1. Who can I contact about this policy?
If you have a question about this policy or how AVHS handles your personal information, please contact us:
- Email: contact@avhs.com.au
- Phone: 1300 766 206
- Post: Australian Veteran Health Services, Level 6, 2 Wellness Way, Springfield Central QLD 4300.
2. When and why is your consent necessary?
When you register with AVHS or receive services from us, we collect and use personal and health information that is reasonably necessary to provide your care and manage our services. Access is limited to people who need the information for your care or for an authorised business, legal or safety purpose.
Where we want to use your information for a purpose that is not directly related to your care or otherwise permitted by law, we will seek additional consent where required.
If an AVHS clinician proposes to use an AI scribe during your consultation, you will be informed before it is used and you may decline or withdraw your consent. Declining an AI scribe will not prevent you from receiving care.
3. Why do we collect, use, store and share your personal information?
AVHS handles personal information primarily so we can provide safe, coordinated and effective healthcare and veteran support services. This may include:
- assessing, diagnosing, treating and supporting your health needs
- maintaining an accurate clinical record and documenting interactions with you
- coordinating care, referrals, investigations and communication with other healthcare providers
- supporting Department of Veterans’ Affairs (DVA) claims, assessments and related services
- managing Medicare, DVA and other billing or payment processes where relevant
- contacting you about appointments, results, follow-up and service arrangements
- meeting legal, regulatory, professional and accreditation requirements
- undertaking internal quality, safety, audit and service improvement activities.
4. What personal information do we collect?
Depending on the services you use, AVHS may collect information such as:
- your name, date of birth, address and contact details
- Medicare, DVA and healthcare identifier details where relevant
- medical history, diagnoses, medicines, allergies, adverse reactions, immunisations and risk factors
- clinical notes, referrals, test results, reports, correspondence and other information relevant to your care
- social, family or lifestyle information where relevant to your care
- billing, payment or claiming information where required
- communications you have with AVHS, including by telephone, email, SMS or through our website.
5. Can you deal with us anonymously or use a pseudonym?
Where it is lawful and practicable, you may ask to deal with AVHS anonymously or use a pseudonym. In many healthcare situations this will not be practical because we need to correctly identify you to provide safe care, maintain an accurate health record, process Medicare or DVA claims, or meet legal requirements.
We will explain if we are unable to provide a particular service without confirming your identity.
6. How is your personal information collected?
We usually collect information directly from you, including when you:
- complete registration, consent or other forms
- attend a consultation or assessment
- telephone us, send an email or SMS, or otherwise communicate with our team
- use our website or interact with AVHS through digital channels.
Where it is not practical or appropriate to collect information directly from you, we may also collect information from:
- your guardian, carer or responsible person
- other healthcare providers, specialists, allied health professionals, hospitals, community health services, pathology providers and diagnostic imaging providers
- Medicare or the Department of Veterans’ Affairs, where relevant to the service being provided
- other organisations or persons where you have authorised the collection or where collection is permitted or required by law.
7. When, why and with whom do we share your personal information?
AVHS only shares personal information where there is a legitimate reason to do so. This may include sharing information:
- with other healthcare providers involved in your care, such as through referrals, reports or care coordination
- with Medicare, DVA or other agencies where required to process claims or provide authorised services
- with service providers that support AVHS operations, such as secure information technology, clinical software or accreditation providers, where they require access to perform their role
- where you have consented to the disclosure
- where disclosure is required or authorised by law, including a court order or mandatory reporting requirement
- where necessary to lessen or prevent a serious threat to life, health or safety and the law permits the disclosure.
Only people who need access to your information for an authorised purpose should be able to access it. AVHS does not sell patient information. All AVHS technology providers use Australian-based infrastructure and subprocessors.
8. Will your information be used for marketing purposes?
AVHS will not use your information to directly market goods or services to you without your express consent. If you consent to receive marketing communications, you may opt out at any time using the unsubscribe option provided or by contacting AVHS.
9. How is your information used to improve services?
AVHS may use information for internal quality improvement, clinical governance, audit, accreditation, training, and service evaluation. Where practical and appropriate, information used for broader analysis or external reporting is de-identified or aggregated so that individuals are not reasonably identifiable.
