Privacy Policy

Notice of Privacy Policy Update

We value your trust and are committed to safeguarding your personal information. To ensure transparency and compliance with Australian privacy laws, we have updated our Privacy Policy.

Key Changes to Our Privacy Policy:

Clearer explanations of how we collect, use, and store your information, including how we will contact you about our services

The updated Privacy Policy will take effect on 5 December 2024.

We encourage you to review the updated Privacy Policy to stay informed about how we handle your information.

You can view the full Privacy Policy below:

This Privacy Policy outlines the personal information handling practices of Hearing Australia in compliance with the Australian Privacy Principles (APP) found at Item 13 in Schedule 1 to the Privacy Act 1988 (Cth) (the Privacy Act). We are committed to safeguarding your privacy, being transparent about how we handle your Personal Information, and complying with all relevant legislation.

This Policy explains:

The types of personal information Hearing Australia collects and holds;
How Hearing Australia collects and stores this information; and
The purposes for which Hearing Australia collects, holds, uses, and discloses personal information.

You should read this Privacy Policy if you are:

seeking access to, or receiving our hearing and/or related services;
an individual whose Personal Information may be given to, or held by, us;
a contractor, consultant, supplier or vendor of goods or services to Hearing Australia; or
seeking employment with us.

The specific legal obligations of Hearing Australia when collecting and handling your personal information are outlined in the Privacy Act. Under the Privacy Act, you have the right to:

Know Why Your Information is Collected: Hearing Australia will inform you about the purpose of collecting your personal information, how it will be used, and who it will be disclosed to.
Anonymity and Pseudonymity: Where practical and lawful, we allow you to interact with us anonymously or using a pseudonym. However, in specific instances, proof of identity will be required.
Access and Correction: You can request access to your personal information and ask for corrections if necessary.
Unwanted Marketing: You can opt out of receiving direct marketing communications from us.
Complaints: You can make a complaint if you believe Hearing Australia mishandled your personal information.

What is Personal information?

The Privacy Act defines personal information as:

Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in material form or not.
It can include information such as:
- a person’s name or address
- bank account details and credit card information
- photos
- information about opinions and what a person likes

Sensitive information is a subset of personal information and is defined in the Privacy Act as information or opinion about an individual’s:

racial or ethnic origin
political opinions
membership of a political association
religious beliefs or affiliations
philosophical beliefs
membership of a professional or trade association
membership of a trade union
sexual orientation or practices, or
criminal record that is also personal information; or
health information about an individual
genetic information that is not otherwise health information
biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or
biometric templates.

Why does Hearing Australia have a Privacy Policy?

The first of the APPs, which form part of the Privacy Act, requires all organisations covered by the Privacy Act to have a Privacy Policy in place.

We collect, hold, use and disclose personal information to carry out functions and activities that are set out in our establishing act, the Australian Hearing Services Act 1991 (the AHS Act) and other legislation that confers powers or functions on HA, including the Public Governance Performance and Accountability Act 1993.

Kinds of information collected and held by Hearing Australia

Our business is to understand and meet our client’s hearing needs and deliver a range of hearing and related services. To do this effectively we need to collect certain Personal Information about you.

We may collect your information for the following purposes:

Provision of Services: To facilitate your use of our website, manage your bookings, and process orders (battery orders/cochlear implant parts etc);

Improving Our Website: To understand how our website is used and to enhance user experience;
Marketing and Advertising: To deliver personalised ads and content, including through retargeting and programmatic advertising viewable on the website;
Security: To protect user data and privacy, including through the use of two-factor authentication (2FA) for existing clients to book online, use our online chat function and manage bookings; and
Client/user surveys - to help us understand client/user feedback about their experiences with and expectations for our products or services, and how their booking process or experience on the website was and could be improved.

The type of personal information we may collect can include:

Information collected from clients:
names (not pseudonyms, as Hearing Australia is required by law to verify the identities of those to whom it provides services)
contact details
street address
citizenship / residency
professional experience
gender
sexual orientation
disability status
language(s) spoken
payment details including bank account details
ethnic origin
business affairs (information about company directorships and other business information is collected in order to determine eligibility for Hearing Australia’s programs)
Pensioner number
Department of Veterans’ Affairs number
Other information relevant to enable Hearing Australia to make its service assessments or perform its statutory functions.

