1. About this Privacy Policy.
Verb Clinic (“Verb”, “we”, “us” or “our”) is operated by JZHAO INVESTMENTS PTY LTD, ABN 20 652 582 431.
We respect your privacy and recognise that information about your health is sensitive. This Privacy Policy explains how we collect, hold, use and disclose personal information when you visit our website, complete our pre-screen, contact us, book a consultation or otherwise interact with Verb.
We are committed to handling personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and applicable health privacy legislation including the Health Records and Information Privacy Act 2002 (NSW) where relevant.
2. How Verb’s services work.
Verb provides an online pathway to alternative healthcare services, including a preliminary pre-screen, appointment booking and access to telehealth consultations.
Verb works with clinical support and telehealth service providers to facilitate appointment bookings, provide access to qualified healthcare practitioners and support the delivery of telehealth consultations.
Where pharmacy services are required following a consultation, Enliven Pharmacy may provide dispensing, pharmacy support and delivery services.
Verb, healthcare practitioners, clinical support and telehealth service providers, and Enliven Pharmacy may each have separate responsibilities for the personal and health information they collect and hold in providing their respective services.
3. Personal information Verb may collect.
The information we collect depends on how you interact with Verb and may include:
- Your name and contact details.
- Your date of birth or age where requested.
- Information submitted through contact or enquiry forms.
- Information provided through the Verb pre-screen.
- Information about your general health concerns, symptoms and previous treatment experience.
- Information required to help facilitate a consultation booking.
- Communications between you and Verb.
- Information relating to enquiries, complaints or feedback.
- Technical information associated with your use of our website, such as device, browser and IP information.
- Cookie and website usage information where applicable.
4. Health information.
Some information collected through the Verb website may be health information and therefore sensitive information under Australian privacy law.
This may include information about your health concerns, symptoms, chronic or ongoing conditions, previous treatments and your response to previous treatment.
We aim to collect only information that is reasonably necessary for the purpose for which it is requested.
5. The Verb pre-screen.
The Verb pre-screen asks a limited number of questions to help determine whether a Verb consultation may be a suitable next step for you.
The pre-screen uses predefined rules based on the answers you provide to generate a preliminary result and direct you to an appropriate next step.
The pre-screen is not a medical consultation, diagnosis or clinical assessment. It does not determine whether you are eligible for any particular treatment or prescription.
A positive pre-screen result does not guarantee that treatment will be recommended. Treatment suitability can only be determined by a qualified healthcare practitioner following an individual clinical assessment.
If your result indicates that booking may not currently be appropriate and you believe you entered information incorrectly, or you would like clarification, you may contact Verb using the details at the end of this Policy.
6. How we collect information.
We generally collect personal information directly from you when you:
- Complete the Verb pre-screen.
- Submit a contact or enquiry form.
- Communicate with us by email, telephone or another method.
- Use or interact with our website.
- Provide feedback or make a complaint.
We may also receive information from an authorised healthcare provider, pharmacy, clinical support or telehealth service provider, or another person where you have authorised the disclosure or where the collection is otherwise permitted by law.
7. Why we collect and use personal information.
We may use personal information to:
- Provide and administer the Verb website and pre-screen.
- Provide your pre-screen result.
- Respond to enquiries and requests.
- Assist you in accessing appropriate healthcare services.
- Facilitate and prefill appointment bookings where appropriate.
- Communicate with you about services you have requested.
- Coordinate authorised administrative matters with healthcare practitioners, clinical support and telehealth service providers, or Enliven Pharmacy.
- Maintain appropriate business and service records.
- Improve the operation, security and performance of our website and services.
- Manage complaints and feedback.
- Meet legal, regulatory and professional obligations.
- Protect the security and integrity of our systems.
8. Booking, clinical support and telehealth services.
Verb works with third-party clinical support and telehealth service providers to facilitate appointment bookings and access to telehealth healthcare services.
When you proceed to book a consultation, the booking service may be provided through a secure hosted booking portal or through a booking portal embedded within the Verb website.
Even where the booking portal appears within a Verb webpage, the booking and clinical systems may be operated by a separate clinical support or telehealth service provider. Information you enter directly into those systems will be handled in accordance with the privacy and professional obligations applying to the relevant provider and healthcare practitioner.
Where appropriate, information you have already provided to Verb may be securely transferred to the booking service to simplify the booking process. This may include information such as your name, contact details and other information reasonably required to prefill your booking.
Where authorised and clinically appropriate, relevant information collected through the Verb pre-screen may also be made available to the healthcare practitioner or clinical service provider to support your consultation.
Depending on the services enabled for Verb, we may receive limited administrative booking information such as appointment references, appointment type, appointment time or appointment status. We will only use such information for purposes connected with administering the service.
