handle and protect the personal information of any individuals (referred to as ‘you’ or ‘your’) who accessed and used our online and phone platform to connect patients (or potential patients) with independent healthcare professionals and organisations for virtual medical consultations (Virtual Clinical Services). 

Importantly, we ceased providing the Virtual Clinical Services on and from 27 June 2022. In accordance with this privacy policy, we will continue to retain the health records of former users of the Virtual Clinic Services for seven years from the date of service (or, in the case of a child, until that child turns 25). If you use our HealthNow mobile application, you should review the HealthNow privacy policy located here. If you use any of our other products or services, you should review Telstra Health’s general privacy policy located here.

This policy is effective as of 27 June 2022, although we may need to change it from time to time. If we do, we will post the updated version on our website at 
https://healthnow.io/content/healthnow/telehealth/privacyvcs.html and it will apply to the personal information that we hold at that time. 

Our collection, use and disclosure of personal information

The types of information we may have collected, and how we use or disclose it, will vary based on the nature of our dealings with you and how you used the Virtual Clinical Services.

For a specific description, please select the following heading which best describes you:

+ You used our Virtual Clinical Services as a patient (or potential patient)

The type of information we may have collected

The types of information we may have collected can include your:

  • name, contact details, age and sex;
  • nationality, racial or ethnic background, and sexual orientation and practices, if this is provided to us by your healthcare professional or as part of any triaging or administrative services we provide;
  • health information, including images and diagnostic information, if this was provided to us by your healthcare professional or as part of any triaging or administrative services we provided;
  • account usernames or passwords used to access the Virtual Clinical Services or any integrated products or services;
  • financial information such as credit card or bank account numbers;
  • unique identifiers, such as your patient ID, Medicare number, or individual healthcare identifier;
  • usage information about your visit to our website and how you used our products and services;
  • records of your communications and interactions with us, or a healthcare professional you connected with, when using the Virtual Clinical Services;
  • location information; and
  • prescription information, accessed via Medview during Telehealth Consultations; and
  • any other information that you, or a healthcare professional you connected with, provided to us directly.

 

How we may have collected it

We may have collected your personal information in the following ways:

  • you gave it to us when you or your representatives interacted with us (for example, when you sought to or used the Virtual Clinical Services, or contacted us for help);
  • we captured the information when you used the Virtual Clinical Services, including when you contacted us through online services;
  • through telephone call recording, if you consented to any calls being recorded;
  • from our corporate customers such as health insurers, hospitals, health service providers, primary health networks, or employers, if they made the Virtual Clinical Services available to you;
  • from healthcare professionals who you connected with through the Virtual Clinical Services or who are otherwise involved in your treatment (such as a referring doctor), or a corporate entity that engages such a healthcare professional; and
  • as otherwise authorised or required by law, such as your My Health Record or Medview.

With your consent, doctors may have accessed Medview, which is an online system for making health information about you available for the purposes of providing healthcare to you. Medview is powered by eRx Script Exchange, which is an electronic transmission of prescription information between doctors and pharmacists. For more information, please refer to Fred IT Group Pty Ltd, or visit www.medview.com.au.

How we use it

We may use, or have used, your personal information for a number of purposes, such as:

  • service provision – providing you with, and support the operation and functionality of, the Virtual Clinical Services (and in particular to have enabled us to connect you with healthcare professionals);
  • administration – properly managing the service we provided to you, such as by maintaining and updating our records and administering any charging or billing;
  • identity verification – where appropriate, to verify your identity;
  • communication – providing you with customer service, assisting you with enquiries and otherwise communicating with you for the purpose of  your experience with the Virtual Clinical Services;
  • operations – monitoring network use, quality and performance, and operating, maintaining, developing, testing and upgrading our systems and infrastructure;
  • improvement – helping us to maintain, develop, evaluate and improve the Virtual Clinical Services and any integrated products or services;
  • direct marketing – if you provided your consent for us to do so, to enable us (and other Telstra group entities and affiliates) to promote and market products and services that we think will be of interest to you. We do not sell or otherwise provide personal information to unrelated third parties for their direct marketing purposes. To opt-out of this type of marketing, please follow the steps outlined in one of our marketing communications or contact us using the details set out in the “How to contact us” section of this policy; and  
  • as otherwise authorised or required by law.

Who we might share or disclose it with

We may share, or have shared, your information with:
  • healthcare professionals, providers or networks – who you connected with or sought to connect with through the Virtual Clinical Services, or who were otherwise involved in your treatment (such as a referring doctor or a specialist who you were referred to), or a corporate entity that engaged such a healthcare professional;
  • My Health Record – we may have uploaded your health summary to your My Health Record, if you or your representative provided your consent to this, or we were otherwise legally authorised or required to do so;
  • service providers – in some circumstances, certain third parties that assisted us in providing you with the Virtual Clinical Services (for example, IT and network service providers, or customer service providers) may have access to your personal information. Where we shared your information with a third-party service provider, we made sure that they first agreed to protect the privacy of your information;
  • government and regulatory authorities – such as law enforcement and national security agencies, and other government and regulatory authorities, if such disclosures are or were required or authorised by law;
  • buyers or prospective buyers – for the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business;
  • our related entities; and
  • other third parties – if the circumstances warrant or warranted such a disclosure or share, but only where this is required or authorised by law.