Information collected from subscribers to Hearing Australia’s electronic publications, notices and event invitations

names
email addresses
occupation category
job title
company
state and country
street address
phone number
website
site visit data
other data fields as required e.g. honorific.

Information collected through Hearing Australia’s website

names
contact details
role(s)
photographs.

Voluntary surveys and research participation undertaken by Hearing Australia’s research arm NAL or its subcontractors

names
contact details
business affairs of individuals
opinions held by individuals
other information relevant to the research to help Hearing Australia perform its functions.

Letters / emails received by Hearing Australia

names
addresses
email address
gender
job title
telephone numbers
business affairs of the author and / or third parties
opinions
details of complaints.

Social media

names (these may be pseudonyms)
email addresses
postal address
opinions
telephone numbers
photographs.

Invoices

Names
addresses
contact details
business affairs
outstanding obligations to Hearing Australia
contractors’ details.

How is personal information collected?

Personal Information collection

Hearing Australia collects personal information from individuals in different ways, including via written forms, our website services and via our call centre and network of hearing centres.

Hearing Australia works hard to ensure it only collects the information we need for the functions or activities that we are carrying out. The main way we collect personal information about you is when you give it to us. However, for practical reasons, Hearing Australia may sometimes collect information indirectly.

Collection may be solicited by Hearing Australia (where you provide the information in response to a Hearing Australia initiated interaction or invitation) or unsolicited (where you initiate the contact and correspond with Hearing Australia).

We may collect your personal information (such as contact details) when you:

contact us to ask for information (but only if we need it);
attend hearing screenings, assessments and/or appointments;
complete application, consent or other forms;
request us to complete applications on your behalf (e.g. online voucher applications);
visit our websites;
register for our products or services;
request information about us, our products or our services;
participate in research (including through the National Acoustic Laboratories (NAL), the research arm of Hearing Australia);
provide feedback, participate in a client survey, comment, or make a complaint to us; and
apply for employment with us.

Sensitive Information collection

We may collect sensitive information such as health-related data. Certain sections of our forms may request you to provide sensitive information (such as information about a person’s ethnic origin, health or sexual orientation) about yourself or other individuals. Sensitive information is given further protections under the Privacy Act.

We will only collect such information if it is directly related to one or more of Hearing Australia’s functions or activities in compliance with the APP and only with your consent.

For example, we would generally need to collect health-related information from you to provide hearing services to you, or if you participate in a research study with us.

We may also collect indigenous and culturally and linguistically diverse identifiers to help us deliver better services to clients in culturally appropriate ways (eg. use of interpreters).

Indirect collection

We may collect personal information indirectly from publicly available sources or third parties involved in your hearing or related health care parties such as:

our authorised representative if you have one (eg. family members or legal guardians); or
others involved in your hearing or related health care (such as your General Practitioner).

We may also collect personal information from publicly available sources to enable us to contact stakeholders who may be interested in our work or in participating in events or consultations with us.

This collection will occur lawfully and fairly. If you are providing any information on behalf of another individual, you must ensure you have the relevant authority to provide their personal information (including any sensitive information) to us for the purposes associated with the applicable collection method.

We will only collect your Personal Information in this way if it is unreasonable or impractical to collect this information directly from you or if we are otherwise permitted to do so by you, or by law.

If the information is sensitive personal information, the collection will only occur if you have consented to it or it is otherwise permitted under the Privacy Act.

Anonymity and pseudonymity

In general, you may wish to communicate and deal with Hearing Australia without revealing your names. However, there are circumstances where Hearing Australia is required to ascertain the identity of the people with whom it deals.

We are committed to continuous improvement and may ask for other information voluntarily from time to time (eg. through customer satisfaction surveys, market research or special offers) to enable us to improve our services and consider the wider needs of our clients or potential clients.

