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Last updated: February 2024
Transcendomics Pty Ltd (ABN: 16 674 671 124) is committed to ensuring the privacy and security of your personal information.
In this document, Transcendomics, Us and We refer to Transcendomics Pty Ltd.
This Privacy Policy (Policy) intends to clearly describe how Transcendomics handles your personal information, including its collection, use, disclosure, retention and security, and any personal information that we collect through our website(s).
Transcendomics is governed by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). The APPs regulate how personal information is handled by us.
‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Transcendomics’ Privacy Policy applies to personal information collected and/or held by Transcendomics.
Additionally, as an organisation operating in Victoria that collects, holds, or uses health information, Transcendomics is also governed by the Health Records Act 2001 (VIC).
We will review this policy regularly, and we may update it from time to time.
We operate Genomical. Genomical is a platform that takes the manual work out of a genomic test. It moves genomic data between testing tools, stores it securely in the cloud, and feeds it back to healthcare systems in a language they can understand. Genomical enables safe storage, authorised access and meaningful use of genomic data, to supercharge precision medicine in Australia.
In operating Genomical, our business purpose is to enable the secure exchange of genomic health information to enable health service providers to deliver better care to their patients. These exchanges occur digitally between authorised health service providers and other organisations such as providers of secondary and tertiary genomics analysis solutions.
We collect personal information about patients, health service providers and other business customers, as part of our routine activities.
We also collect personal information about our staff, job applicants, contractors, and suppliers, as well as the contact details of individuals who work for contractors and suppliers, and other types of professional associates and personal contacts.
The types of information we may collect, and how we use or disclose it, will vary based on the nature of our relationship or dealings with you. We have explained this in more detail below.
You are, or are engaged by, a business customer or healthcare provider that uses Transcendomics products or services.
We maintain records of the interactions we have with customers, including the products and services we have provided to you.
We collect personal information that enables us to provide you with services and allows us to identify you for verification purposes, such as name, contact details (including business address, email address and phone numbers), occupation (including credentials and specialisation), and username or password to access our products and services.
Depending on the particular product or service you use (and how you use it), we may also collect more in-depth information including information about how you use our products and services; records of any interactions or communications you have with us; technical information about our products and services that you access; and any other information that you provide to us directly, or that is provided to us by the business that engages you to facilitate your use of our products and services.
We may also capture product improvement data when authorised organisations and health providers use our solution. This data is used for purposes of issue resolution, service delivery, and product improvement. For example, it may include analyses of transaction volumes and delivery timeframes.
We may ask you to provide us with certain types of personal information if you wish to obtain a particular service or product from us. This might happen over the telephone, through our website, by filling in a paper form, or meeting with us face-to-face. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.
You might also provide your personal information to us, without us directly asking for it, for example if you engage with us on social media.
We may use your personal information for the following purposes:
We may disclose your personal information to third parties that assist us to provide the service or product you have requested (such as IT and network service providers, installation, maintenance and repair service providers, and mailing, billing, and customer service providers); if otherwise permitted or required by law; or for other purposes with your consent.
Where we share your information with a third-party service provider, we make sure that they have first agreed to protect the privacy of your information, and we only provide them with personal information when it is reasonably necessary to do so.
As our primary customer, we may need to share certain information with the business that employs or engages you and that has procured the relevant products and services you use. For example, we may share information relating to individual or group usage patterns and volumes, or potential suspicious use as part of a security investigation.
If it is reasonably necessary to do so, we may share personal information with business partners and advisers who assist us to engage in business related strategy development and analyses (not commercial activity), or the development of business strategies and functions, to help us improve our products and services. However typically this sharing occurs on a de-identified and/or aggregated basis only.
We may disclose your personal information to law enforcement and national security agencies, and other government and regulatory authorities, if such disclosures are required or authorised by law.
You receive health services from a business customer or healthcare provider that uses Transcendomics products and services.
Genomical is a platform that takes the manual work out of a genomic test. It moves genomic data between testing tools, stores it securely in the cloud, and feeds it back to healthcare systems in a language they can understand.
If you are a patient of a health service provider using Genomical, this means that your genomic data will be safely stored by your health service provider on our platform, it can be retrieved and re-analysed later if necessary, and you can have your genomic data transferred if you change healthcare providers.
