Privacy Policy
1. Introduction
This Privacy Policy explains how personal information is handled in connection with the GPClarity software-as-a-service platform (the "Platform").
The Platform is owned by GP Clarity Pty Ltd (ABN 22 658 622 621) of 48 Appian Circuit, Baulkham Hills, NSW 2153 ("GP Clarity"), and is exclusively distributed in Australia by Insqope Pty Ltd (ABN 86 662 373 613) of 33/40–52 Barina Downs Road, Norwest NSW 2153 ("Insqope") (together, "we", "us", "our").
We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"). This Privacy Policy applies to all personal information we collect about users of the Platform and visitors to our websites.
This Privacy Policy is referenced in, and forms part of, the GPClarity End User Licence Agreement (the "EULA"). Capitalised terms used but not defined in this Privacy Policy have the meanings given in the EULA.
2. Roles of Insqope and GP Clarity
The Platform is owned and operated by GP Clarity, while Insqope is the contracting party for end users in Australia and is responsible for sales, marketing, billing and front-line support. Both entities handle personal information in distinct but related ways:
- Insqope handles your Account Data for the purposes of contracting with you, billing, communicating with you, and providing front-line support.
- GP Clarity operates the Cloud Platform, including the hosting infrastructure, the Adapter and the back-end systems that process Aggregated Practice Data, and provides Level 2 / Level 3 technical support.
Both Insqope and GP Clarity are responsible for complying with the APPs in respect of personal information they each handle. Either entity will accept and respond to privacy queries and complaints under this Privacy Policy.
3. What personal information we collect
We are committed to collecting only the minimum personal information needed to operate the Platform.
3.1 Account Data (collected by Insqope)
When you sign up or use the Platform, we collect:
- full name;
- email address;
- phone number;
- role (for example, GP, practice manager);
- practice site name and address;
- provider number (where you choose to provide it);
- password (stored in hashed form only, not in plain text); and
- billing-related information necessary to process your subscription (handled via our payment processor — we do not store full credit card numbers on our systems).
3.2 Practitioner administrative information (handled by GP Clarity)
The Cloud Platform receives the following practitioner administrative information from the Adapter installed in your practice:
- doctor name;
- provider number; and
- practice site name and address.
3.3 Technical information
We collect technical information automatically when you use the Platform, including IP address, browser type, device information, and access logs. This is used for security, troubleshooting and service operation.
3.4 What we do NOT collect
We do not collect patient personal information or patient health information through the Platform. As described in clause 7 of the EULA, the Platform is designed and operated such that it does not store or process personally identifying information of patients. The Adapter aggregates data inside your practice's local network before any data is transmitted, and what is transmitted is doctor-level aggregate, consultation-metric data only (for example: doctor identifier, date, MBS item code, and counts).
If we ever change the Platform's design so that it would collect or process patient identifying information, we will update this Privacy Policy and the EULA and obtain your further consent before that change applies to your account.
4. How we collect personal information
We collect personal information:
- directly from you when you sign up, place an order, contact support, or otherwise communicate with us;
- automatically through the Platform and our websites, via cookies, server logs, and similar technologies;
- from the Adapter installed in your practice, which transmits practitioner administrative information together with Aggregated Practice Data; and
- from third parties, such as our payment processor, in connection with billing.
Where it is reasonable and practicable to do so, we collect personal information directly from the individual it concerns.
5. Why we collect, hold, use and disclose personal information
We collect, hold, use and disclose personal information for the following purposes:
- to provide, maintain, secure and improve the Platform;
- to authenticate users and protect the Platform from unauthorised access;
- to communicate with you about your account, support requests, product updates, renewals and service notices;
- to bill you for the Platform and process payments;
- to provide front-line and technical support;
- to send you marketing communications about GPClarity and related products, where you have not opted out (see clause 9);
- to produce de-identified, aggregated benchmarks and improve the Platform's metrics and methodology;
- to comply with our legal obligations, including under the Privacy Act 1988 (Cth), the Spam Act 2003 (Cth), and tax legislation; and
- to investigate and respond to actual or suspected breaches of our terms or applicable law.
We will not use or disclose personal information for any other purpose unless you have consented, or the use or disclosure is required or authorised by law.
