The purpose of this policy is to outline how FBG as the owner and administrator of Wellbeing Central will collect, store, secure, maintain and use the information that you provide in the course of interacting with Wellbeing Central and the steps FBG will take to ensure your privacy is maintained. The policy also outlines how you can access, request changes to and/or make enquiries or complaints about the information on this site and the way it is managed.

1. Collection of your information

In order to access and use all that is on offer within Wellbeing Central you will be required to provide some information about yourself. This includes during the registration process, when completing assessments, and in the process of setting goals, planning wellbeing activities, completing the ‘My Dashboard’ page and ‘Getting Support’.

Name: We ask you for your name so that we can personalise your profile on Wellbeing Central. Giving us your name also enables us to ensure that your data is correctly assigned to you alone, and only made available on the webpages that you can access. If you seek to remain anonymous you will be unable to register on Wellbeing Central or use the services on offer.

Phone number and Email address: As access to Wellbeing Central is restricted to client employees, we request your work e-mail address to verify your status as an eligible participant. We ask for your phone number so that we can contact you if required. You will receive a call if you have requested EAP or Manager Assist services via Wellbeing Central, in which case the call will be to organise an appointment. The only other time you will receive a call will be if FBG believe you are in need of professional support. FBG has a duty of care as psychologists to ensure recipients of its services receive suitable levels of professional support. If you request EAP or Manager Assist services via Wellbeing Central we ask you for your preferred e-mail address so that we can send you confirmation of appointments. If you opt in for sms reminders and alerts you will receive messages to your mobile solely for the purpose of reminding you about appointments.

Passwords and security questions: Requests for passwords and security questions are additional security measures to avoid the potential that other people can login as you and access your data on Wellbeing Central. They are also required to assist you in retrieving your password if you happen to forget.

Additional demographic information: During the registration process, and in the process of completing WorkWell, additional information about you will be requested so that we can tailor the information provided to you. Some workplace demographics are also valuable in making meaningful comparisons between groups, e.g by location, about service access and wellbeing levels.

When completing the assessments – WorkWell and VIA^TM – you will be asked to provide information related to you, your work and personal life. Your answers to the questions posed will enable you to receive confidential reports about your wellbeing level and your strengths. Your honest responses will ensure we can provide the most accurate and useful information to you. Some demographic data on WorkWell is optional.

Completing information on the ‘My Wellbeing Plan’ page will help you determine your wellbeing goals and activities and allow you plan to improve your wellbeing.

FBG will only seek information about you from you, and we only seek information that is necessary in order to deliver quality wellbeing services that are relevant to you, and required to provide professional support as part of our duty of care to you.

2. Storage and security of data

Our data storage and security policy also meets the recommended standards of the Australian Government as per the Privacy Act. Wellbeing Central, and all its data, is housed on a secure server of sufficient capacity to manage very large volumes of usage. FBG has a number of back-up procedures in place (onsite and offsite) to ensure the data always remains intact, complete, accurate and secure in the event of a system outage, environmental event or any other disruption.

3. Use of data

You are able to use Wellbeing Central in accordance with the contract that exists between your employer and FBG. The contract requires FBG to provide a range of services to you and your employer. One of the services FBG may be contracted to provide to your employer is the provision of aggregated data reports. These reports provide your employer with insights into groups of employees. As an example a report may compare levels of employee wellbeing across divisions in the organisation. At no stage during the production of these reports, or at any other time, will you be able to be identified, directly or indirectly. For group data to be provided, a minimum of ten (10) employees are required per group. If at any stage the number of employees in any one category is below ten (10) we will roll the data up into a larger category to avoid the possibility of identification.

From time to time and in accordance with Victoria's privacy legislation, de-identified and aggregated data (grouped data of multiple participants that does not identify you) may be used for research purposes or other analysis in the interests of improving the understanding of a best practice approach to workplace wellbeing. In all cases, individual confidentiality and privacy is protected.

4. Access to data

The majority of your data on Wellbeing Central will be visible and accessible at any point in time when you are logged into Wellbeing Central. This will include your WorkWell and VIA^TM reports, your wellbeing goals and activities and contact information. You have a right to access your personal information that is stored on Wellbeing Central, subject to exceptions allowed by law. Wellbeing Central includes instructions on how to do this. You also have the right to request that your registration on Wellbeing Central be cancelled and your data removed from the site. If you would like to make such requests please contact FBG. For security reasons you will need to put your requests in writing to techsupport@fbggroup.com.au. At the point in time that FBG’s contract with your employer concludes, FBG will contact you to provide you with an opportunity to download all your information from the site.

The only parties in addition to yourself that will have access to your data will be the FBG team and contractors engaged in the delivery of services to you. The FBG team and contractors will only have access to the data on Wellbeing Central as it relates specifically to their role in the delivery of the services available through Wellbeing Central and the related contract with your employer. The FBG team and contractors are bound by the ethical codes of the relevant registration and professional bodies for psychologists – the Psychology Board of Australia (a National Board that is part of the Australian Health Practitioner Regulation Agency, AHPRA) and the Australian Psychological Society. Both bodies have strict guidelines on confidentiality. All third parties engaged by FBG to provide services on offer via Wellbeing Central will be bound by the same ethical guidelines. Our contract management processes include protections to guard against the inappropriate and/or unlawful access and use of data by any third party.

5. Data Quality

FBG takes reasonable steps to ensure that information stored on Wellbeing Central is accurate, complete and up-to-date. FBG relies on individuals to provide accurate and current information in the first instance and to inform us of changes in their details relevant to services provided. Requests to correct any errors related to your data on Wellbeing Central can be made by contacting FBG. For security reasons you will need to put your request in writing to techsupport@fbggroup.com.au.

6. Complaints

You can make a complaint about the collection or management of your data by e-mailing wellbeing@fbggroup.com.au. FBG is also bound to comply with the Victorian IPPs privacy legislation which indicates complaints can also be made directly to the sourcing agency/the employer.

Updated 10.04.2017