1. About this policy
It is important to us that your privacy is protected, as we believe that privacy is necessary to ensure that you feel comfortable whilst using the site. We value your trust and aim to help you manage your health, or that of your clients, through our service. The protection of your personal information is a vital part of this relationship.
Your account contains information that is related to your specific requirements and circumstances, and we need to tailor this information by identifying you in our systems. In order for us to assist you, we will hold personal information about you – which may include health-related information if you are a using the system as a client. Clinicians or other Health Providers intending to use the online program as a monitoring tool should have an awareness of this policy, particularly Section 18 of this document.
We will act to protect your personal information. We are, in addition, bound by the National Privacy Principles in the Privacy Act 1988 (Cth). Further details concerning your privacy rights can be found at: "The Office of the Federal Commissioner of Privacy" web site.
Any mention of the terms "We" or "Our" throughout this document refers to Sentiens Pty Ltd.
2. Personal and health-related information
Personal information is information that enables us to identify you. It may include your name, age, gender, date of birth and residential address. Health-related information is information or data about your past and present medical/health circumstances. It may include medication details, general health and wellbeing notes, or previous medical history.
3. Collection
Sentiens collects information that can identify you when you enrol or register to utilise the online programs. We may also receive similar information from other sources, which could include:
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your general practitioner;
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your clinician or specialist;
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your government department;
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a health management or consultancy organisation;
Any information received by these sources aims to:
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facilitate your use of the online program by assisting in the enrolment process (including payment, if applicable); and/or
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enhance your progress and development.
We need to tailor the information that we provide to your specific needs by identifying you in our systems. In order for Sentiens to assist you, we will collect and store personal and health-related information about you. This information will either be volunteered by you or collected as authorised by in some form or another. This information may include:
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personal particulars (such as name and date of birth);
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your contact details (including emergency contact details);
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your employment details (such as occupation and status);
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your employer;
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your medications;
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details of any allergies, or special instructions relating to your care;
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details of your condition, immunisations, medical history;
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details of your treatment course, health risk assessment;
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contact details of your doctor(s), specialist(s) or other health carer(s);
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your caregiver's or guardian's details;
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your pharmacy or hospital details;
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information which you enter into this web site; and
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emails sent by you or to you in relation to this web site.
4. Use and disclosure
We use your information for three general purposes.
In general, you will be able to view all the information that Sentiens holds concerning you - however, there are some exceptions to this. For further details on your access rights, refer to the section on 'Access and Correction' below.
The information will be divided and stored in two categories:
Category 1. Provider Information In general, only your linked Provider(s) will be allowed to enter information into this category.
Category 2. Your Information You will be able to enter and change your information. You will have the ability to change your personal information or your health related history. Each time you change this information, it is updated securely on our systems. If appropriate, in approved circumstances, your carer or guardian will be granted access to your online account, and will be able to view everything that you are able to view. Your carer or guardian will also be able to enter and change information in Category 2 on your behalf.
In general, only you and the health care Provider(s) that you specify will be allowed to view the information contained in the above categories - there are some exceptions to this (See Section 6 Exceptions - Use and Disclosure without your consent).
Linked Providers At times Providers will be linked to your account by default according to the pathway in which you have enrolled.
- If you have enrolled and paid for your module online, you do not have a linked Provider (the system recognises your provider as Self Referred). Only you and the system administrators will be able to access your personal information.
- If you have enrolled, and either you or your employer have paid the Service Provider directly (offline), you will have a linked Provider (most likely your Service Provider). If you do not wish for this Provider to have access to your details, your Personal Privacy Settings must be adjusted by you once you have logged into your account. If you would like them deleted from your record altogether, you must contact the system administrators (
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) to remove them.
If you wish to suspend or withdraw from an online program at any time, contact
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. For historical purposes, we may keep some information in our archival systems.
