Privacy Policy
Purpose of the Policy
ASMI takes its obligations under the Privacy Act seriously and would like to take all reasonable steps in order to comply with the Act and protect the privacy of the personal information that we hold. This policy sets out how we intend to do so.
The personal information that ASMI collects
ASMI collects and holds the following personal information:
- Your name
- Job Title/area of expertise
- Business contact details including e-mail address
- Alternative contact details if provided by you
- Membership of professional committees and associations
- Details of interactions with you
Why we collect it
ASMI collects, uses and discloses the information in accordance with the Collection Statement.
ASMI collects data in order to:
- Transmit relevant information regarding the industry and the Association;
- Make contact in order to conduct day-to-day business of the Association;
- Undertake activities to the benefit of ASMI members;
- Comply with any other legal Acts and regulations which may apply to the Association.
Access to your personal information
ASMI provides access to the personal information that we hold about you. Access will be provided in accordance with our Access Policy. If you require access to your personal information please contact the ASMI Privacy Officer, Steve Scarff, c/o ASMI, Level 22, 141 Walker Street, North Sydney NSW 2060. Email: steve@asmi.com.au Tel (02) 9922 5111.
Complaints
If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed please contact the ASMI Privacy Officer. Complaints will be handled under ASMI’s Privacy Complaints Policy.
Storage
We will take all reasonable steps to protect the security of the personal information that we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.
Contract
We do not routinely contract out data storage or processing functions. If ASMI does contract out, we take measures to protect the information by securing confidentiality assurances from our contractors.
Collection Statement
The personal information collected is collected by ASMI secretariat staff.
Type of personal information collected
In some cases this will include a photographic image of you. This is collected by our photographer for inclusion in ASMI Official Publications or as a record of an ASMI official event. It may also include written or spoken information about your contact details, job function, expertise and ASMI contacts with you.
Use and disclosure
Other personal information is collected for the purpose of:
- selling and providing you our services (such as conferences, seminars, information,
publications, consultancy and membership) - processing payment
ASMI will usually disclose this information to:
- our insurer/s
- our world body, the World Self-Medication Industry (WSMI), for single use only.
- Interested parties for the purposes of supporting your business (e.g referring business to members who are contract manufacturers or regulatory consultants).
Legal reasons why we collect the personal information
We collect the information in order to comply with our legal obligations under the Associations Act and our liability insurance.
What happens if you choose not to provide the information
You are not obliged to give us your personal information. However, if you choose not to provide ASMI with the personal contacts details, we may not be able to effectively provide you with ASMI services.
Access
You can gain access to the personal information that ASMI holds about you. If you wish to do so please refer to our Access Policy or contact the Privacy Officer.
Overseas
ASMI sends information overseas on an irregular basis to the World Self-Medication Industry (WSMI). When we do, and the laws of the receiving countries do not have privacy protection laws we will take all reasonable steps to make contractual arrangements that provide for privacy protection of the personal information that we send.
Sources of information
Where possible ASMI will collect the information directly from the member or stakeholder. In some cases we receive contact details from the nominated official member company representative to ASMI.
Access Policy
This policy is directed to those individuals whose personal information is held by our organisation.
Purpose
The purpose of this Policy is to set out how ASMI will provide access to your personal information. The Policy is part of our Privacy Policy and our desire to provide for, maintain and give effect to your right to privacy.
Overriding principles
At all times the conduct under this Policy will be governed by the following principles:
- All requests for access will be treated seriously
- All requests will be dealt with promptly
- All requests will be dealt with in a confidential manner
- Your request to access your personal information will not affect your existing obligations or affect the commercial arrangements between you and ASMI.
Form of Access
ASMI will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that ASMI holds about you. You can make your request in writing to the Privacy Officer. To obtain access you will have to provide proof of your identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.
When will Access be denied?
Access will be denied if:
- the request does not relate to the personal information of the person making the request;
- providing access would pose a serious and imminent threat to life or health of a person;
- providing access would create an unreasonable impact on the privacy of others;
the request is frivolous and vexatious; - the request relates to existing or anticipated legal proceedings
- providing access would prejudice negotiations with the individual making the request;
- access would be unlawful;
- denial of access is authorised or required by law;
- access would prejudice law enforcement activities;
- access discloses a ‘commercially sensitive’ decision making process or information; or
any other reason that is provided for in the National Privacy Principles (NPPs) set-out under the Privacy Act.
Where possible, ASMI will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate ‘intermediary’. Where there is a dispute about the right or forms of access these will be dealt with in accordance with ASMI ‘s Grievance Policy.
Time
We will take all reasonable steps to provide access within 30 days of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will provide information within 14 days.
Costs and charges
ASMI may impose the following charges:
- Photocopying – [$2 per page]
- Delivery cost, if any.
- Access to reports generated from ASMI electronic databases – [$20 per report]
Privacy Complaints: How we handle privacy complaints (for individuals)
Introduction
ASMI Inc (ASMI) understands the importance of privacy to the organisation, its members and other stakeholders. As such ASMI is committed to protecting the privacy of the personal information that we hold. This is part of our organisation’s:
(a) Legal obligations under the Privacy Act 1988
(b) Ethical and business obligations
(c) Service to you
ASMI places high priority on effectively dealing with any complaints dealing about privacy that you may have.
Overriding principles
At all times the conduct under this policy will be governed by the following principles:
(a) All complaints will be treated seriously
(b) All complaints will be dealt with promptly
(c) All complaints will be dealt with in a confidential manner
(d) The privacy complaint will not affect your existing obligations or the commercial arrangements that exist between this organisation and you.
Who may complain under this policy?
If you have provided us with personal information you have a right to make a complaint, have it investigated and dealt with under this policy.
What is a privacy complaint?
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
(a) How personal information is collected
(b) How personal information is stored
(c) How this information is used or disclosed
(d) How access is provided.
What do I do if I have a complaint about privacy practices?
ASMI resolves grievances at the local level if possible. If you have a complaint about privacy please contact the Privacy Officer. All complaints will be logged on a complaints register. You may complain orally or in writing (including e-mail). Usually your contact will be with the Privacy Officer to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter will then be referred to the Executive Director.
Grievance procedure
The goal of this policy is to achieve an effective resolution of your complaint within a reasonable set timeframe [28 days or as soon as practicable]. Once the complaint has been made, the point of contact can then resolve the matter in a number of ways:
1. Request further information and investigation: Your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential.
The complaint may be investigated. The organisation will try to do so within [72 hours/as soon as possible]. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.
2. Discuss options: We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.
3. Refer to Executive Director: If your complaint is not resolved at the local level, it will be referred to the Executive Director. The Executive Director would be provided with the history and may discuss the complaint with the employees, or other parties that are involved.
4. Resolution: You will be informed of the outcome and the reasons for the decision. If this does not resolve the complaint, the matter will be referred to a mutually agreed intermediary.
5. If after the above steps have been followed you are still dissatisfied with the outcome you may refer the complaint to the federal Office of the Privacy Commissioner.
Follow-up of the complaint
Following your contact at the organisation, the Privacy Officer will contact you after approximately six weeks to ensure that you have no further concerns.
Records
The organisation will keep a record of your complaint and the outcome.
Anonymous complaints
ASMI is unable to deal with anonymous complaints as we are unable to investigate properly and follow-up such complaints.
However, in the event that an anonymous complaint is received ASMI will note the issues raised and try and resolve them appropriately. For example, ASMI may wish to conduct further training or provide assistance in a given area.
Information
For any further information about this policy, please contact Steve Scarff, steve@asmi.com.au