Privacy and Information Handling Policy
- 1.1 Who we are In this document, ‘we’, ‘us’, ‘our’ and ‘BLINK Optical’ refers to Blink Optical (Bupa) Pty Ltd and its subsidiaries trading under the name ‘BLINK Optical’, their related entities and bodies corporate. We are part of the Bupa Australia Group of companies.
- 1.2 Protecting your privacy Your privacy and maintaining the confidentiality of your personal information is important to BLINK Optical.This document sets out how we handle your personal information, including the collection, storage, use and disclosure of your personal information, as well as how you can access and change your information, provide us with feedback or make a complaint.This document is amened from time to time. BLINK Optical is bound by the National Privacy Principles set out in the Privacy Act 1988 (Cth) (“Privacy Act”) and any other applicable privacy legislation.
- 1.3 Definitions Consent means your permission. Your consent can be express or implied. Express consent can be written (e.g. when you sign a form or send us correspondence) or verbal (e.g. when you give us your permission over the phone or in face-to-face conversations). Your consent will be implied when we can reasonably form a conclusion that you have given consent by either taking action or deciding not to take action. For example, if you have received direct marketing from us in the past, we have your implied consent to send you further direct marketing, until you tell us otherwise.Personal information has the same meaning that it has under the Privacy Act, namely information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
2. Collection of your personal information
- 2.1 What kinds of personal information does BLINK Optical collect? The amount and type of personal information we collect from you and hold about you will vary depending on whether you are an existing customer, have made enquiries about our products and services and also the extent to which you have used our products and services.If you apply to be, are currently or have in the past been our customer, the personal information that we hold about you may include:
- your name, address, telephone and email contact details;
- your gender, date of birth and marital status;
- records of service contacts such as system notes and voice recordings of telephone conversations you have had with our employees;
- census and statistical information for purposes including product development and risk assessment;
- your Medicare number;
- details of purchases made and professional services used, including the date, etc.
If you have previously contacted us to make an enquiry about our products and services we may hold the information you gave us at that time. In addition, where a customer provides us with information about another person, or where another person is designated to act on behalf of a customer, we may hold that person’s information.
- 2.2 How does BLINK Optical collect personal information? We may collect personal information from you in a range of ways, including:
- when you contact us in person, by phone, via mail, email or online;
- when you subscribe to newsletters or other direct marketing materials;
- when you use professional services;
- when you purchase goods.
If you have provided us with information about another person, then you need to tell that other person that you have done so, that they have a right to access their information and that they can refer to this document for information on how BLINK Optical will handle their personal information.
- 2.3 If you do not provide us with your personal information If you do not provide us with your personal information, we may be unable to provide you with the products or services that you are requesting.
3. Use and disclosure of your personal information
- 3.1 How does BLINK Optical use your personal information? We use your personal information primarily to provide, manage and administer our products and services to you and to operate an efficient and sustainable business.As part of these processes, we may disclose your personal information on a confidential basis to our related entities within the Bupa Australia Group of companies and BLINK Optical businesses.In addition, we may use your information to:
- contact you in relation to any matter relating to you or the products and services provided to you;
- answer your enquiries and deliver customer services to you;
- carry out internal functions such as administration, accounting and information technology;
- monitor, price and evaluate products and services;
- resolve complaints;
- conduct customer surveys;
- conduct marketing, research and statistical analysis;
- comply with any laws or regulations.
- 3.2 Direct marketing From time to time, we may contact you to provide you with information about other products and services offered by us, our related entities and our business partners that may be of benefit to you and your family. This includes information about eyecare or services that can help you improve your wellbeing.When we contact you it may be via mail, phone, email or SMS.We may share your personal information on a confidential basis with our related entities and bodies corporate so that they can offer you products and services.When you become our customer, you consent to us using your personal information for direct marketing purposes (as described in this document), unless you have contacted us to withdraw your consent.If you do not wish to receive marketing material from us you can contact us at any time to let us know. Our contact details are at the end of this policy. When you contact us to make this request, please allow up to 60 days for this change to take effect.
If you request not to receive marketing material, please note that we will still contact in relation to our on-going relationship with you. For example, we will still send you any bills, statements and notices that are relevant to the products and services you hold with us.
- 3.3 Who does BLINK Optical disclose your personal information to? BLINK Optical operates across Australia. In the course of conducting our business and providing our products and services to you, we may disclose your information to our related entities and bodies corporate.In addition, in order to allow us to provide, manage and administer our products and services to you and to operate an efficient and sustainable business, we may be required to disclose your information to third parties. This may include disclosure in the following circumstances:
- government and regulatory bodies, e.g. Medicare;
- auditors and other service providers we may appoint to ensure the integrity of our operations;
- where disclosure is required by law, e.g. compulsory notices from courts of law, tribunals or government agencies.
3.4 How does BLINK Optical store personal information and for how long?
We will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure. This includes a range of systems and communication security measures, as well as the secure storage of hard copy documents. In addition, access to your personal information will be restricted to those properly authorised to have access.
We keep your personal information for as long as it is required to provide you with the products and services you requested from us and to comply with legal requirements.
If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information.
4. Accessing and Correcting your Personal Information
- 4.1 Can I access my personal information? You can ask us for access to the information that we hold about you at any time. Simply contact us (our contact details are listed below) to make your request.We will always endeavour to meet your request for access. However in some circumstances, access to certain information may be declined. This includes the following circumstances:
- we no longer hold or use the information;
- providing access would have an unreasonable impact on the privacy of others;
- the request is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
- providing access would be unlawful;
- denying access is required by law;
- providing access would be likely to prejudice the prevention, detection, investigation and prosecution of possible unlawful activity;
- the information would reveal our commercially sensitive decision-making process; and
- where access would pose a threat to the life or health of any individual.
If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
We may charge you a reasonable fee for access to some types of information. This charge will be limited to the cost of recouping our costs for providing you with the information. For example, document retrieval, photocopy, labour and delivery to you. We will not charge you to make a request to access your information.
You may request access to your personal information by contacting us as per the contact details at the end of this document, or by submitting your request in writing to:
BLINK Optical Head Office, tbc, Sydney
- 4.2 Correcting your personal information To enable us to provide you with the best possible service, it is important that the information we hold about you is accurate. We will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it.If you believe any information we hold about you is inaccurate, incomplete or out-of-date, you should contact us. We will promptly amend your record. Or, if we disagree the changes you request to your personal information, we will give you a reason and put a note on your record indicating that you disagree.
5. Your Privacy Online
- 5.1 Online data collection and use The information handling processes outlined in this document also relate to any personal information collected online via any BLINK Optical website.When an individual accesses any BLINK Optical website, anonymous technical information may be collected about user activities on the website. This may include information such as the type of browser used to access the website and the pages visited.This information is used by BLINK Optical to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details.
6. Resolving your Concerns
You can contact us at any time if you have any questions or concerns about this document or about how your personal information has been handled.
You can contact our Privacy Officer by directing your correspondence to:
BLINK Optical Head Office
Level 1, 319-321 George St, Sydney 2000