2. Information we collect and why we use it?
What personal information do we collect?
'Personal information' means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained.
‘Sensitive information’ is personal information about an individual’s racial or ethnic origin, philosophical or political beliefs, religious beliefs, criminal record, membership of a professional or trade association or a trade union, sexuality, genetics, biometrics, disability, or health information.
THE COLLEGE is responsible for policies and programs that help members access quality and affordable continuing professional development (CPD) materials; post-registration, personal development and higher education; academic research and education events.
Generally, we collect personal information in order to properly and efficiently carry out one or more of our functions or activities. We only use personal information for the purpose(s) for which it was given to us and for directly related purposes (unless otherwise required or authorised by or under law); as consented by you or if a permitted general situation exists.
We will only collect personal information about you if you voluntarily submit it to us by:
- providing your information by form, telephone or facsimile;
- sending us an email;
- sending us information via the ‘Contact Us’ page on our websites; and/or
- including personal information when using any part of our website.
The types of personal information we may collect include:
- your name and birth date;
- your contact information, including postal and residential addresses, telephone and facsimile numbers, and email addresses;
- where relevant your pharmacist registration details including post-nominals;
- information for the purpose of obtaining a unique student identifier for vocational students; and/or
- where relevant to the services we are providing you, your financial information.
We may also store and maintain any content that you provide in connection with our website, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.
We do not usually seek sensitive information for the provision of general member services and industry recognised training programs. Notwithstanding the information below, sensitive information about an individual will not be collected unless the individual has consented or the collection is required by law. We will, where necessary, obtain your explicit consent to collect and use such information.
We will generally hold your personal information as either physical record, records on our servers, and in some cases, records on third party servers, which may be located overseas.
We may collect and hold information about you that is not personal information, including:
- data relating to your activity on our website via tracking technologies such as cookies;
- the identity of your internet browser, the type of operating system you use, your IP address and the domain name of your internet service provider;
- membership numbers allocated to you as identifiers of for the purposes of THE COLLEGE's operations; and
- details of any survey responses you provide.
We may use this information for internal purposes, including administering our services, diagnosing problems, generating statistics and trends, and improving the quality of our products and services.
Personal information collected from participants of nationally recognised training programs
As a government registered training organisation, regulated by the Australian Skills Quality Authority, THE COLLEGE is required to collect a range of personal and sensitive information on participants in nationally recognised training programs. This information requirement is outlined in the National Vocational Education and Training Regulator Act 2011 as well as Standards for NVR Registered Training Organisations 2012, and Data Provision Requirements 2012. The specific data required for collection is outlined in the Australian Vocational Education and Training Management Information Statistical Standard (AVETMISS) data requirements as published by the National Centre for Vocational Education Research (NCVER).
It is also noted that THE COLLEGE is also bound by various State Government Acts requiring similar information collection relevant to state jurisdictions of our operations. The types of personal and sensitive information we may collect for these purposes includes:
- Identity and contact details;
- Employment details;
- Educational background;
- demographic information;
- course progress and achievement information;
- Financial billing information;
- Complaint or issue information;
- Disability status and other individual needs; and
- Indigenous status.
Individuals are advised that although this information is requested, individuals maintain the right to refuse provision of such without penalty.
Personal information collected during CPD accreditation activities
The Pharmacy Board of Australia, in partnership with the Australian Health Practitioner Regulation Agency (AHPRA), has authorised the Australian Pharmacy Council (APC) to accredit pharmacists Continuing Professional Development (CPD) activities. The APC has approval to undertake this role by accrediting organisations that meet strict criteria to accredit CPD on its behalf. Under the auspices of the APC the Australian College of Pharmacy may accredit CPD for pharmacists that is eligible to be used as supporting evidence of continuing competence.
In order to assess applications for accreditation of CPD materials the APC Accreditation Standards for CPD Activities (the Accreditation Standards) states in the performance criteria of element 2.1 for Standard 2: “There must be significant pharmacist and/or other subject matter expert (SME) involvement in the development of the activity” and that “Pharmacists and SMEs involved in the activity development must be able to demonstrate they are suitably qualified and/or experienced”.
In order to determine the qualifications and experience of the developer of CPD activities for accreditation THE COLLEGE requires applicants to submit a copy of their resume. They must also disclose any financial and/or proprietary interests in relation to the sponsor or content of the CPD activity as determined by the performance criteria of APC Accreditation Standards element 2.4 for Standard 2: “All parties involved in development, including expert reviews, must disclose conflicts of interest whether actual or perceived”.
The resume and disclosure are used by College staff only to assess the appropriateness of the developers against the APC standards. Resumes are not given to any parties outside of College staff. Disclosures of interests are communicated to the participants of the CPD activity who may be College members or other associates.
What will we tell you when we collect your personal information?
Whenever we collect information from you, we will do everything we can to let you know:
- how to contact us;
- why we are collecting the information;
- the organisation or types of organisations to which we usually disclose that kind of information;
- if we are required by law to collect the information;
- the consequences (if any) for you if the information is not provided;
- how you may access and correct the information;
- how to complain about a breach of the Australian Privacy Principles; and
- whether we will disclose your information to overseas recipients, and the countries in which such recipients are likely to be located.
When reasonable and practicable to do so, we will collect personal information directly from you or someone authorised by you and not from third parties.
Wherever it is lawful and practicable, you have the option of not identifying yourself or using a pseudonym when entering into transactions with THE COLLEGE.
There are inherent risks associated with the transmission of information over the internet, including via email. You should be aware of this when sending personal information to us via email or via our website or social media platforms. If this is of concern to you then you may use other methods of communication with us, such as mail, fax or telephone (although these also have risks associated with them).
We will record your email address when you become a member, send a message to us, undertake a CPD course or assessment, enrol in an education course, conference or event or subscribe to one of our mailing lists. Any personal information, including email addresses, will only be used or disclosed for the purpose for which it was provided.
Dealing with unsolicited information
From time to time THE COLLEGE may receive unsolicited personal information. Where this occurs we will promptly review the information to decide whether or not we could have collected the information for the purpose of our business activities. Where this is the case, we may hold, use and disclose the information appropriately as per the practices outlined in this policy.
Where we would not have collected this information (by law or for a valid business purpose) we immediately destroy or de-identify the information, unless it would be unlawful to do so.
Collection of information from third parties
Where THE COLLEGE collects personal information from another organisation, we:
- Confirm whether the other organisation has provided the relevant notice to you; or
- Whether you were otherwise aware of these details at the time of collection; and
- If this has not occurred, we will undertake to notify you to ensure you are fully informed of the information collection.