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Optometry Australia’s privacy policy

1.           Who are we?

1.1         Optometry Australia (ABN 17 004 622 431) (Optometry Australia, we, us or our) is a federated not-for-profit organisation and the national peak professional body for optometrists in Australia.

1.2         We operate for the benefit of optometrists and optometry students who are members (Members) of one of our following state divisions (State Division/s):

(a)           Optometry New South Wales/Australian Capital Territory (ABN 78 000 006 093)

(b)           Optometry Queensland/Northern Territory (ABN 54 009 657 265);

(c)           Optometry Tasmania (ABN 18 332 330 199);

(d)           Optometry Victoria/South Australia (ABN 27 451 280 538);

(e)           Optometry Western Australia (ABN 42 736 864 919).

1.3         We provide the following services to Members:

(a)           Represent the interests of Members to third parties to advance the profession of optometry nationally and improve the provision of eye care to the Australian community;

(b)           Develop, coordinate and implement professional development programs, to communicate, provide and inform Members of services that are provided by us;

(c)           Support the professional needs of Members;

(d)           Publish an online directory of Australian optometrists for distribution to the Australian general public containing the following personal information relating to Members. This facility is on an opt-in basis.

(i)            Member name

(ii)           Practice name

(iii)          Practice address

(iv)          Practice phone number

(e)           Create and publish information about the importance of optometry and eye health for the general public;

(f)            Investigate and resolve Member complaints and enquiries

(g)           Monitor and plan for the advancement of the provision of eye care in Australia, including workforce studies; and

(h)           Assist Members to comply with their professional and legislative obligations

2.           What is this Privacy Policy about?

2.1         Optometry Australia values your privacy and works hard to protect the information provided to us.

2.2         This Privacy Policy explains how we manage personal information in accordance with the Privacy Act (1988)Cth) (Privacy Act) including our obligations and your rights in respect of our dealings with your personal information.

2.3         Personal information is information or an opinion about an individual, whether true or not true, which identifies them or from which their identity is reasonably identifiable.

2.4         Please take a moment to read this Privacy Policy as it describes what happens to your personal information that is collected via our (Website) at www.optometry.org.au or through other means when you provide your personal information to us.

3.           How we collect personal information

3.1         We collect and hold personal information in a lawful and fair manner.

3.2         Where it is reasonably practical to do so, we will collect your personal information directly from you when:

(a)           You sign up to become a Member of a State Division.

(b)           You provide personal information directly to a representative at:

(i)            Optometry Australia; and/or

(ii)           one of the State Divisions;

(c)           You make an inquiry through the Website;

(d)           You contact us or one of our State Divisions via telephone or facsimile;

(e)           You correspond with us or one of our State Divisions (whether in writing or electronically), including by an online form through the Website, email, text message or post;

(f)            Administering any of our Services; and

(g)           As otherwise required to manage our business.

3.3         We may also collect personal information through some of the following means:

(a)           from our State Divisions (as set out in detail at clause 3.2 above);

(b)           from publicly available sources, including the Australian Health Practitioner Regulation Authority Register of Practitioners (limited to the collection of personal information about optometrists that is made available by AHPRA to the public); and

(c)           from other third parties such as suppliers, recruitment agencies, contractors and business partners

3.4         If we collect personal information about you from a third party we will, where appropriate, request the third party inform you that we are holding your information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

4.           Types of personal information we collect

4.1         The types of personal information we may collect from Members can include (but is not limited to):

(a)            Name, contact address (such as home, practice, work, or postal address), phone number, email address, date of birth, ;

(b)           Date of joining as a Member;

(c)           Membership category or type;

(d)           State Division to which a Member belongs;

(e)           Information about a Member’s Continuing Professional Development (CPD) including CPD activities, points and any CPR training completed;

(f)            Gender;

(g)           Languages spoken;

(h)           Optometry professional interest areas;

(i)            Equipment available in a Member’s practice;

(j)            Qualifications;

(k)           Medical Endorsements (such as Scheduled Medicines Endorsement);

(l)            Memberships/fellowships of optometric organisations;

(m)          Hours worked;

(n)           A Member’s practice position; and

(o)           Other information that is deemed relevant to the practice of optometry.

4.2         The types of personal information we may collect from individuals who are not Members can include (but is not limited to):

(a)           Name, contact address (such as home, work, or postal address), phone number, email address, date of birth, gender;

(b)           Optometry professional interest areas;

(c)           Equipment available in a Member’s practice;

(d)           Qualifications;

(e)           Medical Endorsements (such as Scheduled Medicines Endorsement);

(f)            Memberships/fellowships of optometric organisations;

(g)           Hours worked;

(h)           A Member’s practice position; and

(i)            Other information relevant to the practice of optometry.

4.3         A Member or non-Member may elect to provide, or not provide, any of the above information. However, where a Member or non-Member refuses to provide certain information, we may be unable provide that individual with certain Services.

4.4         We do not normally collect sensitive information, such as health information and will not collect sensitive information about an individual unless that individual consents to the collection of the information and the information is reasonably necessary for one or more of our functions or activities.

