This policy explains how Clinically handles personal information when a medical practice uses our platform to capture a patient's electronic Assignment of Benefit (AoB) consent for a Medicare bulk-billed service. We handle personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
For routine questions about your own information, your first port of call is the practice that sent you the link — under the APPs they are the entity that collected the information and Clinically processes it on their behalf.
The platform is operated by CCMX PTY Limited t/a Clinically (ABN 24 693 129 056) ("Clinically", "we", "us"). We provide an electronic Assignment of Benefit consent tool to Australian medical practices. We do not provide medical advice and we are not a party to the doctor–patient relationship.
We collect two categories of personal information:
The patient's date of birth is entered by the patient on the consent screen — it is deliberately never carried in the SMS or email link. Where a practice sends the link from its own appointment or messaging system, we never receive the patient's mobile number. Where a practice instead enables Clinically's patient communications, we hold the patient's mobile number and email address so we can send the link on the practice's behalf — see "When your practice sends the link through Clinically" below.
We collect this information so the practice can capture a Medicare-compliant electronic Assignment of Benefit and so the signed record can be retained as evidence of the patient's consent. This is the primary purpose under APP 6, and the regulatory basis is the bulk-bill assignment regime under the Health Insurance Act 1973 (Cth), as amended by the Health Insurance Amendment (Assignment of Medicare Benefits) Regulations 2025. We do not reuse the information for marketing or for any unrelated purpose. The patient is notified of the collection at the point it occurs — on the consent screen, before they sign — consistent with APP 5.
We take the following reasonable steps under APP 11 to protect personal information from misuse, loss, and unauthorised access:
A summary of our security controls is published at /security.
When a patient taps the link their practice sends, they will notice their first name and surname appear in the address bar of their browser. That is intentional and worth explaining in plain English.
The link the practice's appointment system sends is a template. When the practice's system fills it in for the patient, it puts the patient's first name and surname into a special part of the link called the fragment — the part after the # symbol. The fragment lets the consent screen greet the patient by name and confirm what's being signed without us at Clinically having to know anything about that patient in advance.
By a long-standing technical rule of the web, the fragment is never sent to any server. The patient's browser keeps it locally and uses it only to display the page. So when the patient opens the link, Clinically's servers learn nothing about who they are — not their name, not their date of birth, not the appointment. We cannot even tell whether it was the patient or someone else who opened the link.
The trade-off is that anyone who can see the link itself — for example, someone holding the patient's phone, looking over their shoulder, or reading the SMS if it has been forwarded — would be able to read the patient's first name and surname in the address bar. The link does not carry the patient's date of birth, Medicare number, or any clinical detail. The patient still has to enter their date of birth on the consent screen before they can sign.
The SMS the patient receives is sent by their practice's appointment system — a verified, healthcare-grade platform the practice already uses to send appointment reminders, with the patient's prior consent to contact them at that number. The message itself starts with the patient's first name in the body, just like every other reminder their practice sends. The link is part of that same SMS — so the patient's name in the link is no more exposed than the rest of the message: both sit on the patient's device, and the parts of the link that identify the patient do not travel to Clinically until they actively submit a signed consent. Until that moment, our servers know nothing about who opened the link.
When the patient taps "Sign and submit", their name, date of birth, the Medicare items being billed, the date of service, their signing time, their signature image, and a small device fingerprint are sent to our servers over a TLS-encrypted connection. They are then stored in our encrypted database, where they are accessible only to the practice's authorised staff. That stored record is what the practice — and, if asked, Services Australia — rely on as the evidence of the patient's consent.
A practice can send the consent link from its own appointment system, or it can enable Clinically's patient communications and have us send the SMS or email on its behalf. The section above describes the first case. When a practice uses our messaging instead:
A signed consent record is visible only to authorised members of the practice that captured it. Clinically support staff may access a record only on a strict need-to-know basis (for example, to diagnose a fault the practice has reported), and that access is audit-logged. We do not sell, rent, or trade personal information.
Practices are required under Services Australia guidance to retain the completed Assignment of Benefit for at least two years from the date the claim is made. Clinically retains the signed record for at least that period so the practice can meet its retention obligation. Beyond the regulatory floor, retention and destruction settings are being formalised — please contact us at privacy@clinically.com.au for the current schedule or to request earlier deletion of practice-owned records.
Patient contact details and unsigned links. Where a practice enables patient communications, the patient's mobile number and email address are held only while they remain in the practice's patient directory. The practice controls those records directly — it can edit or delete any patient, or clear its entire directory, from its dashboard at any time, and all patient contact details are deleted when the practice closes its account. A consent link sent by SMS or email expires about seven days after it is issued; an unsigned link that expires captures no consent record. We do not retain patient contact details for any purpose beyond letting the practice send the consent message and find that patient again in its own directory, and we never use them for marketing.
Under APP 12 and APP 13, an individual may request access to, or correction of, their personal information. Because the practice is the entity that collected the information, please make routine access and correction requests to the practice directly — they can produce the signed record from their dashboard. If the practice is unable to assist, you may contact us at privacy@clinically.com.au. We do not charge a fee for making an access or correction request.
Under the bulk-bill assignment regime, a copy of the signed Assignment of Benefit is available on request — please ask the practice in the first instance.
If you believe we have mishandled your personal information, write to privacy@clinically.com.au or Suite 2, 710 Hunter Street, Newcastle West NSW 2302. We will acknowledge your complaint and respond within a reasonable period. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner — see oaic.gov.au.
We comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth). If we become aware of a suspected eligible data breach affecting personal information we hold, we will assess it and, where the scheme requires, notify the Office of the Australian Information Commissioner and the individuals at likely risk of serious harm as soon as practicable. Practices using the platform will be notified within 72 hours of confirmation of an eligible data breach affecting their records.
We host personal information on cloud infrastructure located in Australian regions and we design the service to keep personal information onshore. Some operational sub-processors we rely on (for example, transactional email delivery or document rendering services) may process information outside Australia. Where that is the case, we take reasonable steps under APP 8 to ensure the recipient handles the information consistently with the APPs. The current list of sub-processors and their processing locations is published at /sub-processors.
We may update this policy from time to time. Material changes will be communicated to practice administrators by email and reflected in the in-app onboarding flow. The version number and effective date at the top of this page indicate when the policy was last revised; prior versions are archived on request.
Privacy enquiries: privacy@clinically.com.au.
Postal address: Suite 2, 710 Hunter Street, Newcastle West NSW 2302.