The Skin & Cancer Foundation Australia (the Foundation) upholds the confidentiality of information and the privacy of individuals, including the Foundation’s patients. The Foundation is committed to ensuring the privacy of personal information that is provided to us.
- To set out the scope of the Foundation’s commitment in relation to privacy;
- To provide a clear expression of how personal information will be managed by the Foundation.
- the kinds of information that the Foundation may collect about you and how that information is held;
- how the Foundation collects and holds personal information;
- the purposes for which the Foundation collects, holds, uses and discloses personal information;
- how you can access the personal information the Foundation holds about you and seek to correct such information; and
- the way in which you can complain about a breach of your privacy and how the Foundation will handle that complaint.
Health information is:
- personal information or an opinion about:
- an individual's physical or mental health or disability (at any time);
- an individual's express wishes about the future provision of health services for themselves; or
- a health service provided, or to be provided, to an individual;
Other personal information collected to provide, or in providing, a health service;
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not;
Sensitive information means:
- personal information or opinion about an individual's:
- racial or ethnic origins;
- political opinions or political associations;
- philosophical beliefs or religious beliefs or affiliations;
- sexual preferences or practices; or
- criminal record; or
- health information about an individual.
All staff at the Foundation are responsible for ensuring that this policy and the Australian Privacy Principles (APPs) are complied with.
7.1 Collection and use of personal information - Types of personal information collected by the Foundation.
The Foundation will only collect information which is necessary to facilitate the provision to you of health care services by a member of the Foundation or to appropriately manage, conduct and oversee the Foundation's businesses. This may include (as applicable):
- Patients/clients/research participants. The Foundation collects information from you to facilitate the provision of health care services to you by members of the Foundation or to enable you to participate in research studies. This includes collecting personal information such as your name, address, your health history, family history, past and current treatments lifestyle factors, and any other information which is necessary to assist the health care team in providing appropriate care, or our research team in conducting its research.
- VMOs, students, contractors and volunteers. The Foundation collects information from you which is necessary to properly conduct, manage and oversee the Foundation's businesses. This includes collecting personal information such as your name, address, professional experience, qualifications and past employers, and any other information which may be necessary to appropriately conduct, manage and oversee the foundation group's businesses.
- Job applicants. The Foundation collects information from you, which is necessary to assess and engage job applicants. This includes collecting personal information such as your name, address, professional experience, qualifications, references and past employers, and any other information which is necessary to process your job application.
- Donors. Where you have consented, the Foundation collects information from you for the purposes of fundraising for the Foundation group including agreeing the terms of and managing any donations you agree to make. This includes collecting personal information such as your name and address.
7.2 How we collect personal information
We will usually collect your personal information directly from you, however sometimes we may need to collect information about you from third parties, such as:
- Another health service provider;
- Past employers and referees; or
- Related entities (being those listed in the annexure).
We will only collect information from third parties where:
- You have consented to such collection;
- Such collection is necessary to enable us to facilitate the provision of appropriate health care services by a member of the Foundation group;
- Such collection is reasonably necessary to enable us to appropriately manage, conduct and oversee the Foundation's businesses; or
- It is legally permissible for us to do.
7.3 How the Foundation uses your personal information
The Foundation only uses your personal information for the purpose for which it was collected by the Foundation (primary purpose), unless:
- There is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or the Foundation has informed you, that your information will be used for that secondary purpose;
- You have given your consent for your personal information to be used for a secondary purpose; or
- The Foundation is required or authorised by law to use your personal information for a secondary purpose (including for research and quality improvements within the foundation).
For example, the Foundation may use your personal information to:
- Facilitate the provision of health care services to you by a member of the Foundation group;
- Facilitate the provision of any ongoing health related services to you;
- Appropriately manage, conduct and oversee the Foundation's businesses, such as assessing insurance requirements, conducting audits, and undertaking accreditation processes;
- Assist the Foundation to manage, conduct and oversee the Foundation's businesses, including quality assurance programs, billing, improving its services, implementing appropriate security measures, conducting research and training personnel;
- Where required, effectively communicate with third parties, including Medicare Australia, private health insurers and Department of Veterans' Affairs; and
- Carry out fundraising activities (where you have consented).
7.4 Complete and accurate details (Anonymity & Pseudonimity)
Where possible and practicable, you will have the option to deal with the Foundation on an anonymous basis or by using a pseudonym. However, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the assistance or support you are seeking, or deal with you effectively.
7.5 Disclosing your personal information
The Foundation will confine its disclosure of your personal information to the primary purpose for which that information has been collected, or for a related secondary purpose. This includes when disclosure is necessary to facilitate the provision of health care services to you by a member of the Foundation, to help us manage, conduct and oversee the Foundation's businesses, or for security reasons. We may provide your personal information to:
- Medical and other healthcare professionals involved in your care;
- Government agencies, such as defence or department of veterans affairs, where an individual is receiving services with a member of the Foundation under arrangements with those agencies;
- Government departments responsible for health, aged care and disability where the foundation is required to do so;
- Third parties contracted to provide services to the Foundation, such as entities contracted to assist in accreditation or survey processes;
- Research institutions with which the Foundation collaborates;
- Private health insurance providers including Department of Veteran Affairs and Medicare Australia;
- Anyone authorised by you to receive your personal information (your consent may be express or implied);
- Fundraising institutions associated with the Foundation (where you have consented);
- Anyone the Foundation is required by law to disclose your personal information to.
7.6 Third party service providers
Where we engage third party service providers, we may disclose personal information to those service providers who may use, process and/or store that information locally. The Foundation’s IT is very particular about ensuring that all third party service providers have servers located in Australia.
7.7 Data storage, quality and security
Data quality - the Foundation will take reasonable steps to ensure that your personal information which is collected, used, or disclosed is accurate, complete and up to date.
Storage - all your personal information held by the Foundation is stored securely in either hard copy or electronic form.
Data security - the Foundation strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. The Foundation reviews and updates (where necessary) its security measures in light of current technologies.
Online transfer of information - while the Foundation does all it can to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with the Foundation via an online process, it is at your own risk. There are ways you can help maintain the privacy of your personal information, including:
always closing your browser when you have finished your user session;
always ensuring others cannot access your personal information and emails if you use a public computer; and
never disclosing your user name and password to third parties.
7.9 Links to other sites
The Foundation may provide links to third party websites. These linked sites may not be under our control and the Foundation is not responsible for the content or privacy practices employed by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.
7.10 Accessing and amending your personal information
You have a right to access your personal information which the Foundation holds about you. If you make a request to access your personal information, we will ask you to verify your identity and specify the information you require. You can also request an amendment to any of your personal information if you consider that it contains inaccurate information. You can contact the Foundation about any privacy issues as follows: Chief Financial Officer or the Chief Executive Officer. While the Foundation aims to meet all requests for access to personal information, in a small number of cases and where permitted to do so by law, The Foundation may not give access or may do so only under conditions. Subject to applicable laws, The Foundation may destroy records containing personal information when the record is no longer required by The Foundation.
If you have a complaint about the Foundation's information handling practices or consider we have breached your privacy, you can lodge a complaint with:
- The Foundation's Chief Financial Officer by telephoning either Westmead on 02 8833 3000 or by telephoning the Chief Executive Officer Corporate Governance on 02 8651 2000; or
- The Office of the Australian Information Commissioner.
The Foundation deals with all complaints in a fair and efficient manner.