Privacy Policy

Your privacy is important to us. Vitality Works complies with the Privacy Act 1998 (Australia), and this Privacy Policy outlines how we do that.

In short, we only collect information that is relevant to the services we provide, we keep it secure, and do not share it with anyone unless required to under law or where you agree to share it.

Full details are provided below.

If you have any questions about our Privacy Policy, please contact the Vitality Works Privacy Officer at  


1. Who we are

1.1        Australian Wholistic Health and Wellbeing Company Ltd (ABN 70 145 723 119) trading as Vitality Works (Vitality Works) is committed to safeguarding the privacy of your personal information. We are bound by the Privacy Act 1988.

1.2        This Privacy Policy explains our personal information handling practices including the types of information which we collect, what that information is used for, and to whom that information may be disclosed.

1.3        From time to time, Vitality Works may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your personal information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to Vitality Works, we, us or our is also a reference to those related entities.

1.4       This Privacy Policy applies to our personal information handling practices generally as well as to the information collected on the Website.

1.5       Throughout this Privacy Policy, we refer to your personal information, which means information that identifies you as an individual or from which your identity can reasonably be ascertained. Your name, address and telephone number are examples of personal information.

1.6       This Privacy Policy applies to personal information that we collect from clients, customers, Vitality Works employees (including prospective employees), contractors, suppliers and other individuals in the course of our business activities and operations.


2. Personal information

2.1       The type of personal information we collect depends on the nature of our engagement and interaction with you.

2.2       We only collect personal information that is necessary for our functions and activities. For example, where we are providing services to service participants, we may collect your name in order to reserve you a time at which to receive a health service, or we may collect your email address for the purpose of providing you with a consent card and a confirmation of your booking. If you have an adverse event following immunisation, we may need to collect some additional information, including your Medicare number.

2.3       Generally, we try to collect personal information directly from you. As appropriate, Vitality Works may also collect information from a third party, including an employer, a client, a health professional or medical adviser that we have engaged for the purposes of providing health, safety or wellbeing services to you. In either case, we will take reasonable steps to ensure that you are aware of the purposes for which the information is collected.

2.4      In certain circumstances we may collect sensitive information such as health information. This information will only be used for the purposes of providing health, safety and wellbeing services. We will only collect your sensitive information with your consent or otherwise in accordance with and as permitted by the law.

2.5       When you visit our Website, we may record certain information such as your server address, domain name, and the date and time of your visit. This information is used for statistical and Website administration purposes only. To maintain visitor anonymity, we do not associate this information with records containing personal information.

2.6      Personal information (such as your first name and last name, gender, date of birth, address, email address, telephone number, employee identifying number, other contact details) and/or health information (such as medical history, Medicare number etc) may be collected by or on behalf of us to provide certain services (as relevant):

  • Vaccination services;
  • clinical services (including medical treatment and services);
  • pre-employment medicals;
  • digital health and wellbeing services (e.g. Vitality Hub);
  • occupational health and safety assessments;
  • general health assessments;
  • other health, safety and wellbeing services;
  • when you apply for a position with us as an employee, contractor or volunteer, in which case we may also collect your occupation, employment details and resume.

2.7       From time to time we may also collect our customer's personal information such as name, ABNs, payment and bank details in order to provide services.  

2.8      With the exception of your health information that will only be used as reasonably necessary for our activities, we may collect and use your personal information for the purpose of telling you about products or services in which you might be interested. You may opt out of any such marketing communications by using the opt-out mechanism in the communication or by contacting us directly using the Contact Us details below.


3. How we use your Personal Information

3.1       We collect and use personal information for many purposes in connection with our functions and activities, including the following purposes:

  • to enable us to provide you with information, products or services that you request from us;
  • to identify and communicate with you;
  • to otherwise assist customers, clients and employees by providing them with information and support;
  • to collect and process payments;
  • to help us to manage and enhance products or services we provide to you including but not limited to digital health and wellbeing services (e.g. Vitality Hub) and other health, safety and wellbeing services;
  • to undertake occupational health and safety assessments;
  • to undertake general health assessments;
  • to help us to manage and enhance goods and services we procure from our suppliers and subcontractors; and
  • for other internal administrative purposes.

3.2       We may also use your personal information in aggregated and de-identified form (that does not identify any individual) for reporting and analytical purposes, including to improve our services and to identify trends and insights.

3.3       Emails: We may retain the content of any email that you send to us. Any personal information contained within those emails, including your email address, will be only be used or disclosed in the ways set out in this Privacy Policy. Vitality Works’ employees or our Internet Service Provider may monitor your email message content for maintenance purposes or if email abuse is suspected.


