The Victorian Comprehensive Cancer Centre Ltd (VCCC) is committed to respecting the privacy of personal information relating to customers, staff, stakeholders, contractors, volunteers and patients at our members.
The VCCC is bound to act in accordance with both Victorian and Australian legislation relating to this matter. From 12 March 2014 the Australian Privacy Principles (APPs) are in place under the Privacy Act 1988 [LINK http://www.oaic.gov.au/privacy/privacy-act/australian-privacy-principles].
It is recognised that the privacy principles place significant restrictions on the use of personal information and these matters require careful management.
The VCCC also seeks to comply with the Privacy and Data Protection Act 2014 (Vic) (PDPA).
This policy includes the attached Privacy Collection Statement, below.
The VCCC is dedicated to ensuring the privacy of all relevant individuals, and we have implemented security measures and procedures, to provide assurance that personal information will remain secure.
1. Personal and Sensitive Information VCCC Collects and How It Is Collected
The VCCC only collects personal or sensitive information when it is necessary to support our business activities. This means that we collect information for purposes including:
- Internal management and reporting requirements
- The provision of business services, healthcare improvements and research
- Communicating with our stakeholders
- Audit and review of patient data
The VCCC will endeavour to notify at, or before the time, or soon thereafter if we receive personal information about an individual from a third party and to provide information on the purpose, use and access to the information and a copy of our Privacy Collection Statement and Policy.
VCCC collects personal information from you in a variety of ways. These include:
- Information provided when registering for an event or conference
- Information provided by way of contact or interaction through our website or application
- From our Members or other sources when performing services or research when consent has been provided
The VCCC will only collect personal information by lawful and fair means and not in an intrusive manner. Where it is reasonable and practicable to do so, the VCCC endeavours to collect personal information about you directly from you. In some circumstances, however, the VCCC may obtain your personal information from a third party. You generally have no obligation to provide personal information to us, however, if you choose not to provide information we need, we may not be able to provide you with a requested product or service.
Wherever possible, the VCCC will collect de-identified data to perform research and services for our Members and only when necessary to achieve our business purposes. Appropriate safeguards will be developed with our Members where use of data with unique identifiers is required and will comply with the requirements of the PDPA. The VCCC does not directly collect personal or sensitive information and assign unique identifiers to it. Sensitive information (ie genetic or health information) will only be collected with your permission. When feasible, you have the right to provide information anonymously.
When working with our members, the VCCC will ensure compliance with their individual privacy policies and will seek formal approval to proceed from each member participating in a project that involves sharing personal or sensitive information.
The VCCC may collect information including personal details such as address, dietary information, workplace and credit card/banking information to enable payment for services or events. Credit card and banking information collected will be destroyed in a secure manner, within one year of the information being provided. Health data from our members used for research and health care improvements is also collected or utilised by the VCCC as part of its business activities.
2. Use of Information
VCCC uses information we collect from you for the primary business purposes and purposes and related activities of our Members. This means that we use information for purposes such as:
- Providing you with services or events that you have requested
- Helping us manage and conduct research activities
- Helping us improve the services offered at our members
- Communicating with you
The VCCC may also use your personal information for the purpose of marketing our business functions, events and activities to you unless you have requested not to receive such materials.
The VCCC will only disclose your personal information if you consent to such disclosure or if such disclosure is permitted under the Privacy Act, or use it for a secondary purpose without consent unless it is reasonably expected to be used for that purpose as outlined in the Australian Privacy Principles.
The VCCC may disclose personal information to other related organisations. The VCCC may also provide your information to:
- Third parties engaged by VCCC to perform functions on its behalf, such as processing credit card information, order fulfilment, mailouts, shipping, debt collection, marketing, research and advertising
- Third parties authorised by you to receive information held by the VCCC
The VCCC will not transfer your personal information outside Australia unless you consent to such a transfer and the VCCC has satisfied itself that the recipient of the personal information will uphold principles for the handling of personal information, which are similar to the Australian Privacy Principles.
3. Security of Information
The VCCC protects the personal information it holds from misuse, loss, unauthorised access, modification or disclosure by various means including firewalls, password access, secure servers and encryption of credit card transactions. The VCCC will destroy or permanently de-identify personal information no longer needed for any authorised purpose.
4. Updating or Correcting Personal Information
The VCCC endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. If your details change or you believe that any of the personal information we hold about you is inaccurate or incomplete by contacting us.
5. Access to Personal Information
You have the right to seek access to the personal information held about you and to advise the VCCC of any inaccuracy. There are some exceptions to this right set out in the Australian Privacy Principles.
If you make an access request, the VCCC will ask you to verify your identity and specify what information you require. The VCCC may charge a fee to cover the costs of meeting your request.
6. Contacting or Making a Complaint to the VCCC
Craig Zanker, VCCC Director of Finance and Corporate Services
P +61 3 9035 4505
This policy is scheduled to be reviewed at least every three years.
The Executive Director is responsible for facilitating this review. All enquiries and proposed changes to the policy should be directed to the Executive Director.
Date Issued: 7 August 2014
Last Reviewed – Next Review: 6 February 2017 – 6 February 2020
Authorising Officer: COO
Privacy Collection Statement
Protecting your privacy
The Victorian Comprehensive Cancer Centre Ltd (VCCC) is committed to protecting your privacy and to ensuring we can provide you with the best possible care and services. We are bound by the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles. The VCCC also seeks to comply with the Privacy and Data Protection Act 2014 (Vic).
Collection of information
We collect personal information about individuals directly from the individual or their legal representative. We will only collect information for a purpose that relates directly to our functions and activities in cancer research, health service improvement and education. We understand that you may not want to provide information to us and information may be provided anonymously or through use of a pseudonym. The information we request of you may be relevant to providing you, or other Victorianswith the care and services you need in the future. If you choose not to provide us with some or all of the information we request, we may not be able to provide you with the care and services you require. The information we request goes to directly improve the care and outcomes of cancer patients and will greatly assist us to meet this aim.
Use and disclosure
Access and correction of information
We require your consent to collect, use and disclose your personal health information so that we are able to perform research and audit to improve cancer outcomes in Victoria. If we intend to use your health information for any other purpose, we will seek further consent from you.
We will not disclose your information to overseas recipients. If we do, we will take all steps that are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles.
Making a complaint
If you wish to make a complaint about the way we have managed your personal information you may make that complaint verbally or in writing by setting out the details of your complaint to any of the following:
- Craig Zanker, VCCC Director of Finance and Corporate Services
P +61 3 9035 4505
- Office of Australian Information Commissioner