Privacy policy.
Project Reform Pty Ltd ACN 663 608 482 (referred to as “Project Reform”, “we” or “us”) are committed to protecting and managing personal and health information in accordance with the Australian Privacy Principles (known as the APPs) established under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
The APPs provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. The APPs consist of 13 principle-based laws and apply equally to paper-based and digital environments.
This document is referred to as our Privacy Policy. It sets out our policies for managing your personal and / or sensitive information including how we collect, use, hold, store and disclose the information.
In this Privacy Policy, “you”, “your” or “client” refers to any individual about whom we collect personal or sensitive information.
Broadly speaking, when we are referring to personal information, we are referring to information or an opinion about you, or information that is reasonably recognisable as you. It includes information or an opinion that may or may not be accurate and recorded in a hardcopy or electronic form.
When we refer to sensitive information, we are referring to certain personal information that is more sensitive and may include health information or details of memberships of professional associations. Under the APPs,
sensitive information is afforded a higher level of privacy protection and we will use our best endeavours to obtain your consent before collecting this type of information.
This Privacy Policy applies to your personal and sensitive information regardless of how we collect it from you. When you submit information to us, access or use our websites or social media platforms, you are providing your consent to us collecting and managing your personal and sensitive information according to this Privacy Policy.
What information do we collect about you?
When you enquire about our services or become a member of Project Reform, a record is made that includes your personal information.
When you enquire about our membership options or become a member of Project Reform, a record is made that includes your personal and sensitive information.
The types of information that we collect include:
Contact Information: your name, date of birth, sex, contact information and preferences (address, email address, telephone details).
Health Information: your clinical and health-related information.
Lifestyle Information: your health information relating to your lifestyle and medical history relevant to providing healthcare services.
Government Related Identifiers: your Medicare number, Department of Veterans’ Affairs file number, individual healthcare or private health insurance number or patient identifier.
Billing Information: your payment and bank details to process billing and any applicable claims for health rebates.
Identification Documents: your driver's licence, passport or other photographic identification documents for verification purposes.
Photographs & Videos: pictures, videos, sound recordings and other audio-visual recordings that you provide to us or authorise us to take of you.
Social Media Accounts & Handles: your social media accounts, handles, and other personal websites and profiles.
Location-based information: your location information.
Cookies & Other Browser or Device Information: your session cookies and persistent cookies when you visit our website or equipment, and other information regarding your device, browser, Internet Protocol (IP) address and URL information. Cookies that we place may be removed by following instructions that are provided by your browser.
Interaction & Behavioural Information: your interactions, use, habits, behaviours when dealing with us, our website and other applications.
Employee & Recruiting Information: your qualifications and work history, tax file number, bank details, superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions that involve working with children).
Other information: any other administrative and additional information that you provide to us directly or provided by the business that employs or engages in facilitating the provision of health services or as a part of your interaction with us.
Project Reform may collect personal information about other individuals who are not clients of Project Reform. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to Project Reform, and other individuals who interact with us on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Project Reform.
Generally, it would include your name, contact details, and information regarding our interactions and transactions with you. If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
You can always decline to give Project Reform any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about the personal information we have requested, please let us know.
How and why do we collect and use your personal information?
Project Reform collects personal information reasonably necessary to carry out our business, assess and manage our clients’ needs, and provide our products and services. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing client relationships.
Project Reform generally collects personal information directly from you. We may collect your personal information over the phone, by email, through our website or mobile sites, over the internet or when you visit one of our social media sits (such as Facebook, Twitter or Instagram) or when you visit our office in person.
We may also collect personal information about you from other sources, for example: an authorised person acting on your behalf; our affiliated and related entities; third-party agents, suppliers and contractors who assist us in operating our business; recruitment service providers and any referees provided on employment applications; payment and debit service providers processing and managing the transaction on our behalf; and your family and friends through any marketing or promotional activity that we conduct.
