ACA Health Benefits Fund Limited (ACA Health) is committed to maintaining the privacy of individuals whose personal information it collects in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which ACA Health collect, use, disclose, store, secure and dispose personal information.

A copy of this policy may be obtained from ACA Health’s website. If you require a copy of this privacy policy in another form, you may contact ACA Health at any time. ACA Health’s contact details are set out below.

1. What kind of personal information is collected and held by ACA Health?

The kind and extent of personal information collected and held about you depends on whether you are an existing or former member of ACA Health, an applicant to become a member of ACA Health, or whether you have only made enquiries about ACA Health’s products and services.

The personal information ACA Health collects and holds about you may include:

• your name, address and contact details
• your date of birth, gender and marital status
• information concerning your family and domestic relationships (including your relationship to any person insured or proposed to be insured under the same policy as you)
• your employer
• your relationship to other persons insured by ACA Health (where this is relevant to assessing your eligibility to be a member of ACA Health);
• records of interactions you have had with the Fund’s representatives (for example, notes on our IT systems)

If you have, have previously had, or have applied for private health insurance with ACA Health, ACA Health may collect and hold additional personal information about you including:

• • your bank account details, credit card details and other payment information
  • the type of insurance cover you have or have previously had (whether with ACA Health or any other private health insurer);
  • your Medicare number
  • your income and other information relevant to your eligibility for government rebates and incentives for private health insurance
  • health information (including information concerning health services you have received, the provider and relevant dates for services)
  • details of claims you have made and benefits paid

Certain information collected and held by ACA Health is ‘sensitive information’ within the meaning of the Privacy Act. In particular, ACA Health may collect and hold health information.

Whilst you have the option of not identifying yourself, or using a pseudonym, when dealing with ACA Health (for example, when making an enquiry of ACA Health) it will generally not be practicable for ACA Health to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, we may be unable to provide you with goods and services (including private health insurance cover).

2. How does ACA Health collect and hold personal information?

ACA Health collects personal information from you in a number of different ways. For example:

• when you submit an application form or make an application to become a member of ACA Health via our website or over the telephone
• when you make enquiries in person, by telephone, by letter or email, or via our website
• when you make a claim

Where possible, we collect your personal information directly from you. However, there are a number of circumstances where we collect personal information about you from other sources. These circumstances include:

• if you are insured under a policy that insures more than one person (e.g. a ‘family’ or ‘couples’ policy) we may collect information about you from another person covered by the policy
• if you were previously a member of another private health insurer, we may collect personal information about you from that other private health insurer (for example, information relevant to waiting periods)
• where you receive health services, we may collect information about those services directly from the health services provider (for example, if you are admitted to hospital we may collect information about the health services you have received from the hospital)
• where you interact with our official social media channels, we may collect personal information that you provide in that context. For example, if you engage with a post, we may use the information you provide during that engagement to direct you to our website.

As a restricted access private health insurer, ACA Health is associated with certain employers affiliated with the Seventh-day Adventist Church in Australia. By virtue of that association, ACA Health collects limited personal information (for example, basic contact details) of persons eligible to be insured by ACA Health directly from employers in order to inform eligible persons of the availability of ACA Health’s products and services.

If you provide us with information about another person covered under the same policy as you (for example, your spouse or partner or a dependant capable of making decisions in relation to personal information), you must first obtain their consent to do so.

Your personal information is stored securely, primarily in ACA Health’s information technology systems. Information stored in ACA Health’s information technology systems is stored locally at ACA Health’s head office and remotely at a third-party storage facility in Australia. Some personal information processed by our third-party providers may be held remotely outside Australia, including countries such as Germany and the United States. From time-to-time, your personal information may be held in paper-based records at ACA Health’s head office.

We endeavor to ensure your personal information is accurate, up-to-date and complete. You can assist us in doing so by ensuring you notify us when your details or circumstances change.

