(a) The Privacy Amendment (Private Sector) Act 2001

Towards the end of 2001, the Federal government enacted changes to privacy law in Australia. Amendments to the Privacy Act 1988 (Cth) ("the Privacy Act"), regulate the way in which many private sector organisations, including Bullivant's, collect, use, disclose, keep secure and manage personal information. The new provisions aim to give members of the public greater control over the way information about them is handled, and apply to personal, but not business-related, information.

Under the amended Privacy Act, organisations must comply with 10 National Privacy Principles or an approved privacy code.

You can find out more about the Privacy Act at www.privacy.gov.au

(b) Collection of personal information

Our company mainly collects personal information for the following purposes:

• to manage subscriptions to newsletters and other publications
• to provide naturopathic services
• to conduct competitions or other promotions
• to conduct and administer training programmes

We only collect personal information when necessary to provide the relevant services or to assist it in providing better services.

Personal information is normally collected directly from the person it concerns, typically in the following ways:

• as part of a subscription to one of our publications and/or promotions
• as part of a consultation with our naturopathic staff, whether in-store, by telephone, or via the internet
• on the entry form for a competition or promotion
• when consumers participate in marketing surveys
• when participants undertake a training programme

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(c) How we use and disclose personal information

The way we use and disclose personal information depends on how it was collected, and from whom.

i. If you are a patient

We sometimes provides naturopathic consultations or advice, either in person, over the phone, or via our websites. To provide this kind of advice effectively, we may need to collect information about you and your health.

Under both the National Privacy Principles and our Privacy Policy, health information is given special consideration.

Personal information about health is particularly sensitive, and is only collected to ensure that professional, accurate, and practical advice is given by our naturopathic staff. Our company manages health information in accordance with the National Privacy Principles.

We retain this information in order to provide you with a professional level of care, and any personal health information provided to our naturopathic staff is used only for this purpose.

Personal information collected by our naturopaths is not used for direct marketing purposes without your explicit consent. However, the information may be shared between our naturopaths to ensure that the best possible quality of advice is provided.

Sometimes health information may also be used for statistical analysis or other management purposes. When this happens, we respect your privacy, and neither the information that we use nor the results will identify you.

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ii. If you are a consumer

Consumers who use our products are sometimes invited to enter competitions or promotions, or to subscribe to our publications. This may involve providing us with personal information. When we obtain personal information this way, we retain it in order to manage the competition, promotion or subscription. We may also, with your consent, retain your contact details to advise you of promotions or provide other information that may interest you in the future.

The information collected is not disclosed to other organisations except our mailing house (to enable items to be posted to you).

We make every effort to ensure that personal information we collect, use or disclose is accurate, complete and up to date, and anyone can ask to be taken off our mailing list without cost at any time.

In some instances, where we have collected personal information from you, we may be required by law to disclose that information to certain government bodies.

Sometimes we conduct market research. When market research includes personal information, we will either remove identifying details, or obtain your consent for our use of the information.

We may also collect personal information about consumers when goods are returned or in other unusual dealings with individual consumers. On these occasions, personal details are only used for the purposes of managing the matter at hand.

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iii. If you are a trainee/student

We store and maintain records of participants in training programmes. This is for the purpose of administering those programmes and providing advice on further training opportunities. Occasionally, statistical reports are produced that show data concerning attendance numbers. In these instances, only information showing store names and attendance numbers is reported, and the information is not communicated outside our company.

Any personal information collected is not disclosed to other organisations except our mailing house (to enable items to be posted to you), and anyone can ask to be taken off our mailing list without cost at any time.

We make every effort to ensure that personal information we collect, use or disclose is accurate, complete and up-to-date.

In certain instances, where we have collected personal information from you, we may be required by law to disclose that information to certain government bodies.

iv. If you deal with us as a representative of a business

We may keep business contact information about you. We only use this information for normal business purposes.

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(d) Protection of your personal information

Where we contract out some of our activities, such as bulk mailing, that involve your personal information, we take reasonable steps so that your personal information is duly protected.

We store your information on computer databases as well as in hard copy. We take all reasonable steps to ensure the security and privacy of your information. We take reasonable measures so that your personal information is protected from unauthorised access and misuse.

(e) Your rights of access to personal information we hold about you

You can ask us to provide you with access to personal information we hold about you (including for the purpose of advising us of any inaccuracies). We will comply with any such request to the extent required by the Privacy Act. There is no fee for making such a request or for providing access to your personal information. We will endeavour to respond to your request within 14 days.

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(f) Privacy concerns, more information and our contact details

• advise us of any changes to your contact details or other information we may hold
• complain to us if you believe that your personal privacy has been breached
• obtain more information about the way we manage personal information that we hold
• request access to personal information we hold about you
• ask to be removed from our mailing list