Solothurn Wellness Retreat complies with relevant privacy laws and is committed to respecting your privacy.

Solothurn Wellness Retreat is committed to managing personal and health information in an open and transparent way. This includes having this clearly expressed and easily accessible privacy policy in place.
If you would like a copy of this policy in a different format – for e.g. in a different language, please contact us and we will take reasonable steps in the circumstances to accommodate your request.

What kinds of personal information do we collect and hold?

We collect and hold a range of personal information about our guests and their families.

We only collect this personal information where it is reasonably necessary for us to do so in order to carry out our business and deliver our programs and services to you.

The type of personal information we are likely to collect about you will include:

• Name
• Date of birth
• Address
• Contact details
• Next of kin details

“Sensitive information” is specifically defined under the Act and we are obliged to treat this information in a particular way; and fully explain to you why we collect this information and what we do with it.

The types of sensitive information Solothurn Wellness Retreat is likely to collect from you includes:

• personal information about the reasons you are seeking treatment at Solothurn Wellness Retreat, including but not limited to information about substance use disorders, addiction, and mental health conditions.
• Personal health information about your medical conditions
• Personal health information about the prescription medications you are taking
• Criminal history check

We collect this information in order to make decisions about your eligibility for our programs and services, to adequately cater for your needs in tailoring a personalised program, and to appropriately plan for and manage any potential medical or workplace risks in delivering services to you.

If you apply for a William Colhoun scholarship on the grounds of financial difficulty; we will also ask you to supply information about your income and financial circumstances, such as your Centrelink income details and pension status.

This information is collected to help us determine your eligibility for a scholarship.

Information about third parties is sometimes collected in relation to insurance claims.

How do we collect personal information?

We will usually collect your personal information directly from you.

We may collect this information:

• When you telephone us
• When you make contact with us by mail or e-mail
• When you talk to us in person

With your permission, we may also collect relevant personal and health information from your health care providers and other persons/ organizations who provide services to you, such as your lawyer.

Sometimes, we will receive personal information about you which is disclosed by a referral agency or by your family when they are requesting services on your behalf.

Our website may use “cookies” which collect user information and data for statistical and analytic purposes to help us develop our business.

Personal and business details of suppliers, contractors and service providers are collected when they interact with Solothurn Wellness Retreat, so that appropriate financial and business records can be maintained.

Personal information of job applicants and staff, sub-contractors and volunteers is also collected, during the application process (whether or not successful) and during the period of employment, engagement or volunteering, which may also include sensitive information.

Health information can be collected when circumstances require that first aid be administered, for administering sick leave or carers leave, or where injury or insurance claims arise.

Interacting with us anonymously

You are welcome to interact with us anonymously to make a general program query.

However, it is not practicable for us to admit you into a program or deliver services to you if you do not disclose the required personal and relevant health and other information.

How do we store personal information?

Solothurn Wellness Retreat stores information securely in both paper form at our registered office and in electronic form.

Only authorised staff and service providers will have access to your personal and health information.

We will take all reasonable steps to ensure that the personal information you give us is collected, held, used and disclosed in accordance with the purpose for which it was collected from you.

We will also take all reasonable steps to ensure that the personal information you give us is accurate, up to date and complete.

Where it is determined that it is no longer necessary or legally required for Solothurn Wellness Retreat to hold and store personal information, reasonable steps are taken to de-identify or destroy the information.

Use of information

Solothurn Wellness Retreat will only use your personal information for the particular purpose for which it was collected – known as the “primary purpose.”

Usually, this is to deliver programs and services to you.

We may also use your information to:

• Maintain accounts and records
• Undertake analysis of our business processes and outcomes
• Conduct market research and undertake marketing
• Assess and evaluate our programs and services for quality improvement and other purposes
• Review the use of our website

Personal information may also be used by Solothurn Wellness Retreat to conduct criminal record checking and employment screening for staff and sub-contractors, to obtain legal advice, and to participate in legal proceedings.

Your personal information will only be used for secondary or other purposes when:

• Your consent has been obtained; and / or
• When it is reasonably expected to be used for a related purpose; and / or
• Where required or authorised by law or a Court / Tribunal order; and / or
• Where reasonably necessary for enforcement purposed conducted by or on behalf of an enforcement body; and/ or
• Where certain “permitted general situations” or “permitted health situations” exist.

Permitted general situations are where circumstances exist involving:

• serious threats to life, health or safety of any individual; or to public health or safety;
• suspected unlawful activity or serious misconduct;
• missing persons;
• legal or equitable claims and alternative dispute resolution processes.

Permitted Health Situations are where circumstances exist involving:

• the necessity to provide a health service to you; and / or
• the collection of your personal health information is required or authorised by or under an Australian law (other than the Privacy Act); and / or
• the information is collected in accordance with rules established by competent health or medical bodies that deal with obligations of professional confidentiality which govern activities of the professional staff employed by or subcontracted by the organisation.

A further permitted health situation will exist if the use or disclosure is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety, and:

• it is impracticable to obtain the individual’s consent to the use or disclosure,
• the use or disclosure is conducted in accordance with approved guidelines, and
• in the case of disclosure – the organisation reasonably believes that the recipient of the information will not disclose the information, or personal information derived from that information.

