FAIR HEALTH CARE ALLIANCE PRIVACY POLICY

We are committed to managing personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy. It applies to all of the services we offer at Fair Health Care Pty Ltd (ABN 86 622 966 303) (Fair Health Care, we, us, our) and the platforms through which you interact with us, including the Fair Health Care website at fairhealthcare.com.au (Website) and the Fair Health Care progressive web app at app.fairhealthcare.com.au (the App).

By accessing our Website, our App, or engaging with us, you agree to the handling of your personal information in accordance with this Privacy Policy.

Why do we collect your personal information?

The purposes for which Fair Health Care collects, holds, and uses your personal information depends on the nature of your interaction with us and the services we are providing to you, but may include the following purposes:

responding to your requests for information, general inquiries or provision of requested services;
to facilitate the Website and the App;
contacting you and maintaining records of your interactions with us;
providing health insurance assessment and referral services online or via telephone facilitated through the Website, App or other means. This includes providing your personal information to third-party health insurers of your choosing in order to complete any health insurance sign-up process;
administrative purposes associated with providing health insurance referral services, including training and reporting statistical information about our services;
researching, developing and expanding our service offering;
informing you of our activities, events and services;
responding to enquiries and complaints;
for the purpose of marketing and communication; and
to comply with any legislation or regulations as required.

We may also collect your personal information for other purposes from time to time; however, you will be informed of these purposes at the time of collection of your personal information.

What Personal Information does Fair Health Care collect about you?

When you enquire about our services or when you enquire via our Website or register for the App, a record is made which includes your personal information.

The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

your name;
your address, phone number and email address;
your date of birth and gender;
health insurance history; and
any additional personal information you provide or authorise us to collect as part of your interaction with us.

What sensitive information does Fair Health Care collect about you?

When you submit a request through our Website or register for the App, we may also collect health information from you that is considered to be sensitive information under the Privacy Act. This includes your health fund membership details and history, your income threshold, date or year of birth, and State of residence, as is reasonably necessary to provide the requested service.

How do we collect your personal information?

Where practicable, we will collect your personal information directly from you.

Personal Information collected from you directly

Fair Health Care collects only the personal information that is reasonably necessary to carry out our business, assess and manage your health insurance needs, provide health care insurance comparison services and facilitate the App.

We may collect your personal information from you directly when you:

register for, create an account on, or lodge an enquiry through our Website or App;
interact with the Website or App;
communicate with us via telephone, email or social media;
when administering any of our services;
subscribe to our electronic communications;
enter promotions or competitions;
submit an enquiry, a complaint, or provide customer feedback;
download software or the App for the purposes of accessing and using the service;
in administering and performing any contracts with service providers; and
while conducting customer satisfaction and market research surveys.

You can always decline to give Fair Health Care any personal information we request or to remain anonymous or use a pseudonym in your dealings with us. However, that may mean we cannot provide you with some or all of the services you have requested. Please let us know if you have any concerns about the personal information we have requested.

How do we collect your sensitive information?

We will only collect sensitive information about you with your consent or otherwise in accordance with the Privacy Act.

Do we collect your personal information from third parties?

Where reasonably practicable, we will collect your personal information directly from you. However, in some circumstances, we may be provided with or collect your personal information from third parties. Examples of collection of your personal information from third parties include the following circumstances:

where we engage with third parties to collect your personal information directly and voluntarily from you on our behalf. This would include, for example, where a dental practice provides us with your personal information in order to facilitate us contacting you to discuss your health insurance needs. When this information exchange is facilitated, we require the dental practice to confirm that you have consented to the provision of your personal information to us for the purpose of health insurance comparison services;
we engage an organisation to conduct market research on our behalf; or
another person provides information about you, for example, a family member enquiring about or arranging a policy of health insurance that includes you.
any other third party websites or services where you have provided your information for the purposes of receiving a private health insurance quote, and are in a commercial agreement with Fair Health Care to provide these services. In these circumstances, it is your responsibility to read and accept the Privacy Policy of the referring third party website or service. Fair Health Care is not responsible for the content or privacy practices of any such websites or services.

Online data collection and use

You may visit the Website without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy.

The Website and the App use cookies. A “cookie” is a small text file stored on your computer’s browser, which assists in managing customised settings of the Website and delivering content. We may use cookies from time to time to collect non-personal information such as your device type, browser type, IP address, and pages you have accessed on our Website and on third-party websites. You are not identifiable from such information. This information is used for website administration to provide you with a better and more customised service for statistical and maintenance purposes.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on the Website.

