Privacy Policy INTRODUCTION Workforce Health Assessors Pty Ltd (ACN 094 392 588) (WHA, we or us) is committed to protecting your privacy. In Australia, WHA complies with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth). WHA also complies with State and Territory health records legislation. When performing medical assessments for State or Territory agencies, WHA also complies with the information privacy laws of the relevant State or Territory. In New Zealand, WHA complies with the Information Privacy Principles (IPPs) set out in the Privacy Act 2020 (NZ) and the Health Information Privacy Rules (HIPRs) set out in the Health Information Privacy Code 2020 (NZ). This policy is designed to explain how WHA collects, uses, discloses and handles your personal information. We may amend this policy at any time and for any reason. You should check this policy regularly for changes. SCOPE This policy applies to WHA and WHA Group International Pty Ltd. WHAT INFORMATION DOES THIS POLICY COVER? In Australia: Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Personal information may include sensitive information about the individual such as racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic or biometric information. Health information means: (a) information or an opinion about: the health, including an illness, disability or injury, (at any time) of an individual; or an individual’s expressed wishes about the future provision of health services to the individual; or a health service to be provided, to an individual; that is also personal information; (b) other personal information collected to provide, or in providing, a health service to an individual; (c) other personal information collected in connection with the donation, or intended donation, by an individual of his or her body parts, organs or body substances; (d) genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual. In New Zealand: Personal information means information about an identifiable individual. Health information means information or classes of information about an identifiable individual which is: information about the health of that individual, including his or her medical history; information about any disabilities that individual has, or has had; information about any health services or disability services that are being provided, or have been provided, to that individual; information provided by that individual in connection with the donation, by that individual, of any body part or any bodily substance of that individual or derived from the testing or examination of any body part, or any bodily substance of that individual; or information about that individual which is collected before or in the course of, and incidental to, the provision of any health service or disability service to that individual. WHEN DO WE COLLECT PERSONAL INFORMATION? WHA collects personal information from individuals in a number of situations. The most common situations in which we collect personal information are: from candidates for a medical assessment, when they complete a form or questionnaire, or provide us with information verbally or via email; from employers, potential employers and recruitment agencies who request us to perform a medical assessment (requesting organisations); through the medical assessment process and from the medical assessment results; from medical facilities and medical professionals contracted by WHA (contractors); from WHA employees and potential employees; through marketing activities, trade expos, email and online enquiries and similar mechanisms where interested persons contact us about the services we provide and opportunities to partner with us. If you correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protection for these electronic communications that we use in the storage of information received by mail and telephone. Some of our medical assessments are conducted by medical facilities and medical professionals contracted by WHA (contractors). In those cases, the contractor will collect your information and pass it on to WHA. WHAT PERSONAL INFORMATION DO WE COLLECT? The types of personal information we collect from you will depend on the situation in which that information is collected. For example, in relation to a medical assessment, we may collect personal information including: personal details including your name, date of birth and gender; contact details including address, telephone number and email address; identification such as driver’s license details; medical history and assessment results; employer and potential employer contact and payment details; and website use information collected on an aggregated basis as users browse our website. If you do not provide us with all the information we request, we may not be able to provide our services to you. HOW DO WE USE PERSONAL INFORMATION? The purposes for which we will use your personal information will depend on the situation in which that information is collected. We will inform you of the purposes for which we intend to use your personal information at or before the time we collect your personal information. Generally, we may use your personal information for: the purpose for which you provided it to us; purposes which are directly related to the purpose for which you provided it to us; any other purposes to which you have consented; and any other purposes permitted or required by law. For example: when we perform a medical assessment, we may use the candidate’s personal information to book an appointment, send appointment notifications, conduct the assessment, generate an assessment report, contact the candidate or the