3. Why does ACA Health collect, hold, use and disclose personal information?

ACA Health collects personal information from you in a number of different ways. For example:

determining eligibility for membership of ACA Health;

• assessing claims and determining entitlements to benefits;
• calculating and paying benefits;
• collecting and processing contributions;
• communicating with you in relation to your policy;
• administering government levy’s, rebate and incentive programs;
• managing enquires and complaints;
• conducting various internal administration process (for example, audit and assurance, quality assurance, risk management, fraud and loss prevention, and training);
• evaluating and developing products and services

ACA Health may from time to time use sensitive information to identify whether insured persons are suitable for particular products and services. For example, ACA Health may use health information to identify whether a person is a suitable candidate for a health management or chronic-disease management program offered, or made available, by ACA Health. Participation in such programs is completely voluntary.

If you provide ACA Health with personal information about another person covered under the same policy as you (for example, your spouse or partner or a dependant capable of making decisions in relation to personal information), you must inform that person that their personal information has been collected for the purposes set out above.

4. Is my personal information used or disclosed for direct marketing?

From time to time, ACA Health may use or disclose your personal information in order to inform you of products and services which may be of interest to you. If you do not wish to be contacted for this purpose, you may request not to receive direct marketing communications at any time by contacting ACA Health. ACA Health‘s contact details are set out below.

ACA Health will not use or disclose sensitive information about you for the purpose of direct marketing without your consent.

5. To whom does ACA Health usually disclose personal information?

ACA Health may disclose your personal information to third parties in order to provide and administer its products and services. This may include disclosures to:

• hospitals and health service providers from whom you have sought, or from whom you intend to seek, treatment;
• health management providers who offer health management and chronic disease management programs under an arrangement with ACA Health;
• government agencies (such as the Australian Tax Office, Medicare Australia, the Australian Prudential Regulation Authority, the Private Health Insurance Ombudsman and the Department of Health, Disability
  and Ageing);
• other private health insurers, when you transfer to or from another private health insurer;
• ACA Health’s information technology and software system providers;
• third party advisers and service providers to ACA Health (such as auditors, actuaries, consultants and legal advisers). 

ACA Health may disclose personal information to third parties in order to enforce its legal rights (for example, disclosing your contact details to commercial agents to recover unpaid contributions or benefits improperly claimed). ACA Health may also disclose personal information where disclosure is required by law (for example, in response to a subpoena or a compulsory notice from a court, tribunal or government body) 

If you are insured under a private health insurance policy, which covers more than one person (e.g. a ‘family’ or ‘couples’ policy), you should make yourself aware of the privacy settings applicable to your policy (that is, who amongst the insured persons is able to access your personal information).

Information concerning health services received, claims made, and benefits paid (“claims history”) will be disclosed between persons insured under the same policy except where an insured person has requested their claims history be kept private from other insured persons on the same policy.

The claims history of a dependent child aged under 14 years will generally be available to the adults insured under the policy on whom the child is dependent except where:

• the privacy setting applicable to the policy restricts access to one or more adults; or 
• ACA Health, in its discretion, considers such access would be inappropriate. 

ACA Health may, in its discretion, decline to disclose the claims history of a person insured under the same policy where it cannot be satisfied that such disclosure reflects the current intention of the insured person. In that circumstance, ACA Health may seek clarification from the insured person.

It is important to consider the privacy settings applicable to your policy where there are changes in the relationships amongst persons insured under the policy (for example, as children and young people mature or if partners separate). In that circumstance, you should contact ACA Health to change the privacy settings applicable to your policy or discuss whether different insurance arrangements are appropriate to your circumstances.

6. How is personal information handled for travel insurance cover?

ACA Health has appointed GSA Insurance Brokers Pty Ltd (ABN 34 084 437 196) (GSA) as our Insurance Broker in relation to travel insurance policies underwritten by Allianz Australia Insurance Limited ABN 15 000 122 850 AFSL 234708 (Allianz). ACA Health arranges this insurance as authorised representative for AWP Australia Pty Ltd ABN 52 097 227 177 AFSL 245631 trading as Allianz Global Assistance (AGA). AGA issues and manages travel insurance as an agent for the insurer Allianz. If you apply for or purchase travel insurance, the travel insurance is issued directly by AGA. ACA Health does not disclose your personal information to AGA to enable it to process your application f or travel insurance, or to calculate your premium, administer your policy and process your claims.

