The Holistic Health Institute Privacy Policy

Last updated: 16 Aug 2021

1. Policy Statement

The Holistic Health Institute Pty. Ltd. ABN 95 141 331 320 (Holistic Health Institute) is committed to protecting the privacy of the personal information and sensitive information which it collects and holds. We recognise that the information we collect is of a highly sensitive nature. We have adopted the highest privacy compliance standards to ensure personal information is protected.

The Holistic Health Institute complies with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other relevant privacy laws which govern the way in which organisations (such as Holistic Health Institute) hold, use and disclose personal information (including your sensitive information).

The purpose of this Privacy Policy is to explain:

a. the kinds of information that Holistic Health Institute may collect about you and how that information is held;

b. how the Holistic Health Institute collects and holds personal information;

c. the purposes for which Holistic Health Institute collects, holds, uses and discloses personal information;

d. how you can access the personal information Holistic Health Institute holds about you and seek to correct such information; and

e. the way in which you can complain about a breach of your privacy and how the Holistic Health Institute will handle that complaint.

2. Definitions

In this Privacy Policy the following terms have the following meanings:

Health information means a broad category of sensitive information about the health or a disability (at any time) of an individual or their expressed wishes about the future provision of health services to him or her or a health service provided, or to be provided, to them.

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

a. whether the information or opinion is true or not; and

b. whether the information or opinion is recorded in a material form or not;

Sensitive information means:

a. personal information or opinion about an individual’s:

i. racial or ethnic origins;

ii. political opinions or political associations;

iii. philosophical beliefs or religious beliefs or affiliations;

iv. sexual preferences or practices; or

v. criminal record; or

b. health information about an individual.

The Holistic Health Institute is committed to ensuring all of your personal information is afforded the highest level of protection and so for the purpose of this Privacy Policy and our privacy practices, no distinction has been made between the handling of personal information and sensitive information (including health information). Therefore, all information will be referred to as ‘personal information’ throughout this document and offered the same higher level of protection that ‘sensitive information’ and ‘health information’ is afforded under relevant privacy laws.

3. Collection and use of personal information

3.1. Types of personal information collected by Holistic Health Institute

The types of personal information that the Holistic Health Institute collects from you will depend on your relationship with us, the nature of the service we are providing or activity you are involved in and the legal obligations we may have and we will only collect information which is necessary to facilitate the provision to you of services by the Holistic Health Institute or to appropriately manage, conduct and oversee the Holistic Health Institute’s business. This may include (as applicable):

  a. Clients

The Holistic Health Institute collects information from you to facilitate the provision of services to you. This includes collecting personal information such as your name, address, your health history, family history, past and current treatments lifestyle factors, and any other information which is necessary to assist the us in providing appropriate care.

  b. Practitioners, contractors and employees

The Holistic Health Institute collects information from you which is necessary to properly conduct, manage and oversee the Holistic Health Institute’s business. This includes collecting personal information such as your name, address, professional experience, qualifications and past employers, and any other information which may be necessary to appropriately conduct, manage and oversee the Holistic Health Institute’s business.

If you do not provide to us any of your personal information that we require, we may be unable to provide you with the services you are seeking or to otherwise work or transact with you.

3.2. How we collect personal information

We will usually collect your personal information directly from you, however sometimes we may need to collect information about you from third parties, such as:

a. another health service provider; or

b. past employers and referees.

We will only collect information from third parties where:

c. you have consented to such collection;

d. such collection is necessary to enable us to facilitate the provision of appropriate care services by the Holistic Health Institute;

e. such collection is reasonably necessary to enable us to appropriately manage, conduct and oversee the Holistic Health Institute; or

f. it is legally permissible for us to do.

If we receive personal information about you from someone else that we have not requested and we determine that we would not have been permitted to collect that information under privacy law, we will ordinarily destroy or de-identify the information.

3.3. How the Holistic Health Institute uses your personal information

The Holistic Health Institute only uses your personal information for the purpose for which it was collected by The Holistic Health Institute (primary purpose), unless:

a. there is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or the Holistic Health Institute has informed you, that your information will be used for that secondary purpose;

b. you have given your consent for your personal information to be used for a secondary purpose; or

c. the Holistic Health Institute is required or authorised by law to use your personal information for a secondary purpose (including for quality improvements within the Holistic Health Institute).

For example, the Holistic Health Institute may use your personal information to:

d. appropriately manage, conduct and oversee the Holistic Health Institute’s business, such as assessing insurance requirements, and conducting audits;

e. assist the Holistic Health Institute to manage, conduct and oversee the Holistic Health Institute’s business, including quality assurance programs, implementing appropriate security measures, conducting research and training personnel;

f. where required, effectively communicate with third parties.

Ordinarily, the Holistic Health Institute will not transfer your personal information to any person or organisation outside Australia, without your permission. However, the Holistic Health Institute may enter into arrangements with service providers who may store some of the Holistic Health Institute’s data (which may include personal information) overseas. If we do, we will ensure we comply with any privacy law requirements that relate to cross border disclosures of personal information.

