We are committed to ensuring that the privacy of your personal information is respected and maintained at all times. We are bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) and any relevant Health Privacy Principles under State Legislation

This Privacy Policy outlines how we manage your personal information and how we collect, hold, use and disclose that information. Some of the ways in which we collect, use and disclose personal information only apply to specific activities or businesses operated within our group. We have specifically identified where this is the case throughout the privacy policy.

These words when used in this privacy policy have the following specific meanings:

APPs means the Australian Privacy Principles in the Privacy Act.

CRB means a credit reporting body.

Credit information has the same meaning as in the section 6N of the Privacy Act, which for ease of reference could include information such as consumer credit liability information, repayment history information, types and amounts of credit you have sought, default information, and personal insolvency information. Please refer to the Privacy Act for a complete list of all types of credit information.

Credit eligibility information has the same meaning as in section 6 of the Privacy Act, which for ease of reference could include information such as credit reporting information about you that has been disclosed by a credit reporting body or information derived from such information and which has a bearing on your credit worthiness. Please refer to the Privacy Act for a complete list of all types of credit eligibility information.

Health information means information or an opinion about your health or any disability you may have now or previously, your expressed wishes about the future provision of health services to you, other personal information collected to provide or in providing a health service to you, or in connection with the donation of your organs or certain genetic information about you in a form that is or could be predictive of yours or a relative’s health.

Health service means any activity which is intended or claimed to involve assessing, recording, maintaining or improving your health, diagnosing or treating your illness or disability or dispensing prescription medicines by a pharmacist.

IHI number means your individual healthcare identifier number, being the 16 digit number allocated to you by the government and used by health service providers to obtain a secure online summary of your health information via electronic government health platforms such as the ‘My Health Record’ system.

Our group means each of us.

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, personal information includes sensitive information.

Privacy Act means the Privacy Act 1988 (Cth).

sensitive information means information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information other than health information, biometric information for automated verification or identification purposes and biometric templates.

We, our, or us means Global 24 Holdings PTY ltd, and each of their related bodies corporate.

You or your means customers, patients, service providers, job applicants and any other individuals who We come into contact with.

What types of personal information do we collect and hold?

We generally collect and hold:

● Your name, date of birth, postal and email address, telephone number, credit or debit card details, billing and account details, information obtained from any questionnaire which we may ask you to complete, and other information we consider necessary to provide our services to you.

● If we are providing you with a health service (such as allied or occupational health services or if you are visiting our GP clinics for a medical assessment or screening for your employer or potential employer or any other person who referred you to us), we may also collect and hold:

● Your Medicare number, IHI number, health fund number, veteran’s affairs number, occupational health history, medical records, medical prescriptions and other health information or sensitive information about you we consider necessary to provide our services to you or to your employer or potential employer.

If we are providing you or your employer with corporate or third party administration services we may also collect and hold:

● Your insurance (current and historical) details, income, travel itinerary, incident claim details and other details required in order to process claims or provide the services required.

● If you are applying for a job or contract with us, we may also collect and hold:

● Your previous employment history, tax file number, next of kin, skills or competency information, documentary proof of your right to work in Australia or elsewhere, driver’s licence, bank account, superannuation details and sensitive information such as your membership in any trade or professional association.

● If we are considering providing credit to you or an entity related to you, we may also collect and hold:

● Consumer and commercial credit information about you (including without limitation credit information and credit eligibility information).

How do we collect and hold your personal information?

We generally collect personal information about you:

● Directly from you.

For example, in forms and questionnaires you complete for us, and your interactions with us and our staff, such as via our websites, over the phone, via email or in person.

● From our service providers, staff, therapists, doctors and contractors.

For example, from our contracted health professionals, doctors, consultants, clinics, IT service providers and other personnel who assist us or who provide services to you on our behalf or your employer or potential employer.

● From other businesses in our group.

For example, our data processing centre may collect personal information from our GP clinics or medical assessment clinics.

● From other people involved in assisting us with providing services to you or to your employer or potential employer or any other person who referred you to us.

For example, from:- your doctor and other health professionals or government sources such as Medicare, the My Health Record system, Department of Veterans’ Affairs or the electronic transfer of prescriptions (eTP) services, if we are providing a health service to you.

● your relatives or other people in the case of an emergency where you are physically unable to give your consent.

● your employer or prospective employer or any other person who referred you to us, if we are undertaking a medical assessment or screening for your employer or prospective employer or such other person.

● your employer or their insurer, if we are providing corporate services (such as insurance claims management or emergency travel assistance services) to you or your employer.

