PRIVACY POLICY | TBS Physio

TBS PHYSIO’S COMMITMENT TO PRIVACY

TBS Physio Pty Ltd ABN 13 625 007 169 (referred to as TBS Physio) is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we", "us" and “our” refers to TBS Physio and "you" and “your” refers to any individual about whom we collect personal information.

This Privacy Policy applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through our websites (including tbsphysio.com.au), through our [b]agile health and wellness platform located at bagile.com.au, through our social media channel pages which we control (such as our Facebook, Instagram, LinkedIn, YouTube and Vimeo pages) and through email messages that we may send to or receive from you.

ABOUT TBS PHYSIO

TBS Physio is an innovative Sports Medicine Clinic located within the grounds of St Joseph’s College (the College) in Hunters Hill, New South Wales. TBS Physio privately services the College’s students and is the primary provider for the College’s winter and summer sports program including rugby, rowing, football, basketball, athletics and cricket. TBS Physio is a multi-disciplinary team consisting of Director Tim Bushnell and Specialist Dr Nathan Gibbs. TBS Physio strives to provide its clients with a professional standard of sports medicine, with the vision of maximising performance and minimising injury.

WHAT IS PERSONAL INFORMATION?

In this Privacy Policy the following terms have the meanings given in the Privacy Act, which as at the date of this Privacy Policy, are defined as follows:

“personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or an opinion is recorded in material form or not; and
“sensitive information” means: (a) information or an opinion about an individual’s: (i) racial or ethnic origin; (ii) political opinions; (iii) membership of a political association; (iv) religious beliefs or affiliations; (v) philosophical beliefs; (vi) membership of a professional or trade association; (vii) membership of a trade union; (viii) sexual orientation or practices; or (ix) criminal record, that is also personal information; or (b) health information about an individual; or (c) genetic information about an individual that is not otherwise health information; or (d) biometric information that is used for the purpose of automated biometric verification or biometric identification; or (e) biometric templates.

WHAT INFORMATION DOES TBS PHYSIO COLLECT ABOUT YOU?

Clients and prospective clients

When you enquire about our services or when you become a client of TBS Physio or we otherwise provide services to you, a record is made which includes your personal information.

The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

personal details such as your name, title, e-mail address, postal address and other personal or business contact details;
your educational details (such as whether you attend the College or other educational institution);
your professional details (such as your occupation and job title) and information about your employer or an organisation who you represent;
your age or date of birth;
your credit card details or payment information;
your health information and relevant medical history;
your fitness and nutrition statistics or data which you provide us;
details about the services you have purchased from us or which you have enquired about, together with any information necessary to deliver those services and to respond to your queries;
any additional information relating to you that you may provide to us directly through our website or by other means such as over the phone, over social media, via email or in person;
information you provide to us via voluntary client feedback or engagement surveys; and
any additional personal information you provide to us, or authorise us to collect, as part of your interaction with TBS Physio.

Prospective employees / contractors / applicants

We collect personal information when recruiting personnel, such as your name, title, date of birth, gender, contact details, qualifications and work history (including references and other information included in a CV, resume or cover letter as part of the application process). Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which involve working with children).

Other individuals

TBS Physio may collect personal information about other individuals who are not clients of TBS Physio. This includes members of the public who participate in events we are involved with; individual service providers and contractors to TBS Physio; and other individuals who interact with TBS Physio on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with TBS Physio. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.

If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.

Your sensitive information

TBS Physio may collect and process your sensitive information, such as your health information, generally with your express consent and only as reasonably necessary in order for us to provide our services to you. We may also collect such information about you in an emergency or otherwise with your consent or in accordance with applicable laws.

For example, we will collect health information from you with your consents in order to understand your physical health, fitness and any injuries you have or have previously experienced. This will assist us to adequately provide our services.

Children’s personal information

We may collect personal information about children. Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf and provide consent where applicable (for example in respect of collecting health and sensitive information about the child so we can provide services to the child).

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below.

What happens if you don’t provide your personal information?

