Privacy Policy

BONCENTRIC PRIVACY POLICY

Boncentric (ABN 60 167 068 653) is committed to protecting the privacy of your personal information. We recognise that your privacy is very important to you, and believe that this statement will address any potential concerns you may have about how personal information you provide to Boncentric is collected, held, used, corrected, disclosed and transferred.

Background

The Privacy Act 1988 (Privacy Act) is an Australian law which regulates the handling of personal information about individuals. Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

The Privacy Act includes thirteen Australian Privacy Principles (APPs). The APPs provide a privacy protection framework that supports the rights and obligations of collecting, handling, holding, using, accessing and correcting personal information. These APPs complement Boncentric’s commitment to ensuring personal information is managed appropriately and transparently.

The kind of personal information we collect

Boncentric will collect personal information in order to fulfil its obligation to provide services to the participant. Such information will not be used or disclosed for any other purposes without your consent, except in exceptional cases when disclosure may be required by law or is necessary to protect the rights or property of Boncentric, or any member of the public, or to lessen a serious threat to a person’s health or safety.

The types of personal information we may collect include:

▪ identifying information such as name, date of birth, employment details;

▪ contact information such as telephone number and email address;

▪ health information including current and past medical history; and

▪ information about lifestyle, nutrition, fitness and psychological and social health.

Boncentric does not allow the option of participants providing personal information anonymously as it would be impractical in providing personalised medical advice. Personal information is obtained directly from the participant.

Use and disclosure of information

Personal information will be used for the purpose of providing health services to the participant (including referral follow-up and health coaching programs). To that extent, your personal information may be disclosed to other health service providers to whom you have consented or requested for your information to be disclosed.

De-identified, aggregate data may be utilised for the purpose of corporate reporting. Minimum numbers apply for any statistical analysis to ensure anonymity and confidentiality of personal and sensitive health information.

Boncentric will not use any personal information in relation to direct marketing to a participant without that participant’s express consent. Boncentric will evaluate all unsolicited information it receives in order to decide whether it should be kept, acted upon, or destroyed.

Security

Boncentric takes all reasonable steps to protect your personal information from misuse, loss, or unauthorised access, modification or disclosure. We store your information securely and have a range of security controls in place to ensure that your information and documents are protected. All of our staff are trained on privacy and access to personal information is restricted to individuals properly authorised to do so.

If your personal information is no longer needed for any purpose, Boncentric, on an annual basis, will ensure that the information is de-identified.

Identifiers

We will not adopt as our own any identifiers that you may provide to us such as TFNs or Medicare numbers.

Overseas disclosure of personal information

In order to utilise cloud storage and IT servers that are located offshore, we may transfer personal information outside Australia in accordance with the Privacy Act. Where we do, we take reasonable steps to ensure that your information is given the same type of protection as it is afforded within Australia. This may be through satisfying ourselves that the overseas organisation has controls in place to comply with Australian privacy laws, ensuring that the overseas organisation is located in a country which we believe has a similar privacy regime to Australia or through contractually or otherwise mandating the adequate management of the information.

By providing us with your personal information, you consent to us disclosing your personal information to entities located outside Australia for the sole purpose of utilising cloud storage and IT infrastructure. The only country to which this personal information will be transferred to is the USA.

Access to your personal information

You have a right to access your personal information, subject to exceptions allowed by law. Participants are encouraged to make this request in writing, and Boncentric will respond within a reasonable time.

Boncentric will take reasonable steps to correct personal information where they are satisfied they are not accurate or up to date. Participants may also request Boncentric corrects or updates their information, and again, such requests should be made in writing.

Note that we need not provide access to personal information in several types of situations, for example where a request is frivolous, or where to provide access would pose a threat to health or public safety, unreasonably interfere with another person’s privacy, or be a breach of the law. If we refuse access we will advise you of our reasons for doing so.

Complaints

We are committed to providing participants and other parties whose personal information we hold, a fair and reasonable system for the handling of their complaints. Any privacy concerns should be addressed in writing to:

Boncentric Complaints Officer

65/54 Vernon Terrace

Teneriffe, QLD, 4005

Email: complaints@boncentric.com.au

Boncentric will resolve the complaint in accordance with its complaints resolution procedure.

Variation

Boncentric reserves the right to make amendments to this statement at any time. A copy of this Privacy Policy will be available on our website and will also be available on request. Participants acknowledge and agree to comply with this Privacy Policy as amended from time to time.

Further information

Boncentric welcomes your comments regarding this Privacy Policy. If you have any questions or would like further information, please contact the Boncentric Privacy Officer:

Boncentric Privacy Officer

65/54 Vernon Terrace

Teneriffe, QLD, 4005

Email: privacy@boncentric.com.au