However, for most of our functions and activities we usually need your name and contact information and enough information about the matter to enable us to fairly, safely and efficiently, handle your inquiry, request for services, complaint or application.

Whether you will be able to correspond with Hearing Australia on an anonymous basis or by using a pseudonym will turn on the facts, including the purpose for your corresponding with Hearing Australia. In some instances, anonymity may not be practical as Hearing Australia may require proof of your identity before it can action the matter, for example, when you make a request for release of your information.

Marketing Subscription

With your consent, we may use your personal information to send marketing communications through various channels, including phone, SMS, social media, email, or mail. Hearing Australia may use your Personal Information to send you information electronically or by post, including promotional material, about us or our products and services or products which we think may be of interest to you but only with your consent.

These communications may inform you about special offers, discounts, promotions, and services we provide.

Some of the information we collect to provide you with relevant marketing material, may include contact details, linked to the information you provided to us in a subscription form we sent to you in a subscription email, for example, name, last name or your email address.

If you no longer wish to receive marketing or promotional material from us, you can ‘opt out’ or ‘unsubscribe’ by contacting us during business hours using the contact details as set out in this Policy, via our website or by contacting your local hearing centre or calling 134 432.

We will action any request to unsubscribe within 30 days by updating your contact preferences and immediately ceasing to send marketing material.

NOTE: Even if you opt out of receiving our marketing material, Hearing Australia will still communicate with you as part of your ongoing care, for as long as you remain our client. As a health services provider bound by professional and ethical obligations, we reasonably assume your consent to contact you for these purposes, considering the natural deterioration of hearing with age, the impact a hearing condition can have on an individual, and continuous advancements in hearing aid technology.

Social Media

Hearing Australia operates a number of social media channels to which subscribers may sign up. We use social networking services such as Twitter, Facebook and YouTube to communicate with the community about our work.

When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you and the public.

The social networking service and its partners will also handle your personal information for its own purposes and may collect and hold your personal information overseas.

The Hearing Australia Privacy Policy does not apply to external service providers that Hearing Australia may use, for example social media services that Hearing Australia uses may hold your personal information and are required to manage your personal information in accordance with the service provider’s privacy policy and law.

Hearing Australia provides links on its website to other service providers and is not responsible for those service providers.

Registrations and feedback

We will collect information that you provide to us when registering for our events, or when submitting feedback on your experience with our website.

When registering for an event, you may be required to provide your personal information including your name, address, telephone number and email address in the registration form.

Where is the personal information held?

We take measures to protect your personal information from internal and external threats. Hearing Australia takes all reasonable steps to ensure that the Personal Information we hold is accurate, complete, relevant, up to date and to ensure that outdated data is securely destroyed.

To ensure that the personal information we collect is accurate, up-to-date and complete we:

record information in a consistent format;
where necessary, confirm the accuracy of information we collect from a third party or a public source;
promptly add updated or new personal information to existing records; and
regularly check contact details with clients and stakeholders to verify their accuracy.

Hearing Australia holds personal information in a variety of manners. The information may be contained within Hearing Australia’s software and systems, these include:

electronic databases
email
electronic document and records management system
cloud based software
paper files.

Electronic information is accessible only to Hearing Australia employees and contractors who are not permitted to disclose Hearing Australia information.

We train our employees who handle Personal Information to respect the confidentiality and privacy of your information. In doing so, our information management processes must at all times comply with the information storage and security requirements set out in the Archives Act 1983 the Privacy Act and the Australian Government’s security requirements for IT access.

We destroy personal information in a secure manner when we no longer need it. We may however need to retain records for a significant period of time in order to comply with our legal obligations under the National Archives of Australia – Department of Health and Ageing_Record Authority_2011/00396196 (naa.gov.au).

Why is the information collected, held, used and disclosed?

We may contact you to provide you with information and advice in relation to our services and products in order to better manage and support with your hearing condition, tinnitus, or related matters. If you represent one of our clients, we may also provide you with the same information regarding their hearing condition. This could include appointment reminders, information regarding changes to our services and new products, information to get the most out of your hearing aids (if applicable), and a newsletter. This may include communications via phone, SMS, email, or mail.

