Version 1.0
Effective: September 2026

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1. About this Privacy Policy

Pain Education and Management (PEM) is operated by WorkforceIQ Holdings Pty Ltd.

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In this Privacy Policy, PEM, we, us and our refer to WorkforceIQ Holdings Pty Ltd and the Pain Education and Management services it operates.

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PEM provides pain education, care coordination, coaching, digital tools and access to health-related services and programs.

We recognise that information about your health is sensitive and should be handled carefully.

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This Privacy Policy explains how we collect, hold, use and disclose personal information, including health information, when you interact with PEM, including through:

• our website and member portal;

• Pain Pal;

• Pain Tracker;

• Pathways and other education programs;

• coaching and navigation services;

• consultations and health-related services;

• multidisciplinary and care-coordination programs;

• referrals and funded programs; and

• communications with us.

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We manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) where they apply to us, together with other applicable privacy, health-record and confidentiality requirements.

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2. Personal information we collect

The information we collect depends on your relationship with PEM and the services you use.

Identity and contact information

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We may collect information such as your:

• name;

• email address;

• telephone number;

• date of birth;

• address;

• account or member details; and

• other information reasonably required to identify or communicate with you.

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Health information

When relevant to a service we provide, we may collect health information including:

• information about pain and other health conditions;

• areas of the body affected by pain;

• symptoms and descriptions of pain;

• mobility, function and usual activities;

• self-care;

• pain or discomfort;

• mood and emotional wellbeing;

• quality of life;

• the impact of pain or health conditions on work and daily life;

• medications and treatment;

• health goals, challenges and progress;

• responses to questionnaires and patient-reported outcome measures;

• information contained in referrals, assessments, reports and clinical documents; and

• information provided by health practitioners or other organisations involved in your care where authorised or otherwise permitted by law.

 

Health information is sensitive information under Australian privacy law. We seek to collect only information reasonably necessary for the services and activities we provide.

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Pain Tracker information

If you use Pain Tracker, we collect information that you choose to enter about your health, pain and daily life.

This may include:

• areas of the body affected by pain;

• descriptions and characteristics of pain;

• mobility;

• self-care;

• usual activities;

• pain or discomfort;

• anxiety or low mood;

• overall health and quality-of-life ratings;

• the effect of pain on your life;

• factors that affect or trigger your pain; and

• approaches you use to manage pain.

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Pain Tracker may also calculate or generate scores, summaries, trends and other information from information you provide.

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Program and service information

We may collect information about:

• services and programs you participate in;

• appointments and bookings;

• education activities and progress;

• coaching and navigation interactions;

• referrals;

• clinicians or services involved in your care;

• service allocations;

• communications with PEM; and

• outcomes, experience and feedback.

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Website and technical information

When you use our website and digital services, information may also be collected about your interaction with those services, including:

• device and browser information;

• IP address;

• website usage;

• login and authentication information;

• cookies and similar technologies; and

• technical information used to operate, secure and improve our digital services.

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3. How we collect information

We generally collect personal information directly from you.

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This may occur when you:

• create or use a member account;

• complete a form, assessment or questionnaire;

• use Pain Tracker;

• enrol in or participate in a program;

• book or receive a service;

• upload a document;

• communicate with PEM; 

• provide information to a clinician, coach or other person delivering a PEM service.

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Where appropriate and permitted, we may also receive information from another person or organisation involved in your care or the administration of a service, including:

• your GP;

• allied health practitioners;

• specialists;

• pharmacists;

• hospitals and health services;

• rehabilitation providers;

• insurers or workers' compensation organisations;

• government agencies or program funders;

• employers in connection with an employer-funded service; or

• another person or organisation you have authorised.

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Where reasonably practicable, we collect personal information directly from you.

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4. Why we collect, hold, use and disclose information

We may collect, hold, use and disclose personal information where reasonably necessary to:

• provide services you request;

• operate Pain Pal, Pain Tracker, Pathways and other PEM programs;

• understand your needs and assist with care planning;

• provide education, coaching and navigation;

• provide or facilitate consultations and health-related services;

• coordinate services and members of your care team;

• manage appointments and bookings;

• communicate with you;

• monitor progress and changes in health, function or outcomes;

• administer funded programs;

• prepare reports where required for an authorised program;

• maintain appropriate health, service and administrative records;

• improve the quality, safety and effectiveness of our services;

• operate and secure our website, member portal and digital systems;

• respond to enquiries, requests and complaints;

• meet contractual, legal and regulatory requirements; and

• undertake other activities with your consent or as otherwise permitted by law.

