Privacy Policy
At Queensland Fertility Group (also we, us and our), our primary concern is providing you with treatment and healthcare of the highest quality. This requires a relationship of trust and confidentiality – one where we treat your personal health information appropriately and respect your privacy.
This Privacy Policy explains how we protect and handle personal information. We are held to strict privacy and confidentiality requirements under a range of laws and standards, which can include the Privacy Act 1988 (Cth) (Australian Privacy Act) and specific regulation relating to assisted reproductive technology.
Our fertility specialists, nurses, scientists, counsellors and administration staff work together to provide your fertility treatment. They may need access to your personal health information to make sure we provide the most appropriate care.
You are entitled to know what personal information is held about you, how you can access it, why it is held, to whom we may disclose it, and when we need your consent to do this. This policy explains all these details. You can discuss any issue relating to the privacy of your information with your doctor or any staff member, at any time.
Collecting information
Our fertility specialists and staff collect personal information that helps us provide the level of advice, care and management you need, carry out our functions and activities and comply with statutory requirements for collection.
This information may include or relate to:
- name and contact details;
- identity, including healthcare identifiers, gender and date of birth;
- relationship status;
- offspring;
- symptoms, diagnosis, medical results and recommended treatment;
- preferences and opinions, including healthcare preferences and advanced care directives;
- communications, activity and interactions with and relating to us;
- queries, comments, feedback, claims, complaints, disputes and investigations;
- referrals to and from us (e.g. referrals from other health providers);
- Medicare, private health funds, Workcover and other insurance arrangements; and
- payment, billing and accounts.
In many cases we will collect this information directly from you, but we may also get it from other sources – for example, from other medical practitioners, health funds, health providers, your family members and representatives, public sources, government agencies (e.g. for Medicare), and the parties listed below under ‘Disclosures and transfers of personal information’. When processing, analysing and combining information we hold, we sometimes generate new personal information, including inferences, interpretations and opinions. This can arise through both manual and automated processes, including from use of software, AI and peer review.
We may use an AI transcription tool to help us keep records of our consultations and conversations with you. These tools record the audio of your voice and create a clinical note for inclusion in your health record.
Where we are unable to collect personal information, this can affect our ability to provide healthcare and perform the other activities described in the next section.
Purposes for handling your information
We may collect, hold, use and disclose personal information for the following purposes, to the extent permitted by law:
- providing health services;
- sharing your information within the treatment team;
- follow-up telephone and video-conferencing calls, appointment reminders and recall notices via physical mail, email, electronic messaging or secure online platforms in connection with your treatment and healthcare;
- obtaining required treatment consents, e.g. via physical consents, email and secure online platforms;
- making and receiving patient referrals;
- analysing specimens and samples;
- accounts and billing purposes, including Medicare, private health insurance claims and debt collection;
- complaints, investigations, incident handling and insurance purposes;
- managing our practice, including service improvement, risk management, quality assurance, licensing and accreditation, market analysis, auditing, administration, patient surveys, identity and information verification, and keeping our records up to date;
- legal and regulatory purposes, including protecting and defending our legal rights and other purposes as required by law, a court of law or any legislative, statutory or regulatory body (such as public interest, notifiable diseases and donor information);
- training and teaching purposes involving medical students and/or staff;
- telehealth consultations and other secure on-line or remote communications relating to the provision of healthcare and treatment;
- newsletters and marketing communications including patient surveys via email or on-line platforms, electronic messaging, and software applications for the purpose of sharing generic health-related information;
- our licensing and accreditation, which sometimes involves providing a sample of identifying information for confidential review by regulatory bodies, such as the national Reproductive Technology Accreditation Committee (RTAC);
- protecting the safety and security of our patients, staff, clinics, systems and assets;
- facilitating corporate and business sale transactions, such as where we buy or sell a business, or consider doing so, and related activities such as transitioning business activities;
- de-identification to remove information that personally identifies you, after which point we may store, use and disclose the information for broader purposes including research, data analysis and government reporting;
- submission of de-identified patient and treatment information to be recorded in the Australia and New Zealand Assisted Reproductive Technology Database (ANZARD). This ANZARD information may be used for population analysis, research projects, and the publication of our success rates; and
- other purposes as required or authorised by law.
From time-to-time, we may make direct communications to you with information regarding operational updates, and about our products and services that may be of interest to you. You will be able to opt out of receiving our marketing communications when you receive them or you can contact our Privacy Officer.
Importantly, not all personal information is used and disclosed for all of these purposes.
Disclosure and transfers of personal information
We take steps to limit the personal information we disclose and so in practice your personal information is unlikely to be disclosed to all of the parties described below. Further, most disclosures we make will involve only a portion of your personal information. We understand the sensitivity of information about your treatments with us, and take confidentiality and discretion very seriously. We may, for example, seek further consent from you before making certain disclosures.
