Bupa Wellness collects personal information from you before and during our “Services”. If you do not provide all of the information Bupa Wellness requests, we may be unable to provide the services to you. Bupa Wellness may disclose your personal information to its employees, agents, sub-contractors or anyone we engage in providing the services. We may also disclose your personal information to others if required or permitted by law. For example, if we reasonably believe that disclosing the information may lessen or prevent a serious and imminent threat to life, health or safety. You have a right to reasonable access to any information that Bupa Wellness holds about you.
When collecting personal information, Bupa Wellness will, where possible, indicate the purpose for the collection and use of the information, to whom it may be disclosed and how you can request access to the information.
Purpose for Collecting Information
Bupa Wellness only collects information that is needed in order to provide its services. Bupa Wellness provides employee and student health management services to organisations and educational institutions. Its services include, but are not limited to:
- Health promotion activities and events
- Health check screenings
- Executive health assessments
- Group fitness classes
- Massage services
- Ergonomic services
- Influenza vaccination services
- Seminars and webinars
- Online health and wellness resources, e.g. videos, podcasts
- Cooking demonstrations and nutritional consultations.
To effectively provide such services, Bupa Wellness needs to collect certain personal information to ensure the health and safety of individuals participating in its services and to assist in determining the type of services we provide for clients.
Type of Information Requested
Personal information that Bupa Wellness may request includes but is not limited to:
- your name (and signature)
- e-mail address
- phone number
- date of birth
- sensitive information* and
- student ID information (for under 18’s).
- racial or ethnic origin
- sexual health (Student Health Reviews) and gender
- health or genetic information
- biometric information
- Gillick competency testing questions (for under 18’s)
- feedback on services.
* Sensitive information is personal information that includes information or an opinion about:
Bupa Wellness will endeavour to collect all information directly from you. However, on occasion, we may also collect information from other sources, such as from your employer or educational institution.
Use of Personal Information
Bupa Wellness uses the personal information it collects for the purposes of providing, managing and administering appropriate services to you. This includes, but is not limited to:
- scheduling and booking activities and services
- ongoing health monitoring
- selection of various activities and services to offer clients and their staff and/or students
- identifying health risk factors for individuals
- processing payments
- answer your queries and resolve complaints
- quality assurance, service improvement and client satisfaction
- carrying out internal functions like administration, finance, information technology, training and audit;
- conduct marketing and promotional activities;
- conduct research, customer surveys and statistical analysis
- practicing effective risk management
- complying with relevant laws and regulations.
Disclosure of personal information
To be able to effectively provide our services, Bupa Wellness may disclose information to others within Bupa Wellness and to its related companies within Australia and New Zealand. In order to provide, manage and administer our services and to operate an efficient and sustainable business, Bupa Wellness may also disclose information to third parties which may include (but are not limited to) the following:
- contractors or service providers engaged by us
- healthcare referral providers (with your consent or the consent of your authorised representative)
- any persons acting on our behalf, including professional advisers
- on a confidential basis, with our related companies within the Bupa Group
- external auditors engaged by us
- government and regulatory bodies and
- where disclosure is permitted or required by law.
We will disclose your personal information to your employer or educational institution for the purposes of booking your participation in the services and confirming you have attended, and to administer the services within your organisation or educational institution. We will not disclose any information about your health to your employer or educational institution. However, we will disclose de-identified aggregated data resulting from the services your employer or educational institution.
Bupa Wellness will not provide de-identified reporting where the data sample relates to less than 30 individual participants. We will always seek your permission to disclose your personally identifiable information to your employer about what services you have undertaken. Where we engage contractors, service providers or others to act on our behalf, Bupa Wellness will take reasonable steps to protect the privacy of all information disclosed and requires such parties to comply with any relevant Privacy Laws. In the course of operating our business we may in some instances disclose information to recipients located outside of Australia, including in the United Kingdom. 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.
In the interests of public health, if we are alerted that somebody is infected with, or at increased risk of infection with COVID-19, who you are likely to have come into contact with when you received services from us, we will notify the Department of Health and provide them with your name, email address and phone number, so that they can notify you and you can take the necessary precautionary measures.
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 or services that can help you improve your health and wellbeing. 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 and bodies corporate 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 please contact us at any time to let us know. 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 ongoing 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.
Bupa Wellness will take reasonable steps to ensure that the personal information it collects, uses and discloses is accurate, correct and up-to-date. We do this according to our own internal quality and auditing procedures based on ISO 9001:2015 Quality Management System principles.
Personal Information Storage and Security
Bupa Wellness holds personal information in a combination of secure electronic and hard-copy formats. The information we hold is stored within Australia. We take all reasonable steps to ensure that any personal information held by us is protected from misuse, loss and unauthorised access, modification or disclosure. Such steps include, but are not limited to:
- locked and secure physical storage of documents
- premise entry security measures
- network and communications security measures
- quality system procedures.
Bupa Wellness will keep information for as long as it is required to be able to provide the intended services or to meet legal and regulatory requirements. Bupa Wellness will take reasonable steps to permanently de-identify or securely destroy personal information that we no longer require for any purpose except in limited and permitted circumstances.
Accessing your personal information
You have a right to reasonable access to any information that Bupa Wellness holds about you. To request access to your information, please contact us using the contact details at the end of this document. You will be asked to put your request in writing and provide supporting information that identifies you including:
- your name and work address
- the personal information you want
- how you’d like to access the information (e.g. view only access or in hard-copy) and
- if you authorise a person or organisation to access the personal information on your behalf.
We reserve the right to charge you for the cost of retrieving information, assessing the information request (including using an intermediary if necessary) and to provide you access to certain information, as permitted by law. You will be informed of this at the time of making a request. We will always endeavor to meet your request for access within a reasonable timeframe and in the manner requested by you, if it is reasonable to do so. In some circumstances we may decline a request for access to information such as:
- it may threaten your or someone else’s life, health or safety
- it may impact someone else’s privacy and/or
- giving access would be unlawful.
We will give you a response in writing telling you the reasons why your request has been declined and how you can access further external support.
Integrity and Correction of 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 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. We will ask you to put your request in writing and provide supporting information that identifies you including:
- your name and work address
- the personal information you want corrected
- We will respond to your request within 30 days and take reasonable steps to amend your records which may include:
- adding, changing or deleting your personal information or
- we may refuse to correct your personal information because doing so would be unreasonable
We may also have a legal requirement to keep some information we hold about you for a certain period of time and we may not be able to amend or delete this information during this period, as permitted by law.
Your privacy online
Online data collection and use
When you access any Bupa website, anonymous technical information may be collected about your 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 to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details. For more information, please refer to Bupa’s website terms and conditions on https://www.bupa.com.au/terms-and-conditions
Phone: 1300 881 580E-mail: CustomerServiceWellness@bupa.com.au.
If you are not happy with our response, you can seek further advice from the Office of the Australian Information Commissioner by calling 1300 363 992.