What is the information we collect?
Palliative Care Australia Limited (ACN 625 082 493 ABN 85 363 187 904) (PCA, Us, We, Our) is the peak national body for palliative care. We represent all those who work towards high quality palliative care for all Australians. We work closely with consumers, State and Territory organisations that are members of PCA (PCA Member and Affiliate Organisations) and the palliative care workforce with the aim to improve access to, and promote the need for, palliative care.
- Personal information means any information or opinion about an individual who is reasonably identifiable and includes sensitive information (Personal Information).
- Sensitive information means Personal Information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or information about an individual’s physical, genetic or mental health (Sensitive Information).
What is the information we collect?
The type and amount of Personal Information We collect about individuals varies depending on the circumstances, and may be collected in various forms including verbally, or through written records, audio files, and images.
Personal Information We may collect includes: personal and business contact details, including email address, street address, and emergency contact; identification details such as name, date of birth, place of birth, gender, employment details, educational and professional qualifications and other demographic information, all if provided; transactional information such as service requirements, service satisfaction feedback, information requirements, Australian Business Number; and financial information such as bank account details, and credit card number.
Sensitive Information We may collect includes: prognosis and diagnosis, information relevant to care requirements, service and clinical practice information, health assessment feedback, accessibility and dietary requirements, end of life care preferences, and other relevant health information, indigenous status (if provided).
Where practical, Sensitive Information about individuals collected in relation to Our research and studies is de-identified. We will not use or disclose any Sensitive Information other than with your consent.
Why do we need to collect your Personal Information?
PCA primarily collects, uses and discloses Personal Information to inform and enable the services We provide and to enable Us to carry out Our business functions and activities, including –
- facilitating events
- administering programs and services
- administering your interactions and transactions with Us, including donations made to PCA
- enabling third parties to provide services on Our behalf
- providing information and educational resources to you
- maintaining and providing you access to Our website and Mobile Apps
- assisting you with enquiries
- promoting better practice and to facilitate quality improvement of processes
- enabling communication in the form of newsletters, marketing, media releases, event updates and invitations
- collaboration with responsible organisations and PCA Member Organisations, including to provide services
- conducting research and studies
- data processing and analysis
- complying with regulatory, governance, and funding reporting requirements
- contacting next of kin and emergency contacts
- communicating stories of individuals who have or are receiving palliative care, including on Our website
We collect Personal Information reasonably necessary for one or more of our functions or activities. This Personal Information may include sensitive information, and in some instances may include health information. You may decide to provide your Personal Information to PCA for a range of different reasons. By way of example you may wish to:
(a) participate in a research project;
(b) donate money to PCA;
(c) fundraise for PCA;
(d) collaborate with PCA;
(e) attend an event run by PCA;
(g) use a PCA service or product;
(h) receive communications from PCA;
(i) apply for employment at, or volunteer for, PCA;
(j) provide services to PCA; or
(k) connect with us via social media.
While it is possible for you to interact with us under a pseudonym or anonymously in some cases, in certain scenarios it may be necessary for us to collect certain Personal Information from you.
We will only collect the Personal Information than we reasonably require to respond to your request.
How do we collect your Personal Information?
We may collect Personal Information from you in person, in writing, by telephone, through our website, mobile applications and by other electronic communication channels. We may also collect this Personal Information through our staff and other service providers. Wherever practicable, we will collect Personal Information from you directly.
We also collect Personal Information through events and activities that we hold or are involved in, such as seminars, workshops, promotional events, fundraising and other activities.
The kinds of Personal Information we collect will depend on the purposes for which you interact with PCA. The Personal Information we may collect from you may include:
- your full name and prefix (e.g. Mr or Mrs)
- your address
- your phone number
- your email address, so that we can authenticate you electronically and administer your account
- your date of birth
- your gender
- your social network contact and publicly available details
- your employer
- your country or state of residence
- your end-of-life care preferences
- your credit card details and other information which will allow us to process your transaction
- other demographic information
We may also collect Personal Information indirectly such as through–
- mail and electronic correspondence, quotations, invoices received
- your authorised representative, attorney, or guardian, providing it to Us
- internet and publicly available databases
- internet surveys
- PCA Member and Affiliate Organisations
- Our service providers
- government agencies and organisations
If PCA receives unsolicited Personal Information, such as unrequested job applications, it will be handled in accordance with the Act. We may keep records of unsolicited Personal Information if permitted by the Act.
While it is possible for you to interact with Us under a pseudonym or anonymously in some cases, it may be necessary for Us to collect Personal Information in order to respond to your enquiry or provide services. We may not be able to deal with you in some situations unless you provide Us with the Personal Information we reasonably require.
We will only collect Personal Information we reasonably require in connection with the functions and activities or to otherwise deal with you.
How do we store the information we collect?
PCA is committed to protecting Personal Information it collects. We will take all reasonable steps to protect the Personal Information We hold from misuse, interference, and loss, and from unauthorised access, modification or disclosure.
When using electronic systems for storage your Personal Information will be secured by a password accessible by authorised officers that require access to undertake their official functions and roles. Sensitive Information will have restricted access placed on it and will be managed under strict governance requirements which will vary depending on the nature of the Sensitive Information and the electronic system concerned.
Our internally operated electronic databases and network are secured by a firewall and anti-virus software to ensure, so far as practicable, that it is not accessed by unauthorised parties.
Your Personal Information may be stored in hard copy or electronic format in secure facilities that We own and operate, that are owned and operated by Our service providers, or in locations authorised for temporary backup storage This includes but is not limited to the following cloud based applications –
- Doodle Poll
- Google Classrooms
- Survey Monkey
- Events Air
- Hesta Superannuation Portal
- RACV portal ( authorised staff have access to staff salary sacrifice information)
(together Our Cloud Services)
Our website and Mobile Apps have security measures designed to protect against loss, misuse, or alteration to your Personal Information which is under Our control.
How and when do we disclose your Personal Information?
Where necessary, we will disclose your Personal Information to our third party suppliers, partners, collaborators, contractors or others in order to facilitate the Operational Purposes.
Either PCA or our partners may disclose your Personal Information where it is reasonable to do so or where we are authorised or required to do so by applicable law.
PCA may disclose Personal Information to trusted third parties engaged to assist us with services including data processing, data analysis, information technology services and support, fundraising, event management, mobile application, website maintenance/development, printing, record archiving, data mailing and market research.
When research at PCA is approved by an external Human Research Ethics Committee. This research is undertaken in accordance with the terms and conditions specified by the relevant Human Research Ethics Committee, and the principles specified in the National Health and Medical Research Council and the Australian Research Council’s Australian Code for the Responsible Conduct of Research 2007 (the Australian Code). Research participants enrolled in trials or research will be given further information detailing how their Personal Information (including health information) will be handled by PCA, including circumstances where Personal Information may be disclosed.
Overseas disclosure of Personal Information
PCA does not directly share Personal Information with overseas organisations.
Personal Information may be indirectly disclosed overseas by Our use of Our Cloud Services from time to time, the location of which is not reasonably available due to the nature of cloud storage. However, this indirect disclosure is primarily related to storage and transmission of the information.
We take reasonable steps to prevent the Personal Information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure. Our security measures meet industry standards and you can feel confident in our processes. These may include access control procedures, network firewalls, encryption and physical security. Although we will endeavour to protect your Personal Information, we are unable to guarantee that any information you transmit to us over the internet is 100% secure.
Links to other websites
Our website contains links or references to other websites or organisations. We are not responsible for the privacy practices or content of the linked websites and other pages hosted by Us.
Links to third party websites are provided for information, and do not indicate Our endorsement of that business or any assurances about the content on that site. Third party websites may have their own privacy and security policies, which We encourage you to read before supplying any Personal Information to them.
Our interaction with you via the internet and social media
We may display advertisements on our websites and mobile applications. We may add cookies to users’ browsers and use web beacons and measurement software and tools on our websites to enable us to serve ads based on prior visits to the website. Cookies are small files that a website can store on a user’s computer and are used for keeping the ‘state of a user session’ i.e. remembering who you are from a page requesting information through to supplying it.
If you prefer not to have cookies collected, you can disable this option in your browser settings. However, in doing so, you may be unable to access certain pages or content on our website.
When you access our websites and mobile applications, our Internet Service Provider may make a record of your visit and logs the following information for statistical purposes only – the user’s server address, the user’s top level domain name (for example .com, .gov, .au, etc), the date and time of the visit to the site, the pages accessed and documents downloaded, the previous site visited, and the type of browser used.
How can information be accessed and corrected?
You have a right to request access to, or correction of, your Personal Information. However, We will request that you verify your identity prior to considering any such request.
You may request access to the Personal Information We hold about you by contacting Us. We will respond to your request within a reasonable time and provide you with access to the Personal Information We hold about you unless otherwise permitted or required by law. If We deny you access to the Personal Information, We will notify you of the basis for the denial unless an exception applies.
Where reasonable and practicable, We will provide access to the Personal Information We hold about you in the manner you request. PCA at its sole discretion may charge a reasonable fee for granting access to Personal Information We hold about you or your organisation.
If you believe that Personal Information We hold about you is incorrect, incomplete or not current, you may request that We update or correct your Personal Information by contacting Us. We will deal with your request within a reasonable time. If We do not agree with the corrections you have requested (for example, because We consider that the Personal Information is already accurate, up to date, complete, relevant and not misleading), We are not required to make the corrections.
However, where We refuse to do so, We will give you a written notice setting out the reasons. You may request that We make a record of your claim and associate that record with the Personal Information in dispute.
You can contact us through the following channels:
A: Privacy Officer, Palliative Care Australia, PO Box 124 Fyshwick, ACT 2609, Australia
T: +61 2 6232 0708
If you are not happy with the response to your request to access or correct your Personal Information, you may be able to complain to the Office of the Information Commissioner online via www.oaic.gov.au or by calling 1300 363 992.
How long will we keep your Personal Information?
We retain Personal Information after we have used the Personal Information for the purposes for which we collected or received it. The duration that we keep your Personal Information for will be influenced by the nature of that information, and any applicable regulatory requirements. For instance, the minimum recommended period for retention of research data is five years from the date of publication. However, in any particular case, the period for which research data should be retained is determined by the specific type of research. The Australian Code requires for most trials, retaining research data for 15 years or more may be necessary. Financial transaction records are kept for a minimum period of seven years.
For all types of Personal Information, when no longer required or permitted to be retained by law, PCA will use its best endeavours to ensure that all such information will be deleted or destroyed in a secure manner and in a reasonable timeframe.
How to contact us or make a complaint
If you would like to contact us, including to ask a question, request removal from our communications or make a complaint, we may be reached at the details below:
A: Privacy Officer, Palliative Care Australia Limited, PO Box 124 Fyshwick, ACT 2609, Australia
T: +61 2 6232 0700
If you are unhappy with our response to your complaint, you have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to contact the OAIC are provided on its website at www.oaic.gov.au.
You can find more information about privacy and the protection of your Personal Information on the website of the OAIC at www.oaic.gov.au.
PCA’s Disclaimer can be found here.