The types of parties to which we may disclose and transfer personal information include:
- our related companies;
- other health providers, including hospitals, referring providers and those involved in your care;
- My Health Record (unless you have opted out of the My Health Record system) and public health agencies, providers and participants;
- service providers including providers of laboratory analysis, IT, communications, research, investigation, financial and delivery services;
- professional advisers such as auditors, accountants and legal advisers;
- insurers;
- your representatives;
- government and statutory bodies such as Medicare and Workcover authorities;
- professional bodies such as RTAC;
- clinical ethics advisory committees; and
- research bodies and clinical registries such as ANZARD.
The diagnosis and treatment of infertility often involves more than one person (for example, your partner, donors or surrogates). Where you are undergoing treatment with a partner, it is our policy to share all your information with your partner UNLESS you tell us not to disclose your information to your partner.
Some of the parties described above may be in Ireland, the United Kingdom, the United States, Denmark, Singapore and other countries. In addition, if you request us to send materials related to your treatment to another country, we will be required to disclose your personal information to people in that country.
Data quality and security
We aim to ensure the personal information we collect, use, hold or disclose is accurate, complete, up-to-date and relevant to the functions and services we provide. You can help us achieve this by providing correct and up-to-date information.
We also implement controls to help us (and our service providers) store your personal information securely and protect it from unauthorised access, modification or disclosure, whether the information is held in physical or digital form. The types of controls we use, depending on the circumstances, include restricting who can access certain information, authentication controls, security training, vendor management and security testing and reviews.
Access and correction
You can ask us for access to the personal information we hold about you, in part or in full, or ask us to provide it to a third party such as another healthcare provider.
We may ask you to make this request in writing. There may be an administration fee for this service, depending on the nature of access required.
If you feel any of the personal information we hold about you is inaccurate or incomplete, please let us know. In many cases, in accordance with good clinical practice and consistent with our statutory obligations, we do not erase the original record. Rather, we may note your corrections and add them to our records.
Cookies, pixels and tags
Our websites use cookies, pixels, tags and similar technologies. These are small pieces of text stored in your browser or small images embedded in webpages that support the following tasks:
- Basic functions: To help our websites work (for example, remembering which page you are on, or enabling functions like audio or video). We do not collect any personal information when we do this.
- Analytics: To anonymously log user activity to help us understand how our websites are used, and for security purposes. We use Google Analytics to do this. You can opt out of Google Analytics by visiting the Google Analytics opt-out page (see below).
- Advertising: We work with third-party advertising partners to show our advertising to relevant groups of people on social media and other websites. We use cookies, pixels, tags and similar technologies on our websites to better understand your interests. When you take certain actions, such as visiting a page or submitting a form, we share data with our advertising partners to help us make our ads more relevant to you, and to measure and assess how our advertising campaigns are working. This data does not identify you directly, but may include information about your device and browser. Our ad management partners may include Meta, Alphabet /Google and TikTok - you can control how our partners advertise to you on their websites.
Remarketing with Google Analytics
Our websites use analytics data with Google cookies to serve ads based on a user’s prior visits to our website. You have the ability to opt out of these personalized ads by visiting the Google advertising opt-out page. You can also opt out of Google Analytics by visiting the Google Analytics opt-out page.
If you would like to know more about remarketing, you can view Google’s Remarketing Privacy Guidelines and Restrictions pages.
Retention of records
To ensure we comply with regulatory requirements, it is our policy to keep your medical records for at least the period required by the relevant statutory requirements. As a regulated provider of assisted reproductive services, we are legally required under relevant Australian State and Territory assisted reproductive technology laws to retain patient records for extended periods—often more than 50 years.
Contact
We want to make sure your expectations about your privacy protection are the same as ours. If you have any concerns, please discuss them with your doctor or any member of our staff. If, after this discussion, you still have concerns, you can contact our Privacy Officer at: [email protected] or Virtus Health Group Privacy Officer, Level 3, 154 Pacific Highway, Greenwich NSW 2065.
If you are still not satisfied, you may complain to:
Privacy Commissioner
Office of the Australian Information Commissioner
GPO Box 5288, Sydney NSW 2001
Call: 1300 363 992
Website: www.oaic.gov.au
or
The Office of the Health Ombudsman (Qld)
PO Box 13281, George Street, Brisbane Qld 4003
Call: 133 OHO (133 646)
Website: www.oho.qld.gov.au/
or
Health Care Complaints Commission (NSW)
PO Box K549, Haymarket NSW 1240
Call: 1800 043 159
Website: www.hccc.nsw.gov.au
or
Health Complaints Commissioner (Vic)
Level 15, 50 Lonsdale Street, Melbourne VIC 3000
Call: 1300 582 113
Website: https://hcc.vic.gov.au/
or
ACT Human Rights Commission
GPO Box 158 Canberra ACT 2601
Call: (02) 6205 2222
Website: www.hrc.act.gov.au
Changes to this Privacy Policy
We may make changes to this Privacy Policy at any time without notice to you. At any time, our current Privacy Policy is available on our website.