National Rural Health Alliance Privacy Policy

1. Introduction

1.1 The National Rural Health Alliance Ltd (ACN 620 779 606 / ABN 68 480 848 412) (the Alliance, We, Us, Our) collects, stores, discloses and uses a range of personal information.  The Alliance’s key purposes, include:

(a) determining the key issues affecting health of the people in rural and remote areas;
(b) providing related support and advice to governments, the public, educational and research institutions and other bodies; and
(c) promoting good health and wellbeing in rural and remote Australia.

1.2 We collect a range of personal information from members and non-members directly to enable Us to manage membership needs, administer grants and scholarship programs, conduct events and provide information about rural and remote health and other related products and services in order to promote the health interests of the 7 million people of rural and remote Australia, according to the objects of our Constitution.

1.3 We collect, hold, use and disclose personal information for the purpose of carrying out Our functions and activities, in accordance with the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (APPs), which are contained in Schedule 1 of the Act.

 

General Principles

1.4 The Alliance will:

(a) collect only information which is directly relevant and necessary to enable Us to carry out Our key organisational functions and responsibilities;
(b) ensure that people are informed as to why We are collecting their personal information and how We administer the information gathered;
(c) use and disclose personal information only for the functions and activities of the Alliance for which the information was provided, or for a directly related purpose;
(d) obtain consent from the individual concerned before disclosing personal information for a reason other than the one for which it was collected;
(e) provide individuals, on request, with access to the personal information that is held about them, and respect their right to seek its correction;
(f) where practicable, provide the option for an individual to withhold their name or use a pseudonym when dealing with the Alliance;
(g) store personal information securely, protecting it from unauthorised access, modification or disclosure and against misuse and loss; and
(h) review personal information regularly to ensure that it is accurate and up-to-date and confidentially destroy information that is no longer required.

 

2.Collection of information

2.1 Personal information means any information or opinion about an individual who is reasonably identifiable.

2.2 The personal information We collect may include your:

(a) name;
(b) date of birth;
(c) country of residence;
(d) proof of identity;
(e) job title;
(f) organisation/employer;
(g) email address;
(h) postal address;
(i) phone numbers;
(j) web address;
(k) photograph;
(l) biography; and
(m) credit card details.

2.3 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, biometric information, or physical or mental health. Where We collect sensitive information, it is collected in accordance with the Act.

 

3. How is personal information collected?

3.1 The main way We collect personal information about you is when you give it to Us, including by:

(a) providing Us with the information through an online or paper based form;
(b) registering for one of Our events;
(c) join/renew your membership of Friends of the Alliance;
(d) make a donation to the Alliance;
(e) sign up to Our email list;
(f) sign up for Our marketing communications; or
(g) request Us to add you to Our database.

3.2 Personal information is also collected through Our website, mobile applications and by other electronic channels. 

3.3 You acknowledge and accept that for Us to perform Our activities and functions, your personal information must be provided and must be correct and up to date.

3.4 Personal information may also be collected where We are required or permitted to do so by law.

3.5 If we receive unsolicited personal information about you, it will be handled in accordance with the Act.

 

4.Disclosure and use of personal information

4.1 The Alliance recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – i.e. protected on one hand, and made accessible to them on the other. These privacy values are reflected in and supported by Our core values and philosophies.

4.2 As a guiding principle, We do not disclose personal information unless you agree or would expect Us to. You have a right to ask for access to the personal information We hold about you and ask Us to correct any incomplete or incorrect information.

4.3 We will make you aware at the time of collection of your personal information, how We intend to use and disclose that personal information and may also use and disclose your personal information to enable Us to perform and undertake Our activities and functions.

4.4 We will only use personal information in accordance with the purpose for which it was collected. We may also use personal information where:

(a) Consent:  when you have subscribed to receive information from Us;
(b) Performance of a contract:  (or in order to take steps prior to entering into a contract) e.g. for processing payments, registrations or memberships; or
(c) Compliance with law: In some cases, We may have a legal obligation to use or obtain your personal  information.

4.5 We may also make secondary use or disclosure of your personal information, in addition to Our activities and functions, where:

(a) you would reasonably expect Us to for a related purpose;
(b) it is authorised or required by the Act, or any other Australian law or court/tribunal order; or
(c) you have consented to Our use and disclosure of your personal information.

4.6 We do not sell your personal information to third parties, but it may be disclosed to third parties from time to time in relation to Our activities and functions.

4.7 We will not disclose any sensitive information about you, unless you have provided express consent for Us to do so, or We are required or authorised by law.

