Privacy Policy

NeuroHearing is committed to providing quality hearing care to you. This policy explains how we collect, use, store, and protect your personal information, and what your rights are.

We have adopted the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). Because we are a health service provider in Victoria, we also follow the Health Privacy Principles in the Health Records Act 2001 (Vic).

Some of the care we provide is delivered under the Australian Government Hearing Services Program. Records for that care carry extra rules, set by the Commonwealth. Those rules are set out in the Hearing Services Program records section below.

A copy of the Australian Privacy Principles is available from the Office of the Australian Information Commissioner at oaic.gov.au.

What is personal information, and why do we collect it?

Personal information is information or an opinion that identifies you. Examples of personal information we collect include your name, address, email address, phone number, date of birth, and Medicare, pension, or Department of Veterans’ Affairs card details.

We collect this information in a number of ways:

• Directly from you, in the clinic, by phone, by email, or by letter
• From forms you complete on our website and our campaign landing pages
• From our online hearing self-check
• From cookies and similar technology when you use our website (see Our website)
• From your doctor, specialist, or another treating practitioner who refers you to us
• From a family member, carer, guardian, or power of attorney acting for you
• From the Australian Government Hearing Services Program, where you hold a voucher
• From a previous hearing service provider, where you transfer your care to us

We collect your personal information so that we can:

• Assess your hearing and provide your clinical care
• Fit, program, service, and repair your hearing devices
• Book, confirm, and remind you about your appointments
• Bill you, and claim from the Hearing Services Program, Medicare, the Department of Veterans’ Affairs, or your private health fund
• Communicate with your doctor or specialist about your care
• Meet our legal, contractual, and professional obligations
• Send you information about our services, where you have not opted out

We may also use your information for a purpose closely related to the one above, where you would reasonably expect us to. You can opt out of our marketing at any time. See Direct marketing.

When we collect your personal information we will, where reasonable, tell you why we are collecting it and how we plan to use it.

If you do not give us the information we ask for, we may not be able to provide you with safe and appropriate hearing care.

Sensitive and health information

Sensitive information is defined in the Privacy Act to include information about your racial or ethnic origin, political opinions, religious beliefs, membership of a professional body or trade union, criminal record, and your health.

We will only use your sensitive and health information:

• For the primary purpose for which it was collected, which is your hearing care
• For a directly related secondary purpose you would reasonably expect
• With your consent
• Where required or authorised by law

We do not use your health information for marketing without your consent.

Third parties

Where it is reasonable and practical, we collect your personal information only from you.

Sometimes we are given information about you by someone else. This is usually your referring doctor, a specialist, a family member or carer acting for you, or a previous hearing service provider. Where that happens, we will take reasonable steps to make you aware of what we were given.

Disclosure of your personal information

We may disclose your personal information to:

• Your doctor, specialist, or other treating practitioners, so your care is coordinated and safe. Our clinical policy requires us to write to your doctor in certain situations, for example where a hearing result needs medical review before we fit a device.
• Hearing device manufacturers and suppliers, so a device can be ordered, custom made, programmed, serviced, repaired, or claimed under warranty.
• The Australian Government Department of Health and Aged Care, for the Hearing Services Program, including eligibility checks, claims, audits, and compliance reviews.
• Medicare, the Department of Veterans’ Affairs, and your private health fund, where a claim is made.
• Our software and IT providers, who host our patient records, appointment booking, email, and accounting systems on our behalf under contract.
• Our professional advisers and insurers, where needed.
• Anyone you consent to, including a family member, carer, or representative you nominate.
• Anyone else where required or authorised by law.

We do not sell your personal information. We never sell a Hearing Services Program client record, which is prohibited under our contract with the Commonwealth.

Legal requests and summonses

If we receive a summons or a legal request for the clinical information of a Hearing Services Program client, we do not release the record to the requester. We refer the request to the Hearing Services Program at hearing@health.gov.au, and the Program handles it.