● credit reporting bodies, if we are considering providing credit to you or an entity related to you.

We will not collect sensitive information (including health information) about you without first obtaining your consent. Unless one of the limited exemptions under the Privacy Act applies, we will only collect your sensitive information if you consent to such collection and if such sensitive information is reasonably necessary for one or more of our functions or activities.

We hold your personal information in various ways, including in paper and electronic form. We take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure including through implementation of encrypted, password protected, controlled-access digital storage solutions as well as keeping paper forms in secure, restricted access filing systems.

We require that our contracted service providers who assist us in supplying services to you, and to which we disclose your personal information, have in place reasonable safeguards for protecting personal information or are subject to the APPs or, if overseas, are subject to laws similar to the APPs.

For what purposes do we use personal information?

Unless you consent otherwise or where we are otherwise permitted to do so by law, personal information will only be used for the purposes for which it was provided (primary purpose) or for a purpose (secondary purpose) related, or in the case of sensitive information directly related, to the primary purpose. Some examples of the purposes we ordinarily use personal information for are detailed below.

Generally, we will use your personal information:

● To provide you with requested services (including contacting you to make appointments, issue reminders or arrange referrals)

● For our internal management purposes, to manage our relationship with you and to manage the payment and recovery of amounts payable to us by you

● To comply with any law (such as reporting requirements under the Medicare scheme, the pharmaceutical benefit scheme or the My Health Care scheme)

● To enable us to conduct our business generally, such as notifying our medical defence organisations or our insurers, quality assurance, practice accreditation and internal teaching and data processing and handling

● To tell you about our services or products that might better service your healthcare or lifestyle requirements or other opportunities in which you may be interested

● For other purposes which are reasonably necessary in connection with our normal functions and activities

If we are providing you with a health service (such as allied or occupational health services or when you visit our GP clinics), we may also use your personal information:

● To undertake a medical assessment, pre-employment medical, work fitness assessment, drug and alcohol screening, injury management and rehabilitation, medical expert report or executive health assessment

● To provide any other health services or wellness services as requested by you or your employer (or prospective employer)

If we are providing you or your employer with corporate or third party administration services (e.g. claims management), we may also use your personal information:

● To assist with making, assessing, administering or determining any insurance claim made by you or in respect of an incident in which you were involved in

● To provide travel and medical assistance services to you or to your employer

● If you are applying for a job or contract with us, we may also use your personal information:

● To assess and determine your eligibility or suitability for a job or contract with us

● To, with your permission, contact professional or other reference(s) you have provided in connection with a job application to discuss your experience/employment

● If we are considering providing credit to you or an entity related to you, we may also use your personal information:

● To obtain credit information related to you, and to undertake credit reference checks and otherwise assess your credit worthiness (or the credit worthiness of an entity related to you)

We may also use de-identified personal information for research purposes.

Who will we disclose your personal information to?

Generally, we may disclose your personal information:

● To any person you consent to receiving such information (e.g. when you give us your consent to disclose your medical assessment results to your employer or prospective employer or any other person who referred you to us by signing a privacy collection and consent form to that effect)

● To staff and other members of our group (e.g. for data processing, marketing and administrative purposes)

● To our service providers, advisors and contractors who assist us in operating our business (e.g. IT service providers) or who assist us in providing services to you (e.g. our contracted healthcare providers, and other medical staff we refer you to such as doctors, specialists or analysts)

● To any person we are required or authorised by law to disclose your personal information

If we are providing you with a health service, we may also disclose your personal information:

● To your treating doctor or regular general practitioner or specialist

● To your employer or prospective employer or any other person who referred you to us (if we collected the relevant personal information for the purpose of conducting an employment related assessment)

● To Medicare, Department of Veterans’ Affairs, electronic transfer of prescriptions (eTP) services, and other government authorities or databases relevant to the provision of a health service to you

If we are providing you or your employer with corporate or third party administration services (e.g. claims management), we may also disclose your personal information:

● To your employer, and any relevant insurers, underwriters, brokers or medical or legal advisors

● To Workcover and other insurers in relation to employee claims

If you are applying for a job or contract with us, we may also disclose your personal information:

● To any professional or personal reference(s) you provide in connection with your job or contract application

● To our insurers for our own professional insurance purposes

If we are considering providing credit to you or an entity related to you, we may also disclose your personal information:

to the following CRBs:

Veda Advantage Ltd – (www.veda.com.au);

Dun & Bradstreet (Australia) Pty Ltd – (www.dnb.com.au);

Experian – (www.experian.com.au).

