Our Privacy Policy

1. About this policy

This section explains how to read this policy and describes its purpose.  

1.1 Interpretation of this document and general overview

Defining specific terms:

1.1.1 “Clinic” means a program or service whether it be provided by a third party or by our organisation

1.1.2 “Health Information” includes information about the physical, mental or psychological health or disability of an individual or an individual’s wishes about the provision of health services.

1.1.3 “Privacy Information” includes Personal Information and Sensitive Information.

1.1.4 “Personal Information” includes information that is capable of identifying an individual such as name, address and date of birth.

1.1.5 “Sensitive Information” includes information relating to religion, racial or ethnic origin. 

1.1.6 “South Eastern Melbourne Primary Health Network (“SEMPHN”)” refers to the organisation working on behalf of the Australian Government to improve health care in the South Eastern Melbourne Primary Health Network catchment.

1.1.7 “We”, “us” and “our” refer to SEMPHN.

1.1.8 “APPs” refer to the Australian Privacy Principles in the Privacy Act 1988 (Cth).

SEMPHN is subject to the Australian Privacy Principles as laid out in the Privacy Act 1988.

1.2 Purpose of this policy

The SEMPHN Privacy Policy explains how our organisation protects your privacy information.  Along with our Collection Statement our Privacy Policy lays down the principles by which we collect, store, use and disclose any Personal Information you provide to us or we collect from other sources.

Our Privacy Policy also informs clients, prospective clients, stakeholders and anyone else whose Privacy Information is protected in dealing with SEMPHN, about how they can access their Privacy Information, correct Privacy Information held by us, lodge complaints or make any related enquiry.  


2. Type of information we collect and hold

SEMPHN collects information about you to improve the health care system. 

Types of Personal Information we collect:

2.1 Health providers and stakeholders

We collect Personal Information regarding health providers and stakeholders (for example, general practices, aged care providers, government agencies), and their employees to better understand and improve the health system.

The type of information can include:

2.1.1 Name

2.1.2 Contact details

2.1.3 Role/health services provided

2.1.4 Connection with SEMPHN

2.2 Clients

SEMPHN generally collects information about clients for services provided by our Clinics.  SEMPHN collects personal details to facilitate or arrange health services, maintain client records, manage service demand and in some cases, provide health services. 

Where SEMPHN provides a health service, SEMPHN will collect Health Information and Sensitive Information.  This information is needed to properly diagnose health conditions, deliver appropriate services and improve health.  

The types of information collected can typically include (this list is not exhaustive):

2.2.1 Contact details (name, address, telephone number, email address, next of kin)

2.2.2 Age, date of birth, gender, marital status

2.2.3 Driver’s licence number, Medicare number

2.2.4 Medical history, treatment records, images, photographs, family medical histories

2.2.5 Referrals to and from other practitioners and their reports

2.2.6 Ethnic origin (for example, to assess your eligibility for free health services)

2.2.7 If payments or co-payments are required, banking/credit card details

2.3 Website visitors

For our website visitors, we collect information such as your IP address, internet service provider, the web page directing you to our website and your activity on our website.  This information is usually anonymous and we do not use it to identify individuals.  However, due to the nature of internet protocols, such information might contain details that identify you.  This information is collected to ensure that our information has reached its target audience.

2.4 Members

We collect Personal Information regarding SEMPHN members and their representatives to comply with the SEMPHN constitution and to maintain a membership register under the Corporations Act 2001 (Cth).  The details are needed so that we can send notices of general meetings so members can exercise their rights.

The type of information collected can include:

2.4.1 Name

2.4.2 Contact details (address, phone, email)

2.4.3 Proxy, attorney or representative appointments

2.4.4 Class of member

2.4.5 Date membership commenced

2.4.6 Date membership ceased (for past members)

2.5 Prospective employees and directors

We collect Personal Information regarding prospective employees and directors, regarding their skills, interests, qualifications and experience to:

2.5.1 Assess their suitability for potential employment or directorships with us

2.5.2 Match them to suitable projects or roles

2.6 Others

We may collect Personal (including Health) Information related to the general public in connection with our population planning, research and analysis.  This information will generally be de-identified as soon as it is collected.  

We collect the Personal Information of directors, employees and others in connection with our corporate and other administrative functions.  The type of information collected can include:

2.6.1 Name and former names

2.6.2 Contact details (address, phone, email, assistant details)

2.6.3 Date and place of birth

2.6.4 Financial and personal interests which may give rise to conflicts or be required for insurance purposes

2.6.5 Bank account details (for example for reimbursements)

2.6.6 Qualifications obtained


3. How we collect your information 

We may collect Personal Information (not including sensitive information) from people through our marketing, business development, operational, human resources, research or other activities.  

