Privacy Policy

SMITH STREET MEDICAL CENTRE – PRIVACY POLICY

Mutual Growth Partners Pty Ltd (ACN 678 685 919) ATF GPcare Trust (ABN 54 156 377 549) (we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our website, in person, or through other means.

Quick overview

We collect information you provide to us and information we gather when we interact with you
We use this information to provide our services and improve your experience • We protect your information using secure systems and processes
You have rights regarding your personal information, including access and correction rights

Information we collect

Identity and contact details

Name, address, email address and phone number
Age and date of birth
Your next of kin’s/emergency contact’s details
Professional details

Service related information

Payment and transaction details for products and services you’ve purchased from us or enquiries about our products and services
Your preferences for our services and your marketing preferences
Feedback and survey responses

Digital information

IP address and general location information derived from your IP address • Search and browsing behaviour
Website usage patterns
Cookie preferences

Recordings

Call recordings
Records of meetings and decisions

Professional information (for job applicants and workers)

Employment history
Professional experience
Required authorisations and licences
Professional registrations
Information about your right to work in the relevant jurisdiction

Sensitive Information

We handle sensitive information with extra care and protection, and we only collect this information with your consent or when legally permitted. This includes:

Health information (where you are a patient)

Individual or family medical history (to provide healthcare services and support tailored to your needs/ to ensure we can provide safe and appropriate services)
Treatment reports
Referral letters from other health care provider (where relevant to us providing health services to you)
Care plan information, including mental health treatment plan, eating disorder health care plan, and chronic condition management plan as relevant
Your symptoms, health concerns, medications, your treatment wishes and records, pathology records (to assess your conditions and provide you with relevant diagnosis or medical opinion)
If you are a minor, your parent’s details, where this is relevant to our assessment or treatment
Medicare number
Private health insurance details
Any other required personal information requested by us and/or provided by you or a third party

Cultural and background information

Racial or ethnic origin (to provide culturally appropriate services)
Religious beliefs (when relevant)
Criminal record checks (if we need to verify your background before hiring you) • Professional memberships (to assess the suitability for employment)

How we collect personal information

Directly from you when you: when you interact with us, contact us, fill out forms.
Automatically when you: visit our website, use our technologies, interact with our online services.
From third parties: referring doctors or other health care professionals, government services, service providers, business partners, public sources, government organisations and organisations or people authorised by you.
From publicly available sources: such as ASIC and other regulatory bodies and professional networking sites such as LinkedIn.

Why we collect, hold, use and disclose personal information

We collect and use your personal information to run our business and provide our services as set out below.

Business operations

To manage our relationship with you as a customer or supplier
To process and deliver our products and services
To handle your inquiries, support requests, and communications
To maintain accurate records for billing and administration
To verify your identity when required or permitted by law

Communication and support

To respond to your questions and support requests
To communicate important updates about our services
To handle inquiries made through our website or platforms
To manage your participation in surveys, feedback sessions, or events Service improvement
To conduct analytics and market research
To improve our business operations and services
To develop and enhance our applications and platforms
To understand how our services are used

Marketing and promotions

To send you promotional information about our services and events • To inform you about products or services that may interest you
To manage your marketing preferences
To run competitions, promotions, and special offers
To provide additional benefits to our customers

Employment purposes

To assess employment applications
To evaluate candidate qualifications
To manage professional certifications and licences
To maintain employment records

Legal and compliance

To comply with our legal obligations
To respond to court orders or legal processes
To maintain required business records
To fulfill regulatory requirements or reporting obligations
To protect our legal rights and interests or as authorised by law

Our disclosures of personal information to third parties

We may disclose personal information to:

Health care practitioners (where you are a patient)

Specialists
Allied health professionals
Hospitals
Community health services
pathology and diagnostic imaging services
MyHealth Record
Other healthcare practitioners to whom we may refer you, or with whom we may collaborate, to provide you with health services

Service providers

IT service providers
Data storage providers
Web hosting and server providers
Payment processors
Marketing and advertising providers
Analytics providers

Professional advisers

Bankers
Auditors
Insurers and insurance brokers
Legal advisers

Business partners

Our existing or potential agents
Our business partners or contractors

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets: • Your information may be disclosed to our advisers

Your information may be disclosed to the potential purchaser’s advisers • Your information may be included in the transferred assets

Legal and regulatory bodies

Courts and tribunals
Regulatory authorities including as required for reporting obligations • Law enforcement officers

Other parties

Third parties you have authorised
Emergency services when necessary
Any other parties as required or permitted by law

Overseas disclosure

Storage and access

We store your personal information in Australia. However, your information may be accessed from or transferred to locations outside Australia in these circumstances:

When our service providers are located overseas
When we work with overseas business partners
When using cloud-based services or data storage solutions

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information.