Overseas disclosure

Some of the software we use to run the clinic is supplied by companies based overseas. This means some of your information may be stored or processed outside Australia. Where that happens, we take reasonable steps to make sure the provider handles your information in a way consistent with the Australian Privacy Principles.

Information that may be stored or processed outside Australia:

Under our contract with the Commonwealth, we do not store or take a Hearing Services Program client record outside Australia without the Commonwealth’s prior written consent.

If you would like more detail about a particular system, contact us using the details at the end of this policy.

Our website

Our website and our campaign landing pages use cookies and similar technology. These help the site work, help us understand how people use it, and help us measure our advertising.

We use:

• Meta (Facebook and Instagram) advertising tools, which record that a visit or an enquiry came from one of our ads
• Google advertising and analytics tools, for the same purpose

These tools may set cookies in your browser and share limited information with Meta and Google. They do not receive your clinical information.

You can block or delete cookies in your browser settings. Some parts of our site may not work properly if you do.

Our website may link to other websites. We are not responsible for the content or the privacy practices of those sites.

Direct marketing

We may send you information about our services, hearing health, and clinic news by email, SMS, post, or phone.

Opting out of marketing does not stop appointment reminders or messages about your care.

We comply with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

Security of your personal information

Your personal information is stored in a way that reasonably protects it from misuse, interference, loss, and unauthorised access, modification, or disclosure.

We do this using:

• Password protected and access controlled clinical systems
• Encryption of information in transit and at rest in our patient records system
• Locked premises and secure storage for any paper records
• Staff training and confidentiality obligations
• Restricting access to only those who need it to do their job

We only access your record where we have your consent, or where the law allows it. Where you transfer to or from another provider, we confirm your identity using four points of identification before your record is accessed.

Data breaches

If we suspect a data breach that is likely to cause you serious harm, we will assess it and, where the law requires, notify you and the Office of the Australian Information Commissioner. Where the breach involves a Hearing Services Program record, we also notify the Department within the timeframes our contract requires.

How long we keep your information

We keep your clinical record for at least 7 years from the last time you received a service from us.

If you were under 18 when we last saw you, we keep your record until you turn 25.

When personal information is no longer needed and we are permitted to dispose of it, we take reasonable steps to destroy it securely or permanently de-identify it.

Hearing Services Program records

If we provide services to you under the Australian Government Hearing Services Program, some extra rules apply to your record:

• Your record is owned by the Commonwealth. We hold it in trust.
• We cannot destroy or delete it. See the destruction freeze above.
• We cannot sell it.
• We cannot store or take it outside Australia without the Commonwealth’s written consent.
• We will not access it without your consent and four points of identification.
• If you move to another provider, your complete file transfers directly from us to them. You will never be asked to collect it yourself, and we will not contact you to pressure you into staying.

Conditions apply under the Australian Government Hearing Services Program.

Access to your personal information

You have the right to see the personal information we hold about you, and to ask us to correct it. Some limited exceptions apply, for example where giving you access would pose a serious threat to someone’s life, health, or safety, or where the law prevents it.

To request access, contact us in writing using the details below. We will respond within 30 days.

We do not charge a fee for making a request. We may charge a reasonable administrative fee for providing a copy of your information, and we will tell you the amount before we proceed.

To protect your privacy, we will ask you for identification before we release any information.

If we refuse access or refuse to correct your information, we will tell you why in writing, and we will tell you how to complain.

Keeping your information accurate

It matters to us that your information is accurate and up to date, because we use it to make clinical decisions.

We take reasonable steps to keep your information accurate, complete, and current. If anything we hold is wrong or out of date, please tell us as soon as you can so we can correct it.

Policy updates

We may update this policy from time to time. The current version is always available on our website.

Complaints and enquiries

If you have a question or a complaint about your privacy or about this policy, please contact us first. We take complaints seriously and we will work to resolve it with you.

We will acknowledge your complaint promptly and respond within 30 days.

If you are not satisfied with our response, you can take your complaint to:

If your complaint relates to services delivered under the Hearing Services Program, you can also contact the Program directly at hearing@health.gov.au.