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This document (privacy policy) explains how Optometry Victoria South Australia of 28 Drummond  Street, Carlton VIC 3053 (OVSA) collects, uses, discloses and otherwise handles personal information (as defined in the privacy policy) that OVSA collects from you.

OVSA takes its obligations under the Privacy Act 1988 (Cth) (Privacy Act) seriously. This privacy policy outlines OVSA’s ongoing obligations to you in respect of how OVSA manages your personal information, including how OVSA complies with the Australian Privacy Principles (APPs) under the Privacy Act. You can obtain a copy of the APPs by visiting the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.

OVSA reserves the right to change, replace or update this privacy policy from time to time. OVSA will make the new version of the privacy policy available via the same channels as this privacy policy has been made available. OVSA encourages you to regularly review the channels to ensure that you are familiar with OVSA’s current privacy policy.

1.              What is personal information and what personal information does OVSA collect from you?

For the purposes of this privacy policy, personal information is any information or opinion about an identified individual or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or not.

OVSA may collect certain personal information about you in connection with your interactions with OVSA, including:

1.1           your name and other information that may be used to identify you;

1.2           your mail and/or street address information;

1.3           your email address and your telephone number (including your land line and mobile phone number);

1.4           information that you provide to us when you apply for membership of OVSA, such as the name, address and telephone number of the clinic at which you practise;

1.5           your device identity and type, your IP address, geo-location information, page view statistics, advertising data and standard web log information;

1.6           information pertaining to your current and former employment (including the name of your employer, details of your workplace and details relating to your employment contract, such as salary information);

1.7           name of tertiary institute and date of graduation;

1.8           APHRA registration details and AHPRA reports generated for membership;

1.9           Account profile details;

1.10        where not provided elsewhere, details of your practice (including street and mail address, contact number, and position);

1.11        USI number for CPR; and

1.12        any other information that can be used (either singly or in combination with other information) to identify you.

OVSA generally does not collect sensitive information about you, except where you are currently (or have previously been) a member of either OVSA or another organisation affiliated with Optometry Australia. The Privacy Act defines ‘sensitive information’ to include information or opinion about your racial or ethnic origin, your membership of a political party and/or membership of a trade union or other professional body, information relating to your religious or philosophical beliefs, health information, information relating to your criminal record (if any), and information relating to your political opinions.

We may also collect information from you when you register to attend an event undertaken by OVSA or on behalf of OVSA, including information relating to your dietary requirements and any dietary restrictions. Further, by attending the event, you may be photographed or videoed, unless you opt out from being photographed and/or videoed in accordance with the process set out by OVSA from time to time.

From time to time, you may pay to register to attend events or to attend continuing professional development. If you pay via credit card, we may collect and retain the last four digits of your credit card.

Where OVSA collects information about your membership of OVSA and/or any other organisation affiliated with Optometry Australia, such collection will typically only occur with your consent (which can be expressly given or inferred from your conduct with respect to the collection of such information).

This privacy policy explains why OVSA collects the personal information it collects from you, how OVSA may use this information and the potential recipients for OVSA’s usual disclosures of personal information.

2.              How does OVSA collect personal information about you?

OVSA collects personal information in a number of ways, as explained in further detail below. While OVSA uses reasonable efforts to collect personal information about you directly from you, from time to time, OVSA may also collect personal information about you from third parties (including, but not limited to, Optometry Australia, Optometry New South Wales/Australian Capital Territory, Optometry Queensland/Northern Territory, Optometry Tasmania and Optometry Western Australia).

OVSA may collect personal information using any one or more of the following means:

2.1           When you apply for membership of OVSA: OVSA may collect personal information when you apply for membership of OVSA via the functionality made available by Optometry Australia or when you contact OVSA directly to apply for membership of OVSA.

2.2           When you register to attend events hosted or conducted by or on behalf of OVSA: from time to time, OVSA may host or sponsor events that require attendance to be registered with OVSA. When you register with OVSA, you will be asked to provide certain information, including your name, contact details and any dietary requirements.

