Policy Statement 1.17: Privacy

AUSTRALIAN DENTAL ASSOCIATION VICTORIAN BRANCH INC. BRANCH POLICY STATEMENT 1.17 PRIVACY 1. INTRODUCTION 1.1

The Australian Dental Association Victorian Branch Inc. (ADAVB or the Branch) represents organised dentistry in Victoria. It is a formally recognised Branch of the Australian Dental Association Inc. (ADA) and members of the ADAVB are also members of the ADA federally.

1.2

The ADAVB is an association incorporated under the Associations Incorporation Act 1991 (Vic) – Reg’d Assoc. No. A0022649E. It is also registered with ASIC (Australian Registered Body Number ARBN 152948680).

1.3

This policy applies to the ADAVB. The ADA has its own Privacy Policy, which is available here.

1.4

Separate (HR) privacy policies apply to ADAVB employees and committee members, and these should be read in conjunction with this policy.

1.5

This policy sets out how we will collect, use, store, disclose and de-identify your personal information.

2. OUR COMMITMENT TO PRIVACY 2.1

The ADAVB takes its privacy obligations very seriously and wishes to ensure that all personal and sensitive information is dealt with in accordance with all relevant privacy laws and this privacy policy.

2.2

When dealing with your personal information we observe our obligations under the Privacy Act 1988 (Cth) and comply with the Australian Privacy Principles, as well other relevant legislation, including the: 2.2.1

Healthcare Identifiers Act 2010 (Cth);

2.2.2

Health Records Act 2001 (Vic); and

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2.2.3

Spam Act 2003 (Cth).

3. THE TYPES OF INFORMATION WE COLLECT 3.1

The types of personal information we collect include: 3.1.1 Contact details (name, address, professional information, telephone numbers, email, etc); and 3.1.2 Demographic information (gender, date of birth etc.); 3.1.3 Professional Information (Qualifications, Specialty, Continuing Professional Development, etc.); 3.1.4 Activities (Participation in ADA, other dental and community activities and events, ADAVB Regional Group); and 3.1.5 Your preferences, interests and behaviour relating to transactions, products and services, including our digital services.

3.2

The types of sensitive information it collects include records of communication between us, which may include from time to time, information you provide to us or we collect from others. This includes, but is not limited to, the following types of information: 3.2.1

ADA membership status and practice information;

3.2.2

Personal financial information;

3.2.3

Personal credit card data, including where appropriate, credit history; and

3.2.4

Any idiosyncratic or personal formation we obtain from you or others about you.

3.3

By arrangement with the Tasmanian Branch of the ADA (ADATas), selected member services, including conciliation services, are provided to members of ADATas. To the extent required to supply those services, the same information collected about ADAVB members is also collected about ADATas members. The ADATas has its own Privacy Policy which is available here.

3.4

The ADAVB also provides conciliation services to patients, and acts as a corporate authorised representative of Guild Insurance Ltd, the underwriter of the ADAVB Indemnity Scheme, for purposes related to administration of member claims or notifiable circumstances. In this case, the ADAVB may collect and

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share with Guild Insurance Ltd and their legal representatives, the name and contact details of the consumer and if the consumer consents, details about their dental health and treatment. The Guild Insurance Ltd. Privacy Policy is available here.

3.5

The ADAVB provides secretariat support for the eviDent Foundation of which it is the sole member. The ADAVB acts on behalf of the eviDent Foundation to seek donations and to engage dental practices in practice-based dental research.

The eviDent Foundation has its own Privacy Policy which is available here.

3.6

It is important that Members provide the ADAVB with current and accurate information so that the Branch can provide our services effectively.

3.7

The ADAVB uses 24 hour surveillance devices in its offices for security purposes, and the building in which the ADAVB offices are situated also use surveillance devices at entrances and in car parks for the same reason. Notices about this appear in the main foyer and in the reception area of the ADAVB office.

3.8

Visitors to the ADAVB offices should note that all use of the Branch WIFI system is monitored for security purposes whether using a phone, laptop or tablet device.

Logs are maintained of all network activity, and images of browsing sessions are captured whenever a page is visited for longer than 5 seconds, and these may be reviewed by the ADAVB or its IT consultants and service providers.

