INFORMATION HANDLING POLICY

1. Introduction

1.1 About Bupa Medical Visa Services

In this document, 'we', 'us', 'our' and 'Bupa Medical Visa Services' refers to Bupa Australia Health Pty Ltd (ACN 003 098 655) trading as 'Bupa Medical Visa Services' and its related entities and bodies corporate. Bupa Medical Visa Services is part of the Bupa Australia Group of companies.

We provide immigration medical services and health checks on behalf of the Department of Home Affairs (the 'Department'). This means that information collected by Bupa Medical Visa Services about you will be shared with the Department, and you should contact the Department for further information on how they handle your personal information.

You can view the Department’s privacy policy on their website, homeaffairs.gov.au.

1.2 Protecting your privacy

Your privacy and maintaining the confidentiality of your personal information is important to Bupa Medical Visa Services. This document sets out how we handle your personal information, including the collection, storage, use and disclosure of your personal information, and how you can access and change your information, provide us with feedback or make a complaint.

This privacy policy will apply to customers whose personal information is collected in the course of receiving Services from us.

When handling personal information, Bupa Medical Visa Services complies with all relevant privacy legislation, including:

• the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) ("Privacy Act")
• health records legislation, including the Health Records Act 2001 (Vic), Health Records and Information Privacy Act 2002 (NSW), Health Records (Privacy and Access) Act 1997 (ACT); and
• marketing legislation, including the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

1.3 Definitions

In this policy, the following terms have the following meanings:

2. Collection of your personal information

2.1 What kinds of personal information does Bupa Medical Visa Services collect?

We collect personal information that is required by law by the Department for the purposes of your visa application. The information we collect about you may include:

• your name, address, telephone and email contact details;
• a photograph of you for identification purposes;
• your gender, date of birth and marital status;
• your country of origin and passport details;
• employment information;
• payment details;
• health information, including your current and past medical history and the results of any medical tests provided as part of the Services;
• any other sensitive information reasonably required by the Department (for example, your nationality, relevant lifestyle information, sexual preferences and practices);
• any information relating to your visa application as provided by the Department (including your HAP ID), including the types of visa you are applying for and the Services that you must undertake for your visa application.

In addition, where a customer provides us with information about another person, or where another person is designated to act on behalf of a customer, we may hold that person’s information.

2.2 Does Bupa Medical Visa Services collect sensitive information?

When we provide you with our Services, we will collect sensitive information, including your health information, as required for the assessment of your application by the Department and in accordance with the law.

2.3 How does Bupa Medical Visa Services collect personal information?

We may collect personal information from you in a range of ways, including:

• when you make a booking for Services at one of our centres;
• when you contact us in person, by phone, via mail, email or online (or when we contact you through any means);
• when we provide Services to you directly, for example, when you attend one of our centres;
• when you use our website at bupamvs.com.au (refer also to section 5, below).

We will always try to collect your personal information directly from you. However, sometimes we will need to collect your information from other persons or organisations.

This includes when we collect your personal information in the following circumstances:

• the Department provides us with information about you or your visa application; and
• your visa application relates to your family, we may collect information about you from your family member, including any person who is the primary visa applicant.

If you provide us with information about another person, you must ensure you have that person’s permission before doing so and must inform them that they have a right to access their information and that they can refer to this document for information on how we will handle their personal information.

2.4 If you do not provide us with your personal information

If you do not provide us with the personal information we reasonably request, we may be unable to provide you with the Services that you are requesting, which may affect your visa application.

3. Use and disclosure of your personal information

3.1 How does Bupa Medical Visa Services use your personal information?

We use your personal information to provide, manage and administer the Services to you and to operate an efficient and sustainable business. This includes using your information in order to:

• process your booking request;
• provide you with the Services;
• process payments;
• contact you in relation to any matter relating to the Services, for example by sending you booking confirmations and appointment reminders;
• answer your enquiries and deliver customer service to you;
• conduct quality assurance, risk management and compliance activities;
• carry out internal functions, including administration, training, accounting, audit and information technology;
• resolve complaints;
• conduct customer surveys;
• conduct market research and analysis;
• comply with laws and regulations.

3.2 Who does Bupa Medical Visa Services disclose your personal information to?

We provide our Services to you on behalf of the Department, for the purpose of your visa application. As such, we will disclose your personal information (including health information) to the Department for this purpose.

To provide, manage and administer our Services to you and to operate an efficient and sustainable business, Bupa Medical Visa Services may disclose your information to third parties, including:

• anyone engaged by us or acting on our behalf in relation to the provision of the Services or in operating our business. This includes sub-contractors, service providers and suppliers, all of whom are required to handle your personal information in accordance with privacy requirements;
• to healthcare providers to facilitate the provision of our Services to you;
• government and regulatory bodies, including the Department of Home Affairs and the Department of Health;
• any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives;
• lawyers, auditors and other advisors appointed by us or acting on our behalf;
• where we need to disclose information to enforce our legal rights;
• where disclosure is required or permitted by law, including compulsory notices from courts of law, tribunals or government agencies.

Bupa Medical Visa Services has operations across Australia and in the course of conducting our business and providing our Services to you, we handle your personal information in any State or Territory in which we operate.

