The Ear Science Institute Australia (Ear Science), including the Ear Science Implant Clinic, Lions Hearing Clinic and John and Debbie Schaffer Surgical Training Lab, is committed to protecting the privacy of its clients, referrers, donors, partners, suppliers, volunteers, staff and other stakeholders.
Ear Science’s staff will take reasonable steps to ensure you understand:
- The type of information that is being collected;
- Why the information is being collected, and whether this is a legal requirement;
- How the information is used or disclosed;
- Why and when your consent is necessary;
- Ear Science’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.
If you would like a copy of this policy please contact Ear Science using the details at the end of the policy. Ear Science will take all reasonable steps to provide the document in the format you require.
1 What personal information do we collect and why?
We collect personal information that is reasonably necessary so that we may carry out one or more of our functions or activities. The types of personal information we generally collect includes your name, date of birth, address and other contact details such as your telephone numbers and email address. Depending upon the purpose of our interaction with you, we may collect additional personal information including health information.
We may request further information from time to time (e.g. through market research) to enable us to improve our services and consider the wider needs of our customers and potential customers, and to enquire about your participation in clinical research projects.
1.1 Lions Hearing Clinic and Ear Science Implant Clinic clients
1.1.1 Audiological services
We collect certain personal information from you in order to provide you with audiological services and products. This may include:
- your details (including your name, address, date of birth, telephone number, email address and next-of-kin contact details);
- medical history (including current and past medications, treatments, test results and family medical history);
- health information (including genetic information, information about a device you are using, ear impressions, name of your other healthcare providers); and
- billing and account details (including Medicare details, pension card details and private health fund details).
We collect your personal information in order to provide quality health services and products to you at our facility or to facilitate the ordering of devices for surgery at another facility. We also use the information for management of our services, including appointment bookings and recalls, billing, funding eligibility checks, audits, staff training, accreditation, feedback/complaints handling, measuring outcomes, and service planning. We use de-identified information wherever practicable
1.1.2 Data analytics and research
Ear Science is involved in a range of activities to better understand hearing and treatments for hearing loss. These activities include data analytics and other research projects that use information collected during the provision of routine audiological services and research that requires the collection of new information (e.g. additional tests, surveys, or interviews).
We may invite you, as an Ear Science Implant Clinic or Lions Hearing Clinic client, to participate in research involving collecting additional information. We will do so by email, letter and/or phone. The invitation will provide details of the study, including the expected level of involvement. You may decline to participate; this will not affect any care we provide for you. If you decide to participate, the researcher will be provided with your name and contact information in order to formally recruit you into the study.
In some cases, researchers may obtain approval from Ear Science to access information collected during routine audiological services. This activity does not require your active involvement. Reasonable steps will be taken to de-identify information used or disclosed for these purposes.
All research undertaken at Ear Science or using Ear Science collected information is approved by an external Human Research Ethics Committee.
1.2 GPs, ENTS and other referring specialists
Ear Science may collect personal information about individual health practitioners who interact with Ear Science’s clinical services such as referring doctors or other health professionals involved in the care of our clients. This is typically information such as your name, contact details, professional details and information regarding interactions with Ear Science, including your participation in events convened by Ear Science. This information is collected for the purpose of administration, management and operation of Ear Science’s services.
1.3 John and Debbie Schaffer Surgical Training Lab students and program participants
When you register for a training course or educational program at John and Debbie Schaffer Surgical Training Lab, Ear Science will request information to confirm your suitability for the course or program, which may include your professional position and qualifications.
Ear Science may use the information it collects about you to inform you of future programs in which you may be interested. We may also store, collate and analyse the information in a de-identified format for the purpose of planning and management of future Avant Education Centre operations.
1.4 Donors and supporters
When you donate, register for an event or make inquiries about our activities, we may collect your personal information including your areas of interest and event attendance, your donation history and payment information, including your credit card details.
We collect this information to send you receipts as well as surveys, newsletters and information about research, education and fundraising events and activities. We may use your information to contact you to seek financial support for medical research conducted at Ear Science. You may opt out of receiving this information from Ear Science.
1.5 Partners and suppliers
Ear Science may collect personal information about individuals with whom we deal on a commercial basis, such as sponsors, suppliers, contractors and individuals in organisations to whom we provide goods and services or from whom we receive or acquire goods and services. We may collect personal information about you, including your name, position, contact details, licence or registration numbers, ABN, bank details and other information relevant to the capacity in which you are dealing with Ear Science.
1.6 Job applicants
Ear Science may collect personal information when we are recruiting staff and students. Generally speaking, we will collect personal information that you supply to us as part of this process of assessing applications and proposals. The personal information collected about you will include your educational/academic history and work history.
2 Your right to anonymity
You have the option of not identifying yourself, or of using a pseudonym, when dealing with Ear Science in relation to matters where it does not prevent Ear Science from conducting its functions and activities to a standard set by the organisation.
This does not apply when:
- Ear Science is required by law to deal with individuals who have identified themselves;
- Government funding requires personal information for processing payments;
- It is impractical for Ear Science to deal with individuals who have used a pseudonym.
