Virtual PAC Privacy Policy
(last updated: June 2025)
Renewable Anaesthesia Technologies Pty Ltd (ABN: 90 667 871 187) operates Virtual Pre-Admission Clinic (ABN: 90 667 871 187), the digital platform located at https://www.virtualpac.health. Virtual Pre-Admission Clinic (“Virtual PAC”, “we”, “us”, “our”) is a leading digital platform that coordinates and streamlines the pre-admission process for Anaesthetists and patients.
Virtual PAC complies with all applicable Australian privacy laws and recognises that protecting individuals’ privacy is of fundamental importance and required by law. This Privacy Policy explains:
· what sorts of personal information Virtual PAC collects;
· how Virtual PAC may use that personal information and to whom it may be disclosed;
· how Virtual PAC protects the personal information we hold from unauthorised use or disclosure; and
· how you can access and correct the personal information we hold about you, and your options to complain if you believe we have breached our privacy obligations to you.
Virtual PAC reserves the right (at its discretion) to modify, amend or replace this Privacy Policy from time to time to take account of new laws and technology, changes to Virtual PAC’s operations and practices and to make sure it remains consistent with regulatory and medical requirements as well as best practice. The modified, amended or replaced policy will be posted by Virtual PAC to its website in place of the older privacy policy and notified to all users.
Scope
This Privacy Policy applies to patients, parents and guardians, Anaesthetists (and their staff) and any other Virtual PAC platform users (including visitors to the associated website).
This Privacy Policy does not apply to employees of Virtual PAC or employee records.
Definitions
Personal information
According to the Privacy Act 1988 (Cth) (“Privacy Act”), ‘personal information’ means information or an opinion about an identified individual, or about an individual who is reasonably identifiable and this policy adopts this definition.
Sensitive information
According to the Privacy Act, ‘sensitive information’ means personal information relating to a person’s medical or health conditions, lifestyle factors, surgical history and AHPRA provider number. It also includes health or genetic information about an individual or biometric information used for specific purposes. This policy adopts this definition.
We will only:
· collect sensitive information where you agree, and it is reasonably necessary for Virtual PAC’s functions and activities;
· use and disclose sensitive information for the purpose for which it was collected or a directly related secondary purpose that you would reasonably expect, unless you agree otherwise; or the collection, use or disclosure of the sensitive information is otherwise authorised or required by law.
Types of personal information we collect and hold
Virtual PAC collects and holds a range of personal information, including health and other sensitive information, about patients, Anaesthetists and other portal users, which may include the following:
Patients:
· full name;
· date of birth;
· gender;
· contact email and mobile number;
· address;
· next of kin / emergency contact details;
· Medicare number; and
· diagnostic imaging (if this information is volunteered).
Virtual PAC may also collect the following types of sensitive information about patients only where necessary or appropriate or the patient has otherwise consented or volunteered the information:
· past medical and surgical history;
· past history of anaesthesia;
· results from medical and clinical tests (including sleep study results and blood test results);
· medical conditions, symptoms and comorbidities (including mental health);
· known allergies;
· height and weight;
· lifestyle factors (including alcohol and smoking);
· medications and supplements (including injections and puffers);
· specific requests regarding surgery;
· genetic information about an individual that is not otherwise health information; or
· biometric information that is to be used for the purpose of undergoing anaesthesia.
Anaesthetists:
· full name;
· contact details;
· qualifications;
· AHPRA provider number;
· other provider numbers.
Website Users
We may also collect information about you when you access our website using technology called ‘cookies’. That information includes the pages viewed and the information downloaded, the IP address of the computer or mobile used to visit our website, the page from where the individual visited our website, the type of browser used, unique device identifiers and information about websites visited before the individual visited our website. You can configure your browser to disable cookies, but some parts of our website may not function properly (or at all) if cookies are disabled.
