1.1 About Bupa Aged Care
Bupa Aged Care Australia Pty Limited ABN 74 082 931 575 (“Bupa Aged Care", "we" "us" and "our") operates residential Care Homes across Australia and provide GP services at Bupa Seaforth Health and Wellbeing Centre.
Bupa Aged Care is part of the Bupa Australia and New Zealand group of companies, providing a range of health and care services, including:
- health insurance provided by Bupa HI Pty Ltd (bupa.com.au);
- corporate wellness services provided through Bupa Wellness (bupawellness.com.au);
- optical and audiology services provided through Bupa Optical and Bupa Hearing (bupaoptical.com.au and hearing.bupa.com.au);
- dental services provided by Dental Corporation Pty Ltd trading as Bupa Dental (bupadental.com.au);
- visa medical services provided by Bupa Medical (bupa.com.au/medical/gp); and
- health coaching services provided by Bupa Telehealth (bupahealthdialog.com.au).
1.2 Who does this policy apply to?
This policy applies to your personal information if you:
- are a current or former resident of one of our Care Homes, or are a relative or representative of a resident;
- are a current or former patient of Bupa Seaforth Health and Wellbeing Centre;
- have made enquiries or contacted us to enquire about our services or products; or
- have applied for a job with us (but you are not a current or former employee); and
- we hold your personal information.
If you are unsure whether we hold your information or whether this policy applies to you, you should contact us (our contact details are at the bottom of this policy).
2. Collecting your personal information
2.1 What type of information do we collect?
The type of information we collect from you depends on our relationship with you – for example, whether you are a resident in a Bupa Aged Care home, a relative of a resident, or have simply made enquiries about our products and services.
The types of information we collect in relation to residents in Care Homes, includes:
- name and date of birth;
- contact details (including address, phone number(s), email);
- health information (which will include care needs, records of care assessments, clinical records about care or treatment, medical history, test results);
- anyone you have chosen, or who has been appointed to act on your behalf, including friends or relatives, next of kin, persons appointed as power of attorney or guardian;
- billing details;
- records of our interactions with you, for example emails, letters, notes and in some cases voice recordings of telephone conversations you have had with our employees;
- pension or DVA details;
- personal preferences (for example, in relation to activities or events); and
- feedback on services.
If you are a relative or representative of a resident in a Bupa care home, we may collect:
- your name;
- your contact details (including address, telephone number(s) and email); and
- records of your interactions with us (including correspondence like letters and email).
If you are a patient of Bupa Seaforth Health and Wellbeing Centre, we may collect the following types of information about you:
- your name and contact details;
- information about your health including your medical history, medications you take, test results;
- your Medicare and private health insurance details;
- your billing information;
- information about your emergency contact and any person who is able to act on your behalf or is responsible for billing on your behalf.
2.2 How we collect your information
Bupa Aged Care collects information in a number of ways, including:
- if you contact us by email, phone, post or online we will keep a record of that contact;
- when you apply to become a resident in a Bupa Care Home, we will have a record of your application and your resident agreement;
- when you become a patient of Bupa Seaforth Health and Wellbeing Centre, we will collect the information you provide on the new patient registration form.
We will always endeavour to collect information from you directly, however in some cases we may collect information about you from others. For example, we may collect your information from:
- if someone is acting on your behalf, such as a relative, or someone has been formally appointed to act on your behalf, such a person who appointed as your power of attorney;
- from your doctor, specialist, hospitals or other health professionals involved in your care or treatment; and
- from government departments such as the Department of Human Services (including Medicare or Centrelink details) or the Department of Veterans’ Affairs.
If you are providing us information about another person on their behalf, you must ensure that you have their permission to do so and you should inform that person (where practicable) that we will handle their information in accordance with this policy.
2.3 If you do not provide all of the information we have requested
If you do not provide all of the information we have reasonably requested, we may be unable to provide you with the products or services you have requested from us.
2.4 Purposes of collecting your personal information
We collect and hold your personal information in order to provide you with our services and products. For residents in a Bupa Care Home, we primarily collect and hold personal information in order to provide appropriate residential care. For patients of the Bupa Seaforth Health and Wellbeing Centre, we collect information in order to provide GP services and other healthcare services.
Please refer to section 3 (below) for further information on how we use and disclose the personal information we collect.
