Privacy Policy

Our commitment to privacy

Centre for Corporate Health Pty Limited (ACN 086 346 036) and its related companies in Australia (collectively referred to as “CFCH”) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our “Privacy Policy”.

In this Privacy Policy, “we”, “our” and “us” refers to CFCH and “you” refers to any individual about whom we collect personal information and/or sensitive information.

About Centre for Corporate Health

Since 1999, CFCH has been working with organisations and their personnel to assess, treat and prevent a range of corporate health problems and to build resilient workplaces. CFCH’s services include assessing, managing and treating workplace psychological injuries, providing training and coaching to improve leadership and managerial competency and providing Employee Assistance Programs (“EAPs”) to workplaces (collectively the “Services”). CFCH operates a website at www.cfch.com.au (“the Website”).

What information does CFCH collect about you?

The kinds of personal information we collect will depend on the capacity in which you are dealing with us. Generally, it would include your name, contact details and information regarding our interactions and transactions with you.

  • Individuals using our Services

When you commence using our psychological services, we may collect your contact details (such as your name, address and email); details of your date of birth and gender; personal details which pertain to our Services, insurance reports and information relating to insurance claims including witness statements; health information and/or medical and mental health history and contact details for nominated treating practitioners.

As part of administering our Services, CFCH may need to collect health information. When collecting health information regarding you, CFCH will obtain your consent to collect this information and inform you how it will be used and disclosed. If CFCH does need to obtain this information, you will be asked to sign a consent form authorising CFCH to do so.

CFCH will not use the information beyond the consent provided by you, unless your further consent is obtained or the use is in accordance with one of the exceptions under the Privacy Act or in compliance with another law.

Where possible, we collect your personal and sensitive information directly from you. We collect information through various means, including telephone and in-person interviews, during appointments and from forms and questionnaires. If you feel that the information we are requesting, either on our forms or in our discussions with you, is not information that you wish to provide, please feel free to raise this with us.

  • Corporate clients

When you enquire about our services on behalf of your company or when your company becomes a corporate client of CFCH, the types of personal information that we collect from you will vary depending on the circumstances of collection and the kind of service that you request from us, for example, if you are our key contact at your company, if you attend any training that we may provide or use our coaching services. Collected information will typically include:

  • your name, email address, postal address and other work-related contact details;
  • information about your employer or the organisation that you represent;
  • your professional details; and
  • any additional personal information you provide to us, or authorise us to collect, as part of your interaction with us.
  • Insurers

If you represent an insurer (for example, if you are a Case Manager), we may collect the following:

  • your name, email address, postal address and other work-related contact details;
  • information about your employer or the organisation that you represent;
  • your professional details; and
  • any additional personal information you provide to us, or authorise us to collect, as part of your interaction with us.
  • Prospective employees and job applicants

We collect personal information when recruiting personnel, such as your contact details (name, address, telephone numbers and email address); details including emergency contact information, date of birth, country of birth, citizenship, residency and/or visa details; details of current/previous employment; skills and experience; languages spoken and written; qualifications, and driver’s licence details.

Generally, we will collect this information directly from you. However, we may collect your personal information from recruiters we use or your referees. If you accept an offer of employment, we will collect your Tax File Number and details of your superannuation fund.

  • Other individuals

We may collect personal information about other individuals who do not fall within the categories above. This may include details of the next-of-kin of users of our Services, members of the public who participate in events we are involved with, individual service providers and contractors to CFCH and other individuals who interact with us on a commercial basis.

How and why does CFCH collect and use your personal information?

CFCH collects personal information which is reasonably necessary to carry out our business and to provide our Services.  We may also collect information to fulfil administrative functions associated with these Services, for example billing, entering into contracts with you or third parties and managing client relationships.

The purposes for which we usually collect and use personal information depends on the nature of your interaction with us, but may include:

  • Individuals receiving our Services

Your personal information will be used to provide you with our Services including the following:

  • to conduct one or more assessments of your psychological health and well-being;
  • to provide you with the most appropriate Services for your needs, including treatment and counselling;
  • to monitor and investigate existing Services which are being provided to you and plan for future services;
  • if relevant to your circumstances, to provide outcomes of Services to your Case Manager from the insurance company or referring company; and
  • to comply with our legal obligations.
  • Corporate Clients, Insurers and Suppliers

Your personal information will be used to administer and manage our relationship with your company, for example:

  • if you are a key contact at a corporate client, we may use your personal information to engage with you to provide contracted services, for example, if CFCH is preparing a customised Mental Health Intervention Framework for your company, providing training or coaching services or operating your company’s EAP; or
  • if you are an insurer, for example, we may liaise with you to provide progress reports about an insured or assist with a case review.
  • Other Uses of Personal Information

Your personal information may also be used, for example, for the following purposes:

  • responding to requests for information and other general inquiries;
  • managing, planning, advertising and administering programs, events, competitions and promotions;
  • for recruitment purposes, such as assessing suitability for employment, providing performance feedback, making payments and to meet legislative requirements;
  • to send direct marketing messages;
  • for internal business and management processes; and
  • responding to complaints.

