The Holland Clinic Academy Pty Ltd (ABN 35 654 626 187) and The Holland Clinic Pty Ltd (ABN 47 660 358 163) (“we”, “our”, “us”, “The Holland Clinic”), comply with the Privacy Act 1988 (Cth) (“Privacy Act”) and the applicable Privacy Principles in the Privacy Act when handling personal information, together with the Health Records Act 2001 (Vic) (“Health Records Act”) and the applicable Health Privacy Principles in the Health Records Act when handling personal information which is health information together with the General Data Protection Regulation (GDPR) to the extent it applies.
We take the protection of your personal information seriously. Personal information includes personal data (as defined in the GDPR) and means any information or opinion, whether true or not, about a person who is identified or whose identity can reasonably be established or any information relating to an identified or identifiable natural person (“Personal Information”).
We collect Personal Information for the purposes of arranging and delivering sessions, courses and products (“Services”) as well as communicating with you. We may collect information through our website at https://www.thehollandclinic.com.au (“Website”) or in the course of providing Services via the Website, email, in person, verbally or via any other means available from time to time.
We collect Personal Information:
- from clients– when they register an enquiry, enrol in a Course, purchase any program or associated services, purchase any products, attend a clinic, access our Website, subscribe to our newsletter, and/or at any other time from time-to-time in the course of providing Services.
- from third party service providers – when they are engaged to supply services to us (such as but not limited to Services and professional services), provide information to us or invoice us for the provision of services;
- when we receive enquiries through the Website, and when the Website otherwise accessed or used;
- when we receive enquiries via email or telephone.
The kind of Personal Information we may collect will depend on who you are (e.g. a client or third party service provider) and the nature of your interaction with us, and may include your full name, address, email address, date of birth, billing and payment information, health and injury history and other Personal Information. If you do not provide us with all the information we request, we may not be able to provide the Services to you or enable you to participate in requested Services.
Some Personal Information we collect may include health information. Health information includes any information collected about your health or disability, Covid vaccination status and any information collected in relation to a health service you have received (“Health Information”). We may collect Health Information from clients when they attend a clinic to receive participate in Services, and when entering into agreements with us regarding enrolments and participation in our Services. We collect Health Information in order to assist you to safely participate in Services and where required, make appropriate modifications. How your Health Information is dealt with in greater detail below.
The Health Information we collect enables us to arrange for the provision of Services and for the safe, appropriate and accurate provision of Services, to assess the needs of clients in the provision of Services, and for us to generally assist in optimising the quality of our service. We may also be required to collect Health Information in order to comply with our statutory obligations, for example regarding Coronavirus vaccination status.
We may use any Personal Information collected (excluding Health Information) to provide our Services, operate the Website, sign you up to our newsletter, respond to feedback and complaints, communicate with third party service providers or if needed to enforce our Client agreement with you. If you are a third party service provider, we will use your Personal Information to communicate with you including to accept your offer to provide services, correspond with you in relation to the provision of services and to pay your invoices.
In all cases, unless you have opted out, you consent to us using your Personal Information (excluding health information) for direct marketing purposes by us alone in order to tell you about our Services. We may contact you by mail, telephone, email or SMS to market our products and Services. We will always give you the opportunity to opt out of receiving any future direct marketing correspondence.
To the extent that it is collected, we and our Instructors comply with the Health Privacy Principles together with the GDPR in the collection, use and disclosure of all Health Information and to ensure that all Health Information is kept strictly confidential.
We collect your Health Information when you sign up for a course on our Website, complete any intake forms, attend our clinic and/or at any other time from time-to-time in the course of arranging the provision of Services.
We may collect your Health Information:
- as necessary for the safe provision of Services, including recording personal information and Health Information which is relevant to your current situation
- from our customers when they request an assessment for the purposes of advice, and/or purchase any associated products or Services;
- as necessary for the provision of our Services, but only as necessary for the provision of our Services, or as otherwise in accordance with your consent, or as may be required by law including Court order;
- only from you (or from someone authorised by you) (including your caregiver if you have one);
- with accuracy, on the basis that you may at any time request a copy of the health information that we hold by emailing us at firstname.lastname@example.org. In the event our records are found to be inaccurate, we will rectify any inaccuracies on the basis of the further information you provide.
Disclosure and sharing:
You may authorise us to stop processing your Personal Information at any time.
Data security, protection and quality:
We will protect the Personal Information we collect and hold from misuse, loss and interference and from unauthorised access and modification, and to make sure it is accurate, complete and up-to-date when we collect, use or disclose it.
We have procedures of monitoring the security and safety of data as well as procedures in place for dealing with any data breaches, and the associated requirements of notifying you and appropriate authorities where that data security of your Personal Information is breached.
To assist us, please ensure you provide us with your correct details, and let us know if you believe the information we have about you is inaccurate, incomplete, out of date or misleading (and we will take reasonable steps to correct the information). We may take steps to destroy or permanently de-identify information when it is no longer needed for any purpose for which it may be used or disclosed.
Your right to erasure
The right to erasure (which encompasses the ‘right to be forgotten’) gives you a right to require us to delete your Personal Information in certain circumstances, subject to applicable law, and/or to return it to you including, but not limited to, where your Personal Information is no longer necessary for the purpose for which it was collected, or where you withdraw your consent and there is no other legal ground for processing your data. If you wish to have your Personal Information erased and/or returned to you please notify us at email@example.com.
Our Website: www.thehollandclinic.com.au
You can modify your browser to prevent cookie use – but if you do this our service (and our Website) may not work properly. The information stored in the cookie is used to identify you. This enables us to operate an efficient service and to track the patterns of behaviour of visitors to the Website.
Access, correction and complaints:
You can request, and we will provide you with access to, and a copy of any Personal Information we hold about you (including any Health Information) (subject to any applicable legal exceptions). Please also let us know if you have any concerns or complaints about the way we are handling your personal information so we can address them. Requests should be submitted by email to firstname.lastname@example.org. Where our records are found to be inaccurate, or if you wish to modify the Personal Information we hold about you, we will promptly make these changes on the basis of the further information you provide.
Transfer in certain circumstances:
For further information on your privacy rights go to: www.privacy.gov.au
For further information on the Health Records Act, go to: https://www2.health.vic.gov.au/about/legislation/health-records-act; http://www.health.vic.gov.au/hsc/downloads/hppextract.pdf
For further information on the GDPR, go to: https://ec.europa.eu/info/law-topic/data-protection_en