Background

Police Health’s primary purpose for collecting information is to conduct a health insurance business and any health related business, including the provision of goods and services either directly or through a third party.

At Police Health, we are committed to maintaining the privacy of individuals whose information we collect in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988.  Police Health aims to manage personal information that it collects in an open and transparent way.  This Privacy Policy describes how we manage personal information.  If you have any queries about the Policy or the manner in which personal information is managed, you may contact Police Health for further information (contact details appear at the end of this Policy).

Collecting and holding personal information

Police Health collects and holds personal information about people insured under a health insurance policy, providers of health services, suppliers, contractors and other contacts to conduct our activities, understand and meet stakeholder needs and meet our legal obligations.  If you do not provide us with the information we ask for, we may not be able to perform these activities and functions, in particular relating to applications for health insurance cover, administering health insurance policies, providing relevant services, assessing and paying claims and meeting statutory reporting requirements.

An individual may deal anonymously with us when seeking general information about Police Health and its products.  It is not practicable for individuals not to identify themselves or to use a pseudonym when dealing with Police Health in relation to the health insurance or claims.

Police Health will collect and hold the minimum personal information required to perform its functions and activities.  This information may include:

  • Contact and identity information, such as names, addresses, age, gender, employment details, government identifiers, passwords, telephone, mobile and facsimile numbers and email addresses.
  •  Financial information, such as premiums, Australian Government Rebate on private health insurance tier level, bank account details, and employment details.
  • Sensitive information, such as information about claims, health services provided to you and your health.
  • Correspondence or correspondence details, verbal and written, hard copy or electronic.

Where possible, the information is collected from you, from a person or organisation authorised to provide the information on your behalf or from another person insured on your health insurance policy.  Information may also be collected from government agencies, business partners, contractors, employers, other private health insurers, other insurers and service providers.

In particular, when you make a claim, you consent to Police Health collecting sensitive (health) information directly from third parties, or if the information relates to someone other than you on the health insurance policy, you give consent on behalf of that person and you must be authorised to do so.

Where you receive treatment at or by a hospital, our contracted third party, the Australian Health Service Alliance (www.ahsa.com.au) collects personal information about your claim to assist us in assessing and paying your claim and assisting us in meeting our statutory reporting requirements.

Personal information may be collected from a person acting on behalf of the insured person or from an organisation or person when authorised by a person acting on behalf of the insured person.  The circumstances of this collection usually relate to an application for a health insurance policy, amendments or additions to a health insurance policy, amendments or changes to personal details and when making claims under a health insurance policy.

Information may be collected by Police Health by voice, electronically or in hard copy and is stored by Police Health either electronically, in hard copy or both electronically and in hard copy.

HAMB Systems Ltd supports our membership management and claims processing system by the provision of software and hosting services. Personal information is held on systems hosted by HAMB Systems Ltd at its sites.  HAMB Systems is subject to the Privacy Act, and Police Health has agreements with HAMB Systems to ensure the integrity and security of personal information and management of the information in accordance with the Australian Privacy Principles.

Police Health collects personal information on a recurring basis, in particular relating to managing your health insurance with us and when making a claim.  This is your notification that Police Health will collect your personal information on a recurring basis.  When you or your authorized representative interact with us and when you receive treatment for which a claim is made on your health insurance policy, it is reasonable for you to expect that Police Health will collect your personal information.

 If you are the Contributor of a health insurance policy with Police Health, you are responsible for ensuring that every person on the health insurance policy is aware of Police Health’s Privacy Policy, particularly as it relates to the collection, holding, use and disclosure of their personal information for the purposes of their cover and verifying that appropriate benefits are paid.  Where you provide personal information to us about another person on the health insurance policy, you must be authorised to do so.

If you are not the Contributor of a health insurance policy with Police Health, but are making a claim, or otherwise providing personal information, on behalf of another insured person, you must be authorized to do so.

If you or any other person on your health insurance policy does not consent to the collection and the way we use and disclose personal information, we may not be able to provide you with cover.

Use of personal information

Personal information is used for a number of reasons such as:

  • Administering the private health insurance fund and your private health insurance policy.  This includes providing a billing and claims payment service involving assessment, processing, control, auditing, benefit review, research and system maintenance and undertaking related regulatory requirements such as Contributor communication and reporting.
  • Enabling Police Health to comply with legislative requirements for the collection of and submission of data to Government agencies.
  • Developing and providing products and services.
  • Communicating with you general information about Police Health, the health insurance industry, health and well being or other material which we consider may be of interest to you.
  • Advising you of direct marketing offers, such as products and services provided by Police Health or on its behalf, which we consider may be of interest to you. Direct marketing material may be brought to your attention by various means and includes being sent to you through electronic communications such as email or text message. This is your consent to receive marketing material for an indefinite period. If you do not want to receive direct marketing material or offers, you can withdraw your consent by contacting us.
  • Resolving business or legal matters, issues or complaints.
  • Purchasing or providing health or health related services on your behalf, including membership of organisations.
  • Part of the security protocols used by staff of Police Health to confirm the identity of the person being dealt with.
  • Undertaking surveys to improve our products and services.
  • Identifying persons that may benefit from risk management, health management and disease management programs and, where the person has consented or the person would reasonably expect Police Health to do so, for the provision of these health programs.
  • Perform any other functions or activities.

Police Health’s functions and activities and its range of products and services may change from time to time.

