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Privacy Policy

Last updated November 2021

We respect your privacy

DocDir Ltd ACN 653 269 311and its related bodies corporate (as defined by the provisions of the Corporations Act 2001 (Cth)), (DocDir Ltd, we, us and our) respects your privacy and is committed to protecting it.

We comply with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way public sector organisations collect, use, keep, secure and disclose personal information.

The 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.

This Privacy Policy sets out how we handle your personal information.  If you have any concerns or questions, please contact us at the address set out in Section 10 and we will make efforts to resolve your concern or answer your question.  We recommend that you keep this information for future reference.

The kinds of personal information collected, used and disclosed by DocDir Ltd

We will only use or disclose your personal information for the primary purposes for which it was collected, as otherwise required or permitted by law, or as consented to by you.  At or around the time we collect personal information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information. We set out some common collection, use and disclosure instances in the table below.

Types of InformationUsesDisclosures
Purpose: Online enquiries 
Contact information: Such as your name, email address and any other information the individual volunteers in the body of the enquiryThe types of uses we will make of personal information collected for this type of purpose include:

– Services: the provision of our products and services to you including using your personal information in order to contact you regarding services or events we think would be of interest to you.

– Enquiries: Providing any customer service functions, such as responding to any enquiries for further information in relation to our services.
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation:

– Third party service providers utilised in connection with: 
* any administrative matters;
* those who assist DocDir Ltd in providing our services to you;

– Related bodies corporate of DocDir Ltd (including related entities) 

– Third parties in connection with the sale of any part of DocDir Ltd’s business

– As required or authorised by law
Purpose: Marketing services (which include social media, marketing lists)
– Contact information: Such as your name, email address, sexuality, gender, languages spoken, age, Aboriginal / Torres Strait Islander descent

– Interests: Such as the medical professional sought 

– Social media activity: Including “likes”, comments or feedback, photos posted or uploaded and other information pertaining to your social media activities which concern, or relate, to DocDir Ltd.
The types of uses we will make of personal information collected for this type of purpose include, general marketing:

– Offer you updates on services or information that may be of interest to you
– Improve our services
– Marketing and promotional activities by us (including by direct marketing by mail, telemarketing, email, SMS and MMS messages) such as newsletters, blogs and competitions.
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation:
– Those parties listed in the “Online enquiries” section
– Our third party partners, such as magazines, media companies who assist us
Purpose: Clinician nomination and review
– Your contact information: Such as your name, email address, sexuality, gender, other personal information offered in the body of the review including reasons for recommending clinician

– Clinician contact information: Such as clinician’s name, address (or locale or clinic), speciality

The same personal information, as available, will be collected, used and disclosed where a clinician self-nominates. 
The types of uses we will make of personal information collected for this type of purpose include:
– Verify the quality of services the clinician supplies within the LGBTQ+ community
– Creating a directory of recommended clinicians within the LGBTQ+ community
– Collate and record recommendations about clinicians within the LGBTQ+ community
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation:
– Those parties listed in the “Online enquiries” section
– Publication on our website of recommended clinicians, and aggregated, deidentified quantum of recommendations for that clinician 

How DocDir Ltd collects and holds personal information

Collection generally

We will collect personal information in the following manners: 

  • directly from you, via an online form; 
  • directly from a patient that has been treated by you. 

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 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.

Other collection types

We may also collect personal information about you from other sources, such as:

  • when we collect personal information about you from third parties or competitions (including but not limited to our share registry provider); or
  • when we collect personal information about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram etc).

Notification of collection

If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including the following circumstances:

  • where information is collected from any personal referee you have listed on any application form (including any employment application) with DocDir Ltd;
  • 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
  • as otherwise required or authorised by law.

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 DocDir Ltd (in its absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified.  However, where unsolicited personal information is collected in relation to your future potential employment with DocDir Ltd, we may retain this personal information.

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. Refer to Section 8 (Data security and quality) for more information.

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. DocDir Ltd 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.

Uses and discloses of personal information

Use and disclose details 

We provide a detailed list at Section 2 of some common uses and disclosures we make regarding the personal information we collect.  We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:

  • 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;
  • 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;
  • if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
  • if it is required or authorised by law.

Use and disclosure procedures

If we propose to use or disclose such personal information other than for reasons set out in the above table at Section 2 or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use. 

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. 

Direct Marketing 

Express informed consent 

You give your express and informed consent to us using your personal information set out in the “Marketing Services” section of the table at Section 2 of this document above, to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications). 

Inferred consent and reasonable expectations of direct marketing 

Without limitation to paragraph 5.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you. 

Opt-out 

If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 5, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out in Section 10.

Anonymity and pseudo-anonymity 

Due to the nature of the services we provide, it is only practicable or reasonable for DocDir Ltd to transact and correspond with you on a named basis.  Your personal information may be required in order to provide you with our services, or to resolve any issue you may have.

Cross Border Disclosure 

Cross border disclosures

Any personal information collected and held by DocDir Ltd may be disclosed to, and held at, a destination outside Australia, including the United States and Ireland, where we utilise third party service providers to assist DocDir Ltd with providing our services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies. 

As we use service providers, online applications and data storage facilities which can be accessed or disclosed in various countries, it is not always practicable to know where your information may be held. Where reasonably practicable, we will take reasonable steps to inform you as to where your personal information is held or disclosed. 

Provision of informed consent 

By submitting your personal information to DocDir Ltd, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

The Privacy Act 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. By providing your consent, under the Privacy Act, 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 is used by third parties securely and in accordance with the terms of this Privacy Policy. 

If you do not consent 

If you do not agree to the disclosure of your personal information outside Australia by DocDir Ltd, you should (after being informed of the cross border disclosure) tell DocDir Ltd that you do not consent. To do this, either elect not to submit the personal information to DocDir Ltd after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.

Data security and quality 

DocDir Ltd’s security generally 

We have taken steps to help ensure your personal information is safe and protected from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions of personal information, especially where the Internet is involved.

Notwithstanding the above, we will take reasonable steps to:

  • make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
  • protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and 
  • destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection. 

Accuracy

 The accuracy of personal information depends largely on the information you provide to us, so we recommend that you:

  • let us know if there are any errors in your personal information; and 
  • keep us up-to-date with changes to your personal information (such as your name or address). We provide information about how you can access and correct your information in Section 9. 

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 limited circumstances provided by law (including the Privacy Act). You are also entitled to edit and correct such information if the information is inaccurate, out of date, 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 the details set out in Section 10 or submitting a general enquiry on our website.

Resolving Privacy Complaints 

10.1 Complaints generally 

We have put in place an effective 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. 

10.2 Contacting DocDir Ltd 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 by: 

  • Email: privacy@docdir.org.au 
  • Post:  1/888 Brunswick St, New Farm QLD 4005

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

10.3 Steps we take to resolve a complaint

In order to resolve a complaint, we: 

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

10.4 Register of complaints 

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

Consent, modifications and updates 

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, DocDir Ltd 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 DocDir Ltd, but do create contractual obligations on the other party to the contract; and 
  • the consents provided in this policy become contractual terms provided by the other party to the contract. 

By using our website, purchasing a product or service from DocDir Ltd, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing: 

  • to provide the consents given by you in this Privacy Policy; and 
  • that you have been informed of all of the matters in this Privacy Policy. 

We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your personal information due to the changes in our Privacy Policy, please cease providing us with your personal information and contact us via the details set out at the top of this document.