9. Clinical information and healthcare records.
Clinical consultations are provided by appropriately qualified healthcare practitioners through Verb’s telehealth service arrangements.
The treating practitioner is responsible for their clinical assessment, professional decision-making and clinical record-keeping obligations.
Information you provide during a clinical consultation may form part of your healthcare record and will be handled by the relevant healthcare provider and clinical systems in accordance with applicable privacy, health-record and professional requirements.
Verb does not require access to your complete clinical record merely because you have used the Verb website, completed a pre-screen or booked a consultation through the Verb pathway.
10. Enliven Pharmacy.
If a prescription forms part of your treatment plan, relevant information may be provided to Enliven Pharmacy where you request, authorise or otherwise choose Enliven Pharmacy to provide pharmacy services.
This may include information reasonably necessary to dispense a prescription, provide pharmacy advice, arrange delivery or otherwise provide pharmacy services.
Enliven Pharmacy is responsible for the information it collects and holds in connection with its pharmacy services and may have its own privacy policy and terms.
11. Disclosure of personal information.
Where reasonably necessary and permitted by law, we may disclose personal information to:
- Clinical support, booking and telehealth service providers where required to administer or provide the Verb service.
- Healthcare practitioners involved in your care where appropriate.
- Enliven Pharmacy where you have authorised or requested pharmacy services.
- Website hosting, security, communications and technology providers.
- Professional advisers, insurers and auditors.
- Government agencies, regulators, courts or law-enforcement bodies where required or authorised by law.
We do not sell your health information.
12. Website hosting and service providers.
We use third-party technology and service providers to operate our website and provide our services.
These providers may process personal information on our behalf where reasonably necessary to perform their services.
We take reasonable steps to select providers appropriate to the nature and sensitivity of the information involved.
13. Cookies, analytics and tracking technologies.
Our website may use cookies and similar technologies that are necessary for website functionality, security and performance.
We may also use analytics technologies to understand how visitors use our website.
Because interactions with a healthcare website may reveal sensitive information, we take particular care with third-party analytics, advertising and tracking technologies.
We do not intentionally provide health information entered into the Verb pre-screen, booking forms or clinical services to advertising platforms for targeted advertising.
Non-essential tracking or advertising technologies will only be used where appropriate and where any consent required by law has been obtained.
You may be able to manage non-essential cookies through the cookie controls provided on our website.
14. Overseas processing and disclosure.
Some technology, clinical support or telehealth service providers used in connection with Verb may store or process information outside Australia.
Where personal information is disclosed overseas, we will take reasonable steps as required under applicable Australian privacy law.
Where practicable, information about the countries in which overseas recipients are likely to be located will be made available in this Policy or on request.
15. How we protect personal information.
We take reasonable administrative, technical and organisational steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.
These measures may include access controls, secure hosting, authentication, software updates, restricted access and security monitoring.
No internet-based system can be guaranteed to be completely secure.
16. How long we retain personal information.
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, regulatory, professional and record-keeping requirements.
Health records held by healthcare providers are retained in accordance with the health-record laws and professional obligations applying to those providers.
When information is no longer required to be retained, we will take reasonable steps to securely destroy or de-identify it where permitted by law.
17. Accessing or correcting your information.
You may request access to personal information Verb holds about you or ask us to correct information you believe is inaccurate, incomplete or out of date.
We may need to verify your identity before processing a request.
Where the information you are seeking forms part of a clinical record held by your healthcare practitioner or a clinical or telehealth service provider, we may direct you to the appropriate provider to assist with your request.
18. Direct marketing.
Healthcare and administrative communications necessary to provide a service you have requested are separate from marketing communications.
Where you have separately consented to receive marketing communications from Verb, we may contact you with news or information about our services.
You may withdraw your marketing consent at any time using the unsubscribe option provided or by contacting us.
Withdrawing from marketing does not prevent us or a healthcare provider from sending communications reasonably necessary to administer healthcare or an appointment.
19. Data breaches.
We maintain processes for responding to suspected privacy and security incidents.
Where a data breach is subject to notification requirements under the Privacy Act or another applicable law, we will take the steps required by law, which may include notifying affected individuals and the relevant regulator.
20. Privacy complaints.
If you have a concern about how Verb has handled your personal information, please contact our Privacy Officer using the contact details below.
We will review your complaint and aim to respond within a reasonable period.
If you are not satisfied with our response, you may have the right to contact the Office of the Australian Information Commissioner or another applicable privacy or health-record regulator.
21. Changes to this Privacy Policy.
We may update this Privacy Policy where our services, systems, information-handling practices or legal obligations change.
The current version will be published on our website together with the date it was last updated.
22. Contact us.
Verb Clinic
support@verbclinic.com.au