QUEENSLAND COUNTRY HEALTH FUND. privacy policy. Queensland Country Health Fund Ltd ABN better health cover shouldn t hurt

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1 QUEENSLAND COUNTRY HEALTH FUND privacy policy Queensland Country Health Fund Ltd ABN better health cover shouldn t hurt 1

2 2

3 contents 1. Introduction 4 2. National Privacy Principles 5 3. Collecting, Using and Disclosing Personal Information 5 4. Consenting to the Use and Disclosure 7 5. Collecting Personal Information from a Third Party 7 6. Disclosing Personal Information to a Third Party 8 7. Managing Personal Information 8 8. Accessing Personal Information 9 9. Correcting Personal Information Health Fund Contact Information Complaints Changes to this Privacy Policy 11 3

4 1. Introduction 1.1 Queensland Country Health Fund Ltd ( the Health Fund ) is committed to protecting personal information held by the Health Fund. 1.2 This Privacy Policy document forms part of the Fund Rules for Queensland Country Health Fund ( QCHF ) and describes the Health Fund s management of personal information in compliance with its obligations under the privacy legislation. 1.3 Any reference to the Health Fund, we, our or us in this document is reference to Queensland Country Health Fund Ltd. 1.4 In this document, unless the context requires otherwise, the following terms have the following meanings: Access Access involves the Health Fund giving an individual information about themselves held by the Health Fund. Giving access may include allowing a Member to inspect personal information or giving the Member a copy of the information. Collection The Health Fund collects personal information when it gathers, acquires or obtains personal information from any source and by any means. Consent Consent means voluntary agreement to some act, practice or purpose. It comprises both knowledge of the matter agreed to, and voluntary agreement. Consent can be express, that is given explicitly, either orally or in writing. Consent can also be implied, that is, where consent may reasonably be inferred in the circumstances from a person s conduct. Disclosure The Health Fund discloses personal information when it releases information to others outside the organisation. This does not include giving individuals information about themselves. This is addressed under access. Personal information Personal information is information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Sensitive information Personal information includes sensitive information. Sensitive information means information or opinion about an individual s racial or ethnic origin, political opinions, membership of a political association, a professional or trade association or a trade union, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, criminal record or health information about an individual. Use Use of personal information refers to the handling of personal information within the Health Fund. 4

5 2. National Privacy Principles 2.1 The Health Fund is bound by the Privacy Act 1988 ( the Act ), including the National Privacy Principles ( NPP ) contained in the Act and other laws regulating the collection, use and disclosure, and secure management of personal information. 3. Collecting, Using and Disclosing Personal Information 3.1 The Health Fund only collects personal information that is necessary for the performance of Health Fund functions and activities. 3.2 Personal information collected, used and disclosed by the Health Fund will depend upon the nature of the activity or function the Health Fund is performing for the individual. It includes but is not limited to the following personal information: Information individuals give the Health Fund when applying for or requesting a product or service from the Health Fund including: ø name; ø address; ø telephone and contact details; ø date of birth; ø payment and financial institution details; ø i nformation concerning changes of cover, previous or current private health insurance policy details; ø Medicare number; ø registration for the Federal Government Rebate on private health insurance; employer details (for Corporate Health Plan Members) Details of claims made by a Member including the following: ø service type; ø provider; ø date of service; and ø benefits paid Communications between individuals and the Health Fund. 3.3 The personal information collected by the Health Fund encompasses sensitive information which includes an individual s health information, for example, any pre-existing ailments, illnesses or conditions experienced by the individual. 3.4 Sensitive information collected by the Health Fund will only be used for the primary purpose of collection or for a purpose directly related to the primary purpose. 3.5 The collection of individuals health information is strictly regulated by the Act including the NPPs and also the rules established by competent health or medical bodies that deal with obligations of professional confidentiality that bind the organisation. 5