We may also contact you to invite you to participate in research activity, to seek your input to surveys, to invite feedback on our services and products, and to obtain your consent to use your details in our marketing and consumer research activities. In limited circumstances, Hearing Australia may collect and use your Personal Information for other purposes not listed above. If we do so, we will make it known to you at the time we collect or use your personal information.

Hearing Australia will only ask for the information we need to undertake our functions and activities. If you choose not to provide us with information about you, we may not be able to provide all the services you may need.

All the personal information Hearing Australia collects is for the purposes of fulfilling its functions. Hearing Australia’s functions are defined under the AHS Act and include:

the provision of hearing services to voucher holders under the Government’s Hearing Services Program (HSP) and designated persons eligible under the Community Service Obligation (CSO) Program (including children, young adults, adults with complex needs and Aboriginal and Torres Strait Islanders);
the provision of hearing services to Comcare clients and Commonwealth employees;
entering into arrangements with third parties or contractors for the supply, research, design and development of hearing services, including providing services to anyone with a hearing loss;
carrying out research; and
providing advice, education, training and consultancy services in relation to hearing services.

The AHS Act also sets out a range of governance obligations and operational requirements for the organisation. In carrying out our functions and activities we also:

communicate with the public, stakeholders and the media, including through websites and social media; and
assess candidates for career opportunities with Hearing Australia.

Hearing Australia collects Personal Information about you for the primary purpose of providing you with hearing and related services and other purposes such as marketing, conducting market research and undertaking research into hearing health (through our research division, NAL). We will only collect sensitive information with consent and if it is reasonably necessary for, or directly related to, these functions.

NOTE: Hearing Australia will occasionally use personal information for a secondary but related purpose. The use of personal information for this purpose would not be the original purpose for which the personal information was collected. However, Hearing Australia will only use personal information for a secondary purpose if such purpose is related to (or, for sensitive information, directly related to) the primary purpose, and if it is reasonable that the individual would expect Hearing Australia to use the information for this purpose.

In the event that the secondary purpose is not related to the primary purpose, Hearing Australia will seek the individual’s consent before using the information for the secondary purpose. Hearing Australia will not sell personal information to another person.

Disclosure

We may disclose information to service providers for specific purposes, always ensuring contracts include privacy requirements. Sensitive information is disclosed only for the intended purpose or with your consent.

Hearing Australia will not disclose your Personal Information without your permission, unless the disclosure is:

in accordance with what you would reasonably expect us to disclose because it relates to the primary purpose for which it was collected (or if it is sensitive information, that it is directly related);
in accordance with this Privacy Policy or any agreement you enter into with us;
required or authorised by law; or
otherwise permitted by the Australian Privacy Principles (APPs).

Depending on the nature of your engagement with us, we may disclose your Personal Information to third parties that provide products and services to us or through us, or to other third parties. Hearing Australia may also disclose your Personal Information to:

• any person you request or consent to receiving the information (including but not limited to marketing service providers);

• suppliers to Hearing Australia (e.g. manufacturers of hearing aids, ear moulds, Cochlear implants or other related products);

• third party service providers, contractors, consultants or vendors engaged to provide hearing or other services directly related to purpose for which we collect your information on Hearing Australia's behalf;

your general practitioner or other hearing service providers;

your parents, guardians or family members unless you advise us of a Court or tribunal order restricting this disclosure;
the Department of Health and Aged Care for assessing your eligibility, processing your voucher application or for audit purposes;
relevant officers of the Commonwealth, State or Territory Governments (such as Services Australia and the Departments of Veterans’ Affairs, Defence, Education, Employment, or Medicare);
relevant Commonwealth, State or Territory statutory authorities (such as the National Disability Insurance Agency);
relevant Ministers or Commonwealth Parliamentary Committees;
external legal advisers/lawyers;
law enforcement agencies;
the Office of the Australian Information Commissioner (OAIC) or other law enforcement agencies;
other individuals or agencies as Hearing Australia is required, or authorised to, by law;
media outlets for promotional purposes but only with your consent; or
responses to requests for information (including requests under the Freedom of Information Act, the Privacy Act and under various confidentiality provisions under which we operate).

