1. About this Privacy Policy

Whitecoat Operating Pty Ltd ACN [616 486 090] (Whitecoat, we, our, us) provides a range of products and services in the health space, 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).

In the future, Whitecoat intends to provide these services, along with other services, through an application (the Whitecoat Application) which will be available on most mobile devices.

This privacy policy (Privacy Policy) explains how we collect, use, hold, disclose or otherwise handle or manage information about you. It also explains the ways in which you can contact us to access or correct the information we hold about you or make a complaint.

This Privacy Policy applies to the following types of individuals (in each case (you, your):

Public User

An individual who accesses or uses the Whitecoat website in any way, including to search for, compare or select a Healthcare Provider.

Healthcare Providers

An individual who has:

  1. been published on the Whitecoat website as a provider of healthcare services
  2. registered a profile with Whitecoat; or
  3. subscribed to a service provided by Whitecoat.

Whitecoat User

An individual who has:

  1. provided us with feedback on a Healthcare Provider that they have recently received a billable service from; or
  2. provided us with feedback on a Healthcare Provider; or
  3. set up a user account on the Whitecoat Website or the Whitecoat Application.

By accessing and using the Whitecoat Website or downloading the Whitecoat Application, you acknowledge that you have read understood this Privacy Policy and the information collection and handling practices outlined in it.

This Privacy Policy is available, free of charge, on our website or on request using the contact details provided: PrivacyOfficer@whitecoat.com.au.

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.

In this privacy policy, any references to personal information should also be read as references to sensitive information.

General Collections

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.

Public user

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.

Healthcare Providers

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 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.

Whitecoat User

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 and your email and postal addresses;
    • your family and marital status;
    • your employment status;
    • government related identifiers (such as your Medicare number) or registration details (for government rebates);
    • details of your pension or other health care cards;
    • financial information (such as your banking or payment information, credit 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?

Were 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, 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.

Cookies

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 transferred to a third party booking service for the purpose booking an appointment with a Healthcare Provider (Third Party Booking Service).

In those circumstances, your personal information will be collected by that Third Party Booking Service and you refer to the privacy policy for that Third Party Booking Service for information on how they will collect, hold, use and disclose your personal information.

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?

Frome time to time, we may hold your personal information in any combination of data storage facilities, cloud computing facilities or paper based files, which may be operated or held by us or by third party service providers under a contractual arrangement. Where possible, we will seek to ensure that those service providers are bound by obligations of privacy and confidentiality that are similar to those set out in this Privacy Policy.

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 to third party service providers (for example, to facilitate market research);
  • to respond to inquiries about our 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 facilitate our affiliated entities, joint venture partners, business partners or other third-parties contacting you, including for the purpose of direct marketing to you (unless you have unsubscribed);
  • to assess or process an application for employment with us;
  • to comply with any applicable laws;

Where practicable, we will collect, hold, use and disclose your personal information for the purposes described above on a de-identified basis.

Generally, we may disclose your personal information to persons or organisations such as our affiliated entities, joint venture partners, business partners, service providers, professional associations, industry bodies, professional advisors, state registration boards, regulatory bodies, government agencies or other third-parties in relation to any of the purposes described above.

We will not disclose your personal information to anyone for purposes other than those set out above or as otherwise set out in this Privacy Policy unless:

  • 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 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?

Contacting us

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.

Complaints

If you feel that your privacy has not been respected, or we have not conducted ourselves in accordance with this Privacy Policy, please contact our Privacy Officer on 0488 894 483 or email us at PrivacyOfficer@whitecoat.com.au. Where we have received a complaint from you, we will investigate that complaint and to respond as soon as possible. To do so, we may need to ask you for additional information. Generally, we will use our best endeavours to resolve your complaint promptly and to your satisfaction.

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.

9. Updates to this Privacy Policy

This Privacy Policy was last updated on 10/1/17 and is effective from that date.

We may make changes to this Privacy Policy from time to time without prior notice to you, in which case we will make an updated copy of the Privacy Policy available through the Whitecoat Website or the Whitecoat Application.