To whom We disclose your personal information

4.8 The Alliance does not share personal information with third parties except when required to when managing events and/or programs. For example with Our ecommerce provider for processing credit card payments, providing venues with dietary requests, and with travel agencies for travel and accommodation bookings.

4.9 Any organisations which access your information in the course of providing services on Our behalf will be governed by strict contractual restrictions to make sure they adhere to all data privacy laws that apply. The Alliance will independently audit these service providers to make sure they meet our standards.

4.10 We will not share your personal information with anyone else for their own marketing purposes unless We have your permission to do so.

Overseas

4.11 We may disclose personal information to overseas parties using secured cloud services from time to time, the location of which is not reasonably available.

4.12 If We disclose personal information overseas, We will take reasonable steps to ensure that any overseas recipient does not breach the Act and the APP.

4.13 Clause 4.11 does not apply where:

(a) We inform you that if you consent to the disclosure of personal information to overseas parties that clause 4.11 does not apply; and
(b) you consent to the disclosure.

Unsubscribing and opting out

4.14 If you do not wish to receive communications from the Alliance, you may request to cancel such communication by:

(a) unsubscribing to an email newsletter at any time; or
(b) contacting the Alliance at any time via telephone, mail or email using the contact details at clause 12.1.

 

5. Anonymity and Pseudonymity

5.1 You may have the option of not identifying yourself or using a pseudonym when dealing with the Alliance, however, on some occasions it will be impracticable to do this and it may prevent Us from carrying out Our functions and activities. There may also be instances where we are required or authorised by or under the Act, or by a court/tribunal order to deal with individuals who have identified themselves. You will be notified if this is the case.

5.2 You acknowledge and accept that in most instances, We cannot practically provide services to a person who wishes to engage with Us, but who is not prepared to identify themselves.

 

6. Storing and keeping your information safe

6.1 The Alliance takes all reasonable steps to protect your personal information from misuse, interference, and loss and unauthorised access, modification or disclosure.

6.2 The Alliance stores all personal information in a secure database and maintains strict protocols for access and storage of such information. Hardcopy personal information is stored in locked filing cabinets.

6.3 Alliance staff will securely handle and store your personal information in a manner which complies with the Act and the APPs. They are required to ensure that any such personal information available to them is protected from theft, damage, loss, unauthorised access and any other form of abuse or improper use.

6.4 We have implemented appropriate technological and organisational controls to protect your personal information against unauthorised processing and against accidental loss, damage or destruction.

6.5 If We engage service providers or third parties to perform services for Us, We will endeavour to require them to comply with Our Privacy Policy.

How long We keep your personal information

6.6 The Alliance keeps personal information for only as long as is needed. This includes for as long as you continue to consent to be on Our database, or We need to keep it for reporting and analysis purposes.

6.7 The Alliance may also need to keep your personal information for accounting or other lawful purposes. At any time you may request for Us to make your record anonymous by removing all details that identify you. Where appropriate and to the extend required by law, we will consider all requests to delete or de-identify your personal information.

 

7. Website and App

7.1 We may collect the following information through Our website and app, either ourselves or through Google Analytics (which is hosted by a third party):

(a) your computer or device’s IP address (collected and stored in an anonymised format);
(b) device screen size, device type, operating system and browser information;
(c) geographic location (country only);
(d) referring domain and out link if applicable;
(e) search terms and pages visited (clickstream data); and
(f) date and time when website pages were accessed.

7.2 We will treat any personal information collected through Our website and app in the same way as other personal information We collect.

Posting comments on our sites

7.3 When you post information or comment publicly on an article on one of Our sites, the information you post and your username are publicly accessible. This information can be viewed online and collected by other people. We are not responsible for the way these other people use this information. When contributing to a discussion, We strongly recommend you avoid sharing any personal details.

Using our apps

7.4 The Alliance’s event apps include the personal information used to register for the event. From within the App you can manage the ‘opt in’ or ‘opt out’ of being included on delegate lists.

Links to other websites

7.5 Our website and app contains links or references to other websites or organisations. We are not responsible for the privacy practices or content of the linked web sites.

7.6 Third party websites may have their own privacy and security policies, which We encourage you to read before supplying any personal information to them.

7.7 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.

 

8. Correcting your personal information

8.1 We will take reasonable steps to ensure the personal information We have about you is correct. If any of your personal information is incorrect, you may contact Us using the details set out at clause 12.1 to correct your personal information. Further, you can  provide extra information at any time by contacting Us using the details set out at clause 12.1.

8.2 If We refuse to correct your personal information, We will provide you with written notice that sets out Our reasons (other than to the extent it would be unreasonable to do so) and inform you of how to complain about the refusal.

8.3 If We refuse to correct your personal information, you may request that We make a record of your claim that the personal information is inaccurate, out-of-date, incomplete, irrelevant, or misleading. We will take reasonable steps to associate the record in such a way that will make it apparent to users of the personal information.

 

9. Access to personal information

9.1 You can contact Us if you would like to access the personal information We hold about you. We will request that you verify your identity, before We provide you with access to your personal information.

9.2 We will provide you with access to your personal information, within a reasonable period after the request, and in a way that is reasonable in the circumstances, unless exempted by the Act.

9.3 We may refuse to provide you with access to your personal information, or to provide access in the manner you have requested in circumstances where an exception to access applies under APP 12.

9.4 If We refuse to provide you access to your personal information, We will provide you with written notice that sets out Our reasons (other than to the extent it would be unreasonable to do so) and inform you of how to complain about the refusal.

9.5 We may charge a reasonable fee for providing you with access to your personal information, which will be confirmed at the relevant time.

 

10. Direct marketing

10.1 If We have your permission, We may send you materials We think may interest you, such as monthly Bushwire newsletter, conference call for abstracts or registration opening, seeking contributions for Our online Magazine, Partyline, or any other information We deem to be of interest.

10.2 We do not use or disclose your sensitive information for the purpose of direct marketing without your consent.

10.3 Any direct marketing will be conducted in accordance with the Act and other applicable legislation, regulation, or enactment. including the Do Not Call Register Act 2006 (Cth) and the Spam Act 2003 (Cth).

 

11.Responding to your queries or complaints

11.1 You may make a complaint about how We have handled your personal information by contacting Us using the methods described at clause 12 below.

11.2 If you have raised a query or a complaint with Us, We may contact you to answer your query or to resolve your complaint.

11.3 The Alliance will deal promptly with your inquiry or complaint, according to our Complaint Handling Policy. If you are not satisfied with the Alliance’s response to any concerns you may have raised, you can obtain more information about privacy or make a complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au. If you lodge a complaint with the Office of the Australian Information Commissioner, or another regulatory body, We may use and disclose your personal information to assist in any resulting investigation or proceeding.

 

12.Contact details

12.1 If you have a concern or would like to provide feedback about any aspect of the Alliance’s Privacy Policy or you wish to make a complaint about how your personal information is handled by the Alliance, please contact Us by email nrha@ruralhealth.org.au, by telephone on (02) 6285 4660 or through the Contact Us facility on Our website.

 

 

 

 

Attachment 1 - Collection Notice

 

The National Rural Health Alliance Ltd (ABN 68 480 848 412 / ACN 620 779 606) (the Alliance, We, Us, Our) collects, stores, discloses and uses personal information to perform its functions and activities.

All personal and sensitive information is held by the Alliance and its staff in accordance with the Alliance’s Privacy Policy. For further information about the Alliance’s collection, use, disclosure, and management of personal information:

(a) please read the Alliance’s Privacy Policy at: https://www.ruralhealth.org.au/privacy-policy; or
(b) contact the Alliance via the following details:

National Rural Health Alliance Ltd,
First Floor, 10 Campion Street, Deakin, ACT, 2600.
Phone:                 02 6285 4660
E-mail:                  nrha@ruralhealth.org.au.

The purposes for which the Alliance collects your personal information are specified at clause 1 of the Alliance’s Privacy Policy. Generally, you can deal with the Alliance without identifying yourself, however, in certain circumstances it would be impractical to deal with you anonymously.

The Alliance’s Privacy Policy also contains information about how you may:

(a) access, or seek to request, the personal information the Alliance holds about you, at clause 9;
(b) seek correction of your personal information held by the Alliance, at clause 8;
(c) complain about a breach of the Alliance’s privacy obligations and how the Alliance will handle such a complaint, at clause 11;

and includes information about the:

(d) consequences if all or some of the personal and sensitive information is not collected by the Alliance, at clause 5.2;
(e) entities, bodies or persons and the types of entities, bodies or persons, to which the Alliance usually discloses personal information, at clause 0; and
(f) circumstances in which the Alliance is likely to disclose your personal information to overseas recipients 4.11.

By providing the Alliance with your personal information, you will be deemed to have read and accepted the Alliance’s Privacy Policy, as amended from time to time, and the most recent version of which is made available on the Alliance’s website at: https://www.ruralhealth.org.au/privacy-policy

Please ensure you have read and understood the Alliance’s Privacy Policy prior to providing your personal information or contract the Alliance if you have any concerns.

National Rural Health Alliance Ltd,
First Floor, 10 Campion Street, Deakin, ACT, 2600.
Phone:                 02 6285 4660
E-mail:                  nrha@ruralhealth.org.au.