This policy was last updated on 14 May 2014

Who is Resolutions (Int) Pty Ltd?

Resolutions (Int) Pty Ltd is a health care management company providing contract coding, education, auditing and on line application products such as ResiCat and Visicode to approved licensees in order to meet the needs of our clients. We may also market our products and services.

In the course of our business there may be circumstances where we collect personal information. Resolutions have created this privacy statement to demonstrate our firm commitment to privacy and to ensure that such information is handled appropriately. Resolutions are committed to honouring the privacy of our members, all persons having dealings with us including persons from whom or about whom we collect personal information and general users who access our website (“you”).

Definition and application

In this privacy policy, “we”, “us” and “our” means Resolutions (Int) Pty Ltd as Trustee for The Resolutions Trading Trust ABN 29 449 318 376 (‘Resolutions’) of Suite 2/1420 Logan Road, Mount Gravatt, Queensland, 4123, Australia.

We appreciate that privacy is important to everyone, and we are committed to complying with the Australian Privacy Principles (APPs) which are contained in the Privacy Act 1988 (Cth). This policy applies to any person for whom we currently hold or may in the future collect personal information about. This policy does not apply to acts done or practices engaged in which relate directly to the employee records of our current and former employees.  This privacy policy will apply to all of your dealings with us, whether in person, via telephone, email, correspondence or on our website at www.resolutionsint.com as well as where your personal information is disclosed to us via a third party and where an exception does not apply.

Pseudonym / Anonymous

In limited circumstances, and only where lawful and practical it may be possible for you to use a pseudonym or remain anonymous when dealing with us. If you wish to use a pseudonym or remain anonymous you should notify us when making first enquiries. We will use our best endeavours to deal with you as requested. In most cases however it will be necessary for us to successfully identify you in order to do business with you.

What is personal information?

When we refer to personal information we mean information or an opinion about you, from which you are, or may reasonably be, identified, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

This information may include (but is not limited to) your name, date of birth, organisation, driver’s license number, marital status, phone number, email address, address, nationality and employment history. Information or opinions are not personal information where they cannot be linked to a particular individual.

Management of personal information

We manage the personal information we collect by ensuring that all of our officers, employees and subcontractors are aware of and understand our obligations as well as their own obligations under the act. We will achieve this through the provision of training and through maintaining and implementing internal policies and procedures to prevent personal information from being collected, used, disclosed , retained, accessed or disposed of improperly. We implement security measures to keep the personal information we collect safe and we appoint a designated privacy officer to monitor privacy compliance and be a contact for privacy complaints and access or correction requests.

Collecting personal information

We collect and hold different information depending on the services that you are seeking, the services that we are providing to our clients and customers or in the case of prospective employees, the information needed to assess future employment with us. There are two main circumstances where we may collect personal information:

  1. Where people have dealings with our organisation; and
  2. Through the provision of the services that we supply to our clients and customers.

In the first circumstance this may involve people making enquiries about our services, people applying for jobs with us or people contracting with us and other general contact with our organisation. In this first circumstance:

  • Means of Collection: collection of personal information may be via different means including direct contact, telephone, correspondence, email or web based enquiry; personal information is generally collected directly from the individual or organisation.
  • Kinds of Personal Information: the kinds of personal information that we collect and hold include: name, gender, date of birth, address, phone number, facsimile number, email address, banking and credit card details, place and type of business, employment history details (in the case of potential employees) and or other information relevant to providing you with the services you are seeking. In these circumstances we generally do not collect and hold any sensitive personal information. Where you are accessing our website we collect additional data. Refer to the heading “Internet users / Using our website” further on in this policy for these details.

In the second circumstance collection of personal information may occur through the provision of the services that we supply to our clients and customers. In providing our services of coding, training and auditing, which assist our health care provider clients in complying with their auditing and reporting obligations associated with the running of their business of providing health care services to patients, we are required to view, interpret and extract diagnostic and other medical procedure related data from the health records of our client’s patients. This may involve us collecting personal information of our client’s patients. In this circumstance:

  • Means of Collection: collection of personal information may result from different means such as viewing patient files on site or via remote access and extraction of necessary information, receipt from the client of a fax or email containing patient data, accessing patient data which has been uploaded to a web-based application, Dropbox or similar FTP service and extracting necessary information. In these instances personal information is not collected directly from you but is collected from your health care provider as it is unreasonable and or impractical to collect the personal information directly from you. Whilst we attempt to collect the necessary diagnostic information for entry into our programs from de-identified data supplied to us by the health care provider (ie information that is not considered Personal information) there are circumstances where it is necessary to access and view identified data in and or collect personal information from records held and controlled by a patient’s health care provider.
  • Kinds of Personal Information: the kinds of personal information that we collect and hold include medical record number, sex, date of birth, health information – that is, diagnostic and procedure information, date of admission and date of discharge. Where viewing or receiving identified data from which to extract the required information the additional kinds of Personal Information that we may collect and hold include name, address, phone number, facsimile number, email address, health provider. In these circumstances we will collect and hold sensitive personal information being your health information. We do not collect any other sensitive personal information.