5.           Our purposes for handling personal information

5.1         We collect, hold, use and disclose personal information to:

(a)           offer and provide our Services, including the Website;

(b)           manage and administer our Services, including promotional activities for Members and account keeping procedures;

(c)           enforce our rights arising from contracts;

(d)           communicate with Members and interested parties about (including but not limited to) any Services sought or information requested from us;

(e)           send marketing or promotional information in relation to our Services to Members;

(f)            comply with our legal and regulatory obligations;

(g)           consider an application for employment (if applicable);

(h)           otherwise manage our business; and

(i)            any other purpose reasonably related to the purpose for which we have collected it; or

(j)            otherwise with the consent from the individual to whom the information relates, or their legal guardian.

6.           Disclosure of personal information

6.1         We do not share, sell or otherwise disclose your personal information for purposes other than as outlined in this Privacy Policy.

6.2         We will disclose personal information for the following purposes:

(a)           To provide the Services, including:

(i)            To publish a directory of Australian optometrists;

(ii)           to publish an online directory of Australian optometrists to enable members of the public to obtain information about optometrists in Australia;

Note: Members and non-Members may opt out of having their personal information published in the organisation’s directory of optometrists or website directory by notifying us in writing or by editing their profile on the Website.

(b)           To facilitate direct marketing activities from our corporate partners and endorsed product manufacturers or suppliers for the purpose of providing Members with information and benefits available to them; and only with the Consent of Members;

Note: Before we provide a Member’s personal information to a third party for the purpose of direct marketing we require that third party to sign a confidentiality agreement confirming the use of the personal information will be restricted to the agreed marketing activity.

(c)           To provide or arrange professional indemnity insurance for Members;

(d)           To conduct studies with respect to the profession, to support our advocacy on behalf of members, such as workforce studies;

(e)           To fulfil the purpose or which you have provided your personal information to us;

(f)            To an entity we merge with, acquire or that buys us, or in the event of change in structure of our company of any form;

(g)           To comply with our legal obligations;

(h)           To enforce our rights, including to enforce or apply our Terms of Use [insert link] and other agreements we have with you, including for billing and collection purposes; and

(i)            With your consent.

6.3         We may disclose personal information to our State Divisions.

6.4         We may also disclose information to other third parties, such as organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act.  If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

6.5         We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure.

7.           Overseas transfer of personal information

7.1         All personal information is held in Australia.

7.2         As at the date of this Privacy Policy, we are not likely to disclose personal information to overseas recipients.

7.3         We may transfer de-identified aggregate data to partner international organisations including the World Council of Optometry.

7.4         If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act (1988) Cth. We will, where practicable, advise you of the countries in which any overseas recipients are likely to be located.

7.5         If you do not want us to disclose your information to overseas recipients, please let us know.

7.6         From time to time we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions.  Please note that the use of overseas service providers to store personal information does not always involve a disclosure of personal information overseas or to that overseas provider.

8.           Protection of personal information

8.1         We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which are located in Australia.

8.2         We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information to the best of our ability. This also applies to disposal of personal information.

8.3         Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.

8.4         We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

8.5         Whilst we take reasonable steps to maintain the security of your personal information transmitted via the internet, unfortunately, no data transmission over the internet can be guaranteed to be completely secure. Although we strive to protect such information, we do not warrant the security of any information transmitted over the internet and you do so at your own risk.

9.           Cookies

9.1         A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time.

9.2         We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website.  This information will help to better adapt the Website to suit personal requirements.  While cookies allow a computer to be identified, they do not permit any reference to a specific individual.  For information on cookie settings of your internet browser, please refer to your browser’s manual.

9.3         You can block cookies on your specific machine but this may inhibit your ability to access the Website.

10.           Accessing and correcting your personal information

10.1         We take reasonable steps to ensure that the personal information we collect and hold is accurate, complete and up-to-date.

10.2         We encourage Members to regularly review their profile on the Website and contact us if you have any concerns or to make adjustments directly to your membership record through the Website.

10.3         Members and non-Members may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time:

(a)           in writing (including by email);

(b)           in person; or

(c)           by telephone (in this case, our staff will ask relevant questions to confirm the identity of the individual)

10.4         On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for doing so. We may seek to recover from you reasonable costs incurred for providing you with access to personal information held by us.

10.5         We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons.

10.6         We will respond to all requests for access to or correction of personal information within a reasonable time.

11.           Identifiers

We will not adopt, use or disclose any identifier assigned to a Member by a government agency, except where required by law.

12.           Mandatory Data Breach Notifications

12.1         We will notify you and the Office of the Australian Information Commissioner in circumstances where there has been an eligible data breach as required by the Privacy Act.  This is when:

(a)           we suspect that a data breach relating to your personal information has occurred; and

(b)           there is real risk of serious harm to you as a result of the breach; and

(c)           we cannot take remedial steps to reduce the risk of serious harm.

13.           Requests, Complaints or Questions

13.1         If you have any requests, complaints or questions about this Privacy Policy, or how we handle your personal information, or if you wish to access the personal information we hold about you, please contact our Privacy Officer:

The Privacy Officer: John Karis

Post:

Optometry Australia
Attention: National Privacy Officer
PO Box 1037
South Melbourne VIC 3205
Australia
Telephone:        (03) 9668 8500
Email:               national@optometry.org.au

Marked attention: National Privacy Officer

13.2         We take all complaints seriously, and will respond to your complaint within 14 days.

13.3         If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218
Sydney NSW  2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

14.           Changes

14.1         We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you.

14.2         An up-to-date copy of our Privacy Policy is available on our Website and we encourage you to check our Website periodically to make sure you are aware of our current Privacy Policy.

14.3         The last update to this document was January 2020.

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