NARAYANI privacy policy  

Current as of: 17 June 2019  

Introduction  

This privacy policy is to provide information to you, our member, on how your personal information (which includes your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.  

Why and when your consent is necessary  

When you register as a member of our practice, you provide consent for Narayani’s staff to access and use your personal information so they can provide you with the best possible treatment. Only staff who need to see your personal information will have access to it. If we need to use your information for anything else, we will seek additional consent from you to do this. The Narayani Disclosure Statement and Membership Agreement includes a section to provide your informed consent.  

Why do we collect, use, hold and share your personal information?  

Our program will need to collect your personal information to provide treatment services to you. Our main purpose for collecting, using, holding and sharing your personal information is to effectively manage your treatment through instruction and strategies. We also use it for directly related business activities, such as financial claims and payments, program audits, accreditation, and business processes (eg staff training).  

What personal information do we collect?  

The information we will collect about you includes your:  

  • names, date of birth, addresses, contact details  
  • medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors  
  • Medicare number (where available) and if necessary, for identification and claiming purposes  
  • Health fund details.  
  •  

Dealing with us anonymously  

You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.  

How do we collect your personal information?  

Our program may collect your personal information in several different ways.  

1. When you commence the program, our staff will collect some of your personal and demographic information via your registration, and you will then be required to provide further information as outlined on our intake form for your consultation with our Naturopath.  

2. During the course of providing our treatment, we may collect further personal information such as previous hospital discharge summaries and pathology testing.  

3. We may also collect your personal information as part of being a member of the program, for example, when you visit our website, send us an email or SMS, telephone us, make any appointments online, or communicate with us using social media.  

4. In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:  

 

  • your guardian or responsible person  
  • other healthcare providers that are involved in your treatment, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services  
  • your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).  

When, why and with whom do we share your personal information?  

We sometimes share your personal information:  

  • with third parties who work with our program for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with Australian Privacy Principles and this policy  
  • with healthcare providers  
  • when it is required or authorised by law (eg court subpoenas)  
  • when it is necessary to lessen or prevent a serious threat to a member’s life, health or safety or public health or safety, or it is impractical to obtain the member’s consent  
  • to assist in locating a missing person  
  • to establish, exercise or defend an equitable claim  
  • for the purpose of confidential dispute resolution process  
  • when there is a statutory requirement to share certain personal information (eg some diseases require mandatory notification)  
  • during the course of providing medical services, through eTP, My Health Record (eg via Shared Health Summary, Event Summary).  

Only people who need to access your information will be able to do so. Other than in the course of providing services under the program or as otherwise described in this policy, our program will not share personal information with any third party without your consent.  

We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.  

Our program will not use your personal information for marketing any of our goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing.

How do we store and protect your personal information?  

Your personal information may be stored in systems we use as part of managing the program.  

Our program stores all personal information securely in electronic format, in protected information systems and in hard copy format in a secured environment. We secure our premises and use passwords to access any member information, and secure cabinets for hard copy information, for information such as copies of your registration information, evidence of informed consent, disclosure statements, and all member files.  

How can you access and correct your personal information that we hold as part of the program?  

You have the right to request access to, and correction of, your personal information.  

Our program acknowledges members may request access to their records that we hold. We require you to put this request in writing which need to be sent to us via email hello@narayaniwellness.com.au and our practice will respond within a reasonable time, usually 14-30 days. There may be a reasonable fee associated with complying with your request.  

Our program will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, we will ask you to verify that your personal information held by us is correct and current. You may also request that we correct or update your information, and you should make such requests in writing to hello@narayaniwellness.com.au.  

How can you lodge a privacy-related complaint, and how will the complaint be handled by us?  

We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure.  

You can contact us at:  

hello@narayaniwellness.com.au  

Narayani Wellness  

357 Nicholson St  

Carlton North VIC 3057  

03) 90363318  

Our turnaround time for complaints you may have is 14-30 days. However, we take complaints very seriously and will endeavour to address your concerns as soon as is reasonably possible.  

If you are dissatisfied with our handling of a complaint or the outcome you may make an application to the Australian Information Commissioner or the Privacy Commissioner in your State or Territory.  

Privacy and our website  

Your personal information may also be collected through the following services that are used on our website:  

  • User contact forms  
  • Cookies & Analytics Mailing list (via an Opt-In initially, with the ability to unsubscribe or Opt-Out)  
  • Social Network widgets and buttons (Pinterest, Twitter etc)  
  • Direct Marketing  
  • Credit card payments including PayPal  
  • When you sign up with us and create a login with us  
  • Cross-border Disclosure of Personal Information Sign in with Facebook  
  • Third party polling and survey plugins (Survey Monkey etc)  
  • 3rd party commenting (Disqus, Livefyre, IntenseDebate, Google+ etc)  

We only collect personal information on our website for purposes which are directly related to our functions or activities under the Privacy Act, the Freedom of Information Act 1982 (FOI Act), and only when it is necessary for or directly related to such purposes.  

Policy review statement  

This privacy policy will be reviewed regularly to ensure it is in accordance with any changes that may occur. The most up to date version will be available on the Narayani website., at our premises, and upon request.