Disclosure to service providers

Hearing Australia uses a number of service providers to whom we disclose personal information. These include providers that host our website servers, manage our information and communications technology (ICT) and manage our human resources information.

NOTE: To protect the personal information we disclose, we:

enter into a contract or Memorandum of Understanding (MOU) which requires the service provider to only use or disclose the information for the purposes of the contract or MOU; and
include special privacy requirements in the contract or MOU, where necessary.

Hearing Australia does not accept responsibility for use or disclosure of personal information in circumstances beyond our control.

Disclosure of sensitive information

We mainly share your sensitive information only for the purposes for which it was originally collected. Sometimes, we might also share it for closely related secondary purpose that you would reasonably anticipate or have otherwise expressly consented to – for example, to ensure comprehensive management of your hearing.

Disclosure of personal information overseas

Web traffic information is disclosed to Google Analytics when you visit our websites. Google stores information across multiple countries, however the data collected is not personal information and is solely disaggregated data.

When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.

NOTE: Although Hearing Australia will hold, store and use your personal and sensitive information onshore in Australia, Hearing Australia may enter into contracts or arrangements with third parties that may store, hold and use your information overseas.

Accessing and seeking correction of personal information

The Australian Privacy Principles 12 and 13 give individuals the right to access or seek correction of the personal information Hearing Australia holds about them. There is no fee associated with making a request. On receipt of your written request, we will respond within 30 days.

If you make a request, Hearing Australia must give you access to your personal information, and take reasonable steps to correct personal information to ensure that the information is accurate, up-to-date, complete, relevant and not misleading, having regard to the purpose for which it is held.

If you would like access to the personal information Hearing Australia holds about you, or would like to correct personal information which you believe is incorrect, please contact Hearing Australia’s customer services team, setting out your request, and how you can be contacted.

We will ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we will notify you in writing setting out the reasons.

If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.

Ordinarily we will give you full access to your Personal Information and take reasonable steps to correct any personal information you consider is incorrect. However, there may be some legal or administrative reasons to deny access.

If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why.

You also have the right under the Freedom of Information Act (FOI Act) to request access to documents that we hold and ask for information that we hold about you to be changed or annotated if it is incomplete, incorrect, out-of-date or misleading.

How will a request for access or correction be handled?

Hearing Australia will acknowledge the request within 10 working days of receipt and will provide a response within 30 working days. In certain circumstances, Hearing Australia may require more time to process the request, in which case Hearing Australia will notify the applicant of the delay before the 30 days have elapsed.

Note that information held by Hearing Australia forms Commonwealth records. Commonwealth records may generally only be destroyed or amended in accordance with the Archives Act 1983.

Should Hearing Australia decide not to comply with the request to provide or amend the personal information, it will provide a written notice of the refusal, including the reasons for the refusal and the complaint mechanisms available to the applicant.

How to complain about breaches of the APPs

We must manage your personal information in accordance with the obligations imposed under the APPs. If you have concerns about our information handling practices, or for any other queries in relation to this Privacy Policy, please contact us using the details in section 16 below. The Privacy Act notes that any individual who considers that an organisation has interfered with their privacy should make their complaint to that organisation or agency first and allow an adequate opportunity for the complaint to be dealt with by the organisation.

If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint. We respond promptly and, if necessary, involve senior officers for resolution.

We will acknowledge receipt of your request. We will also advise you of the outcome of the consideration of the issues raised. Hearing Australia will investigate your complaint and notify you of the progress of our investigation within 30 days. We will let you know if we can resolve the matter quickly or whether we need more time to investigate and resolve your complaint.