4. WHY WE COLLECT PRIVATE INFORMATION ABOUT YOU 4.1

The ADAVB is a membership organisation of dentists and dentist students which aims to encourage the improvement of the oral health of the public, promotion of the art, science and ethics of dentistry, and provision of support for members’ professional lives. The ADAVB is a peak professional body, which means we embark on the delivery of a range of services and projects to members and to the promotion of dental health and services, support for research into dentistry and oral disease, and engaging with the State Government, and in liaison with the ADA Inc., the Federal Government, to better address the delivery of dental care.

4.2

We collect information about members and others which enables us to communicate with them, introduce them to our organisation and inform them of the work we do.

4.3

We do not use the information in any way other than in the furtherance of our objects and purposes.

4.4

We might also use your information for the following purposes:

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4.4.1

For the immediate reason for which you have provided it to us (for example, to enable the ADAVB to process your request, payment, registration, subscription, access to or delivery of service, etc.);

4.4.2

To maintain contact with you about ADAVB’s work, to report to you about ADAVB’s work, or to encourage you to learn about what the ADAVB does;

4.4.3

Any other purpose directly related to our work and for which you have provided consent (where it is reasonably required by law);

4.4.5

To assess you for ADAVB and external honours and awards; and

4.4.5

To disclose your contact details to the types of organisations to whom we normally do including: 4.4.5.1 Mailing houses for delivery of ADAVB or other dentally related publications to you; 4.4.5.2 ADAVB Regional Group office bearers; 4.4.5.3 Entities engaged by ADAVB to undertake surveys or to collect practice or other data from you on our behalf; and 4.4.5.4 Approved organisations such as affiliated societies, sponsors or partners for the purpose of promoting products for which the ADAVB is directly affiliated.

4.6

We don’t rent, sell or exchange your information.

4.7

We take all reasonable steps to ensure that these organisations are in turn bound by confidentiality and privacy obligations when handling your personal information.

4.8

If you don’t want your personal information disclosed to another organisation, please inform the ADAVB at either the time we collect your information or any later time.

4.9

Sometimes we may be legally required to disclose your information, for example, to government departments. Such information would only be disclosed if legally obligated to do so.

4.10

We may also sometimes share non-personal, non-sensitive and de-identified information with research organisations, and/or with the ADA Inc.

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5. HOW WE COLLECT YOUR INFORMATION 5.1

The ADAVB may collect information from you either directly or from third parties.

Information we collect from third parties may be by formal or informal means.

5.2

Where we collect information from third parties and it is not personal information that is contained in a Commonwealth record, we will take reasonable steps to destroy or de-identify the information as required by law.

5.3

We collect personal information about supporters, donors, volunteers, employees, contractors and visitors to our events. We collect your information in the following ways: 5.3.1

Face to face contact;

5.3.2

Electronically including through our website and online surveys;

5.3.3

Via social media messages or conversation;

5.3.4

During phone calls;

5.3.5

Voice or image recordings;

5.3.6

Whilst delivering and administering services at our facilities; and

5.3.7

From forms, coupons and other correspondence (both in writing and electronically).

6. HOW WE USE YOUR INFORMATION 6.1

We only use your personal and sensitive information for the reason we collect it as set out above and for the purpose(s) for which it was collected, or as otherwise permitted by law.

6.2

We will not disclose the above information that we collect to affiliates without your consent.

7. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION 7.1

You can access your information by asking us or accessing your details through the ADAVB member site using your confidential log in and password.

Occasionally, we may need to refuse your request to access information, for example, where granting you access would infringe someone else’s privacy.

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7.2

When you request access, we will ask you to provide some form of identification so that we can ensure that you are the person to whom the information relates.

7.3

In some cases, we may also ask you to pay a reasonable fee to cover the cost of access.

7.4

If you have a question about this privacy policy or want to access your personal information you can contact the ADA membership team on 03 8825 4600 or alternatively send an email (to garry.pearson@adavb.org). We will aim to respond to you within 28 days of receiving your request. If we’re not able to help with your request, you will receive a written explanation as to why.

8. COMPLAINTS ABOUT A BREACH OF YOUR PRIVACY 8.1

If you are concerned about how we have collected or managed your personal information we request you follow the procedure set out below; 8.1.1

Contact the ADAVB Privacy Officer, who will be the Chief Executive Officer, reachable on 03 8825 4600 or garry.pearson@adavb.org;

8.1.2

Complete the Complaints Form which is available below;

8.1.3

Alternatively you may submit your Complaint Form to the CEO at garry.pearson@adavb.org or 03 8825 4600. In order to effectively address your complaint, we may request further information from you about your complaint and the reasons behind the submission;

8.1.4

After we receive all the information we need from you, allow us approximately 28 days to address your complaint.