requesting organisation to arrange further assessments if required; we may use personal information of WHA employees to manage the employment relationship with that employee; and we may use the personal information of WHA contractors to manage the contractual relationship with that contractor. We will take reasonable steps to ensure any personal information we use is accurate, up-to-date, complete and relevant, having regard to the purposes for which it is used. We do not use personal information for direct marketing purposes. We may use de-identified candidate information to generate reports for State or Federal government departments for averages and benchmarking purposes. TO WHOM DO WE DISCLOSE PERSONAL INFORMATION? The third parties to whom we disclose your personal information will depend on the situation in which that information is collected. We will inform you of the types of third parties to which we may disclose your personal information at or before the time we collect your personal information. Generally, we may disclose your personal data as necessary for: the purpose for which you provided it to us; purposes which are directly related to the purpose for which you provided it to us; any other purposes to which you have consented; and any other purposes permitted or required by law. For example: when we perform a medical assessment, we may disclose the candidate’s personal information to: the contractors who conduct the assessment; the requesting organisation, if any; and/or specialist medical professionals, if necessary to obtain further advice from them; we may disclose personal information to third parties who provide administrative services to WHA (such as technology and data processing services) which assist us to carry out the above purposes. In exceptional circumstances, we may be required or permitted by law to disclose personal information, for example to law enforcement authorities or to prevent a threat to the health and safety of an individual. DISCLOSURE OF PERSONAL INFORMATION OVERSEAS Your personal information is stored in Australia; however, we use contractors located in the Philippines to perform some data processing tasks in relation to medical assessments, and those contractors may have remote access to candidate personal information. We require those contractors to agree to treat all personal information they access in accordance with the Australian Privacy Principles and New Zealand Information Privacy Principles. STORAGE OF PERSONAL INFORMATION WHA take reasonable steps to protect the security of personal information, including the physical security on our premises, electronic security to protect our IT systems, and organisational measures to ensure security measures are complied with by our employees. WHA securely deletes or de-identifies personal information when it is no longer required for any legal or commercial purpose. Upon written request from an individual, WHA will delete or de-identify any personal information it holds about them, unless there is a legal or commercial requirement to retain that personal information. ACCESSING YOUR PERSONAL INFORMATION You have the right to access the personal information WHA holds about you. WHA will require you to provide proof of identity before providing access. You may request access to your personal information by sending a request to [email protected], by visiting Level 4, 15 Victoria Street, Hobart, Tasmania or by telephoning 1300 552 722. WHA will endeavour to respond to your request for access within 30 days. There are certain situations in which we may decline to provide access. In some cases, we may charge an administrative fee which reflects our costs of providing access. If you consider that the personal information we hold about you is incorrect, incomplete or out of date, you may request correction by sending a request to [email protected], by visiting Level 4, 15 Victoria Street, Hobart, Tasmania or by telephoning 1300 552 722. If we agree the information needs correcting, we will take reasonable steps to correct it. If instead we do not agree the information needs correcting, you can ask us to put a statement with your records explaining what you say needs to be corrected. THIRD PARTY WEBSITES We are not responsible for the practices employed by websites linked to or from our website or the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our website. Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. QUESTIONS AND COMPLAINTS If you have any questions, comments or complaints about our handling of your personal information, please direct them to the Managing Director, Workplace Health Assessors, Level 4, 15 Victoria Street Hobart, Tasmania 7000, Australia. All complaints will be acknowledged within five business days of receipt. The contact details of the person dealing with the complaint will be advised to the individual making the complaint at this time. We will consider and respond to a complaint within 15 business days. If you are not satisfied with WHA’s response, you can make a complaint about interferences with your privacy: in Australia to the Office of the Australian Information Commissioner. Their contact details are: Email: [email protected] Post: GPO Box 5218 Sydney NSW 2001 Phone: 1300 363 992 Fax: 02 9284 9666 Web: http://www.oaic.gov.au in New Zealand to the Privacy Commissioner. Their contact details are: Email: http://www.privacy.org.nz/your-rights/making-a-complaint/complaint-form/ Phone: 0800 803 909 Web: http://www.privacy.org.nz/introduction/ This policy was last updated on 7 November 2024. The latest version of this policy is published online at www.wha.net.au.