Privacy Policy
Scope
This document refers to personal data and how it is stored and utilised, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

Manual Practitioner Fiona Lovett (Topaz Health), based at .........Sydney........ which hereafter for the purposes of this Privacy Notice will be referred to as Manual Practitioners, is pleased to provide the following information:

Who we are
Manual Practitioners assess and treat health conditions in accordance with their code of ethics and standards.

Personal Data
a) For the purposes of providing treatment, Manual Practitioners may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Manual Practitioners to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment. As part of our obligations as  healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g. GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
b) For marketing purposes, the Manual Practitioners may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to Manual Practitioners maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Manual Practitioners may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. Manual Practitioners do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
e) Manual Practitioners' website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Websites use cookies to help Manual Practitioners to identify and track visitors and their website access preferences. Manual Practitioners' website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Osteopaths’ website.
f) Manual Practitioners will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
Legitimate interests pursued by Manual Practitioners
To promote treatments for patients with all types of health problems indicated for manual therapy care.

Consent
Through agreeing to this privacy notice you are consenting to Manual Practitioners processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.

Disclosure

Manual Practitioners will keep your personal information safe and secure, only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account. Manual Practitioners will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.

Retention Policy
Manual Practitioners will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details. Records concerning minors (under 18) who have received treatment will be retained until the child has reached the age of 25.

Data storage
All Data is held in the Australia. Manual Practitioners do not store personal data outside Australia. Data is held electronically on a specific designed patient software programme called Cliniko which is password secured. Only the Manual Practitioners have access to this information, with the only exception being the pre-vetted IT consultant for Cliniko when addressing software issues and who can only gain access via remote viewing with the Manual Practitioners permission and in their presence. Pre-vetted receptionists who take bookings and messages for the Manual Practitioners will have access to patient’s contact details such as name, phone number, email and postal address but not to their medical or treatment records. Any hard copy paper forms or medical records supplied by the patient are kept in a secured locked box that only the Manual Practitioners have access to.

Your rights as a data subject
At any point whilst Manual Practitioners are in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Manual Practitioners refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request Manual Practitioners can confirm what information it holds about you and how it is processed.
You can request the following information:
• Identity and the contact details of the person or organisation (Manual Practitioners) that has determined how and why to process your data.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Manual Practitioners and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required
Manual Practitioners will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Manual Practitioners is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to fiona@topazhealth.com.au or by phoning +61 (0)....................or writing to us at the address further below.

Contact Details
Fiona Lovett (Nexus Vitality)
Telephone +61 (0) ............ or email: fiona@topazhealth.com.au
Address:

Email
fiona@topazhealth.com.au

Phone
0422 713 396
(02) 9957 1091 - Blues Point Practice

Address
Blues Point Practice
117 Blues Point Road,
North Sydney NSW 2060

Hours
Tuesday: 8:30am - 7pm
Friday: 8:30am -6pm

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