8.2

If you’re not satisfied with how we have handled your complaint you can also contact the Office of the Australian Information Commissioner (OAIC) (on www.oaic.gov.au/).

8.3

The OAIC is a government body independent of us. It has the power to investigate complaints about possible interference with your privacy.

9. SECURING YOUR INFORMATION 9.1

At the ADA we take reasonable steps to ensure the security of personal and sensitive information we hold and to protect it against loss, misuse or unauthorised access, destruction, use, modification or disclosure. Our IT systems are password protected and comply with applicable security standards.

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9.2

Only authorised personnel are permitted to access these details. It is our policy to: 9.2.1

Permanently de-identify personal information where reasonable and possible; and

9.2.2

Destroy personal information once there is no longer a legal or business need for us to retain it.

10. ANONYMITY 10.1

It is your right to be dealt with anonymously, provided that is it lawful and practicable.

10.2

We will try to accommodate a request for anonymity wherever possible; however we note that in some circumstances, this may prevent us from practically and effectively communicating with you. If this is the case we will notify you.

11. COOKIES AND LINKS TO OTHER WEBSITES 11.1

Cookies 11.1.1 When you visit our website (www.adavb.net) a record of your visit is logged. The following data is supplied by your browser: 11.1.1.1

Your IP address and/or domain name;

11.1.1.2

Your operating platform);

11.1.1.3

The date, time and length of your visit to the website; and

11.1.1.4

The resources you accessed and the documents you downloaded.

system

(type

of

browser

and

11.1.2 This information is used to compile statistical information about the use of our website. It is not used for any other purpose. If you do not want ‘cookies’ to be used please adjust your browser settings to disable them.

11.2

Links to other websites

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11.2.1 Our website may contain links to third party websites, and third party websites may also have links to our website.

11.2.2 The ADAVB Privacy Policy does not apply to external links or other websites. The operators of other websites may collect your personal information.

11.2.3 We encourage you to read the privacy policies of any website you link to from our website.

Branch Policy Statement

1.17

Number Adopted by Council

23 April 2014

Reviewed by Constitution and Policy Committee Amended by Council Relevant Rules Relevant By-Laws See also

ADAVB Branch Policy Statement 1.17

Historical policy reference: 25/07, BPS 1.19 – Employee Disciplinary Policy, Staff Induction Notes

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BPS 1.17 Appendix 1 AUSTRALIAN DENTAL ASSOCIATION VICTORIAN BRANCH INC. (ADAVB) COMPLAINTS FORM INFORMATION FOR APPLICANTS • Complaints should only be lodged by a complainant in writing if you have been unable to resolve your issue or concern informally.

• You will receive acknowledgment of your lodged complaint within three (3) business days of the ADAVB having received your complaint/appeal.

• We may ask you for further information in relation to your complaint.

• The ADAVB will endeavour to revolve your complaint within a reasonable timeframe usually twenty eight (28) business days upon receipt of the written complaint and all further information in relation to it or as soon as practicable. However, in some cases, particularly if the matter is complex the resolution may take longer.

• Applicants may be asked to provide additional information to support their complaint.

• Please complete all fields on this form.

• Please submit this form to garry.pearson@adavb.org PART A - APPLICANT DETAILS Personal Details Title:

First Name:

Gender:

Male

Surname: Female

Date of Birth:___/___/______ Phone (Home):

Mobile Phone:

Home Address: Street: ADAVB Branch Policy Statement 1.17

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Suburb

Post Code

State Country Postal Address (if different from Home Address): Street Suburb

Post Code

State Country PART B - COMPLAINT DETAILS Please provide details of the nature of your involvement with ADAVB Inc. Please provide details of your complaint: (If necessary attach an extra page to outline the details. Any supporting documentation should also be provided - copies required only)

Does your complaint involve behaviour by a particular staff member of ADAVB? (Please circle Yes or No).

Yes

No

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If so please provide the name of the staff member involved and any information about the staff member’s involvement: Name of staff member: Nature of involvement:

Please provide details regarding how the complaint has affected you:

Please provide details in relation to how you became aware of the complaint:

Does your complaint require urgent attention?

Yes

No

Have you lodged a complaint about this issue before?

Yes

No

If yes, when

Have you reported your complaint to any other agency?

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Yes

No

If yes, to whom:

What is your expected outcome?

Please provide the contact number and time to contact you regarding the complaint:

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