This Privacy Policy covers the HCF group of companies (We or HCF Group), being The Hospitals Contribution Fund of Australia Ltd, HCF Life Insurance Company Pty Ltd, Manchester Unity Australia Ltd, HCF Research Foundation Ltd, Railway & Transport Health Fund Ltd, and Transport Health Pty Ltd, but excluding Flip Insurance Pty Ltd, which is covered by its own privacy policy.
We are committed to protecting your privacy and will handle your personal information in accordance with this Privacy Policy, the HCF Data Principles set out below, and our obligations under the Privacy Act 1988 (Cth) (Privacy Act) and other relevant State legislation dealing with privacy and health records. We also comply with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth), as amended from time to time. If you are an Overseas Visitor Health Cover (OVHC) member in the European Union, the processing of your personal information will also be subject to the General Data Protection Regulation (2016/679) (GDPR).
HCF DATA PRINCIPLES
- Your trust is of the utmost importance to us. HCF considers your personal information to be very important and is committed to protecting your privacy.
- Transparency is important. We are open and honest about the way we use your personal information, as set out in this Privacy Policy or as otherwise disclosed to you from time to time.
- Security is front of mind. Safeguarding your personal information against potential cyber security threats is our priority. We continuously invest in comprehensive cyber capabilities to protect your information. We monitor our systems for unusual activity around the clock and regularly conduct robust security testing. We have implemented governance processes and controls to manage cyber risks to ensure the protection and security of personal information you share with us.
WHAT SORT OF PERSONAL INFORMATION DO WE USUALLY COLLECT?
Personal information is broadly, any information about or relating to you where you are identified by us, or can be identified. Sensitive information is a special subset of personal information which includes your health information.
For the purposes of this Privacy Policy, any references to “personal information” includes “sensitive information”.
The personal information that we may collect about you includes:
1. Information relevant to health, life, travel and pet insurance cover, dental and optical services and other related products and services such as your:
- name, residential, postal and email addresses, phone and/or mobile number and other relevant contact details
- family and marital status, date of birth, gender, ethnicity and employment details
- bank account and credit card details and other relevant financial information
- pet details, age, breed and veterinary history
- marketing preferences
- government related identifiers such as your Medicare number and Australian Tax Office file number
- claims information and our analysis of this data, which includes your health information, expenses paid and claimed, the health care providers who treated you and the treatment you receiv
- sensitive information, for example your:
- health records, medical history including but not limited to any illnesses, medical conditions, genetic testing results and health services provided to you
- usage of and data supplied to mobile applications and materials delivered on-line.
2. Additional information in relation to life insurance cover and services, such as your:
- income
- insurance history
- criminal history (for example, when assessing a life insurance claim).
3. Additional information collected from you by phone, our website or mobile applications such as your:
- height
- weight
- blood pressure
- cholesterol levels
- lifestyle (for example, recreational activities, drug and alcohol use, travel)
- mental health status
- smoking history
- occupation (including a description of your duties)
- medical history
- exercise information
- health questionnaire information, including any pre-existing conditions
- family history, including any pre-existing conditions and genetic testing results
- residency details.
4. Additional information in relation to your proposed employment with any HCF Group company such as your:
- previous employment history
- Australian tax file number.
5. In respect of providers to the HCF Group, information such as your:
- name, practice and/or business name, practice, postal and email addresses, phone, fax and/or mobile number
- government related identifiers such as your Medicare provider number, Australian Health Practitioner Regulation Agency number, Australian Company Number and/or Australian Business Number
- claims information for your professional services, your charges and expenses, including out-of-pocket (gap) costs members pay you, and treatments performed, that you and/or our members provide to us from time to time including benefits payable, and results from our analysis of this data, such as out-of-pocket (gap) expenses
- whether or not you are registered for and use HCF’s medical gap arrangements
- feedback from our members on the service that you provide
- feedback from other providers, like hospitals, about the service that you provide in association with them from time to time
- practice/business bank account details.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We may collect the personal information from you (or persons authorised by you):
- in person, via mail, email, mobile applications, our website (including embedded chatbots) or other internet applications including social media (e.g. Facebook, Twitter)
- by phone
- from forms, claims and other correspondence
- while you are using services provided by HCF.
