Notice: ‘We’, ‘Us’, ‘Our’ ‘Clearly Dental’, refers to Dental Corporation Pty Ltd (trading as Clearly Dental) and their related entities and bodies corporate. We are part of the Bupa Australia Group of companies. ‘You’, ‘Your’ refers to individual patients or customers.
Your privacy and maintaining the confidentiality of your personal information is important to Us. We are committed to safeguarding Your personal information. This policy explains what information We collect, how information is collected, used and handled, when information may be disclosed to third parties with Your consent, Your rights for requesting access to or amending Your personal information, as well as how you can provide Us with feedback or make a complaint. When You receive services from Clearly Dental, you agree to the handling of your personal information as outlined in this policy. This document may be amended by Us from time to time.
Consent means Your permission. Your consent can be express or implied. Express consent can be written (e.g. when you sign a form or send us correspondence) or verbal (e.g. when you give us your permission over the phone or in face-to-face conversations). Your consent will be implied when we can reasonably form a conclusion from our pre-established relationship with You that You have given consent by either taking action or deciding not to take action.
Personal information has the same meaning that it has under the Privacy Act 1988 (Cth), namely information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
3. Information We Collect
We will only collect information that is necessary for providing our services to You. We will only collect information that is necessary for the purposes for which it will be used. The amount and type of personal information We collect from You and hold about You will vary depending on whether You are an existing patient of a Clearly Dental practice, have made enquiries about Our products and services and also the extent to which You have used Our products and services. If You apply to be, are currently or have in the past been a patient of a Clearly Dental practice, the personal, or individually identifiable information that We hold about You may include:
- name, address, telephone and email contact details;
- personal details such as age and gender;
- details of previous dentists you’ve been a patient of;
- your Medicare number
- records of service contacts such as system notes and voice recordings of telephone conversation you’ve had with our employees
- census and statistical information for purposes including product development and risk assessment
- financial information (for example, credit card numbers to assist in the administration of payments for dental services).
- details of purchases made and professional services used, including the date;
- and sensitive information including:
- medical records and history;
- family medical history;
- current health and dental assessment; and
- health insurance details.
4. How Information May Be Collected
We may collect personal information directly from you in a number of ways, including:
- You may choose to provide information through the contact forms on Our website;
- From third party payment platform providers such as OPenpay or Afterpay;
- You may choose to provide personal information directly to a Clearly Dental staff member providing services to you;
- when you subscribe to newsletters or other direct marketing materials; or
- you may complete forms, send us an email, provide information during a visit to a Clearly Dental practice or by phone;
- when You use professional services or purchase goods from Us.
We may also collect information from third parties if You have provided them with consent under their own privacy policies:
- we may collect information from third parties such as your health insurance provider or Medicare; or
- we may collect information from dentists, dental specialists or other health practitioners (for example if you were referred to us by another dentist).
If You have provided Us with information about another person, then You need to tell that other person that You have done so, that they have a right to access their information and that they can refer to this document for information on how We will handle their personal information.
If You do not provide Us with Your personal information, We may be unable to provide You with the products or services that You are requesting.
5. Use and disclosure of Your Personal Information
We use Your personal information primarily to provide, manage and administer our services and products to You and operate an efficient and sustainable business. As part of these processes, We may disclose Your personal information on a confidential basis to our related entities within the Bupa Australia Group of companies and Dental Corporation businesses. In addition, We may use Your personal information for a number of purposes, including:
- to provide dental and related services to You;
- to maintain and administer Your patient file(s) at a Clearly Dental practice;
- to contact You in relation to any matter relating to You or the dental services or products provided to You;
- to answer Your enquiries and deliver customer services to You;
- to carry out internal functions such as administration, accounting, quality assurance and information technology;
- to resolve complaints;
- to monitor price and evaluate products and services;
- to conduct marketing surveys, research and statistical analysis (including analysis of potential locations for new Clearly Dental practices);
- to fulfil marketing promotions;
- to administer Your invoicing for dental services, credit card payments, or to collect unpaid invoices;
- to administer payments made by you through a third party payment platform provider;
- to process Your health insurance claims;
- to follow You up regarding further dental examinations or treatments required;
- to send information to You about Us;
- to comply with any laws or regulations.
