Your Local Doctor Pty Ltd (ABN: 21 687 570 850) (“we”, “our”, “us”) is committed to protecting your personal and health information. This Privacy Policy outlines how we collect, use, disclose, store, and dispose of your personal and health information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and applicable state and territory health records legislation.
Our registered address is 10 Primrose Loop, Eglinton, Western Australia 6034, Australia.
A copy of the Australian Privacy Principles may be obtained from the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
1. Anonymity and Pseudonymity
Due to the nature of the health services we provide, it is generally impracticable for us to deal with individuals who have not identified themselves. Accurate identification is required to ensure the safety and continuity of clinical care, to comply with our legal and professional obligations under applicable health legislation, and to meet the requirements of Medicare and private health insurance billing.
2. What Personal and Health Information We Collect
We collect the following types of personal information and health information to provide our telehealth services:
- Identity information: full name, date of birth, gender, residential address, email address, phone number
- Health information: medical history, current symptoms, diagnoses, clinical notes, medications (current and past), pathology and radiology results, referral letters, and any other information relevant to your clinical care
- Medicare and billing information: Medicare card number, Individual Healthcare Identifier (IHI), private health insurance details, payment information
- Telehealth-specific information: consultation date, time, duration, mode (video or phone), technical connection details, identity verification records
3. How We Collect Your Information
We collect your personal and health information primarily from you, through:
- Our website booking forms and pre-consultation questionnaires
- Telehealth consultations (video and phone)
- Email, telephone, and written correspondence
- Third parties such as other healthcare providers, pathology laboratories, and hospitals (with your consent or as required by law)
4. Unsolicited Personal Information
From time to time, we may receive personal or health information that we did not solicit. Where we receive unsolicited personal information, we will promptly assess whether that information is of a kind we could have collected under our standard collection practices. If it is not reasonably necessary for our functions, we will destroy or de-identify it as soon as practicable, unless retention is required or authorised by law.
5. Purpose of Collection
We collect your personal and health information for the primary purposes of:
- Providing telehealth consultation services and clinical care
- Issuing prescriptions, medical certificates, and referrals where clinically appropriate
- Processing Medicare claims and billing
- Communicating with you about your care, appointments, and follow-up
- Meeting our legal, regulatory, and professional obligations
We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
6. Sensitive Information
Health information is classified as sensitive information under the Privacy Act. We will only collect sensitive information with your express consent, or where collection is required or authorised by law. Sensitive information will be used only for the purpose for which it was collected, for directly related secondary purposes, with your consent, or where required or authorised by law.
7. Disclosure of Personal and Health Information
Your personal and health information may be disclosed in the following circumstances:
- To other healthcare providers involved in your care (with your consent)
- To pharmacies for the dispensing of prescriptions
- To pathology and radiology providers for ordered investigations
- To Medicare and private health insurers for billing purposes
- To Halaxy, our practice management and online booking provider, for scheduling and managing your appointments.
- Where required or authorised by Australian law (including mandatory reporting obligations, court orders, and National Law s.140 notifications)
- Where necessary to prevent a serious threat to life, health, or safety
8. Overseas and Cross-Border Disclosure
We use technology platforms to deliver our telehealth services. These platforms include Halaxy, an Australian-based practice management and online booking system we use to manage appointments, bookings, and associated personal and health information. Some of these platforms may store data on servers located outside Australia. Where your personal information is transferred overseas, we take reasonable steps to ensure the overseas recipient handles your information in accordance with the APPs. We will not transfer your health information overseas without your consent, unless an exception under APP 8 applies. Our primary data storage and clinical records are maintained within Australia.
9. Government and Healthcare Identifiers
We collect and use government identifiers such as your Medicare number and Individual Healthcare Identifier (IHI) only for the purposes authorised by law, including Medicare billing, My Health Record integration (if applicable), and healthcare identification. We do not use government identifiers as our own identifiers for you.
10. My Health Record
If you have a My Health Record, information from your consultations may be uploaded to your My Health Record in accordance with the My Health Records Act 2012 (Cth). You can manage your My Health Record settings, including opting out, through the My Health Record website at www.myhealthrecord.gov.au or by calling 1800 723 471.
