This privacy policy covers the HCF group of companies, being The Hospitals Contribution Fund of Australia Limited, HCF Life Insurance Company Pty Ltd, Manchester Unity Australia Ltd, Treytell Pty Limited, HCF Pty Limited and HCF Nominees Pty Ltd.

We are committed to protecting your privacy and will handle your personal information in accordance with this Privacy Policy and in accordance with our obligations under the Privacy Act 1988 (Cth); 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.

What sort of personal information do we collect?

Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or not, or whether it is recorded in a hard or electronic or any other material form or not.

Sensitive information is a subset of personal information which includes your health information.

For the purposes of this privacy policy, any references to “personal information” include “sensitive information”.

The personal information that we may collect about you includes:

  1. information relevant to health, life, travel and pet insurance cover and health, dental and retirement and aged care services such as:
    • your name, residential, postal and email addresses, telephone and/ or mobile number and other relevant contact details;
    • your family and marital status, date of birth, gender and employment details;
    • your bank account and credit card details and other relevant financial information;
    • government related identifiers such as your Medicare number and Australian Tax Office file number; and
    • sensitive information, for example:
      - your health records, medical history and claims and health services provided to you;
      - your membership of political, profession or trade unions/ associations; and
      - your criminal history.
    In respect of health cover, the information collected cannot be used in determining your rate of health insurance premium, except in accordance with the Private Health Insurance Act 2007 (Cth);
  2. additional information in relation to life insurance cover and services, for example, your income and insurance history;
  3. additional information in relation to retirement and aged care services such as:
    • the name and contact details of nominated persons that we are authorised to deal with on your behalf; and
    • sensitive information, for example:
      - your health and medical history and wishes;
      - your racial or ethnic origin;
      - your religious beliefs or affiliations; and
      - your sexual preferences or practices; and
  4. in respect of providers to the HCF group of companies, information such as:
    • your name, practice and/or business name, practice, postal and email addresses, telephone, fax and/or mobile number;
    • government related identifiers such as your Medicare provider number, Australian Company Number and/or Australian Business Number;
    • claims information that you and/or our members provide to us from time to time;
    • your feedback on your services that our members provide us with from time to time; and
    • your bank account details.

How do we collect your personal information?

We collect the personal information you give us (or that persons authorised by you give us on your behalf):

  • electronically including through our website;
  • during phone calls;
  • while visiting our branches and HCF Dental Centres (where we may also use surveillance cameras in public areas);
  • while delivering and administering services at our retirement or aged care facilities and HCF Dental Centres; or
  • from forms, claims and other correspondence, in writing or electronically either completed by you or on your behalf by a guardian or parent if you are under 16 or by another authorised person.

Sometimes we may need to collect personal information from third parties such as:

  • health service providers (such as hospitals, general practitioners and allied health providers) and electronic claiming software providers;
  • another health insurer or re-insurer;
  • brokers or agents;
  • the policy holder, if you are a member or a dependant;
  • government agencies;
  • your employer or advisers;
  • financial or educational institutions; or
  • if you are a provider, from Medicare Australia, electronic claiming software providers and our members.

What happens if you do not give us this information?

It is your right not to give us any information and not to identify yourself to us. However, if you choose not to give us the personal information we request or do not wish to identify yourself to us, we may not be able to:

  1. consider your application for insurance;
  2. administer your policy;
  3. provide you with relevant services;
  4. manage or pay any claims you make under your policy;
  5. provide you with relevant retirement and aged care services or dental treatment; or
  6. consider your recognition as a provider and consequently pay our members for any services you provide.

How do we use your personal information?

  1. Insurance, Health Services and Retirement and Aged Care Services

    Your personal information is collected so that we can comply with laws, manage our relationship with you, record your treatment, provide products and services to you (some of which may be provided by third party providers on our behalf) including insurance and retirement and aged care services and dental treatments, administer, process and audit claims, assess your insurance, health and related lifestyle needs, develop products and services that may better serve those needs, assess your possible interest in any such products or services and tell you about these, resolve any legal and/or commercial complaints or issues, and perform other functions and activities relating to the business of the HCF group of companies.
  2. Developing programs for the benefit of members with health insurance

    From the personal information that we collect from our members in providing health insurance, we are able to develop programs that are intended for the benefit of members. In some instances, participation in these programs 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.

    Where the program is designed to assist members generally, we will inform members via a general communication of the availability of the program, for example, via the web site or through our publications or advertisements, and invite them to participate in the program by opting into the program.

    Where the program is designed to assist members with specific illnesses and conditions we will offer those members the choice of opting in to participate in the program.
    In relation to all programs:
    • Participation is entirely voluntary;
    • Participation or non-participation will not affect your claims benefits or premiums or your client relationship in any way; and
    • 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 and other individuals

If you are a provider (such as a health provider or vet), we collect and use information about providers and their charges that may include personal information to administer claims, deal with complaints and update members. 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.

We may also collect and use or disclose personal information of other individuals, such as guardians or other authorised individuals or carers, representatives of third party service providers, HCF officers and directors and prospective employees, in order to provide our products and services, administer our business, manage job applications and comply with applicable laws.

Requests to stop direct marketing from us

We will communicate with you (e.g. by telephone, 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 simply emailing us at service@hcf.com.au or by calling 13 13 34 and advising us of your request.

Do we disclose information to third parties?