2.3           When you attend events hosted or conducted by or on behalf of OVSA: if you attend any events hosted or conducted by or on behalf of OVSA, you may be photographed and/or videoed by persons authorised by OVSA to take photographs and/or video of the event.

2.4           When OVSA collects personal information from third parties or from publicly available sources of information: OVSA may receive personal information about you from third parties, such as Optometry Australia, Optometry New South Wales/Australian Capital Territory, Optometry Queensland/Northern Territory, Optometry Tasmania and Optometry Western Australia. In particular, OVSA may receive personal information when you (for example) move from another State or Territory to Victoria or South Australia and wish to transfer your membership to OVSA, or when you are visiting South Australia or Victoria and you register to attend a continuing professional development event being hosted by OVSA.

2.5           When you subscribe to receive newsletters and other communications from OVSA: OVSA will collect certain personal information from you when you subscribe to receive newsletters published and distributed by OVSA, as well as other communications that OVSA generally disseminates from time to time. You will be able to exercise an “opt out” functionality that is included with each such communication if you no longer wish to receive such communications or newsletters from OVSA.

2.6           When you otherwise communicate with or interact with OVSA: OVSA may also collect personal information when you submit information to OVSA using any means that OVSA may make available from time to time, including when you telephone OVSA.

3.              Anonymity and pseudonymity

Where it is lawful and reasonable for you to do so, you have the right to deal with OVSA on an anonymous or pseudonymous basis. As permitted by law, and subject to the following, OVSA will give you the option of not identifying yourself, or of using a pseudonym, in dealing with OVSA.

However, if you choose to interact with OVSA in an anonymous or pseudonymous basis, or you do not provide OVSA with personal information on request, then OVSA may be unable to provide you with the services that you request.

Further, OVSA reserves the right to verify your identity in certain circumstances. For example, OVSA may need to verify your identity when you request that OVSA provides certain services to you, in order to assist OVSA to fulfil its obligations owed to you when OVSA has agreed to provide those services to you. Additionally, when you request access to or correction of the personal information OVSA holds about you, or when you wish to make a complaint about how OVSA has handled your personal information, OVSA reserves the right to verify your identity and contact details in order to facilitate its handling and satisfaction of your access or correction request, or to investigate and deal with your complaint.

OVSA may create de-identified or anonymous data from personal information by removing certain components of the personal information that makes such information personally identifiable of you, or through obfuscation or through other means. OVSA’s use or such de-identified or anonymised data is not subject to this privacy policy.

4.              Receipt of unsolicited personal information

Generally, OVSA only collects personal information when it is specifically requested or when OVSA takes active steps to collect that information. From time to time, however, personal information about an individual may be provided or volunteered to OVSA on an unsolicited basis.

Where OVSA receives personal information on an unsolicited basis, then (in accordance with OVSA’s statutory obligations), OVSA will promptly determine whether such personal information could lawfully have been collected had OVSA requested the information or otherwise had actively sought the provision of such information.

5.              Why OVSA collects personal information

OVSA may collect, use, disclose and process personal information for one or more purposes, as set out in further detail below.

OVSA will generally collect, use and disclose personal information for one or more of the following purposes:

5.1           To operate its business;

5.2           To provide products, services and information to you, to OVSA’s service providers, and to take steps in response to information requests or inquiries you may submit prior to entering into a contract or other legal arrangement with us;

5.3           To ask that you participate in and complete questionnaires and surveys, to administer questionnaires and surveys that you have agreed to complete, and to gather information and feedback about OVSA’s performance;

5.4           To comply with OVSA’s contractual and legal obligations, to resolve disputes and to enforce our agreements with you or with third parties;

5.5           To share information with Optometry Australia and with Optometry New South Wales/Australian Capital Territory, Optometry Queensland/Northern Territory, Optometry Tasmania and Optometry Western Australia in order to administer membership inquiries, membership applications and cessation of membership, as well as related obligations;

5.6           For record keeping and administrative purposes, and to consider applications for employment with OVSA;

5.7           For fraud, loss and other crime prevention purposes;

5.8           For direct marketing purposes, including to enable OVSA to send you marketing and promotional messages and other information that may be of interest to you, via email, SMS, social media or direct mail (subject to you not exercising your right to opt out of your receipt of such communications);

