Privacy Policy
Since 12 March 2014, Flinders Fertility has applied the 13 Australian Privacy Principles (APPs), as set out in the Privacy Act 1988 (Cth) (Privacy Act), to the way it collects, holds, uses, and discloses personal information. This policy explains how FF manages personal information in accordance with the Privacy Act 1988 (Cth) and the APPs, including how we collect, store, use, and protect the personal information of our patients, staff, and job applicants.
Flinders Fertility may amend this policy from time to time. Any updates will be published on this website, and the revised version will take effect from the date of posting.
The Australian Privacy Principles
The Australian Privacy Principles (APPs) outline how organisations must handle personal information. They focus on:
- The consideration and collection of personal information.
- The use and disclosure of personal information.
- The integrity and security of personal information.
- The access to and correction of personal information.
Collection and Use of Personal Information
Patient Information
We collect and hold personal information about our patients for the primary purpose of providing safe, high-quality fertility and reproductive healthcare services. The kinds of personal information we may collect and hold include:
- Contact information, such as postal and residential addresses, telephone numbers, and email addresses.
- Details of services provided or requested.
- Health information, medical history, and relevant clinical data.
- Private health insurance, concession card and Medicare details.
- Data relating to online activity on our websites, such as IP addresses or cookies; and
- Survey responses or feedback provided to us.
- We may also collect and hold sensitive information about patients, including:
- Health information (including test results and treatment records).
- Racial or ethnic origin.
- Religious beliefs or affiliations.
- Sexual orientation.
- Genetic information.
This information is used and disclosed only as necessary to deliver clinical care, manage appointments, communicate with patients, meet legal and accreditation requirements, and improve service delivery.
Staff and Job Applicant Information
We also collect, hold, and use personal information about our staff, contractors, and job applicants for recruitment, employment administration, and compliance with relevant laws and standards.
The kinds of information we may collect include:
- Contact details and emergency contact information.
- Employment history, qualifications, registrations, and professional memberships.
- Tax file numbers, bank account details, and superannuation information (for payroll purposes).
- Medical or immunisation information where relevant to workplace health and safety.
- Training and competency records.
- Performance, incident, or professional development records.
This information may be shared with third-party service providers only as required for the business to operate, such as for payroll processing, human resources administration, staff scheduling, or training. Any external providers engaged by the organisation are required to comply with privacy and confidentiality obligations, and only the minimum necessary information is disclosed for these purposes. Where information is shared externally, it is done so securely and in accordance with the Australian Privacy Principles and best practice standards for data protection.
How Personal Information is collected
We only collect sensitive information about patients with their consent, or otherwise in accordance with the Privacy Act, noting that Flinders Fertility is a health service provider. We will only collect personal information where it is reasonably necessary to do so for the conduct of our business. Any collection of personal information by us will be fair, lawful and non-intrusive. We only collect health information if it is reasonably necessary for the delivery of healthcare services.
In the context of our clinical practice, a patient who attends willingly and engages in care is considered to have provided implied consent for the collection of relevant health information, unless they have expressly withdrawn that consent. FF collects personal information about patients in the following ways:
- When information is provided by patients during a consultation with a member of our staff.
- When information is provided by patients or referrers via telephone or facsimile.
- When patients contact us by email or submit information through our website.
- Where reasonable and practical, we will collect personal information directly from the patient.
However, in the course of operating our business, Flinders Fertility may also collect personal information from third parties, such as referring doctors, specialists, or other healthcare providers. Where personal information is collected from a third party, we will, where appropriate:
- Request that the third party inform the patient that we have received their information.
- Explain how the information will be used and disclosed.
- Advise the patient that they may contact FF to access, correct, or update their information.
AI Assisted technology platforms
In February 2025, in line with Flinders Fertility's commitment to delivering high-quality healthcare, an AI-assisted transcription service was introduced primarily to assist with accurately documenting consultations between clinicians/lab and patients, but also for administrative staff to use in their roles.
How do we hold patient information?
We will hold personal information in physical records, electronic records on our servers, and in some cases, records on third party servers. We take active steps to hold all hard copy and electronic records of personal information in a secure manner to ensure that they are protected from misuse, interference and loss, and unauthorised access, modification or disclosure. We have procedures in place to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
How We Use and Disclose Patient Information
Flinders Fertility collects, holds, uses, and discloses personal information primarily for the purpose of providing, coordinating, and improving fertility and reproductive healthcare services. By providing personal information, patients consent to Flinders Fertility using or disclosing their information for the following purposes:
- To deliver and enhance the quality and safety of care provided.
- To communicate relevant information about our services, programs, or upcoming events.
- To send marketing or educational material that may be of interest, where the patient has given consent.
Patients may opt out of receiving marketing or promotional communications at any time by contacting us using the details provided at the end of this policy.