If You submit online forms or send emails to Us containing personal information, We will use that information to respond to Your message or to contact You. The main purpose of collecting and using personal information submitted through Our web site is to respond to customer or patient enquiries or feedback from this site.
We may store Your contact information for future reference.
5.1 Disclosure to Third Parties
In order to allow Us to provide manage and administer Our products and services to You and to operate an efficient and sustainable business, We may be required to disclose Your information to third parties. This may include disclosure in the following circumstances:
- to Your nominated relatives in an emergency;
- to a third party payment platform provider;
- to government and regulatory bodies, e.g Medicare
- to auditors and other service providers We may appoint to ensure the integrity of Our operations;
- to any person or entity acting on Our behalf;
- to dentists, dental specialists and other healthcare professionals, for the purpose of seeking a second opinion or a referral, where You have consented to obtaining the second opinion or the referral;
- to third party health benefit providers and insurance companies (contact information only) to assist in the processing of a claim for reimbursement or payment of all or part of the cost of dental treatment submitted by You or on Your behalf;
- to carry out a review of practice operations for the purposes of improving the quality of care provided;
- where disclosure is required by law, e.g compulsory notices from courts of law, tribunals or government agencies.
If We send your personal information outside of Australia We will require that the recipient of the information complies with privacy laws and contractual obligations to maintain the security of the data.
5.2 Direct marketing
From time to time, We may contact You to provide You with information about other products and services offered by Us, our related entities and our business partners that may be of benefit to You and Your family. This includes information about Clearly Dental practices, including when a new practice opens and you have indicated (online or otherwise) that you are interested in knowing about new studios in certain areas. When We contact You it may be via mail, phone, email or SMS. We may share Your personal information on a confidential basis with Our related entities, related bodies corporate and third parties engaged by Us so that they can offer You products and services and fulfil offers to You. When You become our customer, You consent to Us using your personal information for direct marketing purposes (as described in this document), unless You have contacted us to withdraw Your consent. If You do not wish to receive marketing material from Us You can contact Us at any time to let Us know. Our contact details are at the end of this policy. When You contact Us to make this request, We will action your request within 5 working days.
If You request not to receive marketing material, please note that We will still contact You in relation to Our on-going relationship with You. For example, We will still send You any bills, statements and notices that are relevant to the products and services You have purchased from Us.
6. Handling and storage of Personal Information
We will take reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure. We will take reasonable steps to ensure that personal information provided by You will be handled in accordance with Australian privacy laws including the Australian Privacy Principles. We maintain strict data security standards and procedures with a view to preventing unauthorised access to your data by anyone other than Us.
Your personal information may be handled by Our employees. Information may be used by staff at a Clearly Dental practice for the administration or use of the practice and in the provision of services to You.
We keep your personal information for as long as it is required to provide You with the services and products You requested from Us and to comply with legal requirements.
If We no longer require Your personal information for any purpose, including legal purposes, We will take reasonable steps to securely destroy or de-identify your personal information except in circumstances permitted or required by law.
7. Accessing, Amending, Updating and Correcting Your Information
7.1 Access to personal information
You have the right to access personal information that is held about you. You can ask Us for access to the information that We hold about you at any time. Simply contact Us (Our contact details are listed below) to make your request. We will always endeavour to meet Your request for access within a reasonable time and in the manner requested by You if it is reasonable to do so. However in some circumstances, access to certain information may be declined. This includes the following circumstances:
- We no longer hold or use the information;
- providing access would have an unreasonable impact on the privacy of others;
- the request is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
- providing access would be unlawful;
- denying access is required by law;
- providing access would be likely to prejudice the prevention, detection, investigation and prosecution of possible unlawful activity;
- the information would reveal our commercially sensitive decision-making process; and
- where access would pose a threat to the life or health of any individual.