We may disclose your personal information to overseas recipients. These recipients are generally located in the United Kingdom, Malaysia and Singapore and assist us with insurance, data processing and IT support services. There may be times where we disclose your personal informationto overseas recipients located in other countries on an ad-hoc basis (e.g. to a recipient located in an overseas country to assist us with providing a service to you in that country).

Dealing with us anonymously

You have the option of not identifying yourself or using a pseudonym when dealing with us unless we are required by law or a court or tribunal to deal with individuals who have identified themselves or it is impractical for us to deal with you if you have not identified yourself.

Direct marketing

From time to time we may use your personal information to provide you with marketing materials in relation to offers, specials, products and services that we have available. We will not collect, use or disclose your sensitive information for the purpose of direct marketing without your written consent. You may opt out of receiving marketing communications from us at any time by following opt out instructions provided in such marketing communications.

If requested by us, a CRB may use credit reporting information about you to assess whether you may be eligible to receive direct marketing communications from us (i.e. pre-screening). You have the right to request that CRBs do not use credit reporting information about you for this purpose.

Accuracy of your personal information

While we will endeavour to ensure that the personal information collected from you is up to date, accurate and complete, we will assume that any personal information provided by you is free from errors and omissions. You may request that we update or vary personal information that we hold about you using the contact details set out below.

Requesting access to your personal information

You may obtain access to personal information which we hold about you by contacting us using the contact details set out below. When you request access to your personal information held by us we will endeavour to provide you with access to such personal information as soon as reasonably practicable, provided however that there may be occasions when access to personal information we hold about you is denied. Such occasions would include where release of the information would have an unreasonable impact on the privacy of others.

We may require you to verify your identity and specify what information you require. We will give you reasons if we deny access.

We ask that requests for access to personal information be made in writing. Photo identification may be required and an access fee may be payable.

Making a complaint about a breach of your privacy rights

If you are of the view we have breached the APPs, the Privacy Act, or any related privacy code in dealing with your personal information, you may make a complaint by writing to us using the contact details set out below and we will endeavour to provide you with confirmation as to how we propose to deal with the complaint as soon as reasonably practicable.

If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner by visiting the following website and following the steps: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint.

Changes to our privacy policy

We reserve the right to change this policy at any time. The updated policy will be available on our website.

Contact us

If you wish to request access to your personal information or make a complaint about possible breaches of privacy, please direct your enquiries to:

Privacy Officer Global 24 Level 6 O’Connell Street, Sydney NSW Australia Email: enquires@global24.com.au Phone: +61 2 9312 5172

1 For example, those contained in the Health Records and Information Privacy Act 2002 (NSW) and the privacy provisions contained in the Health Records Act 2001 (VIC).

Global 24 Employment Applications – Privacy

Global24 is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cwth) and any relevant Health Privacy Principles under State legislation in the collection, use, storage, disclosure and destruction of any personal and sensitive information.

When you submit your employment application to Global 24 you can be assured that we are committed to ensuring the privacy of information being collected, which is to be solely used for the purposes of recruitment and selection to assess your suitability for employment with us and our subsidiary companies.

If you have sent an employment application to Global 24 that is in response to a job advertisement and your application is unsuccessful, your personal information will be kept:

indefinitely on the job ad website;

or for a period of three (3) months after which time it will be destroyed for applications sent by email to Global 24, or via our website career page.

Your name and contact details; Your resume or CV with a covering letter; Registrations and insurances (clinical applicants); Academic transcripts; Information collected and disclosed at the time of interviewing; Two reference checks from direct supervisors or managers from current or previous employers (as nominated by the applicant); and Information disclosed at the time of the pre-employment medical and testing, and the results of same; ID verification; Proof of eligibility to work in Australia.

Global 24 may disclose your personal information to, and collect information from, your nominated referees and relevant organisations such as educational institutions, professional bodies and former employers for the purposes of assessing your application and verifying your qualifications, professional registrations and employment history.

As part of our recruitment process, a pre-employment medical and drug and alcohol test is to be undertaken. Global 24, and third parties acting on behalf of Global 24 at our request (for example General Practices that undertake pre-employment medical assessments on our behalf), collect, hold, use and disclose personal information provided and advised by you to enable us to assess and evaluate your suitability for employment. Global 24 does not use or disclose an individual’s health information for any purpose other than the original purpose for which it was collected.

If your application is successful and you become an employee of Global 24 or our subsidiary companies, your personal information will be kept as part of your employee file.