Your privacy rights and choices

Providing information

You can choose whether to provide personal information to us, however, if you don’t provide certain information, we may not be able to provide some services. Let us know if you don’t want to provide information and we will let you know when information is required versus optional.

Access to your information

You can request access to the personal information we hold about you in writing and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Whilst you have the right to access your personal information, there are exceptional circumstances in which we may refuse access to your health information. These include where:

Providing access would be likely to cause significant distress, or pose a risk of harm to you or another person
Your medical record contains the health information of another patient • Your information was disclosed by another patient in confidence
There is a possibility of domestic abuse or child abuse

Where we refuse access, we will explain why and discuss alternative ways to share relevant information with you.

Correction rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction.

Marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

How to contact us about your rights or to make a complaint and what happens next Step 1: Contact our privacy officer

Email: enquiries@smithstmedical.com.au
Phone: 02 4943 3066
Post: 28 Smith St Charlestown NSW 2290

What to include:

Your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers.

Step 2: Our response

We will:

Verify your identity before processing your request
Investigate thoroughly (for complaints) or process your request (for rights) • Respond to you in writing within reasonable timeframes and as required by law • Explain what actions we will take and keep you updated on progress • Not charge you for making a request (except for reasonable access fees if applicable) • Help you understand and exercise your rights

Step 3: If you’re not satisfied (complaints only)

If you’re not satisfied with our response to your complaint, you can:

Ask for a review by our senior management, or
Contact external bodies:
Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au)

This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices.

Protecting your information

We are committed to preserving the confidentiality of the information contained in your medical record. We take all reasonable steps to prevent unlawful interference with your records.

Technical safeguards

Enterprise-grade encryption for data storage and transmission
Restricting access to your electronic records to authorised practice staff only, protected by secure password controls
Regular security testing and monitoring
Automated threat detection systems

Operational security

Staff training on security and privacy
Strict access controls based on job requirements
Regular security audits and incident response procedures testing

Physical security

Secure premises with controlled access
Storing your paper records in secure filing cabinets, accessible only by practice staff • Secure disposal of physical documents
Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

How long we keep your information

We keep your personal information only as long as we need it for the purposes we collected it, or as required by law. When we no longer need it, we securely destroy or de-identify it.

Cookies and Analytics

What We Use

We use cookies, tracking pixels, and similar technologies on our website and in our emails to improve your experience and our services.

Cookies

Small text files stored on your device
Help remember your preferences
Enable certain website functions
Make your interactions with our website more efficient

Tracking Pixels

Tiny, invisible images in web pages and emails
Help us understand how you interact with our content
Allow us to measure email engagement
Enable more relevant content delivery

How we use these technologies

Essential Functions

Remember your login status
Maintain your session security
Store your preferences
Enable core website features

Analytics and Performance

Understand how our website is used
Measure page views and traffic
Analyse user navigation patterns
Identify areas for improvement

Personalisation

Remember your preferences
Tailor content to your interests
Improve your browsing experience
Provide relevant recommendations

Your control

You can manage these technologies by:

Adjusting your browser settings to block or delete cookies
Using privacy-focused browser extensions
Configuring your email client to block images
Using our cookie preference settings

Note: Blocking all cookies may affect website functionality and your user experience. Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google’s advertising features through your Google account settings, browser add-ons, or your device’s privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google’s privacy pages.

Meta advertising tools

We use Meta’s advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

Transcribe our consultations, with your consent
Summarise our notes, where you are de-identified
Automate routine tasks and communications

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with

your personal information, we commit to:

Transparency and control

We’ll inform you when AI is used to make decisions that may significantly affect you • We maintain human oversight and review of significant AI-generated decisions
Our staff are trained to understand AI limitations and verify outputs before relying on them
We implement processes to verify the accuracy of AI-generated outputs Security
We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

We regularly assess and document risks associated with using AI to process personal information
We implement appropriate measures to address these risks
We continuously monitor AI performance and regularly review their impact

Amendments

We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes.

SMITH STREET MEDICAL CENTRE – PRIVACY POLICY

Charlestown

Kotara

Canberra

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