Your health information is part of your care.
Centre for Digestive Health collects information so we can understand your health, provide and adapt your care, administer our services and communicate with you.
Because this may include your symptoms, health history, microbiome information, test results, treatment progress and other sensitive information, we treat your privacy with the same care we bring to your health.
We do not sell your personal or health information.
We do not use your identifiable health information, treatment experience or personal story for advertising or promotional purposes without appropriate consent.
This Privacy Policy explains what we collect, why we collect it, how we use and protect it, who it may be shared with and the choices available to you.
Centre for Digestive Health is operated by The Trustee for TWH Business Services Trust, ABN 25 415 106 728, trading under the registered business name Centre for Digestive Health & Wellness.
In this Privacy Policy, “Centre for Digestive Health”, “CDH”, “we”, “us” and “our” refer to that business.
Our contact details are:
In Clinic:
Centre for Digestive Health
The Wellness House
55 Bathurst Road
Orange NSW 2800
Australia
Online Clinic:
Email: support@centrefordigestivehealth.com
Phone: +61 472 863 729
Website: www.centrefordigestivehealth.com
Centre for Digestive Health provides health services and handles health information.
Depending on the circumstances, our handling of personal and health information is governed by laws including:
the Privacy Act 1988 (Cth);
the Australian Privacy Principles (APPs);
the Notifiable Data Breaches scheme;
the Health Records and Information Privacy Act 2002 (NSW); and
the Health Privacy Principles (HPPs).
Health information is sensitive information and receives additional protection under Australian privacy law.
We aim to collect only what we reasonably need and to handle that information lawfully, fairly, securely and transparently.
The information we collect depends on how you interact with us and the services you receive.
Results from gut microbiome mapping
Personal and contact information
Health history and symptom progress reports
Contact details
This may include:
digestive symptoms;
bowel habits;
bloating;
abdominal pain or cramping;
reflux or heartburn;
nausea;
food sensitivities or intolerances;
allergies;
energy and fatigue;
sleep;
skin symptoms;
stress;
mood or emotional wellbeing where relevant to your care;
medications;
supplements;
diagnosed health conditions;
previous treatment;
infections;
surgery or hospitalisation;
relevant family health history;
pathology results;
functional testing results;
microbiome mapping or microbiome-related information;
treatment responses;
symptom-tracking information;
practitioner observations;
clinical or consultation notes;
protocols and recommendations; and
correspondence relating to your care.
Information collected while providing you with a health service may itself constitute health information under Australian privacy law.
We may keep information relating to:
discovery calls;
consultations;
intake and onboarding;
assessments;
live practitioner sessions;
one-to-one care;
treatment stages;
questions submitted to practitioners;
program progress;
recommendations;
member support;
participation in the 12 Month Gut Health Program; and
use of our private member services.
Testing information
Where testing forms part of your care, we may collect or receive information such as:
test requests;
pathology results;
functional testing results;
microbiome results;
laboratory reports;
practitioner interpretations; and
related correspondence.
Testing providers may also handle your information under their own privacy obligations.
When you purchase a consultation, program or other service, we may collect or process:
billing details;
the service purchased;
amounts paid;
payment status;
transaction references;
refunds; and
instalment or recurring payment information.
Card payments may be processed through third-party payment services.
Our current Gut Health Program payment links use Stripe. Payment providers process payment information under their own terms and privacy policies.
CDH does not need to retain complete card details where those details are securely processed by the payment provider.
We may keep records of communications with you, including communications by:
email;
telephone;
online forms;
video consultation;
member support channels; and
other communication methods used in delivering your care.
When you use our website, technical information may be generated automatically, including:
IP address;
browser type;
device type;
operating system;
referring website or page;
pages visited;
date and time of visits; and
website interaction information.
Our website may also use cookies, server logs and similar technologies.
We collect information directly from you.
This may happen when you:
visit our website;
make an enquiry;
book a discovery call or consultation;
complete an intake form or health questionnaire;
provide your health history;
send us test results;
participate in a consultation;
join a program or membership;
attend a live session;
provide symptom or progress information;
make a payment;
communicate with a practitioner or team member; or
otherwise engage with Centre for Digestive Health.
Where relevant to your care, and where you have authorised it or the law otherwise allows us to do so, we may also receive information from:
your GP;
specialist;
allied-health professional;
other treating practitioner;
pathology or laboratory provider;
testing provider;
authorised representative; or
another person involved in your care.