Sometimes we may need to collect personal information from third parties such as:
- health service providers (such as hospitals, hospital-substitute treatment providers, general practitioners and optometrists and other allied health providers) and other service providers (such as providers of health and well-being services and electronic claiming software providers), recruitment agencies and marketing agencies)
- another insurer or re-insurer
- brokers, agents or referrers
- the policyholder, if you are a partner, or a dependent (for example, a child or a student) who is insured under the policy
- government agencies
- your employer or advisers
- immigration or other agents
- financial or educational institutions
- if you are a provider, from the Department of Human Services, government regulatory agencies, electronic claiming software providers and our members
- research companies that collect feedback from members on behalf of us.
WHAT HAPPENS IF YOU DO NOT GIVE US THIS INFORMATION OR DO NOT WISH US TO USE OR DISCLOSE IT FOR A PURPOSE?
It is your right not to give us any information and not to identify yourself to us (interact anonymously or using a pseudonym) or to tell us that you do not wish us to use or disclose your personal information for a particular purpose or in a particular way. However, if you choose not to give us the personal information we request, or do not identify yourself to us or ask us not to use or disclose your information for a particular purpose, we may not be able to:
- Consider your application for insurance.
- Administer your policy.
- Enter into a contract to provide you with our product or service or provide you with relevant services.
- Manage or pay any claims you make under your policy.
- Provide you with relevant insurance, health, dental or optical services.
- Consider your recognition as a provider or register you and consequently pay our. members for any services you provide in accordance with our arrangements or any other obligations.
HOW DO WE USE YOUR PERSONAL INFORMATION?
1. INSURANCE, HEALTH, DENTAL, AND OPTICAL SERVICES
We use your personal information we collect, under our contract with you, to provide products and services to you (some of which may be provided by third party providers on our behalf) including insurance, health, dental and optical services, recording your treatment, managing our relationship with you, to assess your eligibility to receive a benefit, and to administer, process and audit claims.
We may also use your personal information for related purposes which you would reasonably expect for our legitimate interest in complying with applicable laws, assessing your insurance, health and related lifestyle needs, developing products and services that may better serve those needs, assessing your possible interest in any such products or services and telling you about these, telling you about and otherwise publishing details of provider charges and out-of-pocket (gap) costs our members may have incurred, conducting risk forecasting functions (with your consent), improving our service delivery, asking for your feedback and opinions about services, benefits or product offerings, resolving any legal and/or commercial complaints or issues and performing other functions and activities relating to the business of the HCF Group.
2. DEVELOPING PROGRAMS OR SERVICES FOR THE BENEFIT OF OUR MEMBERS
From the personal information that we collect from our members, in providing health insurance and associated services, we are able to develop programs and services that are intended for the benefit of members.
In some instances, participation in these programs or services is offered to all members. In other instances, the invitation to participate is targeted at specific members who are most likely to benefit from participation in the programs or services.
We may use personal information we have collected to identify members who may benefit from a program or service, and inform members of the availability of the program or service, for example, via telephone, the HCF member app, the HCF website or through our publications or advertisements, and invite them to participate in the program or service.
In relation to all programs and services:
- participation is entirely voluntary
- participation or non-participation will not affect your benefit entitlements or premiums or your client relationship in any way
- if you do not wish to participate in a program after you are invited to join, you may decline the invitation or may, at any time, withdraw from any program in which you may have been enrolled.
PROVIDERS
If you are a provider (such as a health provider), we collect and use information about the provider, including their charges and health outcomes, that may include personal information, to administer claims, deal with complaints, obtain feedback on members’ experience or the performance of providers, update members and understand costs including out-of-pocket (gap) costs. We may publish some, or all, of this information on our website or communicate it to our members in other ways, as a service to our members, including by sharing it through other websites we partner with.
OTHER INDIVIDUALS
We may also collect and use or disclose personal information of other individuals other than members or providers, such as guardians or other authorised individuals or carers, representatives of third party service providers, HCF officers and directors, prospective employees and members of the public, in order to provide our products and services, administer our business, manage job applications (including conducting background checks), comply with applicable laws and provide various promotional offers.
REQUESTS TO STOP DIRECT MARKETING FROM US
We may communicate with you by phone, electronically or mail, about our current and new products and services, including participation in any programs we develop.
You may ask us at any time to stop sending you direct marketing information or being contacted by or on our behalf, in a particular way or at all. You can do this by: