Whitecoat Operating Pty Ltd [ACN 616 486 090] (Whitecoat, we, our, us) provides a range of products and services in the health industry, including operating a website which allows individuals to search, compare and select healthcare providers based on reviews provided by individuals who have received a billable service from a healthcare provider (the Whitecoat Website).
Additionally, Whitecoat provides these services, along with other services, through an application (the Whitecoat Application), which is available on most mobile devices.
An individual who accesses or uses the Whitecoat website in any way, including to search for, compare or select a Healthcare Provider.
An individual who has:
been published on the Whitecoat website as a provider of healthcare services registered a profile with Whitecoat; or subscribed to a service provided by Whitecoat.
An individual who has:
a. provided us with feedback on a Healthcare Provider that they have recently received a billable service from; or b. provided us with feedback on a Healthcare Provider; or c. set up a user account on the Whitecoat Application.
2. What information does Whitecoat collect and hold?
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
Sensitive information is a subset of personal information and is generally afforded a higher level of privacy protection than other personal information. Among other things, sensitive information includes information about your membership of a professional association or your health information.
The personal information we collect and hold will depend on a range of circumstances, including who you are and what products or services you are looking to access or use.
Generally, we will collect and hold any personal information about you:
that is publicly available; that you provide or that can be captured automatically when you access or use the Whitecoat website, the Whitecoat application or any other service provided by Whitecoat; or that you provide to us in any other way, including in the course of applying for employment with us.
If you are a Public User, the personal information we collect and hold about you may also include any information about you that is:
– publicly available; or – that you provide to us in any other way.
If you are a Healthcare Provider, the personal information we collect and hold about you may also include any information about you that is:
provided in the course of you subscribing to one of our services, including:
- your user name and password;
- your identification information, including your first and last name, age, date of birth, gender, and any associated proof of identification (such as your driver’s licence or passport details); your contact information, including your phone numbers and your email and postal addresses;
- details of the healthcare services you provide (such as the types of services provided and the cost or wait time for those services);
- details of any professional memberships, registrations or qualifications that hold or maintain;
- government related identifiers (such as your Medicare provider number, or your company or business number) or registration details (for government rebates);
- financial information (such as your banking or payment information, credit/debit card number, cardholder name and card expiration date); and – any other background or additional information you wish to add to your Whitecoat profile.
provided to us by Whitecoat Users who have recently received a billable service from you; and any other information that you provide to us in any other way.
If you are a Whitecoat User, the personal information we collect and hold about you may also include any information about you that is:
provided in the course of you registering and maintaining an account with us, including:
- your user name and password;
- your identification information, including your first and last name, age, date of birth, gender and any associated proof of identification (such as your driver’s licence or passport details);
- your contact information, including your phone numbers, your email and your physical and/or postal address(es);
- your family members’ names (for the purpose of identifying life covered for private health insurance and Medicare);
- government related identifiers (such as your Medicare number) or registration details (for government rebates);
- details of your pension or other health care cards, including private health insurance cards;
- financial information (such as your banking or payment information, credit/debit card number, cardholder name and card expiration date); and
- any other background or additional information you wish to add to your Whitecoat profile
provided when you provide feedback (including ratings and comments) in relation to a Healthcare Provider from which you have received healthcare services; sensitive information about your health records, medical history, health insurance fund memberships, claims and health services that you have previously received; and any other information that you provide to us in any other way.
3. Dealing with us anonymously or by using a pseudonym
Where practicable, we will allow you to access and use our products or services anonymously or by using a pseudonym, however, in most cases, if you choose not to provide us with your personal information, or the information you provide us is not accurate or complete:
- we may not be able to provide some or all of our products or services to you (such as booking services, the ability to provide feedback on a Healthcare Provider or access to parts of the Whitecoat Application);
- we may not be able to effectively respond to your queries or concerns, or a request to access or correct any information we hold about you; and
- you may not be able to enjoy all of the benefits of being a registered Whitecoat User.
4. How does Whitecoat collect your personal information?
Where practicable, we will generally try and collect personal information directly from you:
- when you interact with us in person, via email or by phone (in which case we may make a call recording of that interaction);
- when you interact with us electronically or online through the Whitecoat website, the Whitecoat application or on social media;
- in the course of you subscribing to one of our services as a Healthcare Provider; or
- in the course of you registering and maintaining a Whitecoat User account with us.
In addition, we may periodically obtain information about you from third parties, including:
- in the case of a Healthcare Provider, from your past or present employer or another Healthcare Provider;
- our affiliated entities, joint venture partners, licensees, business partners and other third-party sources (including professional associations, industry bodies, state registration boards and government agencies);
- organisations who provide services to Whitecoat (such as administration, membership management, marketing or research services);
- third party websites, including websites which operate booking services which can be accessed through the Whitecoat Website or the Whitecoat Application;
- in the case of a Healthcare Provider, from Whitecoat Users in the form of feedback (including ratings and comments); or
- other individuals who are Whitecoat Users (for example, if a family member books an appointment in your name or includes you under their Whitecoat User account).
Information that we collect automatically
When you access or use the Whitecoat website or the Whitecoat application, we will automatically collect certain information from your computer or mobile device, including:
- details of the website that referred or otherwise linked you to the Whitecoat website;
- session data (such as the date and time you visited the Whitecoat website, time spent, content viewed, pages visited and any searches you made during your session);
- your IP or server address or domain name; and
- the type of device, operating system and internet browser you used.
Typically, the information above will be tracked and collected using ‘cookies’, which are small text files placed on your computer for later retrieval by our web server. Cookies do not alter the operation of your computer or mobile device in any way and are frequently used on websites.