We may share or disclose your personal information to third parties or individuals, some of which may be located overseas, including:

  1. to the policyholder, if you are a dependant or another member (e.g. partner or children) on the policy, for the purposes of your HCF membership. Our contract with the policyholder requires us to have full and free communication with the policyholder on all aspects of the policy, including the benefits claimed by any member under the policy;
  2. to organisations that deliver services on our behalf or to us, such as third parties that we contract to assess or process claims, administer programs that we develop for the benefit of members, research companies contracted by us (to ask your opinions on improving any of HCF group of companies’ service, benefits or product offerings) and mailing houses;
  3. other service providers, for example, our advisors;
  4. between companies within the HCF group of companies;
  5. government agencies including law enforcement agencies in cases of suspected fraud;
  6. health service providers (where it is used to improve their ability to provide you with health services);
  7. other insurers or reinsurers including other health insurers where you have moved your insurance to or from HCF; and
  8. where disclosure is otherwise authorised or required by or under an Australian law or court/ tribunal order.
  9. We do not normally give personal information about you to anyone who is not on your membership. You will need to give us written permission if you want someone who is not covered by your membership, such as a friend or carer, to deal with us on your behalf.

Overseas disclosures

Some organisations to which we disclose personal information may be located outside Australia. We will not disclose your personal information to an overseas recipient without taking such steps as are reasonable in the circumstances to ensure that the overseas recipient will not breach the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

How is information from our websites collected and used?

We collect information when you:

  • complete an online form;
  • give us your email address; or
  • access and use any of our services through our website.

We collect data from our website to help us understand which are the most popular pages and when the peak usage times are, along with other information that helps us improve the content and make the navigation easier.

When you visit our website, it will send a cookie to your computer. This is a small piece of information stored on your hard drive which tells us that your computer has accessed our website. The cookie will not be able to identify you. If you do not want to use cookies, you can set your browser to reject them.

HCF uses remarketing with Google Analytics to advertise online. Thirdparty vendors, including Google, show HCF advertisements on website sites across the Internet. HCF and third-party vendors, including Google, use firstparty cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on someone’s past visits to the HCF website.

What about linked websites?

We provide links to third party sites. Since we do not control these websites, we encourage you to review the privacy policies posted on these third party sites. We are not responsible for any practices on linked websites that might breach your privacy.

Storage and security of your personal information

We have put in place safeguards to protect the personal information we hold from misuse, interference and loss, and unauthorised access, modification or disclosure. We destroy or de-identify personal information we no longer need, wherever possible.

In the case of clinical information collected in our HCF operated health service providers, such as our Dental Centres, your information will be held for at least seven years from the last time a health service was provided, in accordance with Health Records legislation. If someone under the age of 18 used the health service, the information will be held at least until that person has turned 25.

How to access or correct your personal information

We take reasonable steps to ensure that the information we hold about you is accurate, up-to-date, complete and relevant when we use it or disclose it. You should contact us if you think your personal information is wrong. If you need to update your contact details, you can do so through the members’ section of our website at hcf.com.au.

If you have a question about this Privacy Policy or want to access or otherwise correct your personal information you can contact us:

  • at any HCF branch;
  • phone 13 13 34;
  • write to Customer Service, The Hospitals Contribution Fund of Australia Limited, 403 George Street, Sydney, NSW 2000; or
  • email service@hcf.com.au

A request for access needs to include a full description of the personal information requested. If making a request in person, you will be asked for two forms of identification, one of which must have a photograph on it. If you request information over the phone, we will ask you identity-related questions so we can verify you. Your request for access to your personal information will be documented, as will details of the request and the identity of the HCF employee who gave it to you.

If you believe that the information we hold about you is inaccurate, out-ofdate, incomplete, irrelevant or misleading, you can request its correction. If we are satisfied that the information needs to be corrected, we will take reasonable steps to ensure that information is corrected and notify you of the correction. However there may be circumstances in which we may have to refuse a request for correction. In such a case you can request that we associate a statement with that personal information that you made a request for correction.

You will not be charged for accessing or correcting your information. We might have to charge for the reasonable cost of processing your access request, including photocopying, copying of radiographs, supplying written reports, administration and postage.

How we will respond to your request

We will acknowledge receipt of your request within 2 working days of receiving your request. We will do our best to deal with your request within 5 working days. If we cannot help with your request, you will receive a written explanation as to why and details of what you can do to take the matter further if you are not satisfied with our response.

Do you want to contact us anonymously?

You can certainly contact us anonymously. If you choose not to be identified, however, we are limited in our ability to insure you, pay your claims or offer you services.

Can you complain about a breach of privacy?

If you want to complain about a privacy breach, you can visit an HCF branch, call 13 13 34 or email service@hcf.com.au. We will do our best to resolve your complaint as quickly as possible.

If you are not satisfied with the result of your complaint to us, you can refer your complaint to the:

Office of the Australian Information Commissioner
Phone: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001
Online form: oaic.gov.au (Privacy Complaint Form)

Need further information?

For more information about privacy in general, you can visit the Office of the Australian Information Commissioner’s website at oaic.gov.au.

Updating our Privacy Policy

We may review, amend or revise our Privacy Policy and the way we handle personal information from time to time.

We will post the updated Privacy Policy on our website at hcf.com.au and its terms will take effect from the date of posting.

Last updated: February 2014


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