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We seek to limit the collection, use and disclosure of personal information to what is reasonably necessary for these purposes.

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5. Health information and consent

Health information is sensitive information and receives additional protection under Australian privacy law.

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Where consent is required for the collection, use or disclosure of health information, we will seek consent appropriate to the circumstances.

Where appropriate, we separate consent decisions so that you can understand and control how your information is handled.

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Accepting or acknowledging this Privacy Policy does not, by itself, mean that you consent to every possible use or disclosure of your health information.

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Where a particular activity requires a separate consent or authorisation, we may ask you to make that decision separately.

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You may withdraw a consent relating to a future use or disclosure, subject to legal, clinical, contractual or record-keeping requirements.

Withdrawing consent does not necessarily require PEM or another health provider to delete information already collected or records that may lawfully be retained.

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6. Pain Tracker

Pain Tracker allows you to record information about your health, pain, function and daily life and see how these factors change over time.

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Using Pain Tracker and sharing Pain Tracker information with clinicians are separate decisions.

• Sharing your Pain Tracker information

• Pain Tracker sharing is off unless you choose to turn it on.

• If sharing is off, your Pain Tracker information is not made available to clinicians through PEM's Pain Tracker clinician-sharing functionality.

• You can use Pain Tracker without turning clinician sharing on.

• If you choose to turn sharing on, clinicians who are authorised by PEM and have appropriate access in connection with your care may be able to view relevant Pain Tracker information.

• You can turn sharing off again through Pain Tracker.

• Turning sharing off prevents subsequent access through that sharing functionality. It cannot reverse information that has already been lawfully accessed or disclosed, or remove information that a clinician has incorporated into their own clinical records.

• PEM records your current sharing preference and information about when that preference was made or changed.

• We may periodically remind you when sharing remains off so that you have an opportunity to review your preference.

• A reminder does not change your preference. Sharing remains off unless you affirmatively choose to turn it on.

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7. Clinicians and your care team

Some PEM services involve GPs, psychologists, physiotherapists, pharmacists, nurses, specialists and other health professionals.

PEM may also work with coaches, care coordinators and other people supporting the delivery of a program.

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Access to personal and health information is intended to be limited to people who require that information for an authorised purpose.

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Where PEM's digital platform provides a clinician with access to information about you, access may depend on:

• verification or authorisation of the clinician;

• the clinician's involvement in your care;

• the service or program in which you are participating;

• permissions established within PEM's systems;

• your applicable consent or sharing preference; and

• other legal or professional requirements.

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Health practitioners may have their own legal and professional obligations concerning information they receive and clinical records they create or maintain.

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8. Funded programs, insurers and employers

Some PEM services may be funded by an insurer, workers' compensation scheme, government agency, employer or another organisation.

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The information PEM provides to a funder depends on the particular program, applicable law, contractual requirements and any authority or consent applying to the service.

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Workers' compensation, insurance, rehabilitation and other funded health programs may require PEM to provide information about participation, assessment, treatment, progress, outcomes or other relevant matters.

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Where an employer funds access to a service, such as an employee-support program, PEM aims to protect individual confidentiality.

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Unless you have authorised otherwise, or disclosure is required or permitted by law, reporting to employers is intended to use aggregate or de-identified information rather than disclose an individual's health information.

 

9. Service providers and digital platforms

PEM uses third-party service providers and technology platforms to operate and support its services.

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Depending on the service you use, these may support functions including:

• website hosting;

• member accounts and authentication;

• databases and information storage;

• forms and questionnaires;

• appointment booking;

• communications;

• video or telehealth services;

• payment processing;

• education and learning systems;

• analytics;

• security; and

• other operational services.

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These providers may process personal information on PEM's behalf or provide infrastructure through which information is processed.

We seek to use reputable providers and limit the information provided or accessible to what is reasonably required for the relevant function.

 

10. Wix and overseas processing

PEM uses Wix to provide important parts of its website, member portal, databases and digital services, including functionality supporting Pain Tracker.

