1. Introduction
Franklin-AI Pty Ltd (ABN 65 655 720 120) of Level P, 24 Campbell Street, Sydney NSW 2000 (Franklin-AI, we, us and our) understands that your privacy is paramount and are committed to protecting your privacy. This policy sets out how we handle information about you.
We may modify or amend this Privacy Policy from time to time and will publish any updated version of this Privacy Policy on our website when we do. This Privacy Policy was last updated on 5 September 2022.
Unless you notify us otherwise, we will assume that you have consented to us handling your personal information in accordance with this Privacy Policy.
2. Collection of personal information
Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in material form or not.
We may collect your personal information when you:
- visit our website;
- sign up to receive communications from us;
- apply to be employed by us, or in the course of your employment with us; or
- contact us by any method, such as telephone, email, post, facsimile or in person,
or otherwise as notified to you from time to time.
The personal information you provide to us will vary depending on the nature of your interaction with us, but may for example include your name, date of birth, contact details, educational qualifications, employment history, tax file number, banking and superannuation fund details and other payroll information, and other personal information contained in any communications you send to us, that you submit or upload to our website or social media pages, or that we receive from third parties. With your consent, we may also collect certain health information, details of any criminal record, and other sensitive information where relevant to an employment application you have made, or an offer of employment you have accepted, with us.
There may be occasions when we collect information about you from a third party, including Harrison-AI Pty Ltd, Sonic Healthcare Limited, and certain third-party service providers such as those who perform criminal record checks for employment applicants. In such instances, we will determine whether we would have been entitled to collect such information from you and to the extent we would not have been entitled to do so, we will destroy or de-identify such information as soon as reasonably practicable.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact us with a general enquiry, we will not ask for your name unless we need it to adequately handle your enquiry.
However, for most of our functions and activities we usually need your name and contact information.
3. Our website
Our web servers may automatically collect information when you visit our websites, including:
- your IP address;
- the date and time of your visit;
- the parts of our website you access during your visit;
- your actions on our website;
- the website you visited immediately before visiting our website; and
- the browser and operating system you are using.
In using our websites, your personal information may be collected through the use of cookies, and cookies may be used by third parties to serve relevant advertising to you. Cookies are small text files placed on your mobile device or computer by our websites which automatically collect information about you without you providing that information to us directly. Most browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies.
Please note that rejecting cookies may mean that some or all of the functions on our website will not be available to you.
Sometimes our websites contain links to other websites. When you access a website other than our websites, we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each website you visit.
4. Using your personal information
The personal information that we collect is generally used to provide products or services to you, and, if you use our website, to track your usage, to evaluate performance of our website, and to keep track of your account settings. Information collected by us may also be used for the following purposes:
- to provide you with information in relation to the products and services we provide;
- to conduct marketing activities and to conduct market research;
- to respond to your questions or suggestions;
- to improve the quality of our products or services;
- to improve the quality of your visit to our websites;
- to allow you to subscribe to receive communications from us;
- to provide training and continuous education of professional personnel; and/or
- to undertake quality assurance activities, practice accreditation, statistical analysis and complaint handling.
If you are a candidate seeking employment with Franklin-AI, we will use your personal information to process your application and assess your suitability for any role. We may retain your information for future reference.
You may opt out of receiving marketing information by notifying us accordingly, or by using any unsubscribe facility we provide for that purpose.
We receive and use de-identified information, including de-identified health information, in order to develop our products and services and for the purposes described in paragraphs (iv), (v), (vii) and (viii) above. We may share such de-identified information with the persons or organisations described in section 5 below. For clarity, de-identified information does not comprise personal information.
5. Sharing your personal information
We will sometimes need to share your personal information with persons or organisations outside Franklin-AI, which may include sharing:
- with our associated entities (as that term is defined in the Corporations Act 2001 (Cth)) for our business purposes, including Harrison-AI Pty Ltd and Sonic Healthcare Limited. Some of our associated entities are located overseas, including in the European Union, although these may change from time to time;
- with third party contractors, including our service providers, who help us conduct our business. Where information is shared with these third parties, we will take all reasonable steps to ensure that third parties observe the confidential nature of such information and are prohibited from using any or all of this information beyond what is necessary to assist us;
- with your representative(s) (e.g. a guardian, carer, translator/intermediary and/or authorised representative) unless you have told us that you do not wish us to disclose information to them;
- with our professional advisors (such as our auditors, insurers, legal advisors and ethics committee), including for medical, insurance, legal, management and/or procedural reasons;
- as permitted or required by law, including but not limited to disclosure to government and regulatory authorities;
- in the event of a dispute, or legal proceeding of any kind between you and us;
- if we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, in which case we may transfer the information we have collected from you to the other company; and
- with research bodies.
We may disclose your personal information to a third party referred to above that is located outside Australia, however due to circumstances which change from time to time, except as indicated above it is not practicable for us to specify the countries in which such third parties are located.
You can contact our Privacy Officer at the contact details below if you have any questions about the disclosure of your personal information.
We may disclose de-identified information to our associated entities and to third parties, including associated entities and third parties located outside Australia, for various purposes and from time to time.
We will de-identify personal information to carry out evaluations of our service quality and timeliness, including providing the de-identified information to other parties to assist us with these activities. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
While we may market the goods or services of third parties in limited circumstances as described above, we will always do so ourselves (or using our own third party contractors). We do not sell, rent or trade personal information to third parties for marketing purposes.
6. Accessing and correcting your personal information
We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under relevant privacy legislation. If you require access to your personal information, please contact our Privacy Officer as described in section 9 below. You may be required to put your request in writing and/or provide proof of your identity for security reasons.
For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.
If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).
We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it. If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.
7. Protecting your personal information
We are committed to protecting your personal information. We take appropriate security measures to protect your personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as:
- access control procedures;
- confidentiality requirements applicable to our employees and subcontractors; and
- network firewalls, encryption and physical security to protect the privacy of your personal information.
Records are held securely for future retrieval in accordance with applicable laws and good business practice. If Franklin-AI no longer needs, or is no longer required, to retain personal information, Franklin-AI will take reasonable steps to destroy the information or will ensure that the information is de-identified.
8. Change of policy
We may modify or amend this Privacy Policy from time to time. We will publish the current version of this Privacy Policy on our website at https://franklin.ai/privacy-policy.
9. Contact information
If you have any queries or complaints with regards to our collection, use or management of your personal information, please contact our Privacy Officer:
Attention: Privacy Officer
Franklin-AI Pty Ltd
Level P, 24 Campbell Street, Sydney NSW 2000
Email: privacy@franklin.ai
If you make a complaint, we will endeavour to respond to it as soon as possible. If you are dissatisfied with our response, you have the right to make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at enquiries@oaic.gov.au