At Teachers Federation Health Ltd ABN 86 097 030 414 trading as Teachers Health Fund (THF), we recognise the importance of privacy. We observe the privacy obligations under the Privacy Act 1988 (Cth) and other relevant state legislations dealing with privacy and health records, as amended from time to time. The Privacy Act provides for the protection of an individual’s personal and sensitive information.
From time to time, THF may collect personal information about a member such as name, date of birth, family members, contact details, claims history, income tier and information regarding products and services members inquire about or obtain through THF so that it can provide insurance cover or other services such as eye care or dental care. THF may also collect personal information about a prospective member such as name and contact details so that it can discuss providing health insurance cover to that prospective member.
THF may also collect bank account details, payroll numbers and information in respect of insurance policies in order to provide members with its services.
THF may collect sensitive information such as a member’s medical procedures, hospital attendances and the provision of ancillary health services, medical history or other health or lifestyle information, or information regarding a membership of a trade union – in order to provide its health insurance services and other services.
THF may collect details of a member’s union membership including a union membership number and the status of membership – to assess whether a member is eligible for membership of THF.
THF may also collect government-issued identifiers such as a member’s Medicare number which is required for reporting purposes.
THF may collect personal information from a member if the member:
THF may also collect personal information from a prospective member from its business development officers visiting educational facilities and events from aggregators, business partners or from member referrals.
THF may collect personal information from third parties in some situations:
THF’s website, online services, interactive applications, email messages and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. THF may use these technologies:
Individuals can disable their web browser from accepting cookies. Certain features of the THF website will not be available to an individual once cookies are disabled.
THF gathers some information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp and clickstream data.
THF uses this information to understand and analyse trends, to administer its website, to learn about user behaviour on the site, to tailor email communications and to gather demographic information about its user base as a whole. THF may use this information in its marketing and advertising services.
THF may also use information collected by cookies to display personalised content and advertising (targeted advertising and online behavioural advertising), based on an individual’s internet usage, and to send marketing materials that THF thinks will be of interest to the individual.
Personal information collected by THF is generally entered into and held in a centralised digital secure repository.
THF will take reasonable steps to protect all personal information it holds from misuse, interference and loss and from unauthorised access, modification or disclosure, including a data breach response plan found in the Business Continuity Management Framework and Policy / Crisis Management Plan.
THF will ensure that appropriate technical and organisational security measures, consistent with standard industry practice, are in place to attempt to safeguard the security and confidentiality of the personal information it collects. Because of the nature of the internet, however, THF does not guarantee that the website or the online and mobile member services are totally protected from hackers or misuse and it will not be responsible for any breach of security caused by third parties. THF does not use any form of encryption (encoding software) to protect information a member sends from their computer to THF over the internet through the use of feedback, enquiry and appointment forms and emails. Encryption software is applied when using online or mobile member services and joining online.
A member does not have to provide their personal information to THF. However, if they do not provide personal information which THF requests from them, THF will make them aware that it may affects THF’s service to them, including:
THF may collect, hold, use and disclose personal information for a number of purposes such as:
THF develops programs and initiatives from time to time to assist members with day to day health and wellbeing issues such as diet and exercise, as well as assistance with illnesses suffered by members. Members may choose to sign up to such programs from time to time. Members are not obliged to join any such programs. If they do join any such programs, THF may use personal and sensitive information already collected from them so that they can get the most benefit from such programs. For instance, if the member suffers from diabetes and chooses to join a program that assists with their diabetes treatment, THF may use earlier personal and sensitive information collected from them in order to advise them on their treatment program.
THF may also use a member’s contact details to send information about THF or its products, services or programs. If a member does not wish THF to send this information, then THF should allow the member the opportunity to tell THF when it collects the personal information. Refer to paragraph 13 of this policy for further details in relation to opting out of THF direct marketing.
THF will not sell a member’s personal information to any third party. THF will not disclose any personal information about a member, except:
Some of the programs that a member may join may be administered by third parties in order to provide the best service to the member. To ensure the efficient administration of such programs, THF may need to disclose a member’s personal information to these third parties. THF will endeavour to ensure that third party program administrators will not disclose a member’s personal information to any third parties.
If a member joins programs through THF which are administered by third parties, the member may need to disclose personal information to these third parties. The third parties do not disclose this information to THF. A member’s disclosure of personal information directly to such third parties would be subject to their privacy policies.
If the THF membership policy covers the main policy holder as a main contributor and a partner or children, THF will only contact the main policy holder regarding anyone else covered on the policy.
THF is not likely to disclose personal information to overseas recipients. However, in some instances THF’s service providers, for example THF’s travel and general insurers may disclose personal information to organisations that may be located overseas. The countries in which these service providers and related companies are located may vary from time to time, but include Singapore, Thailand, Philippines, India, Ireland, the United Kingdom, the USA, Canada, New Zealand, China and countries within the European Union.
Specifically, THF’s service providers may disclose personal (including sensitive) information to recipients outside of Australia when it is collected for travel, general or health insurance arranged or managed by them and where the policy holder may require medical, travel, or related services.
Where personal information has been disclosed to an overseas recipient, there is a possibility that in certain cases that recipient may be required to disclose it under a foreign law.