10. How are document automation technologies used?
AVHS uses secure clinical and business systems to help prepare documents such as referrals, reports, letters, and other healthcare-related records. These systems may draw relevant information from your existing record so that documents can be prepared accurately and efficiently.
Access to these systems is limited to authorised users. Clinicians and staff remain responsible for checking information and documents before they are relied upon or sent.
11. How are Artificial Intelligence (AI) scribes used?
Some AVHS clinicians use Heidi Scribe, an AI-assisted clinical documentation tool, to help prepare notes during or after a consultation. Heidi uses the conversation captured through a microphone to create a transcript and draft clinical note. The clinician must review and, where necessary, correct the draft before relevant information is added to your clinical record.
- You will be informed when Heidi Scribe is proposed for use and you may decline or withdraw consent.
- Your clinician remains responsible for your care, clinical judgement, and the accuracy of the final clinical record.
- Heidi states that, for standard real-time transcription, consultation audio is not retained after processing.
- Heidi states that patient data is not used to train, develop, or improve its AI models.
- Heidi states that Australian customer personal information is stored in Australia. Some platform functions may rely on third-party services subject to data-processing agreements and privacy safeguards.
12. How is your personal information stored and protected?
AVHS stores personal information in secure electronic systems and, where applicable, in other protected records. We use administrative, technical, and physical safeguards appropriate to the information we hold, including access controls, secure systems and confidentiality requirements for staff and contractors.
AVHS takes reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure. If a data breach occurs, AVHS will assess and respond to the incident and notify affected individuals and regulators where required by law.
13. Retention and destruction of information
AVHS retains personal information and health records for the period required by applicable Commonwealth and State or Territory laws, professional obligations and healthcare record retention requirements. When information is no longer required and retention obligations have been met, AVHS will take reasonable steps to securely destroy or de-identify the information.
14.How can you access and correct your personal information?
You may request access to, or correction of, personal information AVHS holds about you. We may need to verify your identity before releasing information.
Requests should be made in writing to contact@avhs.com.au or by post to Australian Veteran Health Services, Level 6, 2 Wellness Way, Springfield Central QLD 4300. AVHS aims to acknowledge requests within 14 days and respond within 30 days where practicable. If information is inaccurate, out of date or incomplete, AVHS will take reasonable steps to correct it.
15. How can you lodge a privacy-related complaint, and how will it be handled?
We take privacy concerns seriously. If you believe your information has been handled incorrectly or you have a concern about privacy, please contact AVHS in writing so that we can investigate and respond.
- Email: contact@avhs.com.au
- Post: Attention: Clinical Manager / Senior Operations Manager, Australian Veteran Health Services, Level 6, 2 Wellness Way, Springfield Central QLD 4300.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC):
- Phone: 1300 363 992
- Online Enquiry: Via the OAIC website at oaic.gov.au
16. How is privacy on the AVHS website maintained?
The AVHS website may use cookies, analytics tools or other tracking technologies, like tracking pixels. Some technologies may involve third-party service providers. Where this occurs, AVHS will take reasonable steps to ensure that personal information is handled consistently with privacy law and this policy.
The AVHS website uses Meta Pixel to collect IP address, site navigation pathway, or unique device identifier. Information collection is kept to a minimum and we do not share any personal or sensitive information. You can manage or disable cookies and some tracking technologies through your browser settings. Disabling cookies may affect the functionality of some website features. By using our website you agree to the use of these technologies.
17. How is this policy reviewed?
AVHS reviews this Privacy Policy regularly and when there are significant changes to our services, technology, privacy practices or legal obligations. The current version will be published on the AVHS website. Where a change is significant, AVHS may take additional steps to notify patients or other affected people.
18. Laws and guidance related to this policy
This policy has been prepared with regard to relevant privacy and health information requirements, including:
- Privacy Act 1988 (Cth) and the Australian Privacy Principles
- Privacy and Other Legislation Amendment Act 2024 (Cth)
- Healthcare Identifiers Act 2010 (Cth)
- My Health Records Act 2012 (Cth)
- Notifiable Data Breaches scheme
- RACGP privacy and health information guidance for general practice.