6 3.6 The personal information collected by the Health Fund about an individual will not be used or disclosed except for a purpose the individual would reasonably expect, a purpose required or authorised by law, a purpose otherwise disclosed to or authorised by the individual, or a purpose set out in this policy, including the following: (a) to provide Members with the products or services they have requested; or (b) to assess an application by individuals for products or services provided by the Health Fund and where that application is approved, to provide those products or services to Members; (c) to assess health insurance benefits payable on Members claims; (d) to pay Members claims to their nominated financial institution; (e) to communicate with Members in relation to the products and services provided to them; (f) to respond to Member queries; (g) to undertake administration activities including accounting and information technology functions; (h) to conduct Member surveys; (i) to resolve Member complaints; (j) to facilitate auditing of the Health Fund s activities; or (k) to comply with any direction provided under a law or regulation authorising the disclosure of personal information, including statutory notices issued by enforcement and other government bodies. 3.7 If the Member fails to give the Health Fund the personal information requested, the Health Fund may be unable to provide the product or service or undertake the activity requested by the individual. 3.8 The Health Fund may also collect some information about individuals when they use the Health Fund s website ( the website ). 3.9 When individuals visit the website, the Health Fund s server may attach a small data file, called a cookie, to the hard drive for the Health Fund s record keeping purposes. The Health Fund does not store any information inside cookies. Cookies are a feature of most websites. Most web browsers are set to accept cookies, but may be set to refuse them. If the Health Fund uses cookies it would be to provide aggregate and anonymous information on how people use the website and what they find interesting and useful on it. The Health Fund would not link this information back to any information Members have otherwise provided The Health Fund tracks usage patterns on an anonymous and aggregate basis. An individual s identity cannot reasonably be ascertained from this information. Each time the website is visited, a web server records the visit, and information that includes the individual s internet provider s address; the date and time of the visit; the pages accessed and documents downloaded and any search items entered If individuals visit the website to complete an online form or to send an to the Health Fund, the Health Fund will record the information given, including addresses. The use of the facilities and information available on the website will determine the type and amount of personal information the Health Fund collects about individuals.

7 4. Consenting to the Use and Disclosure 4.1 Unless otherwise required or authorised by law, the Health Fund will only collect, use or disclose an individual s personal information with the consent of the individual. This authorisation may be provided by the individual to the Health Fund in various ways including the signing of a consent form, expressly or impliedly during communications with Health Fund staff or representatives, in person by phone, in writing by mail or , or through the Health Fund s website. 4.2 On becoming a Member of the Health Fund an individual is taken to have impliedly consented to the Health Fund s use of their non-sensitive personal information for direct marketing purposes, to provide the individual with information about other products and services offered or distributed by the Health Fund or any related company(ies). 4.3 In undertaking marketing activities the Health Fund may disclose Members non-sensitive personal information to any related company(ies) and to organisations to whom the Health Fund contracts out its functions, including mailing houses and information technology service providers. 4.4 A Member may withdraw their consent to the use of their personal information for marketing purposes at any time by contacting the Health Fund. The contact details are provided in Section 10 of this document. 4.5 The law requires the Health Fund to provide Members with certain information about the product or service that they have acquired from the Health Fund. Members will continue to receive this type of information from the Health Fund even if they have elected not to receive direct marketing information about products and services provided by or through the Health Fund. 5. Collecting Personal Information from a Third Party 5.1 Where possible, the Health Fund will collect personal information about an individual only from that individual. However, the Health Fund may be required to collect personal information about an individual from a third party. For example, where a person is noted on a policy as a dependant (including a partner or child) of the policy holder, the policy holder may be required to give the Health Fund details of all persons covered on the policy. 5.2 The Health Fund will only collect personal information about an individual from a third party under the expectation that the third party is authorised to provide this information to the Health Fund and agrees to inform the individual: (a) who the Health Fund is; (b) for what purposes their information will be used and disclosed by the Health Fund; (c) the fact that the individual is able to access their information; (d) the types of organisations to which the Health Fund is able to access their information; (e) the types of organisations to which the Health Fund usually discloses personal information of that kind; 7

8 (f) the main consequences to the individual if all or part of the information is not provided; and (g) the relevant laws that require the particular information to be collected. 6. Disclosing Personal Information to a Third Party 6.1 The Health Fund may disclose individuals personal information to third parties including: (a) Hospitals, medical and ancillary service providers in providing health insurance to Members; (b) other health insurers; (c) contractors including information technology providers and mailing houses; (d) external service providers who the Health Fund engages from time to time to carry out, or advise on its functions and activities; (e) auditors appointed by the Health Fund, regulatory and other external bodies; (f) regulatory bodies and government agencies including Medicare, the Australian Taxation Office, the Private Health Insurance Ombudsman, the Department of Health and Ageing, the Private Health Insurance Administration Council; law enforcement bodies including the State police services; Australian Federal Police and Courts; (g) Australian Health Service Alliance ( AHSA ); (h) Queensland Country Credit Union Limited. 6.2 The Health Fund ensures that all third party service providers to whom individuals personal information is disclosed are subject to the Act including the NPPs or, to arrangements imposing requirements on them equivalent to the requirements under the Act with respect to the protection and management of personal information. 7. Managing Personal Information 7.1 The Health Fund takes reasonable steps to protect the personal information it holds from misuse and loss, and from unauthorised access, modification or disclosure. In considering the security of Members personal information, the Health Fund considers the following: (a) Physical security: (i) (ii) All files containing personal information are stored securely on premises during and after business hours. All files containing personal information are accessible only by staff requiring access to the information to perform tasks in relation to the purposes for which the information was provided. (iii) Drafts, spare copies and extra materials generated in the handling of files containing personal materials are destroyed by means of a secure destruction service. (iv) Personal information that is no longer required is permanently de-identified or destroyed by means of a secure destruction service. 8