We have a general policy to collect Personal Information directly from you, unless it is unreasonable or impracticable to do so.  

We will need your written consent to collect Sensitive Information (which includes health information) about you.

3.1 Health providers and stakeholders

We generally collect Personal Information directly from individuals.  However, for some health providers and stakeholders, we may collect your Personal Information from colleagues or other health providers and stakeholders, or clients.

In some cases, we collect your Personal Information from public sources (for example national health practitioner register, internet) or through your memberships (for example with peak bodies).

3.2 Clients

SEMPHN employees usually collect Personal Information directly from individuals and their representatives at a Clinic unless it is unreasonable or impracticable to do so.  We collect Health and Sensitive Information with your consent in a fair and unobtrusive way.

We also collect information about clients from:

3.2.1 Clients and their representatives through forms, agreements, mail, email, telephone, in-person inquiries and website inquiries

3.2.2 Sub-contractors and practitioners who receive funding from SEMPHN

3.2.3 Referrers and third parties (eg specialists or providers outside the clinics or the programs)

3.2.4 Publicly available sources of information

3.3 Website visitors

We collect data from our website using various technologies, including cookies.  A cookie is a text file that our website sends to your browser which is stored on your computer as a tag identifying your computer to us.  You can set your browser to disable cookies.  However, some parts of our website may not function properly (or at all) if cookies are disabled.

3.4 Members

We collect member Personal Information directly from the member.

If you are a proxy or a representative from a SEMPHN member, we collect your details from your or the appointing SEMPHN member.  

3.5 Prospective employees and directors

We generally collect Personal Information directly from the prospective candidate, but may also do so from recruitment agents, recruiters, referrers, referees, SEMPHN officers/employees or other knowledgeable parties where relevant to the recruitment process. 

3.6 Others

We collect information about directors, employees and others directly from those persons.

In some cases, we collect information about such persons:

3.6.1 Through forms, agreements, general inquiries

3.6.2 From researchers or contractors engaged by SEMPHN

3.6.3 Public sources (for example national health practitioner register)


4. Direct Marketing

4.1 Collecting information indirectly about an individual for marketing to that individual 

If SEMPHN plans to engage in direct marketing using or disclosing information collected:

4.1.1 indirectly about that individual, or 

4.1.2 from the individual and the individual would not reasonably expect us to use or disclose the information for marketing purposes, 

SEMPHN must first obtain consent, unless an exception applies. 

All subsequent direct marketing you receive will include an easy opt-out procedure if at any time you wish us to cease sending you information.  

4.2 Collecting information directly about an individual for marketing to that individual  

If we collect information about you and you would reasonably expect us to use or disclose the information for the purpose of marketing, we will use an opt-out procedure in all our marketing communications.  This means you will be able to easily unsubscribe from all future marketing communications. 


5. Purpose for which we collect and deal with your information

As a general principle, we only use Privacy Information for the primary purpose for which we collect the information or a secondary purpose related to the primary purpose for which you would reasonably expect us to use the collected information.  All the information collected by SEMPHN will be used only for the purpose of improving the medical services for patients, particularly those at risk of poor health outcomes and improving co-ordination of care to ensure patients receive the right care at the right time.

We will make you aware of the purpose for which we collect your information by notifying you about all the relevant matters of that collection.   

We will not use your information for an unrelated secondary purpose unless we obtain your written consent or an exception applies, such as it is impracticable to obtain your consent and we believe that collecting, using or disclosing your information is necessary to lessen a serious threat to the life, health or safety of any individual.   

5.1 Health providers and stakeholders

We collect Personal Information regarding the employees, volunteers and officers of our health providers and stakeholders:

5.1.1 To pursue collaborative projects and matters of common interest

5.1.2 In the course of contracting with them or arranging for the delivery of health services for clients

5.1.3 To distribute information about our activities and publications by way of direct communications/marketing to improve our health system and the health of our clients

We may collect Personal Information regarding your interests to personalise your interactions with us.

5.2 Clients

We collect and use Personal and Health Information for the purpose of:

5.2.1 Providing health services and diagnosing conditions

5.2.2 Managing service demands at the clinics or programs

The following are specific examples of when we collect and use your Personal Information:

5.2.3 To make appointments and send reminder notices

5.2.4 To communicate with other health practitioners as part of a multidisciplinary team

5.2.5 To maintain your personal information, our client records and other medical registers

5.2.6 To inform your nominated emergency contacts (next of kin) of a medical condition

5.2.7 To disclose your health information to paramedics and health professionals in a medical emergency

5.2.8 To use de-identified information to model or forecast service demand]

5.2.9 To liaise with a person’s nominated representative or family members where needed 

5.2.10 To improve our services through quality improvement activities, audits, surveys and program evaluations

5.3 Members

We use Personal Information of members for the purposes including compliance and to administer membership rights and to process your membership documents.