Third-Party Websites

The Website and the App may contain links to third-party websites. Fair Health Care is not responsible for the content or privacy practices of any such websites that are linked to our Website. We encourage you to read and familiarise yourself with the privacy policies of every website you visit. We will not collect personal information from other sources without obtaining your consent.

Fair Health Care uses Google Analytics to monitor the visitors to our Website and App. Based on your interactions with our Website and App, Google and third-party sites may elect to show you content and advertising that directs back to our Website.

Use and disclosure of your personal information

Access to your personal information will be restricted to those persons who require access in order to deliver services to you and who have been properly authorised.

Fair Health Care may be required to disclose your personal information to third parties where necessary to complete a request from you or carry out a service. Examples include:

to health insurance providers where required to facilitate the provision of health insurance, but only with your consent;
to third-party contractors and service providers we use for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs and market research;
to your nominated emergency contact;
to government and regulatory bodies, including Medicare;
to third-party health providers and insurance companies;
to our professional advisors, insurers and agents, and
where required by law.

We may also disclose your personal information to third parties for research purposes; however, this will always be in an aggregated and de-identified format.

Security and storage of your personal information

We take reasonable steps to ensure that your personal information is stored securely and is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. These precautions include:

(a) maintaining physical security over any paper-based and electronic data, such as through locks and security systems at our premises and secure databases (including trusted third-party storage providers located in Australia);
(b) computer and network security, for example, we use firewalls, password-protected secure system access and data encryption;
(c) securely destroying or de-identifying personal information if it is no longer required for the purpose for which it was collected (subject to any relevant record-(d) keeping obligations under Australian law requiring us to retain some information for a certain period of time);
(e) restricting access to your personal information to our employees; and
(f) requesting verification details from you when you wish to discuss any issues relating to the products and services we provide to you.

The Website is hosted in Australia. If you use the Website from outside Australia, you are voluntarily transferring content (potentially including personally identifiable information) to Australia and agreeing that Fair Health Care’s collection, use, storage and sharing of that content is exclusively subject to the laws of Australia rather than the laws of the country in which you are located.

If you choose to provide Fair Health Care with personal information, you are consenting to the collection, use and disclosure of that information and to the transfer of that information to our servers in Australia.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the Internet. Users of our websites are encouraged to exercise care in sending personal information via the Internet, and that transmission of personal information to us is at your own risk.

Does Fair Health Care disclose your personal information overseas?

Fair Health Care will not disclose your personal information to overseas recipients except in the circumstances described below.

Fair Health Care uses overseas contracted service providers for the deployment of the App, software maintenance and support services. These service providers are based in Singapore and may be provided access to your personal information to enable them to provide those contracted services. Additionally, some Fair Health Care website contact forms store data on servers based in Ireland EU. Fair Health Care will only disclose your personal information to overseas recipients, where we have taken reasonable steps to ensure that the overseas recipient does not breach the Privacy Act in relation to your personal information.

Does Fair Health Care use or disclose your personal information for direct marketing?

Fair Health Care may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt out at any time by contacting us using the contact details below.

If you opt out of receiving marketing material from us, Fair Health Care may still contact you in relation to its ongoing relationship with you.

Without your consent, we will not disclose your personal information to third parties for marketing purposes.

How can you access or seek correction of your personal information?

You are entitled to request access to the personal information that we hold about you and/or to make corrections to that information. To do so, please contact our Privacy Officer using the contact details set out below.

You will not be charged for making a request to access or update your personal information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. You can help us do this by letting us know if you notice errors or discrepancies in the information we hold about you and if your personal details change.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Privacy Act. An example could be if we disagree that your personal information requires correction. If we do refuse your request, we will provide you with a written notice stating our reasons for refusal.

How do you make a complaint about the handling of your personal information?

You may contact Fair Health Care at any time if you have any questions, concerns or complaints about this Privacy Policy or how your personal information is handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

Privacy Officer
Fair Health Care Pty Ltd
Suite 1, 600 Victoria Street, Richmond, VIC 3121
privacy@fairhealthcare.com.au

We take all complaints seriously. The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps that can be taken to resolve the complaint. We will generally respond to your complaint within 1 week of receipt.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and your desired outcome. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. We will let you know if the matter is more complex or if our investigation may take longer.

If you are unsatisfied with our handling of your complaint, you may contact the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992, by email enquiries@oaic.gov.au or by using the contact details on the OAIC website.

How are changes made to this Privacy Policy?

Fair Health Care may amend this Privacy Policy occasionally to reflect any updated service offering, data collection and disclosure practices, with or without notice to you. The most recent version of our Privacy Policy is available on our website. Please visit our website regularly to keep up to date with any changes to this Privacy Policy.

This Privacy Policy was last updated in November 2023.