11. Telehealth Privacy
Telehealth consultations are conducted via secure, encrypted video or phone platforms. To protect your privacy during telehealth consultations:
- We verify your identity at the start of each consultation
- Our practitioners conduct consultations from private, secure locations
- We recommend you participate from a private space where you cannot be overheard
- Video consultations are not recorded unless you are informed and consent is obtained
- If your telehealth consultation is interrupted by technical issues, your practitioner will attempt to reconnect or reschedule
If your practitioner determines that a telehealth consultation is not suitable for your needs, they may recommend an in-person assessment, specialist referral, or emergency services as appropriate.
12. Direct Marketing
We will only use your personal information for direct marketing purposes where you have provided express consent. You may unsubscribe from our marketing communications at any time by clicking the unsubscribe link in any marketing email, or by contacting us at re*****@*****************om.au. We will process your request within a reasonable timeframe in accordance with the Spam Act 2003 (Cth).
13. Use of AI and Automated Tools
We may use technology tools to support administrative functions such as appointment scheduling and communication. No clinical decisions, diagnoses, or prescribing decisions are made by automated systems. All clinical care is provided by qualified practitioners who review and make decisions based on their professional judgement.
14. Security of Your Information
We take reasonable steps to protect your personal and health information from misuse, interference, loss, and from unauthorised access, modification, or disclosure. Our security measures include encrypted data transmission, secure access controls, staff training on privacy obligations, and regular review of our information security practices.
15. Retention and Disposal of Health Records
Clinical records are retained in accordance with the Health Practitioner Regulation National Law and applicable Western Australian health records legislation. As a minimum, health records for adults are retained for a period of seven (7) years from the date of last entry. Health records for children are retained until the patient reaches twenty-five (25) years of age, or for seven (7) years from the date of last entry, whichever is later. When your health information is no longer required to be retained, we will take reasonable steps to destroy or permanently de-identify it.
16. Notifiable Data Breaches
In the event of an eligible data breach involving your personal or health information, we will comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988. We will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable, and no later than 30 days after becoming aware of a breach that is likely to result in serious harm.
17. Cookies and Tracking Technologies
We use cookies and similar tracking technologies on our website, including Google Ads, Google Analytics, Google Tag Manager, and Meta Pixel. Please note that browsing health-related pages may reveal sensitive interests. These technologies are used for website analytics, advertising measurement, and service improvement. You can control cookies through your browser settings. Disabling cookies may limit some website functionality. By using our website, you consent to the use of cookies as described in this section. You can withdraw your consent at any time by adjusting your browser settings or by contacting us.
18. Access to Your Information
You may request access to the personal and health information we hold about you by contacting us in writing. We will respond to your request within 30 days. We will not charge a fee for your access request, but may charge a reasonable administrative fee for providing copies of your records. We may refuse access in limited circumstances permitted by law, and will provide reasons for any refusal.
19. Correction of Your Information
If you believe the information we hold about you is inaccurate, incomplete, or out of date, please contact us so we can update our records. If we disagree with a requested correction to clinical records, we will attach your statement of the requested correction to the relevant record.
20. Complaints and Enquiries
If you have any questions, concerns, or complaints about how we handle your personal or health information, please contact us:
Your Local Doctor Pty Ltd
Email: re*****@*****************om.au
Phone: 1300 947 485
Address: 10 Primrose Loop, Eglinton, Western Australia 6034, Australia
We will investigate your complaint and respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with:
- Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au or call 1300 363 992
- Health and Disability Services Complaints Office (HaDSCO), Western Australia: www.hadsco.wa.gov.au or call (08) 6551 7600
- If you are located outside Western Australia, you may also contact the health complaints authority in your own state or territory (for example, the Health Care Complaints Commission in NSW, the Health Complaints Commissioner in Victoria, or the Office of the Health Ombudsman in Queensland).
21. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The most current version will always be available on our website. We encourage you to review this policy periodically.