Sensitive information

We will take reasonable measures to attempt to ensure that we only collect sensitive information in circumstances where:

  • It is reasonably necessary for one or more of the services that we provide or the functions that we carry out; and
  • You consent to the collection of that information (where we are required by the Privacy Act to obtain such consent); or
  • We are required or authorised by law to collect the sensitive information and / or its collection is permitted by the Privacy Act or other relevant legislation.

Purpose of collection

The personal information that we collect and hold about persons depends on their interaction with us. Generally we will collect and hold your personal information for the purpose of:

  • Providing services to you or someone else you know (including your health care provider) and receiving payment for those services;
  • Verifying your identity for the purposes of our interaction with you and to comply with any professional or legal obligations we have to do so;
  • Establishing your authority to provide us with instructions in relation to specific matters;
  • Providing you with information about other services that we offer that we think may be of interest to you;
  • Providing you with information relevant to your type of business or other area of expertise or interest. NOTE: When providing such information we provide details as to how you can opt out of receiving such information if you wish. In addition to those methods advised, you may opt out of receiving such information by contacting us using the details set out at the bottom of this policy. Upon receiving such a request we will remove your contact details from our distribution lists;
    • Facilitating our internal business operations including the fulfilment of any legal requirements;
    • Analysing our services and customer needs with a view to developing new and or improved services;
    • In the case of prospective employees then assessing for future employment with us;
    • Contacting you to provide a testimonial for us;
    • To respond to or provide services in relation to comments, enquiries or requests made via our website;
    • Complying with any legal obligations to collect and hold such information;
    • Providing you with access to our website including all associated applications and information;
    • Providing services to your health care provider where that health care provider is a customer of ours.

Internet users / Using our website

We collect personal information if you choose to provide it to us, for example by emailing us or entering information about yourself into our website. This is for the purpose of providing you with access to our website, including all associated applications and information (the website). From time to time we may use personal information that you have provided to use for the purposes of offering other products and services to you or for one or more of the other purposes stated in this policy.  We also collect navigational data from your use of our website and use cookies to keep track of your use of our website (for example, so that we can remember which website page/s you were viewing when you last visited our website). This information is collected by many sites. When you use our website, cookies will be placed on your computer to keep track of your use of our website. Cookies are also used in surveys, voting, and polling to prevent users from duplicating responses in any Web site events. Cookies do not capture or track any personal information. However, you may elect to set your computer so that cookies are not placed on your computer.

We use your IP address to help diagnose problems with our server, derive usage statistics, and to administer our Website. All usage statistics are only used as aggregated data to derive statistics and is not used to identify individuals accessing the Websites.

Our site uses order forms that allow customers to request information, products, and services. We collect a visitor’s contact information (e-mail address), unique identifiers (their membership identification number), and financial information (account or credit card numbers). Contact information collected from the order form is used to send orders to customers. Financial information is used to collect payment from the user for billable products and services.

Consequences for failure to provide information

If you do not provide the information requested by us, we may not be able to provide you with our services. In the circumstances described in this policy if your health care provider does not provide the information required by us to enable us to carry out our contracted services we will not be able to assist your Health care provider in complying with their auditing and reporting obligations which are associated with running their business of providing health care services to you.

Provision of personal information by a third party

If you provide personal information to use about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy. Where required by the Privacy Act and where an exception does not apply then you must ensure that the individual also provides (before disclosure to us) any consent as required by the Privacy Act with respect to the collection, holding, use and disclosure by us of their personal information as set out in this Privacy Policy.