This section applies only to health-related services provided to THF members by Teachers Healthcare Services (THCS), a subsidiary of THF. THCS may provide such services to THF’s private health insurance members including telephonic services, care co-ordination services, chronic disease and health management programs and online health-related services.
THCS may collect and use personal information, including sensitive information, to provide these services to members including:
If a member uses health-related services, THCS may disclose personal information to THF in order for it to pay benefits and to review, develop and improve the services provided by THF and/or its subsidiaries.
In order to perform the above services, THCS may disclose personal information to third parties such as health service providers, persons authorised by or responsible for the member, and to other parties to whom they are authorised or required by law to disclose information including government agencies.
THF may also use and disclose personal (including sensitive) information:
Participation in any programs offered by THCS is entirely voluntary and a member may withdraw their consent to the sharing of personal and sensitive information or to being contacted in relation to health-related services by contacting THF.
To make request to stop receiving direct marketing communications from THCS or to opt out of the program, a member should contact firstname.lastname@example.org or call 1300 728 188. THCS will give effect to the request as soon as reasonably practicable and, in any case, within 30 days of the request being made to THCS.
Participation or non-participation in the program will not affect a member’s claims from, or contributions to, THF.
If a member requires access to their health-related service records, they may do so by contacting the Clinical Operations Manager directly on (02) 8346 2227 or by email on email@example.com.
THF permits a member to deal with THF anonymously or by using a pseudonym. If the member chooses to do so, however, THF will be limited in the products or services it is able to assist the member with.
As a general rule, THF may allow an individual to contact THF anonymously in some limited circumstances – for example to enquire generally about its goods and services, or to complete a retail transaction at a health centre by paying for goods in cash.
THF uses personal information that it holds about a member to identify services and products that may be of interest to them.
THF may contact a member by email, text message, phone or by post to let them know about promotions or any new or existing products or services. THF also uses internet-based marketing including targeted online advertising and online behavioural marketing.
THF may disclose personal information to other related companies such as THCS to tell members about its products or services.
A member may request not to receive direct marketing communications from THF by contacting it at firstname.lastname@example.org or calling 1300 727 538. THF will give effect to the request as soon as reasonably practicable and, in any case, within 30 days of the request being made to THF.
THF will take reasonable steps to ensure that all personal information it collects or uses is accurate, complete, up to date and stored in a secure environment and is accessed only by authorised personnel for permitted purposes.
If a member wishes to access or correct any personal information which THF holds about a member, or requests its removal from THF records, they should contact the THF via post, fax or email, in person at one of the member contact centres or over the phone with a member of the contact centre.
If a member requires access to their eye care records, eye test results or dental records, they may do so by contacting the eye care or dental care provider directly.
If a member requires access to their health-related service records managed by THCS, they may do so by contacting the Clinical Operations Manager directly on (02) 8346 2227 or by email on email@example.com (refer to section 11).
THF will respond to a member’s access request as soon as practicable and, in any case, within 30 days of the request being made to THF. THF will either respond by providing the member with the access or amendments they have requested, or by providing them with the reasons for refusing to do so.
If THF refuse to amend a member’s health information, the member may request that THF attach to the health information a statement of the amendment sought, and in that case, THF must take reasonable steps to do so.
There are some available exceptions to accessing personal information, which are:
In some circumstances, THF may charge a fee to cover administrative costs in respect of retrieving a member’s personal information and providing it to them. THF will inform the member if there are going to be any such costs involved in retrieving their personal information.
THF views complaints as an opportunity to maintain and enhance customer loyalty and approval and enhance its competitiveness by continuous review and improvement. THF has a Customer Complaint Handling and Dispute Resolution Policy in place for handling the complaints it receives. A copy of this policy is available to members at teachershealth.com.au.
If a member would like to make a complaint about a breach of privacy, THF will make them aware that:
(a) Complaints can be made by contacting the THF Privacy Officer at:
Address: THF Privacy Officer
Teachers Health Fund
GPO Box 9812
SYDNEY NSW 2001
Phone: 1300 728 188
(b) The complaint should first be made in writing. THF will respond as soon as reasonably practicable and, in any case, within 30 days. All complaints are handled in accordance with the THF Customer Complaint Handling and Dispute Resolution Policy.
(c) In the event that the complainant is not satisfied by THF’s response, they may take the complaint to the Private Health Insurance Ombudsman (PHIO) in the first instance. If the complainant is still not satisfied with the outcome, then the complaint may be taken to the Office of the Australian Information Commissioner (OAIC).
(d) PHIO can be contacted on 1800 640 695 or a member can write to:
Private Health Insurance Ombudsman
Office of the Commonwealth Ombudsman
GPO Box 442
CANBERRA ACT 2601
Phone: 1800 640 695
Fax: (02) 8235 8778
See also PHIO website for further details.
(e) OAIC can be contacted on 1300 363 992 or a member can write to:
The Office of the Australian Information Commissioner
Phone: 1300 363 992
GPO Box 5218
Sydney, NSW 2001
See also OAIC privacy complaint brochure for further details:
Updated: 15th December 2015
1300 728 488