3.3 Does Bupa Medical Visa Services send personal information overseas?

Some Services are provided by or on behalf of Bupa Medical Visa Services outside of Australia. This includes offshore medical assessments carried out on behalf of the Department, which will require us to handle your information in the relevant foreign jurisdiction.

3.4 How does Bupa Medical Visa Services store personal information and for how long?

We will take all reasonable steps to ensure that your personal information is stored securely and is handled confidentially at all times. This includes a range of systems and communication security measures, as well as the secure storage of hard copy documents.

In addition, access to your personal information will be restricted to those properly authorised to have access. We keep your personal information for as long as we need it to provide you with the Services and to comply with any legal requirements.

If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information except in limited circumstances permitted by law.

4. Accessing and Correcting your Personal Information

4.1 Can I access my personal information?

You can ask us for access to the information that we hold about you at any time. Simply contact us (our contact details are listed below) to make your request. We will always endeavour to meet your request for access within a reasonable time and in the manner requested by you, if it is reasonable to do so. However in some circumstances, we may be unable to give you access to certain information, including where we no longer hold or use the information.

In some cases, we may no longer have your information as we have released it to the Department. In those circumstances, you should direct your request for access to the relevant agency.

For information about accessing your information from the Department, please refer to the privacy policy on the Department’s website homeaffairs.gov.au.

If we are unable to give you access to the information you have requested, we will give you written reasons for this decision when we respond to your request and how you may complain. We may charge you a reasonable fee for access to some types of information.

4.2 Correcting your personal information

To enable us to provide you with the best possible service, it is important that the information we hold about you is accurate. We will take reasonable steps to ensure your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it.

It is your responsibility to notify us when your details change. In addition, if you believe any information we hold about you is inaccurate, incomplete or out-of-date, you should contact us. We will respond to your request within a reasonable period and take reasonable steps to amend your records.

1. Introduction

1.1 About Bupa Medical Visa Services

In this document, ‘we’, ‘us’, ‘our’ and ‘Bupa Medical Visa Services’ refers to Bupa Australia Health Pty Ltd (ACN 003 098 655) trading as ‘Bupa Medical Visa Services’ and its related entities and bodies corporate. Bupa Medical Visa Services is part of the Bupa Australia Group of companies.

We provide immigration medical services and health checks on behalf of our Clients (as defined in this policy), for example the Department of Home Affairs and other governments.

This means that information collected by Bupa Medical Visa Services about you will be shared with the Client to whom you have made your visa application, and you should contact that Client for further information on how they will handle your personal information.

If you are applying for an Australian visa through the Department of Home Affairs, you should refer to our Information Handling Policy for DHA applicants, available at bupamvs.com.au

1.2 Protecting your privacy

Your privacy and maintaining the confidentiality of your personal information is important to Bupa Medical Visa Services. This document sets out how we handle your personal information, including the collection, storage, use and disclosure of your personal information, and how you can access and change your information, provide us with feedback or make a complaint.

This policy applies to customers whose personal information is collected in the course of applying for and receiving Services from us, as part of their visa application for a Client.

When handling personal information, Bupa Medical Visa Services complies with all relevant privacy legislation, including:

• the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (“Privacy Act”)
• health records legislation, including the Health Records Act 2001 (Vic), Health Records and Information Privacy Act 2002 (NSW), Health Records (Privacy and Access) Act 1997 (ACT); and
• marketing legislation, including the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

1.3 Definitions

In this policy, the following terms have the following meanings:

2. Collection of your personal information

2.1 What kinds of personal information does Bupa Medical Visa Services collect?

We collect personal information that is required by a Client for the purposes of your visa application, and otherwise required by us in order to provide the Services to you. The information we collect about you may include:

• your name, address, telephone and email contact details;
• a photograph of you for identification purposes;
• your gender, date of birth and marital status;
• your country of origin and passport details;
• employment information;
• payment details;
• health information, including your current and past medical history and the results of any medical tests provided as part of the Services;
• any other sensitive information reasonably required by the Department (for example, your nationality, relevant lifestyle information, sexual preferences and practices);
• any information relating to your visa application as provided by the Department (including your HAP ID), including the types of visa you are applying for and the Services that you must undertake for your visa application.

In addition, where a customer provides us with information about another person, or where another person is designated to act on behalf of a customer, we may hold that person’s information.

2.2 Does Bupa Medical Visa Services collect sensitive information?

When we provide you with our Services, we will collect sensitive information, including your health information, as required for the assessment of your application by the Department and in accordance with the law.

2.3 How does Bupa Medical Visa Services collect personal information?

We may collect personal information from you in a range of ways, including:

• when you make a booking for Services at one of our centres;
• when you contact us in person, by phone, via mail, email or online (or when we contact you through any means);
• when we provide Services to you directly, for example, when you attend one of our centres;
• when you use our website at bupamvs.com.au (refer also to section 5, below).

We will always try to collect your personal information directly from you. However, sometimes we will need to collect your information from other persons or organisations.