9 (v) Information about closed Memberships is securely stored; held for the statutory retention period and subsequently destroyed by means of a secure destruction service. (b) Computer and network security: (i) (ii) Access to the computer network is by user identification and password only. Passwords are changed regularly. The system administrator can identify all users by their user identification. Files are regularly backed up and saved at a separate and secure site. (iii) Network security includes firewall and virus protection and network intrusion detection systems. (c) Communications security: No personal information is provided at our offices, over the telephone or by facsimile until the identity of the applicant is verified. (d) Personnel security: (i) (ii) Hard file and computer copies of unsuccessful applications for employment are destroyed by means of a secure destruction service. Appropriate and lawful enquiries are made before an offer of employment is made to any person. Access to Members personal information is restricted to staff required and authorised to have access to that information. 7.2 The Health Fund does not use external identifiers to assist in the management of personal information. 8. Accessing Personal Information 8.1 The Health Fund will provide individuals with access to their personal information it holds on request, except to the extent that: (a) providing access would pose a serious and imminent threat to the life or health of any individual; (b) providing access would have an unreasonable effect upon the privacy of other individuals; (c) the request for access is frivolous or vexatious; (d) the information relates to existing or anticipated legal proceedings between the Health Fund and the individual and the information would not be accessible by the process of discovery in those proceedings; (e) providing access would reveal the intentions of the Health Fund in relation to negotiations with an individual in such a way as to prejudice those negotiations; (f) providing access would be unlawful; (g) denying access is required or authorised by or under law; (h) providing access would be likely to prejudice an investigation of possible unlawful activity; 9

10 (i) providing access would be likely to prejudice: (i) (ii) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; the enforcement of laws relating to the confiscation of the proceeds of crime; (iii) the protection of the public revenue; (iv) the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct, (v) the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders; by or on behalf of an enforcement body; (j) an enforcement body performing a lawful security function asks the Health Fund not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia. 8.2 The Health Fund will handle requests for access to personal information in accordance with the NPPs. 8.3 Requests by Members to access their communications records or Member Benefit Statements are handled by the Privacy Access Officer (refer to Section 10 for contact details). Other requests for personal information are actioned by Health Fund staff. 8.4 The Health Fund will deal with all requests for access to personal information as quickly as possible with the response time determined by the nature of the request. 8.5 The Health Fund undertakes to action requests for personal information within 30 days of receipt of the request with the response time determined by the nature of the request. 8.6 If the Health Fund is unable to provide an individual with access to the personal information requested, the Health Fund will advise the individual its reasons for withholding access. 8.7 There will be no charge for lodging a request for access to personal information. However, the Health Fund may charge Members for providing access. Any charges will be determined in accordance with the reasonable costs incurred by the Health Fund in providing the information requested. Full disclosure of such costs will be provided to the Member prior to the provision of the information. 9. Correcting Personal Information 9.1 The Health Fund takes reasonable steps to confirm the accuracy, completeness and currency of individuals personal information which it holds at the time this information is collected, used or disclosed. Where an individual advises the Health Fund that their personal information is not accurate, complete or up-to-date, the Health Fund will update its records to reflect the correct personal information. 9.2 Members often have one or more Dependants covered by private health insurance under a Membership. Personal information concerning a Member or any Dependants covered by a Membership is confidential to the individual and is not accessible by any other person within 10

11 that Membership, without the appropriate authorisation, after the dependent has attained the age of Health Fund Contact Information 10.1 Requests by an individual to: (a) change personal information held by the Health Fund; (b) access personal information; (c) receive further information about the way the Health Fund manages personal information; (d) opt out of receiving direct marketing; (e) register a complaint about a breach of privacy may be directed to the Health Fund Privacy Access Officer by the following means: Post: PO Box 42, Aitkenvale QLD Phone: Complaints 11.1 The Health Fund encourages any person who is unhappy about the Health Fund s management of their personal information to discuss their concerns and provide the Health Fund with the opportunity of working with them to resolve the matter. Contact details are provided in Section Where a person is not satisfied with the Health Fund s response to a complaint concerning a privacy issue or breach the person may direct their complaint to the Federal Privacy Commissioner by telephone on or in writing to: Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW Changes to this Privacy Policy 12.1 This document is effective as of 1 November The Health Fund reserves the right to change this privacy policy at any time. If the Health Fund does change this privacy policy it will post amended versions in its offices and post an updated version on the website. 11

12 How to contact us If you have any questions or need more information, please contact us by: Branch Visit our website for a listing of all our branches Website Call Queensland Country Health Fund Ltd ABN is a Registered Private Health Insurer. QCHD014 V1.1 05/12 12

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