4. Websites and applications

Information collected via our Website and applications:

4.1       Personal information may be collected by us and by our third party service providers who assist us in operating our websites at,, including their subdomains, and any other website we operate from time to time (collectively the Website), as well as our applications including the Vitality Hub and other health, safety and wellbeing services applications. We may also collect personal information through any on-line registration processes you complete with us via our Website.

4.2      Website analytics: Our website uses Google analytics to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.


5. Links to other websites

5.1       You should be aware that other websites which are linked to our Website might have privacy practices that differ from those outlined in this Privacy Policy. Linked websites are responsible for their own privacy practices.

5.2       We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.


6. Cookies

6.1       We use cookies on our website. A cookie is a small text file placed on your hard drive by our web page server. A cookie can later be retrieved by our web page server. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. Vitality Works uses cookies so that we may interact with your browser. The purpose is to provide you with better and more customised service and provide a more effective website.

6.2      We use cookies:

  • to determine if you have previously visited our Website,
  • to identify pages and content provider sites you have accessed,
  • to store your preferences for certain kinds of information,
  • to store a password so that you are not required to input the password every time you visit our Website, and for administrative and security purposes.

6.3      These cookies do not collect personally identifiable information and we do not cross-match information that has been collected through cookies with other personal information to determine who you are or your email address.


7. Disclosure to third parties

7.1       Vitality Works may disclose your personal information to another organisation or individual in certain circumstances. These include:

  • with your consent;
  • to other service providers, medical professionals or specialist advisers in the context of providing health services to you;
  • to Medicare;
  • to related entities for the provision of certain services and business functions e.g. IT and HR services;
  • to third parties that we engage to assist us in providing health, safety and wellbeing services to our clients, or in the operation of our business (e.g. our subcontractors, advisors and suppliers providing software and platforms to help us collect and store your personal information);
  • when fraud or unlawful activity is suspected by Vitality Works and the information is disclosed to relevant persons or authorities;
  • to any of Vitality Works' internal divisions, business units or departments;
  • to our nominated representatives;
  • to our professional service providers and advisors who perform functions on our behalf, such as lawyers, accountants, insurers;
  • when the use or disclosure is required or authorised by law;

7.2       Where our services are being paid for by your employer your first name, last name and date of birth may be supplied to your employer so that your employer can identify you and verify that you did receive our services. Your first name, last name and email address will be available to your employer before the program in order to administer the booking schedule.


8. Overseas disclosure

8.1       Vitality Works will generally maintain your data within Australia (or in New Zealand in the event that your data is collected by Vitality Works NZ)

8.2      From time to time, some of your personal information (including your sensitive information) may also be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers that we engage to assist us in providing certain health, safety and wellbeing services to our clients (including but not limited to the Vitality Hub services) or in the operation of our business. This may happen if:

  • our offices or related entities are overseas
  • we outsource certain activities overseas
  • transactions, information, services or products have an overseas connection, or
  • our computer systems including IT servers are located overseas.

8.3      In particular, your personal information may be disclosed to third parties in the United States of America, New Zealand and such other countries in which those parties or their, or our, personnel and/or computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy.

8.4      You consent to the collection, use, storage, and processing of your personal information outside of Australia as set out in this Privacy Policy.

8.5      In providing this consent, you understand and acknowledge that while such third parties will often be subject to privacy and confidentiality obligations, you accept that where lawful, such obligations may differ from and be less stringent than the requirements of the privacy laws of Australia in relation to personal information.


9. Security

9.1       We take reasonable steps to protect all of the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. This protection applies in relation to information stored in both electronic and hard copy form.


10. Access to personal information

10.1     If you need to access any personal information we hold about you, please contact us using the Contact Us details set out below. We request that you provide us with as much detail as you can about the particular information you seek, in order to help us retrieve it. An access fee may be charged to cover our costs of providing that information to you.

10.2     In certain circumstances, we may not be required by law to provide you with access to your personal information. If that is the case, we will give you our reasons for that decision. We take reasonable steps to make sure that the personal information we collect, use and disclose is accurate, complete and up-to-date.


11. Changes to this Privacy Policy

11.1       We may update and make changes to this privacy policy from time to time.


12. How do we deal with privacy complaints

12.1      If you want to correct or update your information, or you consider that we may have misused your personal information, or breached this Privacy Policy or our general privacy obligations, please contact us by using the Contact Us details set out below with details of your issue and your email bearing the subject line “Privacy” and we will respond as soon as practicable.


13. Contact us

13.1      For any queries about our use or handling of personal information, or if you wish to make a complaint, please direct any enquiries to our Privacy Officer via:



This Privacy Policy was last updated March 2023