+ You used our Virtual Clinical Services as a healthcare professional or on behalf of one of our business customers

The type of information we may have collected

The types of information we may have collected can include:

  • your name and contact details;
  • your qualifications and details of your professional experience, conduct and occupation/specialty;
  • your age, sex, nationality and languages spoken;
  • usernames or passwords used to access the Virtual Clinical Services;
  • financial information such as credit card or bank account numbers, if you were responsible for payment of, or entitled to receive any, charges;
  • unique identifiers, such as your individual healthcare provider identifier;
  • usage information about your use of the Virtual Clinical Services and how you used any other integrated products and services;
  • records of your communications and interactions you have or had with us, or with patients you connected with through the Virtual Clinical Services;
  • location information; and
  • any other information that you provided to us directly, or that was provided to us by the business that employs or engages you.

How we may have collected it

We may have collected your personal information in the following ways:

  • you gave it to us when you or your representatives interacted with us (for example, when you used the Virtual Clinical Services, or contacted us for help);
  • your employer/engaging business gave it to us to facilitate your use of the Virtual Clinical Services;
  • we captured the information when you used the Virtual Clinical Services, including when you contacted us through online services;
  • through any telephone call recording; and
  • as otherwise authorised or required by law.

 

How we use it

We may use, or have used, your information for a number of purposes, such as:
  • service provision – to provide you with, and support the operation and functionality of, the Virtual Clinical Services (in particular by having connected you with patients);
  • administration – to properly manage the Virtual Clinical Services and how we provided it to you, such as by maintaining and updating our records and administering any charging or billing;
  • identity verification – where appropriate, to verify your identity;
  • communication – to provide you with customer service, assist you with enquiries and otherwise communicate with you to enhance your experience with the Virtual Clinical Services and any integrated products or services;
  • operations – to monitor network use, quality and performance, and to operate, maintain, develop, test and upgrade our systems and infrastructure;
  • improvement – to help us maintain, develop, evaluate and improve the Virtual Clinical Services and any integrated products or services;
  • direct marketing – if you provided your consent for us to do so, to enable us (and other Telstra group entities and affiliates) to promote and market products and services that we think will be of interest to you. We do not sell or otherwise provide personal information to unrelated third parties for their direct marketing purposes. To opt-out of this type of marketing, please follow the steps outlined in one of our marketing communications or contact us using the details set out in the “How to contact us” section of this policy; and
  • as otherwise authorised or required by law.

Who we might share or disclose it with

We may share, or have shared, your information with:
  • patients and other users of the Virtual Clinical Services;
  • service providers – certain third parties that assisted us to provide you with the Virtual Clinical Services (for example, IT and network service providers, or mailing operations and customer service providers). Where we shared your information with a third-party service provider, we made sure that they have first agreed to protect the privacy of your information;
  • your employing/engaging business;
  • government and regulatory authorities – such as law enforcement and national security agencies, and other government and regulatory authorities, if such disclosures were or are required or authorised by law;
  • buyers or prospective buyers – for the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business;
  • our related entities; and
  • other third parties – if the circumstances warranted or warrant such a disclosure or share, but only where this is required or authorised by law.

 

How we hold and secure your information

We may store your information in hard copy or electronic format, in storage facilities that we own and operate ourselves or that are owned and operated by our service providers. These facilities are situated in Australia.

We take privacy and confidentiality very seriously and take reasonable steps to maintain the security of your information and to protect it from unauthorised use and disclosure.  In doing so, we aim to ensure that any recipients of your information protect it in accordance with the Australian Privacy Principles.  If you have consented or requested that we record your consult, the recording may be stored on an interim basis on servers which are operated by offshore providers located in countries such as the United States, Netherlands and Singapore (however these countries may change from time to time).  We do not otherwise transfer any personal information obtained for the purposes of the Virtual Clinical Services to any countries outside of Australia, unless we have obtained your specific consent to do so.

You should be aware that your own email or devices may not be secure, so care should be taken with images and information sent or stored by you.

Access to third-party services

From time to time, we may have provided you with the opportunity to connect to other third-party services or products. We do not endorse these third-party services or products and you should review their corresponding terms and conditions and privacy policies before using any third-party service or product. We accept no liability in relation to third party services or products.

For example, we may have used Blue Jeans Network, Inc. (BlueJeans) as a third-party video conferencing services provider. If we did so, we would have informed you of this, and you agreed that your use of the relevant services would be subject to BlueJeans’ privacy policy, available at https://www.bluejeans.com/privacy-policy

How to access or correct your information or make a privacy complaint

Following the closure of our Virtual Clinic Services business, we continue to retain the health records of former users of the Virtual Clinic Services who accessed, as required by law, for at least 7 years or, in the case of a child, until the child turns 25 years old.

If you wish to access any of your information that we hold, or you would like to correct any errors in that information, please contact us using the contact details set out in the “How to contact us” section of this policy, so that we can respond to your request. We may apply an administrative charge for providing access to your personal information in response to a request.

You may also use these contact details to notify us of any privacy complaint you have against us, including if you think that we have failed to comply with the Australian Privacy Principles, any binding APP code that has been registered under the Privacy Act 1988 (Cth), or any other health records or privacy laws. While we hope that we will be able to resolve any complaints you may have without needing to involve third parties, you may also be able to lodge a complaint with a relevant regulator such as the Australian Information Commissioner (www.oaic.gov.au or 1300 363 992).

How to contact us

If you have any questions in relation to this policy or our management of your personal information, including health information, please let us know by contacting 1800 870 711 (within Australia) or +61 2 9308 9400 (outside of Australia), or by writing to Telstra Health, Level 8, 175 Liverpool St. Sydney, New South Wales 2000.