Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you, your patients and your practice. We’re committed to complying with all applicable privacy legislation in all the countries in which we work and to upholding the Australian Privacy Principles for services we provide in Australia. If your jurisdiction has particular privacy requirements not covered by this policy, please contact us.
What this policy is about
This policy is also intended to describe to you how and why we use your personal data as well as describing options we provide for you to access, update or otherwise take control of your personal data that we process.
If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
Where we provide the Services under contract with an organisation (for example a hospital) that organisation controls the information processed by the Services. For more information, please see Notice to End Users below.
Health Records and Information Privacy
Because we are dealing with sensitive health information, we take privacy very seriously. All staff and contractors must sign a confidentiality agreement before working with us.
All patient information provided to us is kept on secure servers and cannot be accessed by anyone who is not an employee or contractor of Synapse. As soon as your files have been completed, personnel are required to shred any hard copies, and soft copies only will remain on our secure servers until it is no longer needed for any purpose, after which we will take reasonable steps to destroy the information or ensure it is de-identified.
Only you and the staff you authorise from your practice can request access to the information you have provided to us (including your information or that of your patients). Your patients may also request access to information we hold about them and such access may be provided unless it poses a serious threat to the life, health or safety of any individual or if the request for access is otherwise exempted under privacy legislation. No other medical practitioner, hospital, health fund or research body can access that information, unless to do so is authorised under law.
What information do we collect?
We only collect the personal information that is necessary to lawfully and ethically carry on our business, to provide the services our clients require in specific matters, to communicate efficiently with our clients and contacts, to keep our clients and contacts informed of legal developments and events, and to responsibly market our Services. Kinds of personal information we collect include:
Patient information (only as reasonably necessary to provide our services): For our billing service this will include patient name, dates of birth, Medicare information, health fund information, billing item numbers and dates of service. For our clinical coding service this will include complete clinical records, and for our transcription service, this will include audio files of letters and reports containing detailed health information requiring conversion to a written format.
Information you provide to us: We collect information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases of our Services. For example, you provide your contact information and, in some cases, billing information when you register for the Services. We keep track of your preferences when you select settings within the Services.
Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, promotions, activities or events.
Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. In these circumstances you will be asked to provide contact information, a summary of the problem you are experiencing, and any other information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you register for certain paid Services. For example, you might also provide payment information, such as credit or debit card details, which we collect via secure payment processing services.
Information we collect automatically when you use the Services: We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the links you click on and the type, size and filenames of attachments you upload to the Services.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, URLs of referring/exit pages and device identifiers.
Information we receive from other sources: We collect personal information about a person directly from the person concerned when it’s practical to do so. We may do this when a person meets with us, communicates with us by telephone, mail, fax or email, subscribes to our publications, or submits information via our website. We may be unable to provide the information or services a person requests if we are not given the personal information we ask for.
We also obtain information about people from our clients and their agents (in relation to specific matters), from their employers, or from publicly available records.
How do we use information we collect?
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
Patient information: We do not use patient information except strictly for the purposes for which the personal information has been provided.
Generally: We will maintain the confidentiality of the information of our clients and their patients, and we will not disclose such information unless we have the individual’s instructions or are legally able to do so.
To provide the Services and personalise your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying Synapse ads on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers and promotions. You can control whether you receive these communications as described below by opting-out.
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
How do we store and secure information we collect?
We take appropriate steps to ensure that all personal information we hold is protected from loss, misuse, or unauthorised access, disclosure or modification. We maintain physical security over our premises and access to our computer systems is limited by user identifiers and passwords. All our staff and contractors are subject to strict obligations of confidentiality.
The measures we take to ensure compliance cover three (3) broad categories, all of which we comprehensively monitor. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
The measures we take include:
- All staff and contractors sign comprehensive privacy and non disclosure agreements before they commence working with us.
- We have a privacy officer who is responsible for daily monitoring of privacy and security and also for ongoing team training and the induction and training of new team members.
- Team leaders ensure compliance and visually monitor daily operations including the appropriate use of secure logins to all servers.
Physical safeguards for any services provided from our India office include:
- Biometric (finger print recognition) technology is located on all entrances to work areas.
- The office has access control and CCTV monitoring.
- Personnel are only permitted to bring one small bag into work areas and have only one small drawer below their desks.
- Mobile phones are not permitted to be taken into work areas. Mobile phones are locked in lockers at the start of shifts. No personnel are permitted to work from home.
- Opaque film covers all windows where there is a view into a work area and where a computer screen may be visible from behind.
- A security guard is present onsite monitoring the premises.
All Australian offices also have access control and CCTV cameras.
- All servers are located in a secure, temperature controlled server room with 24 hour security and monitoring.
- All personnel work on remote Australian based servers and not on the local computers at which they sit.
- All data is stored in Australia.
- Access to local computers is blocked, all output devices/ports (e.g. USB, writable CD/DVD, flash) are disabled and external email is disabled on the local network.
- We use only communication channels secured by industry standard encryption protocols.
- Network perimeter security is implemented. This firewall ensures personnel cannot access any website that is not work related including all social media sites.
How do we share information we collect?
We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our Services.
Generally, we will only disclose personal information for a purpose that is related to the service that we are providing. We may disclose personal information to organisations that provide us with professional advice, such as solicitors, accountants and business advisors, and to contractors to whom we outsource certain functions such as data entry. These organisations may be located in countries such as Australia, India and the United Kingdom.
Where possible, we contractually obligate our contractors (and in all other circumstances, we take all reasonable measures) to ensure that they comply with the privacy standards required by legislation in the jurisdiction in which the services are being provided.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
How long do we keep information?
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services.
Managed accounts: If the Services are made available to you through an organisation (e.g., a hospital), we retain your information as long as required by the administrator of your account.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Synapse account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How can you access and control your information?
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format.
Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and update your information: Our Services give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Opt-out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.
How do we transfer information we collect internationally?
Our servers are located in Australia. We may transfer and process your information outside of Australia to wherever we or our third-party service providers operate for the purpose of providing you the Services. For example, to facilitate our global operations, our international teams, located in our wholly owned offices in Chennai and Dubai access and work on our Australian servers.
If you do not want personal information regarding you, your patients or your practice (“Your Personal Information”) to be sent outside of the country where you are located, please let us know and we can discuss the options available to you to keep the Personal Information in the country in which you are located (however you should note that these options may require you to pay additional fees).
Notice to End Users
Where the Services are made available to you through an organisation (e.g. a hospital), that organisation is the administrator of the Services and is responsible for the accounts over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organisation’s policies. We are not responsible for the privacy or security practices of an administrator’s organisation, which may be different than this policy. Please contact your organisation or refer to your administrator’s organisational policies for more information.
Contacting us about privacy
To enquire about any privacy issue, to make a request for access to or correction of personal information, or to complain about a possible privacy breach, please contact our privacy officer by emailing firstname.lastname@example.org.