Further information about how Allianz Global Assistance handles your personal information, go to https://www.allianzpartners.com.au/privacy-and-security

7. Is ACA Health likely to disclose personal information to overseas recipients?

ACA Health does not routinely disclose personal information to overseas recipients.

8. How can I access and correct personal information ACA Health holds about me?

You may request access to your personal information at any time. ACA Health will consider and respond to requests for access and amendment within 30 days. The contact details of the Fund are set out below.

In certain circumstances, ACA Health may decline your request to access personal information including but not limited to where:

• giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
• giving access would have an unreasonable impact on the privacy of other individuals (for example, other persons insured under the same policy);
• the request for access is frivolous or vexatious;
• the information you seek to access relates to existing or anticipated legal proceedings between you and ACA Health and would not otherwise be accessible in those proceedings;
• giving access would reveal the intentions of ACA health in relation to negotiations with you in such a way as to prejudice those negotiations;
• giving access would be unlawful;
• denying access is required or authorised by or under an Australian law or a court/tribunal order;
• giving access would be likely to prejudice the taking of appropriate action in relation to suspected unlawful activity, or misconduct or a serious nature, that relates to the Fund’s activities;
• giving access would be likely to prejudice law enforcement activities conducted by, or on behalf of, a law enforcement body (for example, the Police);
• giving access would reveal commercially sensitive decision-making processes.

ACA Health will only grant access to an individual’s personal information where the individual’s identity has been confirmed through appropriate identification procedures. Additionally, requests for access to health information and all requests for amendments must:

• be in writing;
• state the individual’s name and address;
• identify the health information in question;
• specify how the individual wishes to access or amend the information and the reasons for the request; and
• include replacement information if the request is to update obsolete information.

If ACA Health refuses access to health information on the grounds that the information may damage the health of the person seeking access, it will offer to provide the information to their doctor instead.

ACA Health will take reasonable steps to ensure that personal information it collects is accurate, up-to-date and complete. However, if you believe personal information ACA Health holds about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you may request ACA Health correct your personal information at any time.

If ACA Health declines to make the requested correction, you may request a statement from ACA Health with reasons for this decision (except to the extent that it would be unreasonable to do so) once in relation to the requested correction.

9. How can I make a complaint about privacy?

You may contact ACA Health at any time if you have any questions or concerns about this privacy policy or how your personal information has been handled.

If you have contacted ACA Health and your question or concern has not been able to be resolved to your satisfaction, you may make a formal complaint to ACA Health using the contact details set out below. The complaint will be investigated according to the complaint handling process. ACA Health’s Complaints Policy and Procedure is published on ACA Health’s website (https://acahealth.com.au/complaints-policy-procedure/).

If you believe ACA Health may have breached the Australian Privacy Principles, you are entitled to make a complaint to the Office of the Australian Information Commissioner. Full contact details for the Office of the Australian Information Commissioner can be found online at http://www.oaic.gov.au/.

10. How are changes to this privacy policy made?

This privacy policy is reviewed annually or more regularly, when there is a substantial change to ACA Health’s activity, function or practice that impacts the privacy of personal information.

Revisions and updates to this privacy policy will be published on ACA Health’s website (www.acahealth.com.au).

11. How can I contact ACA Health?

The contact details for ACA Health are:

Mail:     

ACA Health Benefits Fund                                                                                                                                            Locked Bag 2014                                                                                                                                                            WAHROONGA NSW 2076

Phone: 1300 368 390

Email:   [email protected]

Web:    acahealth.com.au

Requests to access or correct personal information, or complaints about the handling of your personal information should be marked to the attention of The ACA Health Privacy Officer.