6. Disclosure to third parties
We may disclose personal information to:
- between Insqope and GP Clarity, as needed to operate the Platform and comply with the Master Distribution Agreement between them;
- Australian-based hosting and infrastructure providers that host the Cloud Platform on behalf of GP Clarity;
- payment processors for billing (full card details are handled by the processor and are not retained by us);
- professional advisers (legal, accounting, audit) under a duty of confidence;
- regulators, law enforcement and courts, where required or authorised by law; and
- a successor entity, in connection with a sale, merger or restructure of either Insqope or GP Clarity, subject to that entity agreeing to handle personal information consistently with this Privacy Policy.
We will not sell your personal information.
7. Cross-border disclosure
The Cloud Platform and all Account Data and Aggregated Practice Data are hosted in Australia. We do not currently disclose personal information to overseas recipients.
If this changes in future, we will:
- update this Privacy Policy;
- take reasonable steps to ensure the overseas recipient handles personal information in a manner consistent with the APPs (including APP 8); and
- notify affected users where required.
8. Security
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure, including:
- encryption of data in transit;
- access controls and authentication for our systems;
- Australian-based hosting;
- regular backups and disaster recovery procedures; and
- staff confidentiality obligations.
No information system is completely secure. While we take security seriously, you provide information at your own risk and you are responsible for keeping your login credentials confidential.
If we become aware of a data breach that is likely to result in serious harm, we will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).
9. Direct marketing and opt-out
We may use your contact details to send you marketing communications about GPClarity and related products. You can opt out of marketing communications at any time by:
- clicking the "unsubscribe" link in any marketing email; or
- emailing us at info@insqope.au.
Opting out of marketing will not affect operational communications relating to your subscription (for example, billing notices, service updates, security alerts).
10. Cookies and similar technologies
Our website and the Platform use cookies and similar technologies for:
- authentication and session management;
- security and fraud prevention;
- remembering your preferences; and
- basic analytics about how the Platform is used.
You can configure your browser to refuse cookies, but parts of the Platform may not function correctly if you do.
11. Retention
We retain Account Data for the duration of your Subscription and for a reasonable period afterwards to meet legal, tax, accounting and audit obligations (typically up to seven (7) years), after which we delete or de-identify the information. Aggregated Practice Data may be retained in de-identified, aggregated form indefinitely for benchmarking and product-improvement purposes.
Backups containing personal information may persist for a limited additional period until those backups are cycled out in the ordinary course.
12. Your rights — access, correction and deletion
Subject to applicable law, you may at any time:
- request access to the personal information we hold about you;
- request correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading; and
- request deletion of your account and associated personal information (subject to our retention obligations described in clause 11).
Requests should be made by email to info@insqope.au. We will respond within a reasonable time and in accordance with the APPs. We may need to verify your identity before responding to a request.
There is no charge for making a request, although we may charge a reasonable cost-recovery fee for providing access where the request is voluminous or otherwise burdensome.
13. Complaints
If you believe we have breached the Australian Privacy Principles or mishandled your personal information, please contact our Privacy Officer at info@insqope.au. We will:
- acknowledge your complaint promptly;
- investigate the matter; and
- respond to you within thirty (30) days, or sooner where practicable.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC):
- Website: oaic.gov.au
- Phone: 1300 363 992
- Email: enquiries@oaic.gov.au
14. Children
The Platform is intended for use by registered medical practitioners and practice staff, and is not directed at children. We do not knowingly collect personal information from children.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The current version will always be available at /privacy. We will notify you of material changes by email to your registered email address or via in-product notification. Continued use of the Platform after a change takes effect constitutes acceptance of the updated Privacy Policy.
16. Contact us
If you have questions about this Privacy Policy or how your personal information is handled, please contact:
Privacy Officer, Insqope Pty Ltd
ABN 86 662 373 613
33/40–52 Barina Downs Road, Norwest NSW 2153, Australia
Email: info@insqope.au
For matters specifically relating to the operation of the Cloud Platform, the Adapter, or technical/security incidents, you may also contact:
GP Clarity Pty Ltd
ABN 22 658 622 621
48 Appian Circuit, Baulkham Hills, NSW 2153, Australia
Email: info@gpclarity.com.au