The First Step Program Limited (we, our, us) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information.
We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and the Victorian Health Records Act 2001 and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.
You can read our 'Privacy and Client Confidentiality Policy' here.
What is your personal information?
When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
What personal information do we collect and hold?
We may collect the following types of personal information:
• name
• mailing or street address
• email address
• telephone number
• facsimile number
• age or birth date
• profession, occupation or job title
• details of the services you have used with us or which you have enquired about, together with any additional information necessary to deliver those services and to respond to your enquiries
• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and
• information you provide to us through our clinic, surveys, or visits by our representatives from time to time.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
We are required to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
Management of your Personal Health Information
How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
• through your access and use of our website
• during conversations between you and our representatives; or
• when you complete a form, survey or subscribe to our website.
Cookies
In some cases, we may also collect your personal information through the use of cookies. When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of services you view so that, if you consent, we can send you news about those services.
We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online presence and services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users’ movements, and gather broad demographic information.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
• we may not be able to provide the requested services to you, either to the same standard or at all
• we may not be able to provide you with information about services that you may want, including information about discounts, sales or special promotions; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of service.
We collect, hold, use and disclose your personal information for the following purposes:
• to provide services to you and to send communications requested by you
• to answer enquiries and provide information or advice about existing and new services
• to provide you with access to protected areas of our website
• to assess the performance of the website and to improve the operation of the website
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of The First Step Program Limited, its related bodies corporate, contractors or service providers
• to provide your updated personal information to our contractors or service providers
• to update our records and keep your contact details up to date
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.
To whom may we disclose your information?
We may disclose your personal information to:
• our employees, , contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, and professional advisors such as accountants, solicitors, business advisors and consultants
• suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
• any organisation for any authorised purpose with your express consent.
Direct marketing materials
We may send you direct marketing communications and information about our services that we consider may be of interest to you and fundraising activities. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
We do not provide your personal information to other organisations for the purposes of direct marketing.
How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Operations Manager using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Operations Manager deals with privacy complaints and any complaints should be directed to our Operations Manager using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
Do we disclose your personal information to anyone outside Australia?
We do not disclose personal information to any bodies corporate and third party suppliers and service providers located overseas.
Security
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Operations Manager using the details set out below.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Please contact our Operations Manager at:
Gayle Wood
Operations Manager
The First Step Program Limited
42 Carlisle Street, St Kilda 3183
P: 9537 3177
E: [email protected]
