It also provides information on how you can obtain access to or seek correction of your personal information that we hold.
2. Kinds of personal information collected
The type of personal information we collect and hold may include your full name, email address, postal address, phone number, age, gender, interests and other information relevant to the supply of our services that is collected by the Platform, or that you choose to provide to us. We also collect details about your personal status (e.g. marital/family details) and your relationship to your child/ren. This data allows us to customise the Platform and our services and provide resources based on your personal circumstances.
Some of your personal information may also be considered “sensitive information” under Privacy Laws, such as your “health information”. The type of health information we may collect includes the due date or date of birth of your child, information or opinions about your physical, mental or psychological health, medical history and current medications, and other personal information collected to provide you with health services.
3. Collection of your personal information
In most cases, we collect personal information directly from you and/or your employer (if you have given your consent for your employer to provide it). This may take place when you and/or your employer provides us with your personal information via email, in person, over the telephone or by completing documents, such as an administrative form or an online survey form. It may also take place as part of us providing services to you.
To the extent that any additional obligations arising under the Privacy Laws apply to our collection of your “sensitive information”, we will comply with those obligations and only collect this information from you directly, unless it is not reasonable or practical to do so. In operating the Platform we may additionally collect information that does not personally identify you but monitors your use of the Platform.
4. Reason for collecting your personal information
We collect personal information (including health information) that is reasonably necessary for us to provide the Platform and the services you have requested.
In particular, we collect your personal information (including health information) to:
- provide services and support to you, including timely and relevant information about emotional and mental wellbeing throughout pregnancy and the first twelve months following the birth of a baby;
- enhance your use of the Platform;
- send you general correspondence relating to your Platform account;
- ensure high quality services are provided;
- obtain de-identifiable data for research purposes and to provide reports on the uptake and use of our program(s) to your employer; and
- obtain de-identifiable data for the purpose of further improving the Transition Coaching Program,
Some information requested from you may be identified as mandatory. You do not have to provide us with your personal information or health information. However, if you do not provide the mandatory information, you may be unable to continue using the Platform and/or we may not be able to effectively carry out the Purpose.
5. Storage and security of your personal information
We may hold your personal information (including health information) in any combination of data storage facilities, cloud computing facilities or paper-based files, which may be operated or held by us or by third party service providers under a contractual arrangement. These service providers may provide hosting and/or support services in Australia or overseas. We take care where possible to work with service providers who we consider maintain acceptable standards of data security compliance. By providing us with your personal information, you consent to your personal information being used and stored (including overseas) for such purposes.
We will use reasonable endeavours to maintain the security of your personal information from unauthorised access, modification or disclosure, and misuse and loss. We cannot ensure or warrant that your personal information will always be secure during transmission or protected from unauthorised access during storage. Therefore, you provide your personal information to us at your own risk. Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information in connection with the Platform or our provision of services to you.
Please note that under the law and standards of psychology, your online material pertaining to any assessment results and health information (including the birthdate of your child) is stored securely through a Virtual Private Network (VPN). At any stage, you may request to see the personal information that we hold relating to you. All requests for access to information should be lodged with Transitioning Well, by emailing firstname.lastname@example.org or phoning 1300 824 808.
6. Use and disclosure of your personal information
By providing your personal information (including health information) to us, you consent to us using such information:
- for the Purpose (as described in section 4 above);
- for any purpose directly relating to the Purpose (as described in section 4 above) that you would reasonably expect us to use it for;
- any purpose to which you otherwise consent (including in a collection statement at the point where we collect such personal information); and
- any other purpose required or authorised at law (including the Privacy Laws).
Without limiting the above, you specifically consent to us using and/or disclosing (as applicable) your personal information including health information to:
- contact you to provide feedback about the Platform, including through an anonymous email survey;
- contact you for advertising, promotional, and direct marketing purposes to inform you about our products and services;
- perform administrative functions and activities in relation to our services and the Platform;
- improve our services or Platform and/or develop new products or services, which may involve performing analytics on information that we collect automatically;
- respond to enquiries you make regarding the services or Platform;
- provide you with online training where applicable;
- comply with any applicable laws;
- third parties we engage to perform functions or provide products and services on our behalf; and
- collect and moderate comments and feedback provided by you to the Platform.
If you decide that you do not wish to receive information from us, please contact us with your request to be removed from our mailing list. We will remove your details from our mailing list within a reasonable period of receipt of notice.
Where practicable, we will endeavour to collect, hold, use and disclose personal information for the purposes described above on a de-identified basis.
Where practicable, we will allow you to remain anonymous or use a pseudonym (unless this is against the law, including Privacy Laws).
8. Access, amendment and deletion of your personal information
You must endeavour to ensure that the personal information (including health information) that you provide to us is accurate, complete, up-to-date, relevant and not misleading.
You may ask us to access your personal information in accordance with Privacy Laws, including by asking us to provide you with a complete list of your personal information that we hold, which we will do within a reasonable period of receipt of your request (unless limited by Privacy Laws). Where we are unable to provide you with access to your personal information, you may contact us to amend any of your personal information that is inaccurate, incomplete or out-of-date or request that your personal information be deleted.
We will amend or delete your records as requested within a reasonable period of receipt of notice. If applicable, any legal requirement on us to maintain certain records of your personal information will prevail over any of your requests. We may require identification to be provided before releasing copies of personal information including health information. Where we are unable to provide you with access to your health information, or are unable to correct your health information, we will provide you with reasons in writing within a reasonable period of time.
We may charge you a reasonable fee where you request that we explain the contents of your health information.
If you use a link on the Platform to access a third party website, you do so entirely at your own risk. You should always read the applicable privacy policies on the other websites.
11. Data breach notifications
Under the Privacy Laws, we are required to notify you and the Office of the Australian Information Commissioner if we suspect that a data breach (relating to your personal and/or health information) has occurred and there is real risk of serious harm to you as a result of the breach.
12. Applicable law
The Platform is controlled from our offices in Australia.
13. Contact us
Suite 1b/307 Wattletree Rd
Malvern East 3145
Tel: 1300 824808
14. Making a complaint
If you have any concerns about how we manage your personal information and health information, you may write to our Privacy Officer at Transitioning Well Suite 1b/307 Wattletree Rd Malvern East 3145. We will reasonably endeavour to provide a response within 30 days of receipt of your complaint.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by writing to the OAIC at GPO Box 5218, Sydney, NSW 2001. For further information about the OAIC, please visit www.oaic.gov.au.
If you are not satisfied with our response to your request for access to your health information, you may lodge a complaint with the Health Complaints Commissioner (HCC) by calling the HCC on 1300 582 113 or by making a complaint online via the HCC website. For further information about the HCC, please visit https://hcc.vic.gov.au/.
Last Updated: 9th October 2020