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Privacy Policy

Purpose

The purpose of this policy is to ensure that Kanda (being Blue Network Holdco Pty Ltd and its wholly owned subsidiaries (as defined in the Corporations Act 2001 (Cth) meet our legislative responsibilities under the Privacy Act 1988 and Australian Privacy Principles. 

This Privacy Policy outlines how Kanda collects, uses, discloses and protects personal, sensitive or health information when you use our services or website. 

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/. 

Scope

This policy applies: 

  • to all personal, sensitive or health information including the personal information of employees and clients. 

This policy is applicable to all representatives including key management personnel, directors, full-time workers, part-time or casual workers contractors and volunteers of 

  • Blue Network Holdco Pty Ltd 
  • Kanda Management Services Pty Ltd 
  • Kanda Healthcare Pty Ltd 
  • Kanda PHP Pty Ltd 

 

Policy 

Kanda values your privacy. We are committed to protecting and handling your personal, sensitive or health information in accordance with all relevant legislative requirements. 

Types of information we collect

We collect and hold a range of personal, sensitive or health information in order to deliver our care services and carry out our business functions.  

The kinds of information we collect and hold about you will depend on the nature of your relationship with us and the circumstances of a collection, including whether we collect the information from you as a client, service provider, supplier, job applicant or some other capacity. 

1. Client

If you are a client, we may collect personal information about you when it’s reasonably necessary for or directly related to the provision of services.  

The kinds of personal information may include: 

  • name, signature, address, phone number or date of birth  
  • internet protocol (IP) addresses 

Sensitive information including health information

We may collect sensitive information about you: 

  • when you consent 
  • when the collection is authorised or required by law 
  • where the collection is otherwise allowed under the Privacy Act 

Sensitive information is personal information that includes information or an opinion about an individual’s: 

  • racial or ethnic origin 
  • political opinions or associations 
  • religious or philosophical beliefs 
  • trade union membership or associations 
  • sexual orientation or practices 
  • criminal record 
  • health or genetic information 
  • some aspects of biometric information. 

Our use of client information is also regulated by, the National Disability Insurance Scheme Act 2013, the Aged Care Act 1997, Child Protection Act 1999, Children’s Guardian Act 2019, state privacy legislation and state health records legislation. 

2. Suppliers and service providers

If you are a contractor, supplier or service provider to us (such as IT service providers, medical equipment supplier, repairs and maintenance), we may collect personal information about you, or your employees and contractors, such as: 

a. your name and contact details 

b. your job title, job history, organisation or company name 

c. inancial details such as your bank account to make payments to you 

d. information about performance of the contract or other arrangement between us, and 

e. communications between us.

3. Job applicants

If you apply for a job with us, we may collect information directly from you when you complete an online job application or through an external party, such as a recruitment agency. The information collected may include: 

  • your name and contact details 
  • your resume, covering letter and academic transcript 
  • information provided on your application form or resume, including education level, tertiary institution, language skills, jurisdictions you are qualified to practice in (if applicable), employment history and any other background information relating to your right to work in Australia 
  • information provided to us during an interview or assessment 
  • references from past referees, including past employers 
  • skills and background checks, which may include a criminal history check. 

If you are or become an employee, the handling of your personal information may be exempt from the APPs if it is directly related to your current or former employment relationship with us. 

4. Anonymity and use of pseudonyms

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you. 

5. How we collect personal information

We will collect personal Information about you directly from you, in most cases. 

However, there are some circumstances where it is unreasonable or impracticable for us to do so, we will collect a. personal information from third parties, such as: 

b. associated businesses, government agencies, courts or tribunals, licensing bodies 

c. service providers, including recruitment agencies 

d. referees and previous employers, when you provide references to us in the course of a job application 

e. other third parties that you refer us to 

publicly available sources, such as social media and online searches. 

Where you provide us with the personal information of an individual, you must make that individual aware that we are collecting their personal information and refer them to this Privacy Policy.  

You must only provide Sensitive Information about another individual where you have that individual’s consent to do so. 

6. Purposes of collection, use, disclosure and holding personal information

We collect, hold, use and disclose personal information for the purpose for which it was collected and otherwise as permitted under the Privacy Act.  