CFCH also collects and uses personal information for market research purposes and for service innovation. De-identified and aggregated data, such as statistics, may be provided to our corporate clients, insurers and third parties from time to time.

CFCH generally collects personal information directly from you. We may collect and update your personal information via the Website, over the phone, by email, over the internet (such as when we provide our Services remotely) or in person.

We may also collect personal information about you from other sources, for example:

  • your employer, if your employer has engaged us to provide our Services to its workforce;
  • your insurer, if our Services are being provided in connection with, for example, an insurance claim, or if we have been requested by your insurer to assist with a case review;
  • treating practitioners such as general practitioners, physiotherapists and occupational therapists;
  • if you are a job applicant, from recruitment agencies or referees you have nominated. If relevant to the position you are applying for, we may conduct a background check;
  • our related companies;
  • relevant regulatory bodies; and
  • third party suppliers and contractors who assist us to operate our business.

How does CFCH disclose personal information?

  • Individuals using our Services

Your personal information and your sensitive information (where you have provided consent) may be disclosed to other organisations including:

  • the company who referred you to CFCH for particular Services (for example, your Case Manager at the insurance company who is looking after your Workers Compensation Claim, or the HR manager from your place of employment who asked you to participate in Services provided by CFCH);
  • Emergency Services such as ambulance, police and the fire brigade who may be called upon to assist during the delivery of CFCH programs;
  • CFCH employees/contractors who manage some of the Services we offer to you, such as CFCH Rehabilitation Managers; and
  • doctors and health care professionals, who assist us to deliver our Services and/or your treating psychologist.
    • Corporate clients and insurers

The purposes for which we may disclose your personal information will depend on the Services we are providing you. For example, if you have engaged us to deliver a Service, we may disclose information about you to service providers where this is relevant to our Services.

  • Disclosure to contractors and other service providers

CFCH may disclose information to third parties we engage in order to provide our Services, including contractors and service providers used for data processing, data analysis, client and user satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs and market research. Information disclosed is limited to the information which is reasonably necessary for these third parties to perform their limited functions for us.

Personal information may also be shared between related companies of CFCH, located in Australia.

Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

  • Disclosure for administration and management

CFCH will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

  • administering billing and payments and debt recovery;
  • planning, managing, monitoring and evaluating our services;
  • quality improvement activities;
  • statistical analysis and reporting using aggregated and de-identified data;
  • training staff, contractors and other workers;
  • risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
  • responding to enquiries and complaints regarding our services;
  • obtaining advice from consultants and other professional advisers; and
  • responding to subpoenas and other legal orders and obligations.
  • Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

Except as set out above, CFCH will not ordinarily disclose an individual’s sensitive information to a third party unless:

  • the individual has consented to the disclosure; or
  • the disclosure is authorised or required by law.
  • CFCH is satisfied that harm will come to an individual or the public if the disclosure is not made; or
  • the individual was told at the time the information was collected that a disclosure to a third party would be made.

We will not sell your personal information to any third party.

Does CFCH disclose your personal information overseas?

CFCH does not routinely disclose personal information to overseas recipients.

How does CFCH interact with you via the internet?

You may visit our Website (www.cfch.com.au) without identifying yourself. If you identify yourself (for example, by providing your contact details in an online enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy.

Our Website uses cookies. A “cookie” is a small file stored on your computer or other device’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our Website and on third-party websites. Cookies are used to assist the Website to remember users.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our Website.

CFCH’s Website may contain links to third-party websites. We are not responsible for the content or privacy practices of websites that are linked to our Website.

Can you deal with CFCH anonymously?

If you would like to access any of the Services on an anonymous basis or by using a pseudonym, please ensure that you inform us.

CFCH will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for us to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise the Website, our Services or participate in our events, training programs or activities that we may manage or deliver.

How does CFCH hold information?

We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).

CFCH maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems. Our IT systems comply with relevant security standards. Only authorized personnel are permitted to access these systems. Individual login credentials are encrypted.

Digital data, including personal information collected via the Website, is stored in Australia.

We take reasonable steps to destroy or de-identify information that we no longer require.

Does CFCH use or disclose your personal information for direct marketing?

CFCH may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and training events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.

If you opt-out of receiving marketing material from us, we may still contact you in relation to our ongoing relationship with you.

How can you access or seek correction of your personal information?

You are entitled to access your personal information held by CFCH on request. To request access to your personal information, please contact our Privacy Officer using the contact details set out below.

You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a written reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

What should you do if you have a complaint about the handling of your personal information?

You may contact CFCH at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer using the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.

Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

How changes are made to this Privacy Policy?

We may amend this Privacy Policy from time to time. We will publish any changes to the Privacy Policy on our Website at www.cfch.com.au.

We encourage you to review the Privacy Policy regularly for updates and amendments. 

How can you contact CFCH?

Our contact details are:

The Privacy Officer
Centre for Corporate Health Pty Limited
PO Box Q197
Queen Victoria Building NSW 1230

Last Updated: This Privacy Policy was last updated on 6 March 2020.