NOTE: If you are not satisfied with our response, you can contact the Privacy Commissioner who is part of the Office of the Australian Information Commissioner (OAIC) seeking a review of the decision via the following avenues:

Phone: 1300 363 992

Online: Enquiry Form

Post: Sydney Office - GPO Box 5218 Sydney NSW 2001 or Canberra Office - GPO Box 2999 Canberra ACT 2601

Likelihood of disclosing personal information to overseas recipients

Hearing Australia’s IT providers host our data in Australia. However, in some circumstances, Hearing Australia may use service providers based in other countries, which may involve the disclosure of some personal information.

If Hearing Australia does engage a service provider (e.g. a research company) to collect personal information in Australia, it will contractually require the company to comply with the Australian Privacy Principles.

In circumstances where Hearing Australia is using overseas service providers that may handle personal information, Hearing Australia will additionally select a service provider in a country with similar privacy protections to those afforded by the Australian Privacy Act.

Website

Hearing Australia provides the following privacy statements in relation to website usage.

Site visit data

Hearing Australia’s public website, www.hearing.com.au, is hosted in Australia. There are a number of ways in which we collect information though our website.

Hearing Australia makes a record of all visits on our websites and logs the following information for statistical purposes: the user’s server address, the user’s top level domain name (example: .com, .gov, .au, .uk etc.), the date and time of the visit to the site, the pages accessed and documents downloaded, the previous site visited and the type of browser used.

We use web analytics tools including: Google Analytics, Google Tag Manager, Kentico, Hotjarm and StackAdapt to enhance your website experience, monitor web traffic information and deliver web-based advertising. Google stores information across multiple countries, however the data collected is not personal information and is solely disaggregated data. Data collected in that way is used for improving our services and is stored securely within Australia.

No attempt will be made to identify users or their browsing activities, except where:

a user has signed up to one of our mailing list services; or
in the event of an investigation, when a law enforcement agency or another government agency may exercise its legal authority to inspect our internet web server logs.

Hearing Australia may also use web beacons to track the visiting patterns of individuals accessing our website or click stream data for statistical, reporting and maintenance purposes. If your web browser has ‘Do Not Track’ enabled, we will not track your visit. You can read more about Google Analytics here.

External sites that are linked to or from the Hearing Australia Internet site are not under our control and may collect your Personal Information so you are advised to view their privacy collection notices separately. Hearing Australia is not responsible for any content contained in any external websites, or accidental or malicious damage that may arise to your local systems, data, software or hardware through accessing Hearing Australia's website or any external websites and their content.

Collection of personal information

Hearing Australia will record your email address or other supplied details if you send us an online message or complete a form online.

Supplied information will only be used for the purpose for which you have provided it or a related secondary purpose and will not be added to a mailing list unless you have consented to this. Unless permitted or required by law, we will not use your email or other addresses for any other purpose, and will not disclose them, without your consent.

Editing and deleting your subscriber information

You can unsubscribe to Hearing Australia’s marketing activities by contacting the email address at the bottom of every newsletter or by contacting our general enquiry line on 134 432.

Cookies

We use web browser cookies on this website. Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the website. These cookies do not contain information by which Hearing Australia can identify you.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our website directly or by clicking through an email, or our digital advertisement, or access our website via social media platforms, a cookie may be downloaded onto your computer's hard drive.

We use cookies for functionality but respect your browser preferences. Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing our website. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from our website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Cookies are sent back to the originating server. Session cookies are used during a browsing session at the site. Please note that most browsers can be configured to notify the user when a cookie is received, allowing you to either accept or reject it. If you do not accept cookies, then some of the features on our site will not work as they are intended to.

Contact Information

For any privacy related concerns, you can contact our Privacy Officer online through our enquiry form by clicking here or by any of the options listed below:

Mail: The Privacy Officer, Hearing Australia, Level 5, 16 University Avenue Macquarie University NSW 2109

Email: privacy@hearing.com.au

Phone: Mainline: 134 432

TTY users’ phone: 133 677 then ask for 134 432
Speak and Listen users’ phone 1300 555 727 then ask for 134 432
Internet relay users connect to the NRS then ask for 134 432
Translating and Interpreting Service: 131 450 then ask for 134 432

This Policy was last updated in November 2024.