The type of personal information your health service provider might share with us can include:
The specialist nature of our solutions means that your personal information is collected by your health service provider and stored on our platform during their normal use of our products and services. We rely on your health service provider to have obtained your permission to conduct your genomic test and store your information on our platform.
Our primary business is to operate the Genomical platform, so that health service providers can safely store, retrieve, and share genomic data about patients.
Typically, the only people who would ever see or access your personal information in a patient record would be authorised users of the Genomical platform who have explicit permission from the business customer or health service provider to view the information. However, we may be required to access your personal information (including health information) if it is necessary to facilitate any technical support that we might provide to the business customer or health service provider.
There may also be limited circumstances where we are obligated to use or disclose your information as required or authorised by law.
We do not use your information for direct marketing purposes.
We may provide your personal information to third parties who provide services to us, including organisations and contractors that assist us in connection with the limited purposes for which we use that personal information. Where we share your information with a third-party service provider, we make sure that they have first agreed to protect the privacy of your information, and we only provide them with personal information when it is reasonably necessary to do so.
We will also disclose your personal information to a third party if the circumstances warrant such a disclosure or share (for example, if you directly request us to do so), but only where this is required or authorised by law.
We may disclose your personal information to law enforcement and national security agencies, and other government and regulatory authorities, if such disclosures are required or authorised by law.
You are someone that we otherwise deal with while operating our business
This category includes users of our website, job applicants, staff, and contractors.
The type of personal information we collect will ultimately depend on the nature of our dealings with you. For example, this might include:
We may provide your personal information to third parties who provide services to us, including organisations and contractors that assist us in connection with the limited purposes for which we use that personal information. Where we share your information with a third-party service provider, we make sure that they have first agreed to protect the privacy of your information, and we only provide them with personal information when it is reasonably necessary to do so.
On our website, we may provide links to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.
Transcendomics is committed to ensuring the security of your personal information.
We take reasonable security measures to protect personal information from loss, unauthorised access, use, modification, or disclosure. This includes ensuring personal information is stored securely, not kept longer than necessary, and disposed of appropriately.
Within the Genomical platform, we use best practice network security infrastructure, access control, secure encryption of all information at all times, and physical security.
We retain personal information (including health information) for the period of time required under the applicable law of the jurisdiction, and the relevant period of time depends on the nature of the personal information.
Wherever possible, we ensure that the personal information of customers, staff, suppliers, and other contacts held on our behalf by our third-party providers is stored in a location within the same jurisdiction as the source of the information. For example, information provided to us by a business customer or health service provider in Australia is securely stored within Australia. Our third-party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
If cross-border disclosure to a third-party is required in order for us to provide a service to you, or in the provision of a service to us, we will take reasonable steps to ensure that the third parties do not breach the APPs, including by requiring that the third party has information security measures and information handling practices in place that are of an acceptable standard and approved by us.
You have the right to request access to the personal information Transcendomics holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense.
You also have the right to request the correction of the personal information we hold about you. We will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up to date. Unless an exception applies, we must update, correct, amend, or delete the personal information we hold about you within a reasonable time period. We do not charge for making corrections.
If the information we hold about you has been provided to us by a business customer or health service provider during their provision of care to you, the information will need to be corrected by that business customer or health service provider as the primary source of the information. Any update they make to your information may be passed on to us electronically or manually.
To seek access to, or correction of, your personal information, please contact our Privacy Officer.
If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:
Name: Dr. Natalie Thorne
Title: Chief Scientific Officer
Address: Transcendomics c/oWEHI, Level 5, 535 Elizabeth Street, Melbourne VIC 3000
Phone: +61 458 461 150
Email: privacy@genomical.com.au
While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days.
If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by calling them on 1300 363 992, making a complaint online at www.oaic.gov.au, or writing to them at OAIC, GPO Box 5218, Sydney NSW 2001.
The Genomical team acknowledges the Wurundjeri, Gunaikurnai and all First Nations peoples on whose lands we live and work. We pay respect to their Elders, past and present. We also acknowledge the First Nations scientists, researchers and leaders who are shaping the future of genomic medicine.
