Privacy Policy and Procedure

1. Policy

Perfect Balance Nutrition Pty. Ltd. (PBN) recognises the importance of privacy and is committed to providing quality services that protect personal information acquired in the course of our activities. This policy outlines the management of personal and sensitive information obtained by PBN.

The Privacy Act 1988 (Commonwealth) sets out rules of conduct called the Australian Privacy Principles (APPs), which establish standards for the collection and management of personal information. The 13 APPs came into effect on 12 March 2014 and ensure organisations like the Dietitians Association of Australia (DAA), some small businesses and government agencies protect people’s personal information and are transparent about how they handle this information via individual and organisational specific policies and procedures.

PBN acknowledges that providing personal information is an act of trust and we value the trust that our patients and affiliates have in us and our business. Therefore, this policy serves to capture how PBN will collect, use and disclose personal and sensitive information we obtain in accordance with the Privacy Act 1988 and APPs.

2. Application

This policy applies to all recipients of PBN services; including patients, clients, and affiliates.

3. Procedure

3.1 Collection
PBN collects personal information through various methods of communication including face-to-face appointments, by telephone, email, through the PBN website, training, and presentation sessions or when information is provided to PBN by a referring practitioner.

Information we collect may include:

  • Name
  • Date of Birth
  • Gender
  • Race
  • Address
  • Email address
  • Telephone number/s
  • Medical history
  • Medical test results and records, including doctor referral and/or Care Plan
  • Credit or debit card information
  • Medicare details
  • DVA or Health Care Card details

Sensitive information, such as information relating to a patient’s health and wellbeing, may be collected by PBN in connection with our activities. Such information will not be disclosed without the patient’s consent and only if relevant to the activity.

If a third party provides information about a potential client to PBN, we expect that the third party has advised the individual of the intention to do so and obtained the patient’s consent to release their personal information to PBN. In this case, we may request the third party to direct the patient to PBN’s current Privacy Policy and inform the patient of their option to contact us directly for further information.

By completing and submitting the online contact form on the PBN website, the user consents to their personal information being collected, stored, used and disclosed by PBN as set out in this policy.

There is no obligation to provide personal information to PBN, however, failure to do so may result in PBN being unable to provide services or materials to you.

3.1.1 Purpose of Collection
PBN will generally collect, use and store your personal information for the following purposes:
​Primarily to provide you with our core services and materials, relating to dietetics and nutrition.
For secondary purposes, related to the primary purpose, and the individual would reasonably expect the organisation to use or disclose the information for the secondary purpose.

  • To provide you with information about our services and materials.
  • To reconcile outstanding financial payments in relation to our services.
  • To communicate with other health care providers; including doctors, specialists, and other health professionals, in accordance with legislative and industry standards, to ensure a holistic approach to a patient’s health care.

3.2 Dealing with Personal Information
PBN has implemented physical, electronic and managerial strategies; including password security for computer data files, and secure cabinets for physical documents, to protect personal information. These repositories are located in secure controlled sites.

PBN will not use or disclose personal information to any individual, business, government entity or third party without the consent of the owner of the personal information, except:

  • In response to a validly issued subpoena, court order or other legal process.
  • When necessary to establish or exercise our legal rights or defend against legal action.
  • If the owner of the personal information requests PBN to do so and has provided express authorisation, preferably via letter or PBN Consent Form.
  • Anytime authorisation is given to PBN to release information about individuals, including any request to view an individual’s own information.
  • To protect a person’s health, safety or wellbeing.
  • For secondary purposes related to the primary purpose, and the individual would reasonably expect the organisation to use or disclose the information for the secondary purpose.

As our dietitians practice from various sites across Melbourne, PBN is required to provide a list of our patients to the relevant affiliate hosting our appointments for that day. Consent is sought from patients at the time of their registration with PBN, to provide limited personal information about them to a specific affiliate before their appointment at the affiliate’s venue on a particular date. The purpose of providing this information to the affiliate is to confirm the patient’s booking with our dietitian/s at the affiliate’s venue as patients are required to inform the affiliate’s reception staff of their arrival for their appointment with a PBN dietitian.

For every appointment, PBN will notify the relevant affiliate of the patient’s name, contact telephone number, appointment time, and type of booking on a particular date. At the conclusion of that business day, the affiliate will destroy the PBN patient list containing this information in accordance with legislative requirements.

It is not the intention of PBN to sell, distribute, or lease your personal information to any individual, business, government entity, or third party. PBN will not disclose personal information to overseas recipients.

3.3 Access to, and Correction of Personal Information
PBN works to ensure that the personal information it retains is accurate, complete and up-to-date.
Individuals have the right to access, review, amend and/or delete their personal information recorded by PBN. Requests to do so can be directed to PBN in writing at:

  • PO Box 6058, Vermont, VIC 3133 or
  • admin@perfectbalance.net.au

PBN will not charge a fee for your request to access your personal information, however a small administrative charge may be applied for provision of copies of your personal information. This fee will be discussed at the time of responding to your written request for copies of your personal information held by PBN.

​PBN will take reasonable steps to correct the information if requested. When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information in accordance with legislative requirements.

3.4 Feedback and Complaints
For further information regarding this policy, or to make a complaint about your privacy, or the way in which PBN has collected, stored, used or disclosed your personal information; please contact PBN in writing:

  • PO Box 6058, Vermont, VIC 3133 or
  • admin@perfectbalance.net.au

PBN will investigate any complaints received in writing and make reasonable efforts to resolve any issues identified as soon as possible. If you remain dissatisfied with our response to your complaint, you can refer your complaint to:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney, NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Fax: (02) 9284 9666
Website: www.oaic.gov.au

4. Review

This policy and procedure document will be reviewed in 5 years, or if required to reflect changes in practice or legislative obligations.

5. Definitions

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:​

  1. whether the information or opinion is true or not, and,
  2. whether the informaiton or opinion is recorded in a material form or not.

Sensitive information means:

  1. information or an opinion about an individual‘s:
    1. racial or ethnic origin; or
    2. political opinions; or
    3. membership of a political association; or
    4. religious beliefs or affiliations; or
    5. philosophical beliefs; or
    6. membership of a professional or trade association; or
    7. membership of a trade union; or
    8. sexual orientation or practices; or
    9. criminal record;
      that is also personal information; or
  2. health information about an individual; or
  3. genetic information about an individual that is not otherwise health information; or
  4. biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
  5. biometric templates.

Client/s means a person or persons receiving or registered to receive dietetic and nutritional information from PBN dietitians and/or staff members.

Patient/s means a person or persons receiving or registered to receive dietetic and nutritional services from PBN dietitians.

Affiliate/s means a person, business or organisation connected to PBN through a business agreement related to PBN’s operation of services from their premises (e.g. medical, community and/or recreational centre).

6. References

Privacy Act 1988

Australian Privacy Principles
Dietitians Association of Australia Privacy Policy

Office of the Australian Information Commissioner