If you provide personal information about another person, please ensure you are authorised to do so.
To understand your health
We use information about your symptoms, history, testing and previous treatment to build a clearer picture of what may be contributing to your concerns.
To personalise your care
Your information may be used to develop, deliver and adapt your care plan, including microbiome-informed recommendations and stage-specific support.
To monitor progress
We may use symptom and treatment-response information to understand how your body is responding and whether your care should change over time.
To provide practitioner support
Information relevant to your care may be accessed by practitioners and authorised team members involved in delivering or administering that care.
To coordinate care
With your consent, or where otherwise permitted by law, we may communicate with GPs, specialists, laboratories or other healthcare providers involved in your care.
To provide our programs and membership
We use relevant information to administer program access, member support, live sessions, one-to-one care and the private member resource library.
To communicate with you
We may contact you about:
appointments;
consultations;
treatment;
testing;
your program;
member access;
payments;
administrative matters;
service changes; and
support enquiries.
To process payments
We use the information required to administer fees, instalments, payments, refunds and financial records.
To improve our services
We may use information to understand how our services are working, improve the patient experience, improve educational materials and manage the quality of our services.
Where appropriate, we prefer aggregated or de-identified information for these purposes.
To meet our legal and professional obligations
We may use or disclose information where reasonably necessary to meet legal, regulatory, accounting, insurance, professional or other lawful obligations.
Health information is sensitive information.
We generally collect health information where:
you consent to the collection and it is reasonably necessary for our services;
your consent can reasonably be implied from your request for health care and the information is necessary to provide that care; or
collection is otherwise authorised or required by law.
You do not have to provide information to us.
However, if relevant health information is not provided, we may be unable to properly assess your circumstances, safely provide certain services, personalise your care or coordinate your treatment.
Consent to receive health care does not mean unlimited consent to every possible use of your information.
Where a separate use requires separate consent, we will seek it.
The Centre for Digestive Health program is built around personalised, microbiome-led care.
The program may involve:
microbiome mapping;
personalised protocols;
monitoring digestive and whole-body symptoms;
treatment-stage information;
ongoing practitioner support;
live member sessions;
private one-to-one care; and
a private member resource library.
Information collected through the program may form part of your health record and will be handled accordingly.
Includes access to weekly live practitioner member sessions in which members can learn from questions and experiences discussed during the session.
These sessions have been designed to reduce unnecessary identification between members.
Where the platform and session format allow:
participants see the host rather than one another;
you may use your first name, initials or a preferred display name; and
you decide what personal information you disclose within the group environment.
You should only share information you are comfortable discussing in that setting.
Other members are required to respect the confidentiality of information shared within the membership.
A group environment cannot provide the same level of privacy as an individual consultation. Where information is particularly sensitive or requires focused clinical discussion, a private one-to-one conversation may be more appropriate.
Some live educational or support sessions may be recorded for the private CDH member library.
Where a session is being recorded, members will be notified.
Recordings created for the private member library are intended to remain within the membership and must not be reproduced, distributed, published or shared outside the program.
We aim to minimise unnecessary inclusion of identifiable member information in recorded educational content.
Promotional use is separate
Joining a program or participating in a session does not by itself give CDH permission to use your identifiable:
health information;
treatment experience;
personal story;
testimonial;
photograph;
image;
video; or
voice
for advertising, social media, promotional campaigns or other direct marketing.
Where we wish to use identifiable patient material for those purposes, we will obtain the consent required for that use.
Declining promotional consent will not affect your access to care.
CDH publishes patient experiences and treatment stories from time to time.
Where a testimonial, image, treatment story or case study identifies or could reasonably identify a patient, we will obtain appropriate permission for the intended use.
Where practicable, clinical or educational case material may be de-identified.
Centre for Digestive Health also provides the InnerMap symptom-tracking application.
InnerMap operates differently from our website and clinical systems.
Information entered into InnerMap is designed to remain on the user's own device and is stored in an encrypted local database.
CDH does not automatically receive information merely because you use InnerMap.
Information leaves the device only when you choose to export and share a report using your own email or another external method.
If you choose to send an InnerMap report to a CDH practitioner, information contained in that report becomes information received by us and will then be handled as health information under this Privacy Policy.