Sentiens will keep your personal information confidential, and only use and disclose it in accordance with your authority - there are some exceptions to this, which are specified below. Note that your acknowledgement of this document in the enrolment or registration process signifies to us your authority, unless revoked in writing, for uses outlined in this document, and the document titled Terms and Conditions.
We will not sell or rent your personal or health-related information to anyone.
5. Disclosures to other organisations
The types of organisations that Sentiens usually discloses your personal information to include:
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Sentiens associates - which means a holding company, subsidiary or subsidiary of a holding company, and any company in which Sentiens has a controlling interest or shareholding.
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Web site service providers or developers - which means the web site host and service providers / developers, system administrators, software developers, hardware and software suppliers and other related service providers who may access your information as part of providing services to Sentiens. Such associations are covered by a Confidentiality Agreement.
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Collective information to third parties - which means any other information, statistical and non-identifiable, may be used and/or distributed to third parties to develop and enhance Sentiens services and to contribute to research.
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List of authorised viewers - any person or organisation that you consented to having access to your information before you received your HealthSteps login details.
At any time in the future, you may withdraw your consent for any of the above uses and disclosures of your personal information (except when legal obligations must be met; or under circumstances listed below under Exceptions - Use and disclosure without your constent).
6. Exceptions - Use and disclosure without your consent
In certain circumstances, Sentiens may use and disclose your information without your consent. These circumstances include:
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if the use or disclosure is required or authorised by law;
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circumstances which override the duty of confidentiality; or
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in accordance with allowable uses and disclosures under the National Privacy Principles (NPP).
For example, in an emergency medical situation we will allow an emergency logon to be activated in order to access your medical record and supply this information to the necessary health authorities or your next-of-kin.
Further examples of circumstances in which Sentiens may use and disclose your information without your consent include:
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when we obtain information concerning child abuse;
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when we obtain information concerning infectious diseases, which we are obligated to report;
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where there is a serious and imminent threat to an individual's life, health or safety;
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circumstances as documented in the NPP (2.4), where information is provided to caregivers or guardians;
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when it is in the public interest, or a serious threat to public health or public safety;
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when use or disclosure of health information is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety (NPP 2.1(d));
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when we obtain information concerning unlawful activity (NPP 2.1(f)); or,
when disclosure is reasonably necessary for certain purposes for law enforcement bodies (NPP 2.1(h)).
7. Data quality
Sentiens appreciates that it is important to keep your information accurate, complete and up to date - and takes reasonable steps to ensure this. The Service enables you to change your basic demographic information and your password. Any other change of details can be requested by forwarding an email with your required changes to the support email:
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.
8. Data security
This website takes every precaution to protect your information. When customers submit sensitive information via the website, such information is protected both online and off-line.
To protect the security of your personal, financial and health related information we have put in place:
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encryption of all transmitted information (including personal and financial details) using Secure Sockets Layer (SSL);
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Sentiens employees bound by Privacy Policy & Confidentiality Agreements;
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physical security of the server that personal information is stored;
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limited access by Sentiens staff to your information;
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regularly updated security and encryption technology;
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allocated information security responsibilities;
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information back up procedures; and,
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an internal Information Security Policy.
Despite taking these security measures, no data transmission over the internet is 100% secure. There is also some risk that thieves, hackers or unauthorised users will find a way to gain unauthorised access to our systems. You should protect against unauthorised access to your personal information by:
9. Access and correction
Sentiens will take reasonable steps to ensure your information is accurate, complete and up to date. However, if you find that your recorded information is inaccurate, you may wish to access your information in order to correct it.
There is no fee for requesting access, although we may charge a reasonable fee for the cost of processing your request.
Access will be denied in some circumstances These circumstances, as stated in the Guidelines to the National Privacy Principles NPP6 (2001), include: where;
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providing access would pose a serious and imminent threat to the life or health of any individual;
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providing access would have an unreasonable impact on the privacy of others;
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the request is frivolous or vexatious;
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access relates to existing or anticipated legal proceedings;
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denying access is required or authorised under law;
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providing access would be unlawful; or
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access may be denied in accordance with the National Privacy Principles, and in particular with Section 6.