You can always decline to give TBS Physio any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested or we may not be able to do business with you effectively or meet the expectations of clients. If you have any concerns about personal information we have requested, please let us know.

HOW AND WHY DOES TBS PHYSIO COLLECT AND USE YOUR PERSONAL INFORMATION?

TBS Physio collects personal information reasonably necessary to carry out our business, to assess and manage our clients' needs, and provide our services to you. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing client and other business relationships.

The purposes for which TBS Physio usually collects and uses personal information depends on the nature of your interaction with us, but may include:

responding to requests for information and other general inquiries about our services;
scheduling and arranging physiotherapy consultations;
providing you with preventative exercise programs using our [b]agile platform;
managing our relationship with you if you are a supplier or business partner;
managing, planning, advertising and administering programs, events and competitions which may be of interest to you;
researching, developing and expanding our facilities and services;
informing you of our activities, events, facilities and services;
recruitment processes (including for contractors, volunteers, internships, student placements and work experience); and
responding to enquires and complaints.

TBS Physio generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:

third party suppliers and contractors who assist us to operate our business; and
our employees, agents, contractors and suppliers.

TBS Physio also collects and uses personal information for market research purposes and to innovate our delivery of services.

HOW DOES TBS PHYSIO INTERACT WITH YOU VIA THE INTERNET?

You may visit our websites without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to TBS Physio will be managed in accordance with this Privacy Policy.

TBS Physio's websites use cookies. A 'cookie' is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

TBS Physio's websites may contain links to third-party websites. TBS Physio is not responsible for the content or privacy practices of websites that are linked to our website.

CAN YOU DEAL WITH TBS PHYSIO ANONYMOUSLY?

TBS Physio will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is not practicable for TBS Physio to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

HOW DOES TBS PHYSIO HOLD INFORMATION?

TBS Physio stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia and the United States of America). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

TBS Physio maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.

We take steps to destroy or de-identify information that we no longer require or as required by applicable law.

DOES TBS PHYSIO USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

TBS Physio may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable privacy laws. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message.

If you opt-out of receiving marketing material from us, TBS Physio may still contact you in relation to its ongoing relationship with you.

HOW DOES TBS PHYSIO USE AND DISCLOSE PERSONAL INFORMATION?

For clients

The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.

TBS Physio may also disclose personal information to third parties who engage us to provide services to you. For example, if we have been engaged by a school (such as the College) to provide services to the school’s students, we may disclose students’ personal information to the school (for instance, if a student is injured TBS Physio may contact the student’s relevant coach or teacher to discuss).

For participants

If you are a participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.

Disclosure to contractors and other service providers

TBS Physio may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.

Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

Use and disclosure for administration and management

TBS Physio will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

administering billing and payments and debt recovery;
planning, managing, monitoring and evaluating our services;
quality improvement activities;
statistical analysis (including analysing trends) and reporting;
training staff, contractors and other workers;
risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
responding to enquiries and complaints regarding our services;
obtaining advice from consultants and other professional advisers; and
responding to subpoenas and other legal orders and obligations.

Business sale or corporate transaction

We may share your personal information with third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, acquisition or corporate restructure is being contemplated by us).

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection (such as a specific privacy collection statement or notice) or otherwise as set out in this Privacy Policy.

DOES TBS PHYSIO DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?

TBS Physio works with service providers and commercial interests across the globe, including in the United States of America. It is likely that your personal information will be disclosed to overseas recipients.

Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to access your personal information held by TBS Physio on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?

You may contact TBS Physio at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that TBS Physio may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

HOW CHANGES ARE MADE TO THIS PRIVACY POLICY?

TBS Physio may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. We will also try to let you know about major changes to our Privacy Policy (for example by putting up a notice on our website).

HOW CAN YOU CONTACT TBS PHYSIO?

The contact details for TBS Physio are:

TBS Physio Privacy Officer

St Joseph's College, Mark Street, Hunters Hill NSW 2110

admin@tbsphysio.com.au

+61 410 895 714

This Privacy Policy was last updated in September 2024