InnerMap has its own detailed Privacy Policy explaining its local-storage, encryption and export arrangements.
We do not sell, rent or lease your personal or health information.
Information may be disclosed where reasonably necessary to provide your care, operate our services or meet our legal obligations.
This may include disclosure to:
CDH practitioners and staff
Practitioners and authorised team members may access information required to provide or administer your care.
Other healthcare professionals
With your consent, or where otherwise permitted by law, we may communicate with your:
GP;
gastroenterologist;
specialist;
allied-health practitioner; or
other treating healthcare provider.
Laboratories and testing providers
Information necessary to arrange, process or interpret testing may be provided to laboratories or other testing providers.
Technology and service providers
We may use third-party providers to support functions such as:
website operation and hosting;
appointment scheduling;
member services;
video conferencing;
secure information storage;
communications;
IT support; and
payment processing.
These providers may only receive information required for the services they perform.
Payment providers
Payment information may be processed by third-party payment services such as Stripe and, where offered, other payment providers.
Professional advisers
Where reasonably necessary, information may be provided to professional advisers such as:
accountants;
auditors;
insurers;
legal advisers; and
information-security advisers.
Health information will not be disclosed merely because it might be commercially useful.
Government, regulators or other authorities
Payment information may be processed by third-party payment services such as Stripe and, where offered, other payment providers.
Professional advisers
Where reasonably necessary, information may be provided to professional advisers such as:
accountants;
auditors;
insurers;
legal advisers; and
information-security advisers.
Health information will not be disclosed merely because it might be commercially useful.
Some of the third-party technology providers used in delivering CDH's online services are international providers.
This means personal information may, depending on the service being used, be processed or stored outside Australia.
Countries in which recipients or service-provider infrastructure are likely to be located include the United States of America, particularly in connection with services such as online payment processing, scheduling and video conferencing.
Other locations may apply where an international provider operates distributed infrastructure or engages authorised subprocessors.
Where an overseas disclosure of personal information occurs, we take reasonable steps required by Australian privacy law in relation to that disclosure.
Where practical, we also seek to minimise the amount of health information provided to third-party systems.
You may contact us if you would like further information about the overseas handling relevant to a particular service you use.
Clinical and administrative communications are different from marketing.
We may send communications reasonably necessary to provide or administer your care, including information about:
consultations;
appointments;
testing;
treatment;
your program;
payments;
account or member access; and
changes affecting the service you receive.
We may separately send newsletters, educational updates or information about CDH services where permitted by law.
Where required, you will be given an opportunity to opt in or unsubscribe.
Health information and direct marketing
We do not use or disclose your health information for direct marketing unless the consent required by law has been obtained.
Becoming a patient, attending a consultation, joining a program or disclosing a health condition does not by itself constitute consent to use that health information for direct marketing.
You may withdraw marketing consent for future marketing communications by contacting us or using the unsubscribe facility provided.
Our website may use cookies, server logs and similar technologies to:
operate website functionality;
maintain security;
remember preferences;
understand website usage; and
improve the website experience.
Technical information collected may include:
IP address;
browser type;
device information;
operating system;
pages viewed;
referring page; and
interaction information.
You can manage many cookies through your browser settings.
Blocking some cookies may affect website functionality.
Because this is a health-related website, we take particular care not to intentionally provide identifiable clinical records, test results or treatment information to advertising platforms for behavioural advertising.
Our website may link to websites and services operated by third parties.
Those services operate under their own terms and privacy practices.
The presence of a link does not mean CDH controls the way the external provider handles personal information.
Social media is not an appropriate place to disclose confidential clinical information.
For personal health matters, please contact us through an appropriate private communication channel.
Accurate information matters to personalised care.
We take reasonable steps to ensure personal information we use or disclose is accurate, complete, relevant and up to date for the purpose for which it is being used.
Please let us know if information relevant to your care changes, including changes to:
your contact details;
medications;
health status;
treating practitioners; or
other significant information.
We take reasonable steps to protect personal and health information we hold from:
misuse;
interference;
loss;
unauthorised access;
unauthorised modification; and
unauthorised disclosure.
Depending on the system and information involved, safeguards may include:
access controls;
authentication measures;
encrypted connections;
secure systems;
staff confidentiality requirements;
restricted access;
security updates; and
appropriate controls applying to third-party providers.
No electronic system or internet transmission can be guaranteed to be completely secure.