We may also supply our membership list to government to comply with funding requirements.

We also use our member’s lists to distribute information about our activities and identify persons interested in a directorship.

5.4 Prospective employees and directors

We use Personal Information about our prospective employees and directors for predominately to consider the application.

5.5 Website visitors

We use information regarding website visits for the purpose personalising of your website visit or to enable remarketing website functionality.

5.6 Others

SEMPHN may also collect and use Personal Information from others for our operational, human resources, research referral or other corporate activities.


6. Cross border transfer or disclosure of information  

In the event we engage in cross border transfer of information, such as routing or storing information on cloud servers located overseas or transferring information to an office of our company overseas, we will ensure that adequate security mechanisms are in place to protect your information.  For example, we will enter into a contract with the cloud server that ensures the information is for the limited purpose of storing and managing the Personal Information. 


7. Maintaining the integrity currency and safety of your privacy information 

This section explains how SEMPHN holds your Privacy Information, how you can access your Privacy Information, update your Privacy Information, complain about an alleged breach of the APPs or make any related enquiry.

7.1 Maintaining currency of your information  

SEMPHN relies on accurate and reliable information to deliver necessary and effective services.  If we are satisfied that any of the information we have about you is inaccurate, out-of-date, irrelevant, incomplete or misleading, or you request we correct any information, we will take reasonable steps to ensure the information held by us is accurate, up-to-date, complete, relevant and not misleading.

If we disclose your Privacy Information that is later corrected, we will, or else you may ask us to, notify the entity that received the incorrect information about that correction.

Should we refuse to correct the information, we will explain the reasons for refusal.  We will also show you the complaint procedure if you wish to lodge a formal complaint about our refusal.

7.2 Safety of your information

All Privacy Information is securely stored using appropriate physical and/or electronic security technology, settings and applications, and by ensuring staff dealing with privacy information is trained in our privacy policies and procedures. 

These policies are designed to protect Privacy Information from unauthorised access, modification or disclosure; and from misuse, interference and loss.


8. Accessing your information or lodging a complaint 

8.1 Accessing and correcting information 

You are entitled at any time, upon request, to access your Privacy Information held by us.  We will respond within a reasonable time after the request is made and give access to the information in the manner requested by you, unless it is impracticable to do so.  We are entitled to charge you a reasonable administrative fee for giving you access to the information requested.  

Should you be refused access to your information, we will explain the reasons for refusal - any exceptions under the Privacy Act or other legal basis relied upon as the basis for such refusal – and, if you wish to lodge a formal complaint about our refusal, we will explain the complaint procedure. 

8.2 Lodging a complaint

Should you wish to complain about a potential breach of this Privacy Policy or the Australian Privacy Principles please contact our Privacy Officer. 

The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.  

8.3 Contact details

Privacy Officer
South Eastern Melbourne Primary Health Network
Phone: 1300 331 981
            03 8514 4499
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.


SEMPHN Collection Statement

The purpose of this Collection Statement is to explain why we collect your personal information, whether we disclose that information, the main consequences of not providing us with your personal information, and how you may access your personal information.  This Collection Statement will also notify you of all relevant matters relating to personal information under the Australian Privacy Principles (the “APPs”).  This is not our Privacy Policy, which you can view on our website www.semphn.org.au.  

How we collect personal information: our general policy is to collect information from you directly and not from third parties.  If it is unreasonable or impracticable to collect personal information from you directly, we may collect this information from third parties mentioned in our Privacy Policy. 

Why we collect personal information: we collect your personal information for the primary purpose of increasing the efficiency and effectiveness of medical services for patients, particularly those at risk of poor health outcomes, and improving co-ordination of care to ensure patients receive appropriate care at the right time.  We provide the full list of purposes for which we collect your privacy information in our Privacy Policy.  

The consequences of not providing us with personal information: by not providing us with your personal information we might not be able to perform some of our essential functions.

Access and correcting your personal information: you are entitled, upon request, to access your personal information at any time, unless there is an exception which applies under the Privacy Act.  The integrity of the information we hold is important to us and we will endeavour to ensure that your personal information is up-to-date and accurate.  

Please refer to our Privacy Policy for further details about how South Eastern Melbourne Primary Health Network holds your personal information, how you can access your personal information, correct your personal information and other related matters.  

Lodging a complaint: if you wish to complain about a potential breach of this Privacy Policy or the Australian Privacy Principles please contact our Privacy Officer. 

The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.

Our contact details:
Phone: 1300 331 981
             03 8514 4499
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

May 2017

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