Purpose for collecting personal information
Virtual PAC’s primary purpose for collecting personal information is to support its functions and activities, including to:
· operate the Virtual PAC Platform and provide pre-admission clinic services for patients and their Anaesthetists;
· coordinate and enable communication between Anaesthetists and their patients/guardians;
· fulfill legal requirements including:
o taking reasonable steps to reduce the risk of harm to patients and others;
o make reasonable adjustments for patients and others; and
o ensure, as far as reasonably practicable, the health and safety of people in Virtual PAC workplaces;
· communicate with third parties (including other medical practitioners, medical clinics, hospitals) where express consent and instructions to do so are obtained first;
· comply with necessary regulatory requirements, standards and reporting obligations; and
· any other purposes that would be reasonably expected.
Patients
In relation to personal information of patients, Virtual PAC’s primary purpose of collection is to facilitate communication between you and your Anaesthetist to enable your Anaesthetist to provide you pre-operative and ultimately operative services in an efficient manner for patients, and perform necessary associated administrative activities including:
· supporting patients to access and obtain relevant health information and on provide it to their Anaesthetist;
· updating patients through SMS notifications for their upcoming procedure;
· educating patients on the service provided by their Anaesthetists; and
· supporting patients’ social and emotional wellbeing and health.
Virtual PAC does not provide medical or related services and does not use your information for such purposes. Virtual PAC’s use of your information is limited to facilitating communication with your Anaesthetist who will provide the relevant medical services and will do so with their own skill and expertise and without any advice or direction from Virtual PAC.
In some cases where Virtual PAC requests personal information about a patient, if the information is not provided, the Patient may not be able to use the Virtual PAC platform and the Patient and Anaesthetist may need to conduct those activities in another way not using the Virtual PAC Platform.
How does Virtual PAC collect personal information?
Virtual PAC collects personal information about an individual directly from that individual, where reasonable and practicable to do so. We collect the information in a variety of ways, including:
· electronic or paper documents (including emails, patient forms) face-to-face meetings, emails and telephone calls;
· from our website using various technologies, including ‘cookies’;
· Jotform online form application;
· polls, surveys and/or electronic questionnaires;
· authorised information sharing with other parties (such as medical professionals, parents/guardians and hospitals); and
· from publicly available sources.
Cookies and analytics
Virtual PAC may also collect data from its website using various technologies, including ‘cookies’. A ‘cookie’ is a text file our website transmits to an individual’s browser which is stored on the individual’s computer as an anonymous tag identifying the individual’s computer (but not the individual) to us. The browser may be configured to disable cookies, but some parts of our website may not function properly (or at all) if cookies are disabled.
How do we use and disclose the personal information we collect?
As a general principle, and in accordance with our statutory obligations, we only use and disclose personal information for:
· the primary purpose for which the information was collected (which is typically to provide this information to the patient’s Anaesthetist and provide communications from the Anaesthetist to their patient.);
· a secondary purpose that is related to the primary purpose and for which you would reasonably expect us to use the collected information;
· a secondary purpose that is directly related to the primary purpose where it is sensitive information; or
· as otherwise required or authorised by law, including the APPs.
We will take reasonable steps to make individuals aware of the purpose for which the information collected may be used or disclosed, including by reference to this Privacy Policy.
In particular, we may disclose personal information to the following people, where appropriate:
· third party service providers that provide legal, administrative, financial and data management services to Virtual PAC;
· Anaesthetists and medical treating practitioners;
· parents, guardians or emergency contacts;
· third parties to whom you authorise us to disclose your personal information;
· where authorised or required by law or court order, or other governmental order or process, such as where we believe in good faith that the law compels us to disclose information in order to:
o lessen or prevent a serious threat to your life, health or safety or public health or safety, where it is impractical to obtain your consent;
o take appropriate action in relation to suspected unlawful activity or serious misconduct;
o to locate a person reported as missing;
o to assert a legal or equitable claim; or
o to conduct an alternative dispute resolution process; and
· where we are required to do so as a result of any obligations we owe under a contract.
