QSA is committed to respecting and protecting the privacy and the confidentiality of personal information we collect from our service users, and to being honest and transparent in the way that we collect, store, use and disclosure personal information. QSA is also committed to meeting the requirements of The Privacy Act 1988 and the Australian Privacy Principles (APP).
The purpose of this privacy policy is to inform users of our service about the type of personal information we collect, how we handle personal information, how we use personal information, and when we are required to or might disclose personal information. This policy applies to all of our service users including (but not limited to) our members, members authorised representatives non member clients, health care practitioners, and other Scheme stakeholders.
By becoming a member of QSA, by interacting with our website and online portal, or by requesting we provide you with information or other services by email, by phone or in person, you indicate that you accept this Privacy Policy as amended from time to time. Please regularly review our Privacy Policy to ensure that you are aware of any changes.
What is Personal Information and why do we collect it?
Personal Information is information that identifies you as an individual. QSA is required by the Australian Government to collect personal information about you when you apply for participation in the Stoma Appliance Scheme. We may also collect personal information about you which is reasonably necessary to deliver our support services to you. Examples of personal information collected by QSA may include your name, address, email address, phone number/s, IP address, device information, Medicare information, Department of Veterans Affairs information, Centrelink concession information and other information related to your participation in the Stoma Appliance Scheme or as a user of our services. Your personal information is obtained in many ways including via our membership application form and the Stoma Appliance Scheme registration form, by telephone, by facsimile, by email, via our website, through order placement, through your online portal account and via third parties such as through organisations that work collaboratively with us (for example: a referring hospital or another stoma association).
We collect personal information for the primary purposes of providing our services to you (including the issuing of ostomy products supported through the Stoma Appliance Scheme) and for delivering information and support to you. We may also use your personal information for secondary purposes closely related to the primary purpose in circumstances where you would reasonably expect such use. We do not use your personal information for direct marketing however we may use your personal information to communicate to you information about your membership with Queensland Stoma Association Ltd and/or about matters relating to your participation in the Stoma Appliance Scheme. Communication may be sent by email to the email address provided by you (or your representative) or by mail to your postal address.
You may unsubscribe from our mailing lists at any time by contacting QSA by telephone to 07 3359 7570, by email to [email protected], or by letter to PO Box 370, CHERMSIDE SOUTH.
What is Sensitive Information and why do we collect it?
Sensitive information is defined in the Privacy Act as information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. QSA is required by the Australian Government to collect sensitive information about you when you apply for participation in the Stoma Appliance Scheme. We may also collect sensitive information about you which is reasonably necessary to deliver support services to you. Examples of sensitive information that may be collected by QSA include information related to your stoma including your type of stoma and the reason for your stoma surgery.
Sensitive information will be collected when we have your consent and when the collection is necessary for us to assess your eligibility for participation in the Stoma Appliance Scheme. We may also collect your sensitive information when it is reasonably necessary for us to carry out one or more of our services, functions or activities.
Sensitive information will be used only for the primary purpose for which it was obtained or for a secondary purpose that is directly related to the primary purpose in circumstances where you would reasonably expect such use.
What if you don’t provide us with your Personal Information?
Depending on the circumstances, if you do not provide us with your personal information, we may not be able to deliver certain support services to you. For example: should you wish to remain anonymous, we may be able to provide you with general stoma related information however we would not be able to register you as a participant with the Stoma Appliance Scheme.
Cookies
Cookies are small data files stored in your device’s memory that do not, of themselves, identify individuals personally. We do not use cookies on our website but cannot guarantee the policies of websites linked to our website or the policy of authorised third parties.
We do collect your IP address and device information when you access your online portal account. The purpose for this collection is to assist us with operational difficulties or to support issues with our services. This information does not identify you personally.
Third Parties
Where reasonable and practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties such as a family member or medical professional. In such a case we will take all reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
QSA will not disclose your personal information except where you have provided your consent, where you would reasonably expect us to do so for the delivery of our services to you, or where we are required or authorized to disclose your personal information by law. Examples of when we may disclose your personal information include when:
- a permitted health situation exists in relation to the use or disclosure of the information by QSA to your Stomal Therapy Nurse or Medical Professional;
- we are required to disclose your information for purposes related directly to your eligibility to receive stoma products funded by the Stoma Appliance Scheme. For example, we are required to disclose your personal information to Services Australia when claiming reimbursement for the cost of products issued to you through the Stoma Appliance Scheme. We may also be required at times to disclose your personal information to another Australian stoma association authorized to distribute products through the Stoma Appliance Scheme;
- we are required to resolve processing issues related to the supply of products to you through the Stoma Appliance Scheme. For example: if our software claiming system is unable to process your order transaction, we may be required to disclose details related to that transaction to our IT support provider (The Australian Council of Stoma Associations) to help resolve the issue;
- you ask us to communicate with another organisation on your behalf (eg: Centrelink to establish a Centrepay arrangement);
- you ask us to assess your eligibility for Department of Veterans Affairs support; or
- you ask us to contact an ostomy product supplier on your behalf to arrange for a direct delivery order, a product sample, or any other ostomy product matter that can only be dealt with directly with the supplier.