We therefore also maintain processes for responding to suspected privacy and security incidents.
If we become aware of a suspected breach involving personal information, we will assess and respond to it in accordance with applicable privacy law.
This may involve:
containing the incident;
investigating what occurred;
taking remedial action;
assessing whether serious harm is likely; and
notifying affected individuals and the Office of the Australian Information Commissioner where required by the Notifiable Data Breaches scheme.
Health records are subject to specific retention requirements.
For health information covered by NSW private-health-provider retention requirements:
where the patient was an adult when the information was collected, health information must generally be retained for 7 years from the last occasion on which a health service was provided; and
where health information was collected while the patient was under 18, it must generally be retained until the patient reaches 25 years of age.
Other legal, professional or recordkeeping requirements may require certain information to be kept for a different period.
Information that is no longer required and may lawfully be disposed of will be securely destroyed or permanently de-identified as appropriate.
Where NSW law requires a record of the disposal of health information to be retained, we will retain that record.
You may ask to access personal or health information we hold about you.
Requests can be sent to:
support@centrefordigestivehealth.com
We may need to verify your identity before releasing information.
We will respond in accordance with applicable privacy and health-record laws.
There are limited circumstances in which access may lawfully be refused or restricted.
Where required, we will explain the reason and any available complaint or review options.
You may ask us to correct information you believe is:
inaccurate;
out of date;
incomplete;
irrelevant; or
misleading.
Contact support@centrefordigestivehealth.com and tell us what you believe should be corrected.
Clinical records sometimes need to preserve the original entry as part of the historical record.
Where appropriate, a correction, clarification or notation may therefore be added rather than deleting the original entry.
You may ask to access personal or health information we hold about you.
Requests can be sent to:
support@centrefordigestivehealth.com
We may need to verify your identity before releasing information.
We will respond in accordance with applicable privacy and health-record laws.
There are limited circumstances in which access may lawfully be refused or restricted.
Where required, we will explain the reason and any available complaint or review options.
You may ask whether personal information can be deleted.
Health records cannot always be deleted on request.
We may be required to retain information because of:
health-record retention laws;
professional obligations;
continuity-of-care requirements;
insurance requirements;
accounting or taxation obligations; or
actual or anticipated legal matters.
If information cannot lawfully be deleted, we can explain why and consider whether another step, such as correction or notation, is appropriate.
Where lawful and practicable, you may interact with us anonymously or under a pseudonym for certain general enquiries.
It will generally not be practicable to provide personalised clinical care, arrange testing, maintain an appropriate health record or administer certain transactions without knowing your identity.
Within some member environments, you may use your first name, initials or a preferred display name to reduce unnecessary identification to other participants.
Where required, appropriate parent or guardian consent will be obtained for children under 16 years.
You may authorise another person to communicate with us or receive information on your behalf.
Before disclosing health information, we may require confirmation of:
your authority;
the representative's identity;
guardianship;
power of attorney; or
another lawful basis for access.
Listing someone as an emergency contact does not automatically give that person unrestricted access to your health information.
If you believe we have mishandled your personal or health information, please contact us so we can investigate.
Email: support@centrefordigestivehealth.com
Please include enough information for us to understand:
what occurred;
what information was involved;
when it occurred, if known; and
the outcome you are seeking.
We will investigate privacy complaints and respond within a reasonable period.
If you are not satisfied with our response, you may also have the right to contact:
Office of the Australian Information Commissioner (OAIC)For matters arising under the Privacy Act 1988 and Australian Privacy Principles.
Information and Privacy Commission NSW (IPC NSW)For matters arising within its jurisdiction under NSW health privacy law.
We may update this Privacy Policy when our services, systems, technology or legal obligations change.
The current version will be published on our website with its latest revision date.
Where a change materially affects the way existing personal or health information is handled, we will take any additional steps required by law.
A change to this Privacy Policy will not be used as a substitute for specific consent where specific consent is required.
If you have questions about this Privacy Policy, want to access or correct your information, or wish to make a privacy complaint, contact:
Centre for Digestive Health
In Clinic:
The Wellness House
55 Bathurst Road
Orange NSW 2800 Australia
Online Clinic:
Email: support@centrefordigestivehealth.com
Phone: +61 472 863 729
Website: www.centrefordigestivehealth.com
We collect information to understand your health and support your care.
We protect it because privacy is part of that care.