Finally, a permitted health situation will also arise when the organization provides a health service to the individual, and:

• the recipient of the information is an authorized representative or person responsible for the individual,
• the individual is either physically or legally incapable of giving consent to the disclosure, or physically cannot communicate consent to the disclosure,
• another individual providing the health service (the ‘carer’) is satisfied that either the disclosure is necessary to provide appropriate care or treatment of the individual, or the disclosure is made for compassionate reasons,
• the disclosure is not contrary to any wish expressed by the individual before the individual became unable to give or communicate consent of which the carer is aware or of which the carer could reasonably be expected to be aware, and
• the disclosure is limited to the extent reasonable and necessary for providing appropriate care or fulfilling compassionate reasons.

Disclosure of or access to information

We collect, hold, use and disclose your personal information for the primary purposes of providing programs and services to you.

Where permissible, we disclose your personal information to other persons/organisations who are also involved in providing you with services. This can include sub-contracted service providers such as specialist therapists.

We also collect, hold, use and disclose your information for the following purposes:

• in order to comply with our legal obligations under various laws
• so that we can improve our services through quality improvement and program evaluation activities
• for direct marketing
• for the purposes of obtaining professional advice

Unless relevant to any of the circumstances outlined above; we do not provide your information to overseas recipients.

We collect, hold, use and disclose information about our employees and sub-contracted service providers for following purposes:

• to administer employment arrangements, personnel development and management responsibilities
• to provide care and services to our guests
• for quality improvement and marketing purposes
• to meet our legal obligations such as the requirement to obtain criminal record checks for staff and sub-contractors involved in providing services to our guests.

Unless relevant to any of the circumstances outlined above; we do not provide information about staff or sub-contracted service providers to overseas recipients.

Direct Marketing

Solothurn Wellness Retreat may use your personal information to keep you up to date with information about our programs and services through direct marketing. We will only do this:

• Where you have directly supplied us with your personal information (or if collected from someone else; you have given your permission for us to use it – e.g. your name and mailing address) and it is reasonably expected that the information would be used for marketing purposes; and
• A simple opt out of direct marketing communications has been provided and you have not opted out.
• You have given us specific consent to use your information for direct marketing communications.

Relevant personal information may be supplied to a third party engaged by Solothurn Wellness Retreat to undertake marketing activities on our behalf.

You can contact us at any time and let us know that you do not want to receive direct marketing communication from us.

We will process your request within a reasonable timeframe, usually within seven days.

How can you access and correct your personal information?

You can contact us in writing and request access to any personal information that Solothurn Wellness Retreat holds about you at any time.

We will ensure that your request is responded to within a reasonable timeframe and that we supply the information to you in the format you have requested (as long as this is reasonable and practicable).

You may be required to pay the reasonable costs of supplying this information to you (e.g. the costs of photocopying the documents).

Certain exceptions do apply which may restrict your access to your personal information held by us. These exceptions include:

• Where it is reasonably determined that granting access would pose a serious threat to the life, health, or safety of an individual; or to public health or safety; and / or
• Where granting access would have an unreasonable impact on the privacy of other individuals; and / or
• Where the request is frivolous or vexatious; and / or
• Where legal proceedings are underway.

Solothurn Wellness Retreat may also deny access in some circumstances:

• Where it is required to do so by law; or access would be unlawful; and / or
• Where commercial negotiations or decision-making processes may be prejudiced; and / or
• Where unlawful activity or serious misconduct is suspected; and /or
• Where enforcement related activities may be prejudiced.

If access is refused, Solothurn Wellness Retreat will give the individual a written notice which sets out the reasons for refusal, how to complain about the refusal, and where it relates to a commercially sensitive decision-making process, the reasons for refusal may include an explanation of the nature of the commercially sensitive decision.

Requests to update or correct your personal information

Solothurn Wellness Retreat is committed to ensuring your personal information is accurate, current, complete and relevant (having regard to the purpose for which it is held).

You can contact us at any time and request that we correct or update personal information held by Solothurn Wellness Retreat about you. We will take all reasonable steps to ensure we follow your request, usually within a period of 30 days.

If we have previously made an authorised disclosure of your information to a third party and you ask us to advise that third party of a correction to your personal information; we will take all reasonable steps to ensure we follow your request unless it is impracticable or unlawful to do so.

If we refuse to correct your personal information as you have requested, we will provide you with a written notice that sets out the reasons for refusal, and how to complain about the refusal.

How can you complain about a breach of the Australian Privacy Principles (APPs)?

Solothurn Wellness Retreat takes your privacy seriously.

If you have a complaint about how your personal information has been handled; you should let us know in writing.
Once you have contacted us, we will take the following steps:

• We will promptly acknowledge your complaint so you know we have received it and are taking steps to investigate and resolve it.
• Undertake an investigation to determine whether or not there appears to have been a breach of Solothurn Wellness Retreat’s obligations under the Act. In most cases, this will be completed within 6 weeks.
• Keep you updated on the progress of your complaint if the investigation takes longer than expected.
• Advise you of the outcome of the investigation, any relevant findings and any actions taken as a result.
• Keep a record of your complaint in a complaint register; which we maintain for legal and record keeping purposes and also for quality improvement purposes, including to make recommendations for updates to our information handling practices and protocols.

Your complaint will not be investigated if it is considered to be frivolous or vexatious.

If the preliminary assessment finds that the matter is complex or of a serious nature, independent investigators and/or legal advisors may be retained to assist with the investigation.

If you are not satisfied with the investigation or the outcome, you can lodge a complaint with the Office of the Australian Information Commissioner.Further information can be found at http://www.oaic.gov.au/privacy/making-a-privacy-complaint.