Privacy Policy

1. About This Policy

This Privacy Policy explains how IMG Registration Australia ("IMGRA", "we", "us", "our"), ABN 42 862 720 911, collects, holds, uses, and discloses personal information.

As a sole trader, our annual turnover may fall below the threshold at which some businesses are exempt from the Privacy Act 1988 (Cth) ("Privacy Act"). Regardless of any exemption that may apply, we have chosen to handle personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act, because our clients share sensitive professional, educational, and identity documentation with us and are entitled to expect a high standard of care.

2. Information We Collect

Depending on the services you engage us for, we may collect:

• Identity information: name, date of birth, contact details, nationality, passport/visa details where relevant to the advice sought;
• Professional and educational information: medical qualifications, transcripts, exam results (e.g. AMC, PLAB, USMLE), employment history, CV/resume, references;
• Registration-related documents: AHPRA/AMC portfolio information, correspondence with regulators, PESCI-related documents, and supporting evidence for applications;
• Communications: emails, consultation notes, enquiry form submissions, and records of advice given;
• Payment information: processed via our third-party payment provider (we do not directly store full card details);
• Technical information: website usage data collected via cookies or analytics tools, where applicable.

We do not seek to collect health information about you (such as clinical or medical history) unless you volunteer it as part of explaining your circumstances, or it is contained within documentation you provide to us for the purpose of an application (for example, where a regulator's process requires disclosure of a health matter). Where this occurs, we treat that information as sensitive information under the APPs and apply a higher standard of protection to it.

3. How We Collect Information

We collect personal information directly from you, primarily through:

• Website enquiry forms and booking systems;
• Email and other written correspondence;
• Consultations (telephone, video, or in person);
• Documents you upload or send to us for review.

We do not knowingly collect personal information about you from third parties without your knowledge, except where necessary to deliver a service you have requested (for example, liaising with a recruitment partner at your request).

4. How We Use Your Information

We use personal information to:

• Provide advisory, document review, and related services you have requested;
• Communicate with you about your engagement, bookings, and invoices;
• Improve our services and develop resources, templates, and content (using de-identified or aggregated information wherever possible);
• Meet our legal, accounting, and regulatory obligations;
• With your consent, send you marketing communications, which you may opt out of at any time.

5. AI and Automated Tools

Client documents (including CVs, qualifications, exam results, and identity documents) may be reviewed by and/or processed through AI or automated document-review tools as part of our current review workflow. We may use AI-assisted tools for limited administrative functions that do not involve your identifying or sensitive documents, such as drafting general website content, scheduling, or template preparation. If our use of AI tools changes to include processing of client-identifying or sensitive documents in future, we will update this Policy and, where required by law, seek your consent before doing so.

Our AI provider is hosted entirely in Australia and is never shared with the wider internet.

We currently use the following third-party service providers, which may involve limited data processing on our behalf: Microsoft 365 suite of applications.

6. Disclosure of Information

We do not sell your personal information. We may disclose personal information to:

• Service providers who support our operations (e.g. cloud storage, email, payment processing, scheduling), on a confidential, need-to-know basis;
• A regulator, college, employer, or third party, but only where you have specifically authorised us to liaise with them on your behalf;
• Professional advisers (e.g. our accountant or insurer), where necessary for our own business operations;
• Law enforcement or regulatory bodies, where required or authorised by law.

We do not disclose your information overseas except to the extent that a service provider we use (such as a software provider) stores or processes data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure the overseas recipient handles your information consistently with the APPs.

7. Data Storage and Security

We store personal information using a combination of secure cloud-based systems and, where applicable, physical records, and take reasonable steps to protect it against misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include restricting access to information on a need-to-know basis and using reputable, secure third-party platforms for storage and communication.

No method of electronic storage or transmission is completely secure. While we take reasonable precautions, we cannot guarantee absolute security of information transmitted to us electronically.

8. Retention

We retain personal information only for as long as necessary to provide our services, meet legal and accounting obligations, and manage any potential disputes. Where information is no longer required for these purposes, we take reasonable steps to securely destroy or de-identify it, unless we are required by law to retain it for a longer period.

9. Access and Correction

You may request access to, or correction of, the personal information we hold about you by contacting us at hello@imgra.com.au. We will respond within a reasonable time and, in most cases, within 30 days. We may need to verify your identity before providing access. There is no charge for making a request, though reasonable costs may apply to fulfilling extensive requests.

10. Complaints

If you have a concern about how we have handled your personal information, please contact us at hello@imgra.com.au in the first instance. We will investigate and respond within a reasonable time. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

11. Cookies and Website Analytics

Our website may use cookies or similar technologies to understand how visitors use our site and to improve user experience. You can control or disable cookies through your browser settings; doing so may affect the functionality of our website.

12. Children's Privacy

Our services are directed at adult medical practitioners and graduates. We do not knowingly collect personal information from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version will always be available on our website, and material changes will be dated at the top of this document.

14. Contact Us

Business: IMG Registration Australia
ABN: 42 862 720 911
Email: hello@imgra.com.au