- the information would reveal our commercially sensitive decision-making process; and
- where access would pose a threat to the life or health of any individual.
If We are unable to give you access to the information you have requested, We will give you written reasons for this decision when we respond to your request. If You have any concerns about the refusal, please see section 13 for further information about how you can give us feedback.
We may charge You a reasonable fee for access to some types of information. This charge will be limited to the cost of recouping Our costs for providing You with the information. For example, document retrieval, photocopy, labour and delivery to You. We will not charge You to make a request to access Your information.
You may request access to your personal information by contacting Us as per the contact details at the end of this document.
7.2 Correcting your personal information
To enable Us to provide you with the best possible service, it is important that the information We hold about You is accurate. We will take reasonable steps to ensure that Your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it. If You believe any information We hold about you is inaccurate, incomplete or out-of-date, You should contact Us to let Us know. We will respond to Your request within a reasonable period and will take reasonable steps to amend Your records.
7.3 Online data collection and use
When you access any Clearly Dental or Bupa Group website (including the Clearly Dental website), we collect certain anonymous technical information about user activities on the website. This may include information such as the type of browser used to access the website and the pages visited.
This information is used by Bupa and Clearly Dental to make decisions about maintaining and improving our websites and online services.
For more information, please refer to the website terms and conditions on www.clearlydental.com.au/terms-and-conditions.
7.4 Cookies and analytics
A "cookie" is a small text file placed on your computer by a web server when you access a website. Cookies are frequently used on websites. Cookies in themselves do not identify the individual user, just the computer used.
You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. For example, you can set your browser to notify you when you receive a cookie or to reject cookies. However, if you decide not to display cookies, then you may not be able to gain access to all the content and facilities of this website.
8. Website Security
The protection of personal privacy is a priority for Us.
Our website does not provide facilities that guarantee secure transmission of information over the internet. You should be aware that there are risks in transmitting information across the internet, including online forms and email. If you are concerned about conveying sensitive or personal material to Us over the internet, contact us by telephone to discuss the matter.
Our website contains links to other websites (for example, Google). You should take care in providing personal information to external websites linked to Our website. We are not responsible for the privacy practices of other websites or external websites linked to this website and separate terms and conditions and privacy policies are likely to apply to your use of those external websites.
We collect standard web server/visitor traffic information, commonly referred to as aggregate information, regarding overall website traffic patterns. Normally, web servers collect this type of basic information as part of their web log processes. We only use this information for statistical, reporting and website administration and maintenance purposes. It is not used in a way that individually identifies You, and We do not report on individual users.
All the before and after photographs on Our website are from actual procedures on patients at our practices. No retouching or other modification has been conducted on the photographs. All patients who appear in these photographs have signed consent release forms and no photos are displayed without their written consent. The photographs published do not predict future patient results, as all customer or patient results are different for each person.
12. Changes to the Privacy Statement
We may change the content or services found on Our website at any time without notice. Consequently Our Privacy Statement may change at any time also without notice.
13. Our Contact Information and Resolving your Concerns
You can contact us at any time if you have any questions or concerns about this document or about how your personal information has been handled.
You can contact our Privacy Officer by directing your correspondence to:
The Privacy Officer, Bupa Dental Corporation, Level 15, 33 Exhibition Street, Melbourne, VIC, 3000
We will manage any concerns internally, directly with you.
If, after contacting Us, You still have concerns or don’t understand a decision We’ve made, You can contact Our Corporate Centre on the contact details below:
PO Box 1439
Lane Cove, NSW, Australia 1595
If You are not happy with Our response, or if You do not feel Your complaint has been resolved, You are able to seek advice from the Office of the Australian Information Commissioner by calling 1300 363 992.