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Ear Science Institute Australia - Privacy Policy, June 2015

The Ear Science Institute Australia (ESIA), including the Ear Science Clinic, Lions Hearing Clinic and The Avant Education Centre, is committed to protecting the privacy of its clients, referrers, donors, partners, suppliers, volunteers, staff and other stakeholders.

This privacy policy has been compiled in the interests of openness and transparency and explains how we manage the personal information of all our stakeholders in accordance with our obligations under the Commonwealth Privacy Act 1988 (amended 2012) and the Australian Privacy Principles (APPs). 

ESIA’s staff will take reasonable steps to ensure you understand:

  • What information has been and 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.
  • ESIA’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 ESIA using the details at the end of the policy. ESIA will take all reasonable steps to provide the document in the format you require.

What personal information do we collect and why?

We collect the 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.  

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.

Lions Hearing Clinic, Ear Science Clinic patients:

In order to provide effective audiological services we may ask you for:

  • your medical history including, where relevant, a family medical history;
  • your Medicare number and information about your privacy health insurance;
  • payment information such as your credit card details;
  • current medications or treatments used by you;
  • the name of any care provider, health service provider or medical specialist whom we refer you back to or has referred you to us, copies of any referrals and reports;
  • test results and samples.

Research Participants:

If you participate in the research and clinical trial activities that ESIA conducts, we collect personal information to record your involvement, to process the results of the research and clinical trial, and to contact you regarding participation in future studies.  The information we collect from you will generally be sensitive information because it will be your health information. We may request other sensitive information such as your racial or ethnic origin. 

We may collect your personal information including:

  • your medical history including, where relevant, a family medical history;
  • your Medicare number and information about your privacy health insurance;
  • payment information such as your credit card details;
  • current medications or treatments used by you;
  • the name of any care provider, health service provider or medical specialist whom we refer you back to or has referred you to us, copies of any referrals and reports;
  • test results and samples.

Information may also be collected about individuals who are not research participants when ESIA makes a record about a research participant.  For example, when collecting emergency contact details or a family medical history.

From time to time we may collate and analyse statistical data from information we have previously collected.  In these cases, the data will be de-identified and aggregated before it is disclosed to third parties.

All research and clinical trials undertaken at ESIA are approved by an external Human Research Ethics Committee.  Research participants enrolled in trials or research will be given further information detailing how their personal information (including health information) will be handled by ESIA.

GPs, ENTS and other referring specialists:

ESIA may collect personal information about individual health practitioners who interact with ESIA’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 ESIA, including your participation in events convened by ESIA.  This information is collected for the purpose of administration, management and operation of ESIA’s services.

The Avant Education Centre students and program participants:

When you register for a training course or educational program at The Avant Education Centre will request information to confirm your suitability for the course or program which may include your professional position and qualifications.  

ESIA 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.

Donors and supporters:

When you make a donation, 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 ESIA.  You may choose what you receive at any time.  If you do not wish us to use your personal information for any of the above purposes please contact us using the details at the end of this privacy policy.

Partners and suppliers:

ESIA 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 ESIA.

Job applicants:

ESIA may collect personal information when we are recruiting staff, PhD and Honours 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.  We will collect personal information about you from third parties, such as your referees, as part of our assessment of your suitability for a position. 

This Privacy Policy does not apply to employee records held by ESIA relating to an employee or former employee of ESIA.

Your right to anonymity

You have the option of not identifying yourself, or of using a pseudonym, when dealing with ESIA in relation to matters where it does not prevent ESIA from conducting its functions and activities to a standard set by the organisation.

This does not apply when:

ESIA is required by law to deal with individuals who have identified themselves
It is impractical for ESIA to deal with individuals who have used a pseudonym.

Collection of information

The type of information that we collect from you will depend on the circumstances of collection and on the type of interaction you have with us.  In most cases we collect your personal information directly from you when you have contact with us in person, over the phone, via email or over the internet.

ESIA’s typical procedures for collecting your personal information are:

Staff collects your personal and demographic information via registration when you present at ESIA for the first time. Clients of Ear Science Clinic and Lions Hearing Clinic are encouraged to pay attention to the collection statement attached to/within the form and information about the management of collected information and client privacy.

During the course of providing medical services, ESIA’s healthcare practitioners will collect further personal information from you, or with your permission from your GP or other medical practitioner.

Personal information may also be collected from your guardian or responsible person (where practicable and necessary).

Integrity of Information

ESIA undertakes to ensure that the information requested and collected is accurate, up to date and complete.  We undertake reasonable steps to ensure that the information we use in the course of our functions and activities is accurate, up to date, complete and relevant.  We will contact you to verify the information in order to uphold this obligation.

Storage of information

Your personal information may be held at ESIA in various forms:

  • As paper records
  • As electronic records
  • As photos, scans or digital images

ESIA holds all personal information securely, whether in printed or electronic format, in protected information systems or in hard copy format in a secured environment. Information contained in an electronic database is password protected, which may be an ESIA database, a database maintained by a cloud hosting service provider or other third party database storage or server provider.