We may receive information about you that we have taken no active step to collect. If this does occur, we recommend contacting us and asking for the personal information to be de-identified or destroyed.
The purposes for which Project Reform usually collects and uses personal information depends on the nature of your interaction with us, but may include: communicating with you confirming your identity; responding to requests for information, complaints and enquiries; administrative, management and operational purposes; informing you about our business offerings, news, updates, direct marketing material, activities, facilities, services and events; managing, planning, advertising and administering programs, events, competitions and performances; researching, developing and expanding our facilities, products and services; recruitment processes (including for volunteers, internships and work experience); taking photographs, videos or other audio-visual recordings of you for testimonial, marketing or other promotional purposes; market research purposes and to improve our business offerings; through surveillance and security cameras that capture your image; processing your purchases, orders, transactions or sales, including the processing of payments, arranging shipping and providing you with tax invoices or order confirmations; for any other purposes (including secondary purposes) that you would reasonably expect; and to enable us to comply with our obligations under the law.
You can always decline to give us your personal information, but that may mean that we cannot provide you with some or all of the products and services you have requested.
Who do we disclose your personal information to?
During the conduct of our business, we may use and disclose your personal information to the following parties: our affiliated and related entities; our engaged contractors, agents, suppliers who assist us in operating our business; commercial partners under an agreed information sharing arrangement; payment and debit service providers and processors; our marketing research service providers and digital marketing agents; our professional advisors, such as our lawyers, accountants and financial advisors; relevant courts, tribunals or regulatory authorities and law enforcement bodies; anyone else to whom you authorise us to disclose your information or that would be reasonably expected; and other companies or individuals as necessary to enable us to provide you with our products and services.
Project Reform takes reasonable steps to ensure that the third parties we engage take reasonable steps to protect your personal information following the APPs and in a similar manner with this Privacy Policy. Our third-party service providers are required only to use the personal information disclosed to them by us for the purpose that it was provided to them. Additionally, the third parties to who we have disclosed your personal information may contact you directly to let you know they have collected your personal information and give you information about their privacy policies.
Project Reform may also use Google Analytics to help us understand how our customers and clients use our platforms, products and services. You can read more about how Google uses your personal information via https://www.google.com/intl/en/policies/privacy/. You may also opt-out of Google
Analytics here: https://tools.google.com/dlpage/gaoptout . Do we disclose personal information to overseas recipients? Your personal information may be transferred to recipients located in countries that have data protection laws which protect personal information in a way which is at least substantially similar to the APPs. Accordingly, there may be mechanisms available to you to enforce the protection of your personal information under that overseas law. In the circumstances, we do not require the overseas recipients to comply with the APPs, and we will not be liable for a breach of the APPs if your personal information is mishandled. We also disclaim responsibility to the extent permitted by law and note that you may not have a remedy under Australian law.
Do we use or disclose your personal information for direct marketing?
Project Reform may use or disclose your personal information to inform 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, we may still contact you concerning any ongoing relationship with you.
How do we hold, store and secure your personal information?
Project Reform takes reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. For example, we may maintain computer and network security, use firewalls and other security methods and other security systems such as user identifiers and passwords to control access to our computer systems.
Please be aware that there is no transmission method over the internet or through electronic storage that is fully secure and safe. We cannot guarantee the security of your personal information that we hold, but we do take reasonable steps to protect your information. If we are required by law to inform you of any misuse, interference, loss or unauthorised of your personal information, then we will notify you electronically, in writing or by telephone.
Our websites, applications or email systems may not use encryption or other technologies to ensure the secure transmission and receipt of information via the internet. Anyone using our website or receiving an email from us is encouraged to exercise care in sending personal information or depositing money via the internet. We recommend that you refrain from clicking any unsecured links or opening unknown attachments.
If you hold any concerns or become suspicious of any misuse, interference, loss or unauthorised access to our website, our email systems or to our business more generally, we ask that you contact us immediately to verify your concern or suspicion.