3. Using and disclosing your personal information
3.1 What we may use your information for
We use your personal information to provide, manage and administer our services and products to you and to operate an efficient and sustainable business. As part of doing so, we may use your personal information to:
- provide you with appropriate residential care and services;
- provide clinical services to you (for example, services by nurses, doctors or other healthcare professionals);
- contact you, or your relative or representative about matters relating to you, your care or the products and services we provide to you;
- schedule and book activities and services;
- process payments;
- answer your queries and resolve complaints;
- undertake quality assurance and service improvement;
- carry out internal functions like administration, finance, information technology, training and audit;
- undertake customer surveys, customer and market research and analysis;
- monitor, price and evaluate our services and products;
- conduct marketing and promotional activities;
- practise effective risk management; and
- comply with relevant laws and regulations;
3.2 Disclosing your personal information
Bupa Aged Care will disclose your personal information where required to provide you with our services or products. In some instances, we may disclose personal information to third parties, including to:
- anyone engaged on our behalf to provide products and services, such as contractors or service providers. We require all service providers that we engage to protect the privacy of your information and to comply with any relevant privacy laws;
- healthcare providers who are involved in your care, such as doctors, hospitals, allied health professionals and specialists;
- government and regulatory bodies including the Department of Human Services, State or Territory health departments, the Aged Care Complaints Commissioner and the Aged Care Quality Agency;
- on a confidential basis, with our related companies within the Bupa Group;
- any persons acting on our behalf, including professional advisers;
- where disclosure is permitted or required by law
Where we engage contractors, service providers or others to act on our behalf, Bupa Aged Care will take reasonable steps to protect the privacy of all information disclosed and requires such parties to comply with any relevant privacy laws. You have the right to ask these organisations or contractors for access to information they hold about you.
In the course of operating our business we may in some instances disclose information to recipients located outside of Australia, including in the United Kingdom.
3.3 Direct marketing
From time to time, we may contact you (by post, email, phone or SMS) to provide you with information about products and services offered by us, our related entities and our business partners that may be of interest to you. This includes information or services that can help you improve your wellbeing.
We may share your personal information on a confidential basis with our related entities and bodies corporate so that they can offer you products and services and fulfil offers to you.
When you become our customer, 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.
4. Security, access and correction
4.1 How we store your information securely
Bupa Aged Care stores personal information in a combination of electronic and hard copy (paper-based) formats.
We take all reasonable steps to protect the personal information we hold and ensure it is secure, this includes the following measures:
- secure physical storage of documents;
- appropriate security measures on premises we occupy;
- network and communications security measures;
- restricting access to physical or electronic records only to authorised personnel; and
- monitoring, compliance and quality system procedures.
We keep information for as long as it is required to be able to provide the intended service(s) or to meet legal and regulatory requirements. If we no longer require personal information for any purpose, we will take steps to permanently de-identify or securely destroy it in line with organisational procedures.
4.2 Accessing your personal information
You have a right to reasonable access to any information that Bupa Aged Care holds about you. To request access to your information, please contact us (our contact details are outlined below).
We may ask you to submit your request in writing and provide proof that you are legally entitled to obtain access to the information you are requesting (for example, if you are making a request on behalf of someone else).
We reserve the right to charge for providing access to certain information, as permitted by law and you will be informed of this at the time of your request. We will always endeavour to meet your request for access within a reasonable timeframe and in the manner requested by you if it is reasonable to do so.
However, in some circumstances we may decline a request for access to information such as where we no longer hold the information, or where denying access is permitted or required by law. 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.
4.3 Updating or correcting your 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 your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it. In addition, if your information changes you should contact us to let us know.
If you believe any information we hold about you is inaccurate, incomplete or out-of-date, you should contact us (our contact details are below).
5. Privacy and security online
5.1 Online security
Our website at bupaagedcare.com.au site uses Secure Socket Layer (SSL) encryption to keep your transactions secure and private. SSL is the industry standard for data encryption. It provides a secure link between your browser and our server, and scrambles your personal information to ensure it is kept private during transmission over the internet.
5.2 What we collect when you use our website
When you access the bupaagedcare.com.au website or any Bupa website, we may collect anonymous technical information about your use of the website. This may include information such as the type of browser used to access the website and the pages visited.
This information is used by Bupa to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details.
You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. For example, you can set your browser to notify you when you receive a cookie or to reject cookies. However, if you decide not to display cookies, then you may not be able to gain access to all the content and facilities of this website.
6. Contacting us
6.1 Our contact details
If you would like to access your personal information, correct or update your information, give us feedback or make a complaint you can contact us as per the following details:
For Bupa Seaforth Health and Wellbeing Centre customers:
Call us on 1300 510 674
Write to us at Bupa Health and Wellbeing Centre 550 Sydney Road, Seaforth, NSW 2092
6.2 Complaints about how we handle your information
If you would like to make a complaint about the handling of your information we encourage you to contact us to try to resolve the matter first. We will always try to work with you to resolve the issue. In some cases we may need to investigate the matter first and we will keep you updated on the progress of such investigation.
If we have tried to resolve your complaint and you are not happy with our response, you may also contact the Office of Australian Information Commissioner by calling 1300 363 992 or by visiting oaic.gov.au.