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Personal information processed through Wix may be processed or stored outside Australia.

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Wix advises that information relating to users of Wix websites may be processed by Wix.com Ltd in Israel and may also be processed by Wix group companies, infrastructure providers and subprocessors in other countries.

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Wix's technology infrastructure and service providers operate across multiple jurisdictions, including the United States, countries within the European Union, the United Kingdom, India and other locations.

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The particular countries and service providers used by Wix may change as its infrastructure and services change.

Other technology providers used by PEM may also process information outside Australia.

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Where the Australian Privacy Principles apply to an overseas disclosure by PEM, we take reasonable steps to comply with applicable cross-border disclosure requirements.

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You may contact us if you would like further information about overseas handling relevant to your personal information.

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11. How we protect information

PEM takes reasonable technical, administrative and organisational steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

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Depending on the system and information involved, these measures may include:

• account authentication;

• access and permission controls;

• restrictions on clinician and administrative access;

• secure technology and hosting services;

• controls limiting access to relevant patient information;

• confidentiality obligations;

• monitoring and audit processes where appropriate; and

• procedures for responding to privacy and security incidents.

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Pain Tracker and other PEM digital services use access controls intended to prevent one member from accessing another member's information and to restrict clinician access to authorised circumstances.

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No internet-based or electronic information system can guarantee absolute security.

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If we become aware of an eligible data breach, we will assess and respond to it in accordance with applicable law, including the Notifiable Data Breaches scheme where applicable.

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12. Retention and deletion

PEM retains personal information for as long as reasonably required for the purpose for which it was collected and to satisfy applicable health-record, legal, contractual, financial and other record-keeping requirements.

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When personal information is no longer required and PEM is not legally required or otherwise permitted to retain it, we take reasonable steps to destroy or de-identify it.

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Deleting a website or member account does not necessarily result in the deletion of health, clinical, financial, contractual, audit or other records that PEM or a health practitioner is required or permitted to retain.

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13. Accessing your information

You may request access to personal information PEM holds about you.

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We may need to verify your identity before providing access.

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There are circumstances under Australian privacy law in which access may be refused or limited. If that occurs, we will generally explain the reason where required and permitted by law.

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14. Correcting your information

You may ask us to correct personal information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading.

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We will take reasonable steps to consider and respond to correction requests in accordance with applicable privacy requirements.

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15. Communications and direct marketing

We may use your contact information to communicate with you about:

• services you use;

• appointments;

• programs;

• account matters;

• important service information; and

• other matters connected with your relationship with PEM.

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We may also send information about PEM services, programs or resources where permitted by law.

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You may opt out of marketing communications using the unsubscribe mechanism provided or by contacting us.

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Opting out of marketing does not prevent PEM from sending communications reasonably necessary to administer a service, appointment, program or account.

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16. Cookies, analytics and website information

PEM's website and digital services may use cookies and similar technologies to:

• provide website and member functionality;

• maintain sessions and authentication;

• understand how services are being used;

• improve website performance;

• maintain security; and

• support other legitimate website functions.

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Third-party services integrated with the website may also use cookies or similar technologies.

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Where required, information or choices relating to these technologies may be provided through the website or relevant platform controls.

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17. Data breaches

PEM maintains processes for responding to suspected loss, unauthorised access or disclosure of personal information.

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Where a breach is likely to result in serious harm and the requirements of the Notifiable Data Breaches scheme are met, PEM will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

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18. Privacy enquiries and complaints

If you have a question or concern about how PEM has handled your personal information, please contact us.

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Please provide enough information for us to understand the issue and investigate it.

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We will seek to acknowledge and respond to privacy complaints within a reasonable period.

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If you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

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19. Contact us

Pain Education and Management (PEM)
Operated by WorkforceIQ Holdings Pty Ltd

Email: support@managepain.au

Website: managepain.au

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20. Changes to this Privacy Policy

PEM may update this Privacy Policy when our services, technology, information-handling practices or legal obligations change.

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The current version and effective date will be published on our website.

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Where we make a material change relevant to a service for which acknowledgement or consent is required, we may ask you to review and acknowledge the updated Privacy Policy or provide a new consent before continuing to use that service.