Where personal information is stored with a third party, we have arrangements which require them to maintain the security of the information. We take reasonable steps to protect the privacy and security of that information, but we are not liable for any unauthorised access or use of that information.

Your personal information will stay on the database indefinitely until you advise you would like it removed, unless we de-identify it or destroy it earlier in accordance with relevant regulatory requirements.  Due to the complexity of ESIA’s operations, your personal information may be stored simultaneously in more than one database or location.

Use and disclosure of information

Personal information will only be used for the purpose of carrying out the functions and activities of ESIA, unless otherwise consented to.  

Some disclosure may occur to third parties engaged by or for us for business purposes, such as accreditation, direct marketing or for the provision of information technology. These third parties are required to comply with this policy.

We will inform you where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).

We will not disclose your personal information to any other third party without providing you with the reason for the information transfer, full disclosure to you, and receipt of full consent from you. ESIA will not disclose personal information to anyone outside Australia without need and without your consent.

Exceptions to disclose without your consent are where the information is:

  • A court order to produce your personal health information
  • Where we are required to by law
  • Necessary to lessen or prevent a serious threat to a client’s life, health or safety or public health or safety
  • It is impractical to obtain the clients consent
  • Statutory medical notifications

ESIA will not use any personal information in relation to direct marketing to you without your express consent. You may opt-out of direct marketing at any time by notifying ESIA by phone, in a letter or email.

Access and corrections to information

You are entitled to request access to all personal information including your medical record by contacting ESIA. Contact details are provided at the end of this policy.

ESIA asks that where possible the request be in writing. ESIA may impose a charge for photocopying or for staff time or other associated costs incurred in the processing of the request.  We will inform you of any likely costs.

Access to your personal information may be declined in special circumstances such as where giving access would be unlawful. You will be notified in writing where we are not able to provide the requested information.

Access can be denied where:

  • Providing access would create a serious threat to life or health
  • There is a legal impediment to access
  • The access would unreasonably impact the privacy of another person
  • The request is frivolous
  • The information relates to anticipated or actual legal proceedings and you would not be entitled to access the information in those proceedings; and
  • In the interests of national security

Any refusal to give access will be notified in writing with the stated reason for the refusal and the mechanisms available to complain about the refusal.

It is the policy of ESIA that where you dispute the accuracy of the information recorded, you are entitled to correct that information and ESIA, where deemed necessary, will take all steps necessary to record all of the corrections and place them on file.  ESIA reserves the right to keep the original record.

Where the information that is corrected has been disclosed to a third party, ESIA will disclose the corrected information to that third party unless it is impractical or unlawful to do so.

We will take reasonable steps to correct personal information where it is satisfied it is not accurate or up to date. From time to time, we will ask you to verify your personal information to ensure it is correct and up to date.  If you believe that the information we hold about you is inaccurate or incomplete please let us know and we will investigate.

Any refusal to correct the personal information as requested by an individual will be notified in writing with the stated reason for the refusal and the mechanisms available to complain about the refusal.  ESIA will hold a statement of the individual’s claim of inaccuracy and link it to the statement so that it is apparent to users of the information.

Website usage information

When you access our website, we may use software embedded in our website (such as Javascript) and we may place small data files (or cookies) on our computer or other device to collect information about which pages you use and how you reach them, what you do when you visit a page, the length of time you remain on the page and how we perform in providing content to you. Our website may use Google Analytics features, which tracks your internet usage and discloses this to other members of the Google Ad network.

A cookie does not identify individuals personally, but it does identify computers. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. You can also opt of Google Analytics by clicking on Ad Settings.

We may gather IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.

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 web site to our site does not require permission. If you have a link you’d like us to consider adding to our web site, please send an email to enquiries@earscience.org.au 

Sending us an email

You also may decide to send us personal information, for example, in an electronic mail message containing a question or comment, or by filling out an online form that provides us this information. We use personally identifying information from emails primarily to respond to your requests. We may forward your email to other employees who are better able to answer your questions. We may also use your email to contact you in the future about our programs that may be of interest.

We will not obtain personal information about you when you visit our web site, unless you choose to provide such information to us. Providing such information is strictly voluntary. Except as might be required by law, we do not share any information we receive with any outside parties.

Complaints

We take complaints and concerns about the privacy of your personal information very seriously.  If you have a complaint you should contact ESIA with details of your complaint. All complaints will be handled fairly and as quickly as possible in accordance with our complaints resolution procedure.

Amendments to this privacy policy

We reserve the right to amend this privacy policy at any time. If we decide to amend this policy, we will take all reasonable steps to ensure that this website is updated as soon as practicable. Please check this website periodically to ensure that you have our most up to date privacy policy.

Contact

If you have any questions about privacy related matters please contact ESIA on:

Tel: (08) 6380 4900

E-mail: enquiries@earscience.org.au

Postal address:   Ear Science Institute Australia, Suite 1, Level 2, 1 Salvado Road, Subiaco, WA 6008