Your privacy is important
This statement outlines the Australasian College of Nutritional and Environmental Medicine’s (ACNEM) policy on how ACNEM uses and manages personal information provided to or collected by it.
ACNEM is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act and is compliant with the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Information Privacy Principles contained in the New Zealand Privacy Act 1993.
What kind of personal information does ACNEM collect and how does ACNEM collect it?
The type of information ACNEM collects and holds includes (but is not limited to) personal information, including sensitive information, about members, prospective members, applicants for registration, suppliers, conference delegates, staff and other individuals who interact with ACNEM (such as by using ACNEM’s services or visiting the College’s website).
This information may include a person’s name, address, phone number, email address, bank account details, photograph and signature. The full details of personal information that ACNEM collects can be found in the questions that ACNEM asks and in the forms individuals complete when dealing with ACNEM, its agents and contractors.
Personal Information you provide
ACNEM will generally collect personal information held about an individual by way of phone calls, forms (including application forms, registration forms), meetings, etc. You do have the right to seek to deal with us anonymously or using a pseudonym, but in almost every circumstance it will not be practicable for us to deal with you or provide any services to you except for the most general responses to general enquiries, unless you identify yourself.
Personal Information provided by other people
In some circumstances ACNEM may be provided with personal information about an individual from a third party, for example.
In relation to employee records
How will ACNEM use the personal information you provide?
ACNEM will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which you have consented.
- to provide membership services and benefits and maintain membership and service/benefits records;
- to assist, support, provide and improve continuing professional development and education and training;
- to enable planning, policy and service development and to market, advertise or otherwise promote ACNEM, including to inform individuals of events, special offers or additional services provided by ACNEM;
- to monitor, deal with, report and investigate potential misconduct;
- to appropriately interact with government and regulatory bodies relating to the profession;
- to implement, monitor and maintain quality assurance processes and systems, as well as processes and systems concerning regulatory matters, registrations, accreditation, audits, risk and claims management (including dealings with insurers);
- to procure funding, donations or other support for the activities of ACNEM;
- to enable internal administration, training, assessments and reviews;
- to provide or undertake any of the other activities referred to in this Policy; and
- to conduct or facilitate research or surveys for purposes related to ACNEM and/or one or more of the above activities.
In relation to direct marketing, ACNEM will use your personal information for direct marketing where you have provided that information, and you are likely to expect direct marketing; only then you will be sent direct marketing containing an opt out. If we use your personal information obtained from elsewhere we will still send you direct marketing information where you have consented and which will also contain an opt out. We will always obtain your consent to use sensitive information as the basis for any of our direct marketing.
Job applicants, staff members and contractors:
In relation to personal information of job applicants, staff members and contractors, ACNEM’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be.
The purposes for which ACNEM uses personal information of job applicants, staff members and contractors include:
- for insurance purposes;
- for human resource purposes;
- consultants who provide services or undertakes activities in conjunction with or in association with ACNEM; and
- to satisfy ACNEM’s legal obligations.
Where ACNEM receives unsolicited job applications these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.
ACNEM also obtains personal information about volunteers who assist ACNEM in its functions or conduct associated activities, such as to enable ACNEM and the volunteers to work together generally and on specific projects and/or on committees or working parties.
Marketing and fundraising
ACNEM treats marketing and seeking donations for the future growth and development of ACNEM as an important area of business. Personal information held by ACNEM may be disclosed to an organisation that assists in ACNEM’s fundraising.
Who might ACNEM disclose personal information to?
ACNEM may disclose personal information, including sensitive information, held about an individual to:
- government departments;
- people providing services to ACNEM, and
- anyone you authorise ACNEM to disclose information to.
Information requests from members regarding other members
Requests for information from a member of ACNEM regarding another member will be handled by the Privacy Officer. Business details including business telephone numbers, practice details and/or email addresses will be provided. ACNEM will also confirm that a member is a member. Any other information will not be provided unless required by law and/or with the member’s permission.
Information requests from the public regarding members
Requests for information from a member of the public regarding an ACNEM member will be handled by the Privacy Officer. Business details including business telephone numbers, practice details and/or email addresses will be provided. Information is readily available from the ACNEM website under the ‘Find an ACNEM Practitioner’ page. ACNEM will also confirm that a member is a member. Any other information will not be provided unless required by law and/or with the member’s permission.
Sending information overseas:
ACNEM will not send personal information about an individual outside of Australia and New Zealand without:
- obtaining the consent of the individual (in some cases this consent will be implied); or
- otherwise complying with the Australian Privacy Principles and the New Zealand Privacy Principles or other applicable privacy legislation.
We do use overseas providers of IT services including cloud services.
How does ACNEM treat sensitive information?
In referring to ‘sensitive information’, ACNEM means:
information relating to a person’s racial ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record, that is also personal information; and health information about an individual.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.
Management and security of personal information
ACNEM’s staff are required to respect the confidentiality of personal information and the privacy of individuals.
ACNEM has in place steps to protect the personal information ACNEM holds from misuse, loss, unauthorised access, modification, interference or disclosure by use of various methods including locked storage of paper records and ‘password protected’ access rights to computerised records.
Updating personal information
ACNEM endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. A person may seek to update their personal information held by ACNEM by contacting the Privacy Officer of ACNEM at any time.
The Australian Privacy Principles require ACNEM not to store personal information longer than necessary.
You have the right to check what personal information ACNEM holds about you.
Under the Commonwealth Privacy Act and the Health Records Act, an individual has the right to obtain access to any personal information which ACNEM holds about them and to advise ACNEM of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation. To make a request to access any information ACNEM holds about you, please contact the Privacy Officer in writing.
ACNEM may require you to verify your identity and specify what information you require. Although no fee will be charged for accessing your personal information or making a correction, ACNEM may charge a fee to retrieve and copy any material. If the information sought is extensive, ACNEM will advise the likely cost in advance.
How long will ACNEM keep my information?
Under our record keeping and disposal policies, your personal information that is no longer required will be de-identified or destroyed. In many circumstances, however it will be kept for marketing purposes, as you will have consented to that in writing with us.
Enquiries and privacy complaints
If you would like further information about the way ACNEM manages the personal information it holds, please contact the Privacy Officer ([email protected]). If you have any concerns, complaints or you think there has been a breach of privacy, then also please contact the Privacy Officer who will first deal with you usually over the phone. If we then have not dealt satisfactorily with your concerns we will meet with you to discuss further. If you are not satisfied with our response to your complaint within 30 days from this meeting then you can refer your complaint to the Office of the Australian Information Commissioner via: email: [email protected]; tel: 1300 363 992; fax: +61 2 9284 9666 or to the Office of the Privacy Commissioner (NZ) – www.privacy.org.nz