Use and disclosure

Generally, we only use and or disclose personal information about you for the purposes for which it was collected (as set out above) or as authorised under law. However we may disclose personal information about you to:

  • Service providers, who assist us in operating our business, including IT service providers who assist in managing our servers and networks including but not limited to “cloud” utilising providers such as Dropbox and other FTPs in order to perform one or more of our functions or activities or for the service provider to fulfil their service obligations to us. These service providers may not be required to comply with our privacy policy. We use our best efforts to ensure the contracts with such service providers only permits those service providers to use the data collected for the purpose of supplying the contracted IT service to us ie to diagnose problems and to administer our website as the case may be;
  • Contractors that we engage to assist us in operating our business including in providing our services to our clients;
  • A purchaser of the assets and operations of our business providing those assets and operations are purchased as a going concern;
  • Our related entities;
  • Entities where we are compelled by law to disclose;
  • Law enforcement agencies, government agencies, courts or external advisors or in accordance with other laws.

We do not sell, rent or trade personal information to or with third parties.

Consent

By providing us with your personal information, or in the case of where your information is disclosed to us by your Health care provider then by your Health care provider providing us with your personal information (including sensitive Personal information such as health information) you consent to us collecting, using and disclosing your personal information (including sensitive personal information such as health information where applicable) to the entities required in the normal course of our business as detailed in this privacy policy and those required by law.

Overseas disclosure and consent

We do not disclose personal information to overseas recipients apart from any disclosures which may occur as a result of the use by us of IT service providers who assist in managing our servers and networks and software including but not limited to “cloud” utilising providers, web-based applications and Dropbox or similar FTP services. These providers may be based overseas or use overseas infrastructure to perform services for us including in the USA (as at May 2014). These providers may not be required to comply with our privacy policy and these overseas countries may not have privacy laws that provide the same level of protection as Australia’s privacy laws. In regards to our applications you will be advised of this situation at the time of purchase.

Where the provision of this information to these providers is not considered a “disclosure”, we may provide this information as part of our “use” of this information for the purposes of allowing those IT providers to assist us in operating our business and providing required services to you. <

Where the provision of this information to these providers is considered a “disclosure” then by having dealings with us, providing your personal information to us or to your health care provider in circumstances where they engage us to assist them with their internal business operations and or consenting to your health care provider disclosing your personal information to us or entities such as ours you consent to the disclosure of your personal information to the overseas recipients described above in the circumstances described above only and on the basis that, whilst those overseas entities may be required to comply with similar laws to the Australian Privacy Laws we cannot confirm this requirement and we will not be required to take reasonable steps to ensure that the overseas recipient complies with the Australian Privacy Principles or otherwise be liable or accountable for how that recipient handles your personal information.

Government-related identifiers

We do not generally collect government-related identifiers; however, in the event that we do, then we will not use or disclose them unless we are required or authorised to do so by law or by a court or tribunal order or in order to fulfil our professional obligations to a State or Territory authority.

Direct marketing

From time to time we may use your personal information to provide you with current information about our products and services, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone. If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us using the contact details below or by following the opt out instructions on the marketing communication received. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity. Where we collect your personal information as part of provision of our services to your health care provider then your personal information will not be used for direct marketing.

Links

Our site contains links to other sites. Resolutions is not responsible for the privacy practices or the content of other websites linked from Resolutions websites. Linking to other websites does not indicate any endorsement of the content or products provided on such sites.

Security

We hold personal information in different ways including:

a) Physically:

a. On our premises; and

b. By third party data storage providers.

b) Electronically, by one or more of the following means:

a. Through internal servers, websites, online applications;

b. Through a private cloud with servers located in Australia;

c. On external servers located in Australia;

d. On electronic storage devices, including CD, DVD, USB and HDD;

e. By a third party data storage provider in Australia;

f. By an off-side data replication provider in Australia; and

g. By an email filtering host.

We take reasonable steps to ensure the security of personal information held by us from risks such as loss or unauthorised access, destruction, misuse, modification or disclosure. However, we do not guarantee that personal information cannot be accessed by an unauthorised person (for example, a hacker) or that unauthorised disclosures will not occur.

Some of the methods we use to store and secure information include one or more of the following:

a) Password protection for our IT systems;
b) Secure log in for access to our database and that of our clients;
c) Use of secure servers and data centres;
d) Use of locked filing cabinets for the storage of personal information held on paper files;
e) Use of premises that are locked when unattended and protected by electronic security;
f) Undertaking penetration testing to ensure security exists at government levels and standards;
g) Conducting independent security auditing on our application security;
h) Destruction of personal information that is no longer needed for any purpose is conducted by secure means such as shredding.

Security in regards to our products is advised at the time of purchase. For the latest information on Resolutions’ security practices and locations of our facilities, equipment and suppliers you may be required to make personal contact with a senior Resolutions staff member.