Disclosure of personal information

Police Health may disclose your personal information (including sensitive health information) to other individuals on your health insurance policy for administering the policy, including for the payment of benefits.  As the Contributor is the holder of the health insurance policy, we disclose all personal information about all insured persons on the policy to the Contributor, including details of all benefits and services claimed on the policy.  We send all communications on health insurance policies, including those that cover more than one person, to the address supplied by the Contributor.  In addition, at the time of joining Police Health, the Contributor authorises Police Health to share personal information amongst individuals on the health insurance policy. 

A person over the age of 14 years may request to have their sensitive information kept private from other persons insured on the policy.  Police Health will endeavour to keep the information private, but will be obliged to disclose information on request by the Contributor of the insurance policy, or a parent or guardian of the person.  If any insured person aged 18 years or older wants to guarantee that their personal information (in particular sensitive information) is not disclosed to other persons on the health insurance policy, they will need to purchase their own health insurance policy.

Police Health may need to disclose personal information to various organisations such as:

  • Government agencies, including Medicare, Private Health Insurance Ombudsman, the Department of Health and the Private Health Insurance Administration Council;
  • Other private health insurers or other health insurance industry bodies;
  • Health service providers;
  • Professional advisers.
  • Persons or organisations authorised by you (this includes other people covered under the same health insurance policy) and your agents and advisers;
  • Insurers or legal representatives of insurers, or statutory authorities such as WorkCover, in relation to claims made for damages or compensation for motor vehicle or other accidents or workers compensation.
  • Organisations contracted by Police Health to assist in the delivery of our functions and services.  This includes our contracted third party agents such as the Australian Health Service Alliance Ltd (Note: From time to time, we disclose personal information to the Australian Health Service Alliance who provides clinical, classification and contract support in order to assist us with correctly assessing a claim for payment and to identify persons who could potentially benefit from a chronic disease management program), organisations that provide mail out services and organisations that supply and support our information technology infrastructure;
  • To business partners who provide services direct to you on our behalf or business partners from which we purchase services on your behalf and this includes organisations that results in you also becoming their client and/or member (note: this may involve the retention of disclosed personal information by the business partner to deliver their services to you);
  • Payment system operators and financial institutions;
  • Your employer; and/or
  • Other parties to whom we are authorised or required by law to disclose information, such as auditors and actuaries.

 Police Health will not sell your contact details or add your contact details to mailing lists of third parties unrelated to your health insurance policy without your prior consent.  Police Health will require that business partners and contractors comply with the Australian Privacy Principles.

 Police Health is not likely to disclose your personal information to overseas recipients.

Security

Police Health takes all reasonable steps to ensure that your personal information is kept secure and protect your information from misuse, loss and unauthorized access, modification or disclosure.  Paper documents are protected from unauthorized access through the application of a security system at our premises.  Computer and network security systems include, amongst other things, the use of firewalls, encryption technology and password protection.

Police Health Internet website and electronic exchanges

When you visit the Police Health website, a record of your IP Address is collected and from this your Internet Service Provider can be determined.  This is a standard function of all web-servers.

Police Health makes limited use of cookies.  Non-persistent cookies are generated when you enter the “Check your Details” section of the website and log in.  These cookies are deleted when you close your browser or it expires.  If you do not want to use cookies, you can set your browser to selectively accept cookies or reject them, but this may affect the availability of some features of the website.

You acknowledge that the Internet is not a secure environment.  Police Health can not guarantee the security of information you send and receive by electronic means, and hence electronic exchanges are undertaken at your own risk.

Police Health provides links to third party sites.  These sites are not under the control of Police Health and hence Police Health is not responsible for any practices by these third parties that may breach your privacy.  Police Health encourages you to review the privacy policies of these third parties.

Use and access of the Police Health website must be in accordance with the terms and conditions published on the website.

Police Health provides Contributors with access to Online Member Services in accordance with the published terms and conditions.  

Correcting, updating and accessing of personal information

Subject to any legislation, an individual has a right to request reasonable access to their personal information and to request its correction.  Generally, obtaining access, updating and correcting your personal information is undertaken by our Customer Services Officers using one of the points of contacts listed further below. 

Depending on the information and how it is stored, information may be viewed at Police Health, accessed through the Online Member Service or sent to the requestor.  Police Health reserves the right to charge an administration fee for the provision of the information to cover costs incurred.

Police Health has the right to withhold the release of personal information in certain circumstances.

The accuracy of your personal information is important to us.  If you believe that any personal information is not accurate, complete or up to date, Police Health should be advised in writing as soon as practicable.

Complaints

Questions about Police Health’s Privacy Policy and privacy practices, requests for access and correction of personal information that you believe have not been addressed or complaints about a possible breach of privacy should be directed to the Privacy Officer using the contact details listed below. 

Contact details for Police Health

Postal Address:        PO Box 6111

    Adelaide  SA  5001

Phone number:        Adelaide local - (08) 8112 7000

                                    Other areas - 1800 603 603

Facsimile number:  (08) 8112 7099   

Email address:        enquiries@policehealth.com.au

Information about Privacy

Information about privacy, including links to the Privacy Act 1988 and the Australian Privacy Principles can be found on the Website of the Office of the Australian Information Commissioner http://www.oaic.gov.au.

Privacy Statement changes

From time to time, Police Health may modify this Policy.  Where this occurs we will publish the new Privacy Policy on our website www.policehealth.com.au.

Policy Administration

Date Policy Approved                           7 May 2014

Policy Review Date                               31 March 2017

Oversight Responsibility:                      Risk Management and Compliance Committee