Flinders Fertility may also use or disclose personal information when required or authorised by law. Examples include:
- To prevent or reduce a serious threat to health, safety, or life.
- To meet reporting and reimbursement requirements with Medicare or private health insurers.
- To report assisted reproductive technology (ART) treatment and pregnancy data to the Australia and New Zealand Assisted Reproductive Database (ANZARD), which is reviewed by the Reproductive Technology Accreditation Committee (RTAC).
We may share personal information with related entities or trusted third parties, such as suppliers, technical support providers, or professional advisors, when necessary to facilitate clinical or administrative services. Any third-party disclosure is made only for legitimate business or healthcare purposes, and we take reasonable steps to ensure that all external parties handle personal information securely and in accordance with the Privacy Act 1988 (Cth) and Australian Privacy Principles.
Quality Improvement and Research
We are committed to continuously improving the quality and safety of our services. To support this, we may use information from our medical records for quality assurance, audit, and research purposes. Any information used in this way will be de-identified, meaning that details that could personally identify an individual (such as name, date of birth, or contact details) will be removed.
Participation in these activities helps us and the wider medical community improve patient care, but privacy will always be protected. No identifiable information will be disclosed or published without explicit consent.
How can patients access or correct information?
Patients may request access to, or correction of, their personal information at any time by submitting a written request using the contact details provided at the end of this policy. Patients do not need to provide a reason for requesting access to their information.
Flinders Fertility may charge a reasonable fee if locating or preparing the requested information requires significant time or resources. However, no fee will be charged for correcting personal information held in our records. We aim to respond to all requests for access or correction within a reasonable timeframe and will take appropriate steps to ensure that personal information is accurate, complete, and up to date.
In some circumstances, we may be unable to provide access to certain information, for example, if doing so would unreasonably impact the privacy of others, or if we are legally required to withhold the information. If access is refused, or if a requested correction cannot be made, we will provide the reason for the decision in writing.
Identifiers
Flinders Fertility assigns its own identifiers, being a unique number to identify individuals, and will not adopt government related identifiers in respect of your personal information.
Anonymity
Where practicable, we will allow patients to deal with us anonymously or under a pseudonym. This option will not be available where we are required or authorised by law to deal with individuals who have properly identified themselves, or if we need to verify your identity in order to provide services to you. Further, if you choose not to give us personal information that we request from you, we may not be able to provide you with any goods or services you have asked us to supply.
Cross Border Disclosures of Information
As at the date of this policy, Flinders Fertility will not disclose personal information to overseas recipients unless required according to current legislation of the Australian Privacy Principles Act (1988) (Privacy Act 1988), unless written consent is obtained from you. If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act.
Data Security and Breach Response
Flinders Fertility is committed to maintaining the security and confidentiality of all personal information it holds. Appropriate technical, administrative, and physical safeguards are in place to protect information from misuse, loss, unauthorised access, modification, or disclosure. Information is stored securely in electronic and physical formats with access restricted to authorised personnel only. All staff are required to comply with confidentiality obligations, data protection standards, and secure handling procedures for both clinical and administrative information.
In the event of a suspected or actual data breach, Flinders Fertility follows the OAIC Notifiable Data Breaches (NDB) Scheme and the organisation’s internal Data Breach Response Procedure, which includes:
- Immediate containment of the breach to prevent further exposure. Assessment of the nature, scope, and impact of the breach.
- Notification to affected individuals and the OAIC where required under the NDB Scheme.
- Review and remediation to address underlying causes and prevent recurrence.
All breaches or near misses are recorded and reviewed as part of the organisation’s risk management and governance framework, ensuring continuous improvement in data security practices. Further information about managing and responding to data breaches is available from the Office of the Australian Information Commissioner (OAIC).
Questions or complaints
If you have any questions about the Flinders Fertility Privacy Policy or how we handle personal information, or if you wish to make a complaint, please contact our Privacy Officer or Chief Executive Officer using the details below.
Flinders Fertility takes all privacy concerns seriously and is committed to maintaining transparency and accountability in how personal information is managed. All enquiries or complaints will be acknowledged promptly and assessed by the designated Complaints Manager in consultation with the relevant department(s) and the CEO.
Individuals have the right to:
- Request access to the personal information we hold about them;
- Request correction of inaccurate, incomplete, or outdated information; and
- Raise a concern or complaint about how their personal information has been handled.
All requests and complaints should be made in writing to:
Privacy Officer Flinders Fertility, Level 1, 3–9 Gordon Street, Glenelg SA 5045
Email: enquire@flindersfertility.com.au Phone: (08) 8155 5333
We will acknowledge all privacy-related enquiries or complaints promptly and aim to provide a written response within 30 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) for further review:
Office of the Australian Information Commissioner (OAIC) Website: www.oaic.gov.au Phone: 1300 363 992 Mail: GPO Box 5218, Sydney NSW 2001