5.9           To assist in the investigation of suspected illegal or wrongful activity, and to protect and to defend our rights and property, or the rights or safety of third parties;

5.10        To comply with laws, regulators, court orders and other legal obligations, or pursuant to legal processes;

5.11        To maintain a safe working environment for OVSA’s staff, contractors and visitors.
OVSA collects, uses and discloses personal information in relation to your contract and salary information for the purpose of undertaking contract review services. Notwithstanding any other statement in this privacy policy, OVSA will not use or disclose personal information relating to your contract or your salary information for the purpose of marketing (including direct marketing).

6.              Disclosure of personal information to third parties

In the course of fulfilling the purpose(s) for which OVSA collected personal information about you, OVSA may disclose personal information to third parties. Such disclosures will be on an as-needs basis only and only to the extent necessary to fulfil one or more of the purposes for which OVSA collected the information, together with any secondary purpose related to the primary purpose(s) for which the information was collected, and otherwise as required or authorised by law.

This section of the privacy policy sets out the usual recipients of OVSA’s disclosure of personal information:

6.1           Your organisation. Where you deal or engage with OVSA on behalf of a third party organisation, OVSA may disclose some or all of your personal information to other persons from your organisation in order to enable OVSA to operate its business and to provide its services and information to you and your organisation.

6.2           Other State and Territory Optometry organisations. From time to time, OVSA may disclose your personal information to Optometry Australia, and to other State and Territory-based Optometry Australia-affiliated organisations in order to facilitate the administration of your membership and for related purposes.

6.3           Service providers. OVSA may disclose personal information to its business partners, distributors, service providers, marketing providers, and vendors in order to enable OVSA to operate its business and to provide its services and information to you. OVSA may also disclose personal information for other technical and processing functions, such as to enable a third party to send emails or other communications on OVSA’s behalf, for the purpose of OVSA receiving technical support, and for analytics and marketing purposes. Such third parties may be given access to personal information, but such access would be provided only as needed to enable those third parties to perform their functions and supply their services to OVSA, and they may not use personal information for other purposes.

6.4           Persons authorised by you. OVSA may disclose some or all of your personal information to persons whom you have authorised OVSA to disclose your personal information.

6.5           As authorised or required by law. OVSA may also disclose some or all of your personal information to comply with applicable laws and regulations, to respond to a lawful request for information OVSA receives, or as otherwise pursuant, authorised or required by law (including under the Privacy Act 1988 (Cth) and any other information privacy or data protection law that applies to OVSA). OVSA may also use and disclose personal information to establish or exercise its legal rights, to enforce its contracts with you or your organisation, this Privacy Policy, or agreements with third parties, to assert and defend against legal claims, or if OVSA believes such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

6.6           Professional advisers, insurers and auditors. OVSA may also disclose some or all of your personal information to its professional advisers (including lawyers and accountants), its insurers and its auditors for the purpose of its advisers, insurers and auditors completing their obligations owed to OVSA.

7.              OVSA’s use and disclosure of de-identified or anonymised data. OVSA may create de-identified or anonymised data sets from personal information by removing data components that makes the information personally identifiable to you or through obfuscation or through other means. OVSA’s use and/or disclosure of anonymised or de-identified information is not subject to this privacy policy.

8.              Links to other websites. The OVSA section of the Optometry Australia website may contain links or otherwise provide access to websites, mobile applications or Internet locations owned or operated by third parties (Third Party Sites). This privacy policy does not apply to Third Party Sites. OVSA encourages you to read the privacy policies of any Third Party Site with which you choose to interact.

