1. Collection and holding of Personal Information
Touchstone Life Care Pty Limited (“us”, “our” and “we”) collect and hold the following personal information:
- personal details such as your name, title and gender
- images of you
- contact details such as your address, postcode, email address, telephone number(s)
- information about your health, health conditions, values, preferences and beliefs relevant to your future health care
- directions about your future health care
- personal information about people you nominate as being relevant, or to have access to, your advance care plan, such as your spouse, your General Practitioner, family members or friends
- details of your responsible person/s including their name, address, phone number, email address and their relationship to you
- personal details provided in relation to support calls, enquiries and complaints
- information you provide through customer surveys
- your opinion and feedback about our services
- usage details such as information and feedback about your use of our products and services
- online details such as your use of our website including cookies, web beacons and IP addresses
- information collected by Google Analytics, Google Adwords and Google AdSense.
If you do not provide this information, we will not be able to provide you with access to our
Save for information collected by Google, we hold all information in an AWS instance located in Australia. The applicable AWS policy to same can be found at https://aws.amazon.com/compliance/australia-data-privacy/
The information collected using Google Analytics, Google Adwords and Google AdSense is held by Google. The applicable Google policy can be found at https://policies.google.com/privacy?hl=en.
The use of these providers and policies may change from time to time and we will notify you in relation to same if that occurs.
Other than data collected by Google and persons nominated by you to receive your plan, we do not disclose any of your information outside Australia.
For the purposes of the GDPR, we are the data controller and AWS and Google (and their associated parties as set out in their respective Privacy Policies) are data processors.
Touchstone Life Care retains de-identified information about the ACP plans stored
on this database for the purposes of research and analytics.
2. Use and Disclosure of Personal Information
We use and disclose personal information for the following purposes:
- to respond to you
- to provide you with the services you have contracted for
- to provide you with access to (including a free trial of) one or more of our products or services
- to process and manage a subscription to a product or service
- to provide a person you have nominated with access to your advance care plan
- to provide persons who scan your QR code and enter the security PIN number with access to your advance care plan
- to provide health care providers with access to your plan
- to communicate information contained in your advance care plan for your benefit
- to protect personal information, including health information, handled (transmitted, stored, processed) by us
- to undertake quality assurance processes, including assessing whether or not a product or service is working as promised
- to monitor, detect and respond to cybersecurity or privacy incidents
- where required or authorised by or under law or a court/tribunal order
- to provide same to any future nominated trusted partners and care management services with whom we may integrate in the future for the purpose of providing quality care planning and management and subject to any applicable third party Privacy Policies.
3. Quality of Data, Access, Correction and Complaints
You may request access to make a correction to or make a complaint in relation to any personal information about you held by us, using the contact details provided below. We will acknowledge receipt of your complaint promptly. We aim to respond to your request for access/correction within 30 days of receiving the complaint or request.
If you are unhappy with our handling of your complaint, you can contact the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/privacy/privacy complaints/.
Touchstone Privacy Contact Information
Email: firstname.lastname@example.org (attention Privacy Officer)
Touchstone Life Care Pty Limited
11-17 York St
Sydney NSW 2000