If Sentiens denies you access for any reason, or refuses to correct your personal information, we will provide you with the reasons why you have been refused access, or the right to correct your personal information.
How you can gain access. For confidentiality reasons, you will be required to complete a 'Request For Access Form' before gaining access to your information. You will also be asked to provide various forms of identification such as your driver's licence.
If you require access to personal information other than your own, then you must provide proof of your relationship to that other person (for example, child or dependent), and of your right to access that information.
Not possible to correct all records. Sentiens maintains back-ups and of all your personal information to protect against loss or damage, and for disaster recovery purposes. In some cases it will not be possible, or reasonably feasible, to correct every record of personal information that Sentiens holds about you.
Identifiers Sentiens will use its own assigned user identifier to recognize consumers. We will not emulate or misuse third party identifiers, such as Medicare number.
10. Transfers of data to foreign countries
Sentiens may transfer personal information to foreign entities in the following circumstances:
11. Archiving of Data
Sentiens is obliged to store your personal and health-related information for a minimum of 7 years. If you are under 21 years of age, we will store your information for a minimum of 7 years after you reach the age of 21. We may store information after this period.
12. Emails
Sentiens may monitor consultancy-related e-mails you send for quality management purposes. The Support team will preserve the content of any email you send us if we believe that we have a legal requirement to do so.
Emails may be lost or incorrectly sent to the wrong address. You should use a return receipt on emails which you send to confirm that they have been received. The content of your email may be monitored for quality control, systems administration or legal compliance purposes.
13. Cookies
Sentiens may follow traffic patterns throughout the website. We may investigate how you utilise this site by tracking how you navigate through various screens. We may also note the web site from which you came, if applicable. We do this to help us improve the quality of the service to you.
We may also use a feature of your browser called a "cookie" to assign a "User ID." Cookies, by themselves, cannot be used to detect your identity or the identities of any of our users; it only identifies your computer to our systems when you visit our site. If you do not wish to receive any cookies you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on this site.
14. Children's privacy
This site is not intended or designed for the use of children under the age of 18.
15. Business transfer
If Sentiens transfers it's business, part of it's business or an asset (such as a web site) to another party, then the new party will be required to comply with this Privacy Policy.
16. Links to other web sites
This site may contain links to other health web sites and other general web sites for reference (Linked Sites). Sentiens is not, or will not be held responsible for the privacy practices or content of these Linked Sites. It is your responsibility to ensure you understand the privacy practices and security of a Linked Site.
17. Compliance
This Policy is in compliance with the legislation of the Commonwealth of Australia, particularly the Privacy Act (1988), in reference to the collection and management of personal and health related information. Our standard practices are also aligned with the guidelines documented in the Privacy Act.
18. Provider Terms
You, as a Provider, agree to abide by the terms outlined in this document when protecting the privacy of each of your linked clients. Your use and disclosure of information belonging to your clients must be aligned with this policy, as well as the National Privacy Principles and the Privacy Act 1988. Your obligations under this Policy survive the termination of any agreement between you and Sentiens.
19. Contact us
If you have any questions, or would like further information about this Privacy Policy or our Terms & Conditions, please contact us by sending an email to
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. We also welcome any feedback you may offer in regards to our Service.
Alternatively, you may send a letter to:
e-Health Support
c/- Sentiens Pty Ltd PO Box 842 WEST PERTH WA
AUSTRALIA 6872
We are physically located at:
36 Parliament Place
West Perth WA, Australia 6005
20. These terms may change
The stipulations outlined in this policy are subject to change at any time without prior notice. It is your responsibility to regularly check our Privacy Policy and the Terms & Conditions documents for any updates that may affect your acceptance of these policies. Sentiens will endeavour to notify you of any substantial changes to this Privacy Policy within 30 days following date of amendment.
21. Acceptance
You accept that your use of this site indicates your acceptance of this Privacy Policy and our Terms of Use / Disclaimer.
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