Third-party service providers
When Virtual PAC engages third parties to provide products and/or services to Virtual PAC, such as Jotform, Google Workspace and payment processors, such third parties may have access to personal information Virtual PAC holds about individuals. Virtual PAC does not authorise those third parties to use any personal information disclosed to or accessed by the third party for any purpose other than to facilitate the third party’s completion of its obligations owed to the Virtual PAC.
Disclosure of personal information overseas
Virtual PAC will not disclose personal information about an individual to a recipient outside Australia without:
· obtaining the consent of the individual (in some cases this consent will be implied); or
· otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.
From time to time, Virtual PAC may use third-party online platforms to store and manage personal information regarding the service it provides. This may include the personal information of patients. Virtual PAC may also engage third parties to provide services to Virtual PAC that involve the use of personal information, such as services relating to emails and surveys. This personal information may be stored in the 'cloud' which means that it may reside on a cloud service provider’s server which may be situated outside Australia.
Virtual PAC does not otherwise disclose or allow third parties outside Australia to access the personal information Virtual PAC holds.
Direct marketing
Anaesthetists who are prior or current users of Virtual PAC, may from time to time receive communications. If you would like to opt-out of receiving marketing material, please contact Virtual PAC’s Executive Officer (see below). There will also be a simple “unsubscribe” (opt out) method in any marketing emails. If you opt-out of receiving marketing material from us, we may still otherwise contact you in relation to our existing relationship with you other than for the purposes of marketing.
Security and retention of personal information
Virtual PAC takes the security seriously and takes reasonable steps to protect any personal information it holds from misuse, interference and loss. This includes technology security measures such as employing passwords and multi-factor authentication measures to protect electronic records, and organisational measures, such as access control protocols and employee training on data protection.
All Virtual PAC’s users are required to respect the confidentiality and privacy of all individuals who interact with Virtual PAC.
Accessing the personal information we hold
An individual is entitled to access the personal information we hold about that individual. All enquiries should be directed to Virtual PAC’s Executive Officer (see below).
We will respond to such requests within a reasonable period of time. We reserve the right to charge a reasonable fee to cover the costs we incur in providing access, but this is usually not required.
We reserve the right to refuse access where a legal exception applies, for example, where releasing the information would unreasonably impact the privacy of another individual. Alternatively, we reserve the right to redact the information made available, to protect the privacy of other individuals. We also reserve the right to verify the identity of the person requesting the information and their entitlement to access it.
Quality of the personal information we hold
We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy, completeness and currency of the information we hold largely depends on the accuracy of the information supplied to us or which we collect.
If at any time you discover that any information held about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you can request correction of the information by contacting Virtual PAC’s Executive Officer (see below). Virtual PAC reserves the right to verify your identity before processing a correction request.
Lodging a complaint
If you wish to make a complaint to Virtual PAC about how Virtual PAC handles your personal information we ask that you make the complaint in writing to Virtual PAC’s Executive Officer (see below).
Virtual PAC will promptly acknowledge receipt and will respond to you within a reasonable time period (generally within 30 days). Where the complaint requires a more detailed investigation, the complaint may take longer to resolve, and we will keep you updated as to progress.
Virtual PAC reserves the right to verify the identity of the individual making the complaint and to seek further information from the complainant about the circumstances of the complaint. Virtual PAC reserves the right to refuse to investigate or to otherwise deal with a complaint where permitted under the Privacy Act. For example, Virtual PAC may refuse to investigate or to otherwise deal with a complaint if Virtual PAC considers the complaint to be vexatious or frivolous.
If you are not satisfied with our response to your complaint, or you consider that Virtual PAC may have breached the Australian Privacy Principles or the Privacy Act, you can make a complaint to the Office of the Australian Information Commissioner (“OAIC”).
Office of the Australian Information Commissioner
Postal address: GPO Box 5288 Sydney NSW 2001
Phone: 1300 363 992
Email: foi@oaic.gov.au
Website: www.oaic.gov.au
How to contact us
If you have a query in relation to this privacy policy or wish to make a complaint, please contact:
Executive Officer
support@virtualpac.health
Version: June 2025