3 How do we collect information?
Your personal information will normally be collected directly from you when you complete forms, questionnaires and surveys, when observations are taken, when you report information to our staff about your health and in some cases by way of ear impressions and photographs taken of you for a clinical purpose. There may be occasions where we will need to obtain information from others, including from:
- your family;
- your guardian or responsible person (where practicable and necessary);
- third-party health care providers (including your current or former doctors, physiotherapists, occupational therapists, psychologists, dentists, diagnostic imaging and pathology companies and other hospital and day surgery units);
- device manufacturers if you receive a device as part of your care e.g. Cochlear;
- Medicare, DVA and/or your health insurer;
- your My Health Record.
If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including:
- government departments, to verify your entitlement to work in Australia;
- police agencies to obtain your criminal history record;
- academic institutions;
- your current or previous employers; or
- your referees.
4 Security and storage
We store your personal information in various forms, including hard copy and electronically. We take all reasonable and appropriate steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored. Due to the complexity of Ear Science’s operations, your personal information may be stored simultaneously in more than one database or location.
5 Use and disclosure of information
Personal information will only be used and disclosed for the purpose of carrying out the functions and activities of Ear Science unless otherwise consented to or authorised by law.
We may disclose your personal information:
- to third-party health service providers involved in your care (e.g. referring health service providers, your doctor, other medical professionals, hospitals, relevant clinical registries, pharmacy services, diagnostic imaging and pathology companies);
- to our staff involved in providing you care or administrative support;
- to the relevant Government Department to check your funding eligibility and obtain Hearing Services Program Voucher;
- to private health insurers, Medicare, Hearing Services Program, NDIS or other Government Departments to process claims or payments made about your treatment including for device replacement and parts; and as part of the relevant funding body auditing, compliance and accreditation procedures;
- to the manufacturer of your device(s) (e.g. Cochlear) to purchase the device; to improve the accuracy of registration information held by the manufacturer about recipients of their device; to facilitate device adjustments, repairs and upgrades; for device warranty monitoring; to enable the manufacturer to identify recipients who may be interested in receiving information about products or promotions; to support the prompt payment of claims for reimbursement including private health insurance claims (note that the manufacturer may also liaise with the hospital where you have your procedure and your private health insurer);
- to your next-of-kin nominated on your admission paperwork (e.g. if we need a decision to be made about your care and you do not have capacity to make the decision for yourself, or to let your contact person know when you are ready to be collected to go home);
- to My Health Record, unless you direct us not to;
- to courts or Government Departments where we are legally required to do so (e.g. subpoenas, mandatory reporting of child abuse or other matters, notification of certain communicable diseases);
- to medical defence organisations or insurers to meet our obligations;
- to our suppliers (including service and content providers engaged by or for business purposes such as accreditation or the provision of IT services), contractors, service providers, professional advisors, dealers and agents;
- when it is necessary to lessen or prevent a serious threat to a person’s life, health or safety of public health or safety, or it is impractical to obtain your consent; or
- where you have consented.
Ear Science will not disclose personal information to anyone outside of Australia without your consent.
6 Direct marketing
If you provide your consent, we may use your personal information to identify a product or service that you may be interested in and to let you know about that product or service. You may opt out of direct marketing at any time by notifying Ear Science by unsubscribing from the mailing list using the link embedded in the direct marketing communication, or otherwise advising us via phone, in a letter or email via the contact details listed below.
7 Access to and correction of information
You are entitled to request access to, or correction of, the personal information we hold about you by contacting us using the details provided at the end of this policy.
Ear Science asks that where possible the request be in writing. We will need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, we will provide you with access to the personal information you request within a reasonable time and usually within 30 days. We may impose a charge for photocopying or for staff time or other associated costs incurred in processing the request. We will inform you of any likely costs prior to incurring them.
Access to and correction of your personal information may be declined in special circumstances. You will be notified in writing where we are not able to provide the requested information.
Any refusal to correct the personal information as requested by you, will be notified to you in writing with the stated reason for the refusal and the mechanisms available to complain about the refusal. You may also ask us to hold a statement of the claim of inaccuracy and link it to the statement so that it is apparent to users of the information.
Access can be denied where;
- To provide access would create a serious threat to life or health
- There is a legal impediment to access
- The access would unreasonably impact on the privacy of another
- Your request is frivolous
- The information relates to anticipated or actual legal proceeding and you would not be entitled to access the information in those proceedings.
8 Collection of information via our website
A cookie does not identify individuals personally, but it does identify computers. Our web pages may contain electronic images, known as web beacons. These electronic images enable us to count users who have visited certain pages on our website. Web beacons are not used by us to access your personal information, they are simply a tool we use to analyse which web pages are viewed, in an aggregate number.
9 Links to other websites
Throughout our web pages, we provide links to other servers which may contain information of interest to our readers. We take no responsibility for and exercise no control over the views or accuracy of the information contained on other servers. Creating a text link from your website to our site does not require permission. If you have a link you’d like us to consider adding to our website, please send an email to firstname.lastname@example.org
10 Feedback and Complaints
We take complaints and concerns about the privacy of your personal information very seriously. If you have a complaint, please contact our Privacy Officer using the contact details provided at the end of this policy with details of your complaint.
We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.
Phone: (08) 6380 4900
Postal address: Ear Science Institute Australia, Suite 1, Level 2, 1 Salvado Road, Subiaco, WA 6008