By becoming or remaining a client of the Holistic Health Institute or by providing your personal information to us, you consent (to the extent that we require your consent under privacy laws to do these things) to the Holistic Health Institute collecting, using and disclosing your personal information in accordance with this Privacy Policy.

3.4. Complete and accurate details

Where possible and practicable, you will have the option to deal with the Holistic Health Institute on an anonymous basis or by using a pseudonym. However, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the assistance or support you are seeking, or deal with you effectively.

4. Disclosing your personal information

4.1. Disclosures

The Holistic Health Institute will confine its disclosure of your personal information to the primary purpose for which that information has been collected, or for a related secondary purpose. This includes when disclosure is necessary to help us manage, conduct and oversee the Holistic Health Institute’s business, or for security reasons.

We may provide your personal information to:

a. government departments responsible for health, aged care and disability where the Holistic Health Institute is required to do so;

b. third parties contracted to provide services to the Holistic Health Institute, such as entities contracted to assist in accreditation or survey processes;

c. anyone authorised by you to receive your personal information (your consent may be express or implied);

d. fundraising institutions associated with the Holistic Health Institute (where you have consented);

e. anyone the Holistic Health Institute is required by law to disclose your personal information to.

4.2. Third party service providers

Where we engage third party service providers, we may disclose personal information to those service providers who may use, process and/or store that information overseas.

5. Direct marketing

The Holistic Health Institute also collects your personal information for marketing purposes, including e-newsletters, promotions and special offers. Our communications may be sent to you in various forms, including mail, SMS, in-app notifications, fax and email in accordance with applicable laws. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

If you have received marketing information from the Holistic Health Institute and you wish to stop receiving it, you can contact us (either using the contact details below or the opt-out mechanism detailed in our marketing material) and ask us to stop sending the marketing information within a reasonable time after your request has been made. You will not be disadvantaged if you choose to opt out of receiving marketing material.

The Holistic Health Institute may occasionally provide its marketing material to third parties to distribute material on the Holistic Health Institute’s behalf.

6. Data storage, quality and security

6.1. Data quality

The Holistic Health Institute will take reasonable steps to ensure that your personal information which is collected, used or disclosed is accurate, complete and up to date.

6.2. Storage

All your personal information held by the Holistic Health Institute is stored securely in either hard copy or electronic form.

6.3. Data security

The Holistic Health Institute strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure

6.4. Online transfer of information

While the Holistic Health Institute takes all reasonable steps to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with the Holistic Health Institute via an online process, it is at your own risk.
There are ways you can help maintain the privacy of your personal information, including:

a. always closing your browser when you have finished your user session;

b. always ensuring others cannot access your personal information and emails if you use a public computer; and

c. never disclosing your user name and password to third parties.

7. Your use of our website

We will only collect personal information through our website if you voluntarily provide it – for example, if you submit information via a web page form or you send us an email. Any personal information you provide to us through our website will be handled in accordance with the principles described in the preceding sections of this Privacy Policy.

When you access our website, we will keep a record of your visit. We may collect the following information that does not identify you in relation to your use of our website: your computer address, the date and time of your visit, the type of browser you use, the pages you visit, the information you request and the country from which you request information. We collect this information for statistical purposes and to monitor and improve our website and services.

8. Use of cookies

A ‘cookie’ is a small data file placed on your machine or device which lets the Holistic Health Institute identify and interact more effectively with your computer.

Cookies are industry standard and are used by most websites, including those operated by the Holistic Health Institute. Cookies can facilitate a user’s ongoing access to and use of a website.

Cookies allow the Holistic Health Institute to customise our website to the needs of our users. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. However, cookies may be necessary to provide you with some features of our on-line services via the Holistic Health Institute’s website.

9. Links to other sites

The Holistic Health Institute may provide links to third party websites. These linked sites may not be under our control and the Holistic Health Institute is not responsible for the content or privacy practices employed by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.

10. Accessing and amending your personal information

You have a right to access your personal information which the Holistic Health Institute holds about you. If you make a request to access your personal information, we will ask you to verify your identity and specify the information you require.

You can also request an amendment to any of your personal information if you consider that it contains inaccurate information.

You can contact the Holistic Health Institute about any privacy issues as follows:

Attention: Privacy Officer

Holistic Health Institute

PO Box 530, Waverley NSW 2024

While the Holistic Health Institute aims to meet all requests for access to personal information, in a small number of cases and where necessary and permitted to do so by law, the Holistic Health Institute may not give access or may do so only under conditions.

Subject to applicable laws, the Holistic Health Institute may destroy records containing personal information when the record is no longer required by the Holistic Health Institute.

11. Complaints

If you have a complaint about the Holistic Health Institute ‘s information handling practices or consider we have breached your privacy, you can lodge a complaint with:

a. the Holistic Health Institute using the contact details listed in clause 10 above; or

b. the Office of the Australian Information Commissioner. The Holistic Health Institute deals with all complaints in a fair and efficient manner.

Approved by: Charles Boyle (Managing Director)

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Sat – Sun: Closed

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