You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser, however if you disable cookies on your computer, this may result in you being unable to use the Whitecoat website to the fullest and optimum extent.
Generally, the information we collect through cookies will be aggregated and not attributed to individual users.
Third party booking services
In some cases, when you select ‘Make an Appointment’ on the Whitecoat website or through the Whitecoat application, you may be transferred to a third party booking service for the purpose booking an appointment with a Healthcare Provider (Third-Party Booking Service).
In some cases, these Third-Party Booking Services may provide us with reports on the number of bookings started and/or completed using their online booking service. These reports will generally be de-identified and will not contain personal information about Public Users or Whitecoat Users, however, they may contain some personal information about Healthcare Providers.
5. How does Whitecoat hold your personal information?
We will take such steps as are reasonable in the circumstances to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of these steps may include employing the following security measures:
- physical measures (such as restricting access to our premises and securely destroying paper-based files);
- technical measures (such as employing appropriate firewalls and intrusion prevention systems on our systems and encrypting the data we collect and transmit); and
- administrative and organisational measures (such as restricting the access and use of personal information by Whitecoat employees).
Retention of personal information
Generally, we will retain your personal information until we no longer need it for any purpose that is permitted by the Privacy Act or to comply with an Australian law or a court/tribunal order. In that case, we will take such steps as are reasonable in the circumstances to destroy or de-identify the information.
6. Why does Whitecoat collect, hold, use and disclose your personal information?
Generally, we collect, hold, use and disclose personal information for the following purposes:
- to contact you and otherwise manage our ongoing relationship with you;
- to provide, promote and market any of our products or services from time to time;
- to provide and operate the Whitecoat website and the Whitecoat application, which may involve:
- publishing certain information about Healthcare Providers to allow individuals to search, compare and select Healthcare Providers;
- contacting Whitecoat Users to ask them to provide feedback about a Healthcare Provider that they have recently received a billable service from;
- collating and moderating comments and feedback provided by Whitecoat Users in order to display that feedback anonymously;
- contacting Healthcare Providers and Whitecoat Users in relation to our products or services;
- to provide any online booking services that are made available through the Whitecoat website or the Whitecoat application;
- to contact you for the purpose of direct marketing in relation to our products or services, or the products or services of our affiliated entities, joint venture partners, business partners or other third-parties (unless you have unsubscribed);
- to perform administrative functions and activities in relation to our products or services;
- to improve our products or services, or to develop new products or services, which may involve:
- performing analytics on information that we collect automatically;
- disclosing information of a de-identified nature to third party service providers (for example, to facilitate market research);
- to respond to inquiries about the Whitecoat website, the Whitecoat application or any other products or services that we provide from time to time;
- to contact Healthcare Providers in order to:
- explain the products or services that Whitecoat provides;
- explain how they may control the information displayed on the Whitecoat website;
- advise them they can opt-in if their address information is not publicly available;
- tell them about the booking services available from Whitecoat or other Third Party Booking Services;
- to refer a Healthcare Provider to a Third Party Booking Service;
- to assess or process an application for employment with us;
- to comply with any applicable laws or industry regulations.
Where practicable, we will collect, hold, use and disclose your personal information for the purposes described above on a de-identified basis.
- you authorise us to do so;
- your safety or the safety of others in the community is at risk; or
- we are required to or permitted by law or industry regulation to do so.
7. How can you gain access to and correct your personal information?
How can you access your personal information?
If you would like to request access to the personal information we hold about you, you can contact us on 0488 894 483 or email us at PrivacyOfficer@whitecoat.com.au.
In most cases, we will need to verify your identity before we can provide you with access. There may also be circumstances in which we are not required to provide you with access to all or part of the personal information we hold about you.
In particular, for Healthcare Providers:
- if you are a mobile Healthcare Provider working out of your personal home, you may have us remove your practicing location provided that it is not publicly available;
- you may also have us remove your practicing location for safety or other compelling reasons; and
- if you have registered a profile with Whitecoat, you can choose to hide all comments about you at any time through your profile preferences.
How can you correct your personal information?
The accuracy and quality of your personal information is important to us. If you would like to request that we correct any personal information we hold about you, or advise us of any changes to your contact details and other information, you can contact us on 0488 894 483 or email us at PrivacyOfficer@whitecoat.com.au.
We will take such steps as are reasonable in the circumstances to ensure that the personal information that we collect, hold, use and disclose is accurate, up-to-date and complete.
In most cases, we will need to verify your identity before we can correct the information we hold about you. There may also be circumstances in which we are not required to correct the personal information we hold about you.
Access and correction through the Whitecoat profile
If you have registered a profile with Whitecoat as a Healthcare Provider or a Whitecoat User you may be able to access and correct some of your personal information when you log on to your Whitecoat profile.
Moderating comments and rating about Healthcare Providers
We endeavour to keep comments and ratings about Healthcare Providers as accurate and informative as possible. For more information, please see our Moderation Guidelines.
8. How can you contact us or make a complaint?
If you have a query in relation to how we collect, use, hold, disclose or otherwise handle or manage your personal information, you can contact our Privacy Officer on 0488 894 483 or email us at PrivacyOfficer@whitecoat.com.au.
If we are unable to satisfactorily resolve your concerns and you wish to lodge a complaint, you can contact the Office of the Australian Information Commissioner (OIAC) which has the power to investigate the matter and make a determination.
You can also contact the OAIC or visit the OAIC’s website at https://www.oaic.gov.au/ for further information about the Privacy Laws and the application of the Privacy Act.