QSA is unlikely to disclose your personal information to overseas recipients.
Security and Storage of Personal Information
We hold personal information in both hard copy and electronic formats. Paper files are stored securely onsite in a manner that reasonably protects it from misuse, interference, loss, unauthorized access, modification or unauthorized disclosure.
When storing your personal information electronically, we use a secure server using the latest SSL (secure sockets layer) encryption technology.
The steps we take to ensure personal information that we collect and hold electronically is protected from misuse, interference, and loss, as well as unauthorised access, modification and disclosure include:
- Website protection measures (such as encryption, firewalls and anti-virus software;
- Access restrictions to our computer systems including the mandatory use of multifactor authentication where available;
- Staff training and implementation of workplace policies and procedures that cover confidentiality and privacy, and access, storage and security of information
We discourage the sending of personal information including orders which contain your personal information via email and encourage you to register to use our secure online portal. If you are unable to use our portal we encourage you to post communication which contains your personal information (including orders) to our postal address.
When your personal information is no longer needed for the purpose for which it was collected, we will take all reasonable steps to destroy it or to permanently de-identify it. However, some personal information is required to be kept by law and will be stored in our files in a secure facility and kept by us for the mandatory retention period.
Third Party Websites
Links to third party websites that are not controlled by Queensland Stoma Association Ltd are provided on our own website for your convenience. We are not responsible for the security or privacy practices of those websites.
Access to your Personal Information
You have a right to access the personal information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your personal information, please make your request to us in writing.
In order to protect your personal information you will be required to provide photo identification before we can release such information.
Maintaining the Quality of your Personal Information
It is an important part of providing our services to you that your personal information is up to date and we will take all reasonable steps to make sure that your personal information is accurate and complete. To assist with this process, it is important that you advise us as soon as soon as possible of any changes to your personal information so that our records can be updated. A request to update your personal information can be made by phone, post, or by submitting a profile change in your secure online portal account.
Non-identifiable Information
Non-identifiable information is information about people but the identity of the people is not known and their identity cannot be found out. De-identification involves removing or altering information that identifies an individual or is reasonably likely to enable their identification. Where information is non-identifiable, it is no longer personal information and can therefore be used or shared in ways that might not otherwise be permitted under the Privacy Act 1988 (Cwlth). The benefit of sharing non-identifiable information is that it can help to provide insight into health related trends which may help to inform health policy and to improve healthcare planning.
QSA may share non-identifiable information about the services we provide to you to third parties but only where the purpose of the disclosure is to assist the wellbeing of persons living with a stoma, where the requesting third party is a reputable organization, and where the use of the data is transparent and appropriate. Typically non-identifiable information may be amalgamated and used for research into ostomy related matters with details provided under such headings as age range, gender, geographical location and types of products used in the stoma management of those concerned. Non-identifiable information shared will be limited to only that data that has been deemed necessary to achieve the intended purpose. QSA will assess and manage re-identification risk prior to sharing non-identifiable information and will only share non-identifiable information using a secure file transfer process. QSA will always comply with relevant Privacy Laws and any other statutory requirements of State and Federal legislation.
More information about how and why we may share non-identifiable information can be found in the QSA Policy- QSA RP1 Participation in a Research Project.
Notification of a Data Breach
If we become aware of unauthorized access to or loss of your personal information, we will promptly:
(a) notify you;
(b) investigate the cause;
(c) do our best to remedy any consequences; and
(d) tell you what steps we have taken to prevent a reoccurrence
Complaints
If you have a complaint about how we collect or handle your Personal Information, please contact us at:
The Secretary
Queensland Stoma Association Ltd
PO Box 370
CHERMSIDE SOUTH QLD 4032
Email: [email protected]
We treat any complaints about privacy seriously and will do our best to respond to your complaint within seven days of receiving it. If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner in Australia or the Office of the Privacy Commissioner in New Zealand.
Policy Updates
This Policy may change from time to time. A copy of our Privacy Policy is available by contacting QSA