9.              Disclosure of personal information to recipients located outside Australia. Generally, OVSA does not disclose personal information to recipients located outside Australia. However, OVSA may engage third party service providers (including cloud providers and website hosting providers) that provide some or all of their services to OVSA from location(s) outside Australia. If OVSA does so, then OVSA will take reasonable steps to ensure that such service providers deal with the personal information to which they have access in a manner consistent with this privacy policy and in compliance with the requirements of the Privacy Act 1988 (Cth). If you communicate with OVSA via email, through a social network service or through some other electronic process, the communication may be routed through servers that are located outside Australia and, in relation to a message sent to OVSA through a social network service (such as Twitter or Facebook), the social network provider and its partners may collect, hold and process personal information in a jurisdiction outside Australia.

10.           Security. OVSA takes reasonable steps to ensure that your personal information is kept secure and protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. OVSA uses technical and organisational security measures designed to secure and protect personal information. Please note, however, that OVSA cannot eliminate security risks associated with the storage and transmission of personal information, including through the Internet, which is an inherently insecure medium.

11.           Quality of personal information. OVSA takes reasonable steps to ensure that personal information collected, used and disclosed is accurate, complete and up-to-date. However, the accuracy, completeness and currency of the personal information OVSA holds largely depends on the accuracy, completeness and currency of the information you supply to OVSA. If at any time you discover that any personal information OVSA holds about you is inaccurate, incomplete, outdated, irrelevant or misleading, please contact OVSA to request correction of the information. OVSA will handle a correction request in accordance with the procedures set out in this privacy policy and in compliance with the Privacy Act. In doing so, OVSA reserves the right to verify the identity of the person making the correction request before processing the request.

12.           Access to and correction of personal information

12.1        OVSA will provide access to your personal information within a reasonable period of time following OVSA’s receipt of your request, unless an exception applies. OVSA may refuse access to your personal information under the Privacy Act in any of the following situations: (a) where the access to information would pose a serious threat to the life or health or safety of the individual, or to public health or public safety; (b) where the request is frivolous or vexatious; (c) where the request relates to existing or anticipated legal proceedings or to current negotiations between OVSA and the individual making the request; (d) the request is unlawful, would impede or prejudice any investigation of unlawful activity; or (e) where OVSA is required or authorised by or under Australian law or court/tribunal order to not comply with the request.

12.2        Where OVSA does not provide you with access to your personal information, OVSA will explain to you the reason for denying access and provide details in relation to the relevant complaint process, should you not agree with OVSA’s reasons.

12.3        While OVSA will not charge a fee for making an access request, OVSA is authorised by law to charge a reasonable fee to cover its costs incurred in providing access to your personal information. OVSA reserves the right to charge such fee to you in order to cover its costs incurred in providing you with access to your personal information.

12.4        If you can establish that the personal information OVSA holds about you is not accurate, complete or up-to-date, or is irrelevant or misleading, then OVSA will take reasonable steps to correct the information. If OVSA has disclosed inaccurate, incomplete, out-of-date, irrelevant or misleading information to a third party, OVSA will take reasonable steps to ensure that the recipient is aware of the correction to such information.

12.5        OVSA may request from you information in order to verify your identity and your connection to the individual about whom you request personal information, if required. Further, OVSA reserves the right to redact information included in the personal information to which you are granted access, in order to protect the privacy of other individuals.

13.           Complaints procedure. If you have any query or complaint about how OVSA has handled your personal information, please contact OVSA, using the details set out below. OVSA will provide a response to you within a reasonable time period following receipt, in accordance with applicable law. OVSA reserves the right to verify the identity of the person making the complaint and to seek (where appropriate or reasonable) further information from the complainant about the circumstances of the complaint. OVSA reserves the right to refuse to investigate or to otherwise deal with a complaint where permitted by law. For example, OVSA may refuse to investigate or to otherwise deal with a complaint if OVSA considers the complaint to be vexatious or frivolous. If you are not satisfied with OVSA’s determination in response to your complaint, then you may escalate your complaint to the Office of the Australian Information Commissioner.

14.           Contact OVSA. For further information about OVSA’s privacy policy or practices, or to request access to or correction of your personal information OVSA holds about you, or to make a complaint, please contact OVSA using the details below:

14.1        Email: privacy.vicsa@optometry.org.au

14.2        Mail address: 28 Drummond  Street, Carlton VIC 3053

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