Updating your personal information

It is important to our relationship that the personal information we hold about you is accurate and up to date, complete, relevant and not misleading. If at any time you are of the view that personal information about you is not accurate, complete or up to date or is irrelevant or misleading, please write to us with your request for correction. Our policy is to consider any requests for correction in a timely manner. We will take reasonable steps to correct the information. If we refuse to correct your personal information we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint. If we disagree with you about whether your personal information is accurate, complete or up to date and you ask us to associate with your personal information a statement claiming that your personal information is inaccurate, incomplete or out of date we will take reasonable steps to do so. In accordance with the Privacy Act we will not charge you for correcting or associating a statement with your personal information.

Your rights

You can seek access to personal information which we hold about you. If you wish to exercise your right under the Privacy Act to seek access to the personal information that we hold about you, we ask that you write to us and we will explain how we handle your access request. Whilst we will not charge you for making the request, in accordance with the Privacy Act, we may charge you for the cost of providing access to these records.

There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious. An explanation will be provided to you if we deny you access to your personal information we hold.

Complaints about a breach of privacy

If you wish to complain about an alleged privacy breach we request that you follow the following process:

a) Make the complaint to us in writing.
b) We will take reasonable steps to investigate the complaint and respond to you within a reasonable time.
c) In the unlikely event that the privacy issue cannot be resolved between us and you then you may take your complaint to the Office of the Australian Information Commissioner.

If you have any questions or comments about this privacy policy, or if you wish to complain about how we have handled personal information about you, please contact us on the contact details set out below:

Our organisation: Resolutions (Int) Pty Ltd as Trustee for The Resolutions Trading Trust ABN 29 449 318 376
Contact person: The Principal Privacy Officer
Phone: +61(0)7 3849 6885 (or 1300 733 809 within Australia only)
Email: privacy@resolutionsint.com
Address: PO Box 2060, Mansfield DC, Queensland 4122 Australia

Changes to our Privacy Statement

This policy was lasted updated on 14 May 2014. We might change this privacy policy from time to time. When we make changes, we will post a notice on our website homepage and make a new copy of the updated privacy policy available on our website. If you continue to use our website after we do so, you will be taken to have accepted the new privacy policy.

Why did you receive an email from us?

If you received an email from us, a) your email address is either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future (“opt-in”), or b) you have registered, purchased or otherwise have an existing relationship with us. We respect your time and attention by controlling the frequency of our mailings.

How can you stop receiving email from us?

Each email sent contains an easy, automated way for you to cease receiving email from us, or to change your express interests. If you have received unwanted, unsolicited email sent via this system please forward a copy of that email with your comments to enquiry@resolutionsint.com for review.

Copyright information

© 2014 Resolutions (Int) Pty Ltd, All Rights Reserved.

This site was created by, and is the copyrighted property of, Resolutions (Int) Pty Ltd, all rights reserved. All contents, including images and graphics, on this website are copyrighted by Resolution (Int) unless otherwise noted. You must obtain permission to reproduce any information, graphics, or images from this site. Permission must also be obtained to link to this or any other of Resolutions (Int)’s websites. To request permission, please use the contact form on the
Contact Us page.

Comments and submissions

Resolutions (Int) welcomes your comments. All comments, suggestions or other information sent by you to this site are for internal use by Resolutions (Int) or its advertisers or business partners, or in response to solicitations on this site, will become Resolutions (Int)’s property.

All intellectual property rights therein are transferred to Resolutions (Int).

Any postings to publicly available portions of the Resolutions (Int) Web site are non-confidential for all purposes.

Disclaimer about the Resolutions Int Pty Ltd website
1) Use of the information and data contained on this WWW site on these pages is at your sole risk.
2) The information and data on this WWW site is provided on an “As is, As Available” basis without warranty of any kind.
3) Information on this WWW site is subject to change without notice.
4) Resolutions (Int) Pty Ltd., its agents, officers and employees:

(i) make no representations, express or implied, as to the accuracy of the information and data contained on this WWW site.

(ii) accept no liability for any use of the said information and data or reliance placed on it.

(iii) make no representations, either expressed or implied, as to the suitability of the said information and data for any particular purpose; and

(iv) make no warranties that the said information and data is free of infection by computer viruses or other contamination.

5) Resolutions (Int) Pty Ltd. and its agents and employees do not endorse or in any respect warrant any third party products or services by virtue of any information, material or content referred to or included on, or linked from or to this WWW site.
6) All advice and information contained on this web site is of use only to Health Information Management professionals including health professionals. We do not tender any advice which may be construed as advice on health or medically related topics. This site is intended as a source of information for health professionals.

This policy was lasted updated on 14 May 2014. We might change this privacy policy from time to time.