THE TRUSTED DIETITIANS
FEES & POLICIES
Privacy policy
Retention and destruction of personal information
We are required by law to retain health records for minimum periods. Generally, we retain an adult patient’s health records for at least 7 years from the date of last service, and health records for patients treated as children until they reach 25 years of age, consistent with our obligations under the Health Records (Privacy and Access) Act 1997 (ACT). Once we no longer require your personal information and are not legally required to retain it, we will take reasonable steps to destroy or permanently de-identify it.
About this policy
Live Better Nutrition is a trading name for Speed to Insight Pty Ltd (ABN 82 617 438 909), which operates a dietetics business in Australia. References to “Live Better Nutrition”, “we”, “us” and “our” in this Policy refer to Live Better Nutrition.
Live Better Nutrition is bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). The APPs are designed to protect the confidentiality of information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and managed. Personal information is, generally speaking, information or an opinion relating to an identified, or reasonably identifiable, individual.
In addition, because we provide health services and hold health records in the Australian Capital Territory, we are also bound by the Health Records (Privacy and Access) Act 1997 (ACT), which regulates how health records are collected, held, used, accessed and corrected in the ACT. Where we provide services at our New South Wales clinics, we are also bound by the Health Records and Information Privacy Act 2002 (NSW). Health information we collect through telehealth consultations with clients in other States and Territories is handled in accordance with the Privacy Act and any equivalent State or Territory health records legislation that applies.
This policy explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about this information.
Why do we collect personal information?
We collect personal information about our patients, suppliers, contractors and other contacts to understand and meet their needs, to conduct our activities and meet legal obligations.
What personal information do we collect?
The types of personal information we may collect include contact information (such as your name, address, email address, fax and telephone number) and any feedback that you provide to us about our products and services, our website, or other matters.
Sometimes our activities require us to collect sensitive information. For more details, see the section “Sensitive information is subject to greater restrictions”, below.
What other information do we collect?
Personal information may be collected by way of forms filled out by individuals (including via online forms), surveys, emails, telephone conversations, online user-generated content and market research, face-to-face meetings, interviews and consultations.
You may in some circumstances have the option of not identifying yourself or using a pseudonym when you deal with us.
We also collect statistical information about visitors to our website using web analytics technology provided by third party service providers such as Google Analytics. These services may use cookies to assist us in understanding how visitors access and utilise our site. Generally this information cannot be used to identify particular individuals. However, in some circumstances it may include a visitor's internet protocol (IP) address, which could be linked to an individual.
We also advertise our services through Google Ads. Where you arrive at our website from one of our advertisements, Google conversion tracking cookies may record that a booking or enquiry was made, so that we can measure how our advertising is performing. This information is reported to us in aggregate and does not identify you to us. We do not use remarketing or retargeting advertising, and we do not build advertising audiences based on the pages you visit on our site. You can review and adjust how Google uses information for advertising at myadcenter.google.com, and you can opt out of Google Analytics using the browser add-on Google provides.
We also maintain a presence on social media platforms. We do not publish patient or clinical information on social media. If you contact us through a social media platform, any personal information you provide is also subject to that platform’s own privacy policy, and we ask that you do not share health or other sensitive information through public posts or messages.
How might we use and disclose your personal information?
We may use and disclose your personal information for the primary purpose of collection, or for reasonably expected secondary purposes which are related to the primary purpose, or for purposes to which you have consented, and in other circumstances authorised by the Privacy Act.
Generally, we may use and disclose your personal information for a range of purposes, including to:
— provide you with our products or services that you have requested;
— respond to your queries or feedback;
— analyse and improve all aspects of our business including, but not limited to, our business systems, processes, outcomes, communication, website, engagement and performance;
— provide you with any communications or publications in which we think you might be interested, or which you have requested;
— facilitate your participation in forums, social events and educational events.
Where we send you communications or publications, you may opt out at any time by using the unsubscribe facility in the message or by contacting us. We will not use or disclose your personal or sensitive information for direct marketing purposes without the consents required by law.
Disclosure of personal information to other parties
We may also disclose your personal information if it is required or authorised by law, where disclosure is necessary to prevent a threat to life, health or safety, or where we are otherwise permitted by the Privacy Act.
We do not sell or license your personal information to third parties.
Overseas disclosure
We store our patients’ clinical records in Cliniko, a practice management system that holds data within Australia and is suitable for clinical use. Our clinical records are not stored or disclosed overseas.
Some personal information is handled through Google services (email and website analytics), and Google may store and process this information on servers located overseas, including in the United States. This includes information contained in emails we send and receive — for example, patient referrals sent to us by referring practitioners, which may contain personal and health information. Other than through these service providers, we do not disclose patient information overseas.
Sensitive information is subject to greater restrictions
Some of the information we collect may be “sensitive information”, including information or an opinion about an individual’s health.
We may use and disclose your sensitive information for the primary purpose of collection, or for reasonably expected secondary purposes which are directly related to the primary purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Act (for example where required or authorised by law to be disclosed, or where disclosure is necessary to prevent a threat to life, health or safety).
Security and management of personal information
We will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. The ways we do this include:
— limiting physical access to our premises;
— limiting access to the information we collect about you — only those of our personnel who need your information to carry out our business activities are allowed access;
— requiring any third party providers to have acceptable security measures to keep personal information secure; and
— putting in place physical, electronic, and procedural safeguards in line with industry standards
Data breaches
If we become aware of a data breach that is likely to result in serious harm to individuals whose personal information we hold, we will assess it and, where required, notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme under the Privacy Act.
Links from our website to other websites
Our website may contain links to third party websites. We do not operate these websites and therefore are not responsible for the collection or handling of personal information by the operators of these websites.
Accessing the information we hold about you
Under the APPs, you may be able to obtain a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard. To make a request to access this information, please contact us in writing. We will require you to verify your identity and specify what information you require. We do not charge for making a request. We may charge a reasonable fee for the cost of retrieving, reviewing and copying the material requested; any such fee will not be excessive, and we will advise you of it before proceeding.
Correcting the information we hold about you
Please contact us at the contact address set out below if you believe that the information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will take reasonable steps to correct it so that it is accurate, up-to-date, complete, relevant and not misleading. If we do not agree that a correction is required, you may ask us to associate a statement with the information noting your view that it is inaccurate or out-of-date.
Updates to this policy
This Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The current version of this Privacy Policy is available on the Live Better Nutrition website.
Complaints
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process, or you may decide to make a formal complaint with the Office of the Australian Information Commissioner, the regulator responsible for privacy in Australia.
We will deal with complaints as follows:
Step 1: Tell us about it
If you would like to make a complaint, you should let us know by contacting our Privacy Officer (contact details below).
Step 2: We will investigate
Your complaint will be investigated by our Privacy Officer. A response to your complaint will be provided in writing, ordinarily within 30 days.
Step 3: Contact the OAIC if required
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can contact the Office of the Australian Information Commissioner (complaints must be made in writing): Director of Compliance, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001 — www.oaic.gov.au
Contact us
Any complaints or correspondence in relation to this Privacy Policy should be sent to our Privacy Officer at:
Speed to Insight Pty Ltd t/a Live Better Nutrition
GPO Box 2815, Canberra ACT 2601
Attention: The Privacy Officer
We will endeavour to respond to all complaints and correspondence promptly.