We collect, hold, use and disclose personal information for a range of purposes including: 

a. to supply our services 

b. to respond to your enquiry and communicate with you about your enquiry 

c. to verify and process payments 

d. for our administrative, insurance and risk management purposes and internal record keeping 

e. to provide you with support and deal with any complaints or feedback you have 

f. to manage our relationships with our clients, service providers, suppliers and contractors 

g. to consider job applicants for current and future employment 

h. for marketing, business development and direct marketing purposes, including to organise events 

We may use and disclose your personal information for other purposes required or authorised by or under law (including purposes for which you have provided your consent).

7. Disclosure of personal information to third parties

We may disclose your personal information to third parties in accordance with the Policy in circumstances where you would reasonably expect us to disclose your information.  These third parties may include, where appropriate: 

  • financial institutions for payment processing and fraud detection and management 
  • our contracted service providers 
  • in the case of a sale of our business (in whole or in part) to the purchaser (as an asset of the business) 
  • if you are a job applicant, referees whose details you provide to us. 

We will not send you marketing emails or texts without your consent. 

8. Retention of personal information

We will not keep your personal information for longer than we need to. When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years. 

9. Online activity

When you access our websites, we may collect information from and about your device including 

a. browser type 

b. language preference 

c. referring site 

d. the date and time of each visitor request and 

e. Website usage statistics, such as the pages viewed, and the length of time viewed. 

We cannot identify you from this information. If collected, this information will be used and disclosed by us in anonymous, aggregated form only, for purposes including statistical analysis and website development. 

We also use cookies on our websites.  A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website(s) before, so we can distinguish you from other users of the website.  

We do not use cookies to identify you, just to improve your experience on our website(s). 

10. Overseas disclosure

Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if: 

  • you have given us your consent to disclose personal information to that third party, or 
  • we have an enforceable contractual arrangement with the overseas recipient that requires the recipient to handle the personal information in accordance with the Australian Privacy Principles 
  • the disclosure is required or authorised by an Australian law or court / tribunal order. 

11. How we hold, store and protect personal information

We generally hold personal information in computer systems, including computer systems operated for us by our service providers. We do maintain some paper records which contain Personal Information.  

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

12. Requests for access and correction

You have a right to request access to your personal information we hold and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. For access and correction, contact our Privacy Officer at the details below. 

In order to protect your personal information, we may require identification from you before releasing the requested information. 

13. Complaints and concerns

Please contact us at the address below if you would like any further information, or have any concerns or complaints, about the manner in which we have collected or handled your personal information or would like to complain about a breach of the APPs. We will respond to complaints within a reasonable period (usually 30 days). 

If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Office of the Australian Information Commissioner at oaic.gov.au, calling 1300 363 992 or emailing enquiries@oaic.gov.au. 

14. Contact

If you would like more information about the way we manage personal information, would like to request access to or correction of personal information that we hold about you, or wish to make a complaint, please contact us. 

Privacy Officer 

Email:  privacy@cruxms.com.au 

Write: PO Box 446, Bundaberg, Qld.  4670 

Call:  07 41335887 

 

Definitions

Information 

Information is defined in the Privacy Act to mean information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. 

Sensitive information 

Sentitive information is a sub-set of Personal Information and is defined in the Privacy Act to mean information or an opinion about an individual’s racial or ethnic origin; political opinions, religious or philosophical beliefs or affiliations; memberships of trade union, trade or professional association; sexual orientation or practices; criminal record; health information, genetic or biometric information, or biometric templates. 

Legislation

Privacy Act 1988 

National Disability Insurance Scheme Act 2013 

Aged Care Act 1997 

Child Protection Act 1999 (Qld) 

Health Records and Information Privacy Act 2002 (NSW) 

Health Records Act 2001 (Vic) 

Health Care Act 2008 (SA) 

Health Records (Privacy and Access) Act 1997 (SA) 

Health Records Act 2001 (WA) 

Health and Disability Services (Complaints) Act 1995 (WA) 

Health Records (Privacy and Access) Act 1997 (ACT) 

Information Privacy Act 2009 (Qld) 

Privacy and Personal Information Protection Act 1998 (NSW) 

Privacy and Data Protection Act 2014 (Vic) 

Government Information Privacy Act 2009 (SA) 

Information Privacy Act 2014 (ACT)