This includes when we collect your personal information in the following circumstances:

• a Client provides us with information about you or your visa application; and
• your visa application relates to your family, we may collect information about you from your family member, including any person who is the primary visa applicant.

If you provide us with information about another person, you must ensure you have that person’s permission before doing so and must inform them that they have a right to access their information and that they can refer to this document for information on how we will handle their personal information.

2.4 If you do not provide us with your personal information

If you do not provide us with the personal information we reasonably request, we may be unable to provide you with the Services that you are requesting, which may affect your visa application.

3. Use and disclosure of your personal information

3.1 How does Bupa Medical Visa Services use your personal information?

We use your personal information to provide, manage and administer the Services to you and to operate an efficient and sustainable business. This includes using your information in order to:

• process your booking request;
• provide you with the Services;
• process payments;
• contact you in relation to any matter relating to the Services, for example by sending you booking confirmations and appointment reminders;
• answer your enquiries and deliver customer service to you;
• conduct quality assurance, risk management and compliance activities;
• carry out internal functions, including administration, training, accounting, audit and information technology;
• resolve complaints;
• conduct customer surveys;
• conduct market research and analysis;
• comply with laws and regulations.

3.2 Who does Bupa Medical Visa Services disclose your personal information to?

We provide our Services to you on behalf of our Clients, for the purpose of your visa application with the relevant Client. As such, we will disclose your personal information (including health information) to the relevant Client for this purpose, and any related purposes.

To provide, manage and administer our Services to you and to operate an efficient and sustainable business, Bupa Medical Visa Services may disclose your information to third parties, including:

• anyone engaged by us or acting on our behalf in relation to the provision of the Services or in operating our business. This includes sub-contractors, service providers and suppliers, all of whom are required to handle your personal information in accordance with privacy requirements;
• to healthcare providers to facilitate the provision of our Services to you;
• government and regulatory bodies;
• any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives;
• lawyers, auditors and other advisors appointed by us or acting on our behalf;
• where we need to disclose information to enforce our legal rights;
• where disclosure is required or permitted by law, including compulsory notices from courts of law, tribunals or government agencies.

Bupa Medical Visa Services has operations across Australia and in the course of conducting our business and providing our Services to you, we handle your personal information in any State or Territory in which we operate.

3.3 Does Bupa Medical Visa Services send personal information overseas?

If the Client to whom you have made your visa application is located outside of Australia, we may send your personal information to that Client in the relevant foreign jurisdiction.

3.4 How does Bupa Medical Visa Services store personal information and for how long?

We will take all reasonable steps to ensure that your personal information is stored securely and is handled confidentially at all times. This includes a range of systems and communication security measures, as well as the secure storage of hard copy documents.

In addition, access to your personal information will be restricted to those properly authorised to have access. We keep your personal information for as long as we need it to provide you with the Services and to comply with any legal requirements.

If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information except in limited circumstances permitted by law.

4. Accessing and Correcting your Personal Information

4.1 Can I access my personal information?

You can ask us for access to the information that we hold about you at any time. Simply contact us (our contact details are listed below) to make your request. We will always endeavour to meet your request for access within a reasonable time and in the manner requested by you, if it is reasonable to do so. However in some circumstances, we may be unable to give you access to certain information, including where we no longer hold or use the information.

In some cases, we may have released your information to the Client to whom you have made your visa application, and in those circumstances you should direct your request for access to that Client.

If we are unable to give you access to the information you have requested, we will give you written reasons for this decision when we respond to your request and how you may complain. We may charge you a reasonable fee for access to some types of information.

4.2 Correcting your personal information

To enable us to provide you with the best possible service, it is important that the information we hold about you is accurate. We will take reasonable steps to ensure your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it.

It is your responsibility to notify us when your details change. In addition, if you believe any information we hold about you is inaccurate, incomplete or out-of-date, you should contact us. We will respond to your request within a reasonable period and take reasonable steps to amend your records.

5. Your privacy online

5.1 Online data collection and use

When you access our website, anonymous technical information may be collected about user activities on the website. This may include information such as the type of browser used to access the website and the pages visited.

This information is used by Bupa Medical Visa Services to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details.

For more information, please refer to the website terms and conditions.

5.2 Cookies

A 'cookie' is a small text file placed on your computer by a web server when you access a website. Cookies are frequently used on websites. Cookies in themselves do not identify the individual user, just the computer used. We use cookies to collect data to help us determine which pages are most popular, peak usage times and other information that helps us make our websites easier and more efficient for you to use. When you visit our websites we may set a cookie on your machine so that when you next visit our websites it links to your personal information that is stored on our system.

You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. For example, you can set your browser to notify you when you receive a cookie or to reject cookies. However, if you decide not to display cookies, then you may not be able to gain access to all the content and facilities of this website.

6. Contacting Bupa Medical Visa Services

If you have any questions, feedback about this policy or how your information is handled by Bupa Medical Visa Services, or would like to make a complaint, you can contact us at any time by emailing us at enquiries@bupamvs.com.au.

If you are not happy with our response, or if you have a complaint that you do not feel has been resolved, you are able to seek advice from the Office of the Australian Information Commissioner by calling 1300 363 992 or visiting oaic.gov.au.