Project Reform hold and store your personal information in paper-based files, other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas), which may include cloud-based storage providers.
Paper-based Storage
Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
Electronic Storage
Your personal information is usually collected in electronic form.
Third-Party Storage
Your personal information may be collected in electronic form for use or storage with a third-party storage provider that we engage.
We cannot ensure that your personal information is or will remain secure. This is due to us not having control over the third-party provider’s policies and procedures concerning the handling and storing your personal information.
What are the choices that you can make about your personal information?
At any time, you can request us to: delete or destroy your personal information; de-identify your personal information; access or correct your personal information; provide you with a copy of your personal information.
Please understand that we may not be able to entertain your request if it is unlawful to do so or is otherwise impractical or unreasonable to do so in our discretion.
Delete or destroy your personal information
Until you request for it to be deleted or destroyed, your personal information is kept by us for as long as necessary to provide our products and services to you and for legitimate and essential business purposes, such as complying with our legal obligations or settling disputes. This means that your personal information can be held for some time.
Remaining Anonymous & De-Identification
Project Reform may require you to provide specific details and information to enable us to provide our products and services to you. We try to allow you to stay anonymous or use a pseudonym in your dealings with us where it is lawful and practicable to do so. For example, when making a general and nonspecific enquiry. Typically, it is not possible for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect your personal information, you may not be able to utilise our products and services, deal with us or participate in our events, programs or activities we manage or deliver.
Accessing or correcting your personal information
You are entitled to access or request a copy of your personal information held by us by sending us a request.
You will not be charged for requesting to access or copy your personal information, but you may be charged for the reasonable time and expense incurred in compiling the information.
You are responsible for ensuring that your personal information with us is accurate and up to date. We take steps to ensure that the personal information we collect, use or disclose is accurate and up to date. You can help us do this by letting us know if you notice errors, inaccuracies or discrepancies in the information we hold about you and letting us know if your details change.
We may decline your request to access or correct your personal information in accordance with the APPs. If we refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
Does the European Union General Data Protection Regulation apply to us?
The European Union (EU) General Data Protection Regulation (GDPR) contains new data protection requirements and is effective as of 25 May 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive EU-wide law that governs the use, sharing, transferring and processing of any personal data that originates from the EU. The GDPR applies to the data processing activities of businesses, regardless of size, that are data processors or controllers with an establishment in the EU.
Consequently, Australian businesses of any shape and size may need to comply if they have an establishment in the EU, if they offer goods and services in the EU, or if they monitor the behaviour of individuals in the EU. There are also some notable differences, including certain rights of individuals (such as the ‘right to be forgotten’) which do not have an equivalent right under the APPs and the Privacy Act.
In some circumstances, the GDPR provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your personal information is handled in a manner inconsistent with that law.
However, the fact that you may be located in Europe does not on its own entitle you to protection under the GDPR. Our website does not explicitly target customers located in the EU, and we do not monitor the behaviour of individuals in the EU. Accordingly, Project Reform does not currently believe that the GDPR applies.
What should you do if you have a complaint about the handling of your personal information?
You may contact us at any time if you have any questions or concerns about this Privacy Policy or about how your personal information has been handled. You may make a complaint to our privacy officer using the contact details set out below.
Complaint handling process
Our 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 contact you within thirty (30) days of the date we receive the written details of your complaint to acknowledge that we have received it. We may ask you to provide further information about your complaint and the outcome you are seeking.
Our privacy officer will review the way we dealt with your personal information, conduct an internal investigation (if necessary) into the complaint and will likely respond to you within thirty (30) days of the date we acknowledged receipt of your complaint. 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 sixty (60) days of receipt of the complaint. If the matter is more complex or our investigation takes longer than anticipated, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that Project Reform may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au .
Our contact information
We welcome any comments or questions about our Privacy Policy. All enquiries should be directed to Project
Reform’s Privacy Officer at the following contact details:
Email: info@projectreform.com.au
This Privacy Policy was last updated on 2/10/2023 .