Privacy Policy

Protecting your privacy is important to us.

Skin Cancer College Australasia (SCCA) and its Related Bodies Corporate (having the meaning given in the Australian Corporations Act 2001 (Cth)) values your privacy and is committed to protecting your personal information.  SCCA is bound by the Australian Privacy Act 1988 (Cth) and, as applicable, the New Zealand Privacy Act 1993 (together, “Privacy Law”) which govern our obligations when it comes to collecting, using, storing and disclosing your personal information.

What is personal information?

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can be reasonable ascertained, from the information or an opinion.

The kinds of personal information collected, used and disclosed by SCCA

We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you.  At or around the time we collect personal information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information. We set out some common collection, use and disclosure instances in the table below.

Types of personal information	Uses	Disclosures
Purpose: General enquiries, and registering for Membership and SkinTalk Online Forum
Contact information: Such as your name, address, billing address (if different to address), email address, phone numbers, professional practice details. Details for payment: Such as: Delivery information, Billing and account details, and Payment card details. Practitioner details: such as RACGP, ACRRM, MCNZ / RNZCGP numbers, or APNA, NCNZ or RCNA numbers Online blogs/Forums: Information such as: User account information such as username and password and other contact information. Any other information provided to SCCA or posted on the SkinTalk Forum or Blog. Member Service: Information collected by our support staff regarding member service. Locate a Doctor: If you are an eligible member and opt-in to this service, your name, title and credentials/ postnominals. The service will also publish your practice details including practice name, business address, email, and website addresses.	The types of uses we will make of personal information collected for this type of purpose include: Identity verification: If required, the verification of your identity and practitioner details. Services: The provision of our services to you including: Using your personal information to administer our services and provide our products. Payment processing, including charging, credit card authorisation, verification, and debt collection. To provide Member service functions, including handling enquiries and complaints. Permit you to access and interact with our SkinTalk Online Forum Marketing: using your personal information for the purposes set out in “Marketing” section below. General administrative and security use such as protections from fraud, security threats, fraud, or criminal activities; administrative and management’s use Locate a Doctor: If you opt-in to this service, to include your name on our publicly-searchable register of accredited skin cancer doctors.	The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation, to: Third parties connected with the services including payment gateway providers and financial institutions. Service providers (including IT service providers and consultants) who assist SCCA in providing our products and services. Related bodies corporate of SCCA (including related entities). Third parties in connection with the sale of any part of SCCA’s business or a company owned by an SCCA’s entity. To the general public, if you opt-in to our Locate a Doctor service. As required or authorised by law.
Purpose: SCCA conferences, events and training courses
Participant registration information: Your name, SCCA or third party membership or accreditation details (as applicable), contact address, billing address (if different to your contact address), email address, phone number/s, practice name, and optionally your dietary and accommodation preferences (as applicable).	The types of uses we will make of personal information collected for this type of purpose include: Identity verification: If required, the verification of your identity and practitioner details. Services: The provision of our conference, event or training services to you including: Communication regarding this event. To provide event service functions, including handling enquiries and complaints. To meet your preferences for provided catering or accommodation (as applicable). Marketing: using your personal information for the purposes set out in “Marketing and media enquiries” section, below.	The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation, to: Third parties connected with providing the conference, event, course or related services including venue providers, event organisers and IT service providers whom we have engaged to promote and deliver the activity for or on behalf of SCCA. The parties listed in the disclosure column for Marketing and media enquiries, below. Related bodies corporate of SCCA (including our related entities). As required or authorised by law.
Purpose: Marketing and media enquiries
Contact information relating to blog and news updates: Such as your name, email address. Social media activity: any social media activities which concern, or relate, to SCCA. Media enquiries: Such as your name, email address, organisation and any other personal information you may voluntarily share in your enquiry.	General marketing and consumer analytics: using your personal information: To update you on products or events which may be of interest to you. To aggregate with other information and to then use it for marketing and consumer analytics, including conducting and facilitating surveys and feedback. For Marketing and promotional activities by us (including by direct mail, telemarketing and email) such as our email alerts, product awareness information and newsletters. For the Uses detailed above in “General enquiries”. Online accounts or social media: If you participate in our social media platforms and you provide us your personal information, we will use it for: Responding to social media messages. Fulfilling social media platform rules. Media enquiries: To respond to your enquiry.	We may disclose your personal information to: Third parties connected with the marketing process who assist us in providing our products and services to you. The parties listed in the Disclosure column for “General enquiries”.

 

Openness

SCCA will ensure you are aware of our Privacy Policy and its purpose. We will make this information freely available to you in relevant publications and on the SCCA website. In the unlikely instance that our Privacy Policy conflicts with the Privacy Law, the Privacy Law prevails. For further information about the Privacy Law and protecting your privacy visit the website of the Office of the Australian Information Commissioner or Office of the New Zealand Privacy Commissioner.

Data collection

Collection generally

SCCA will only collect information that is necessary for the primary function and performance of the SCCA and will always notify you when we collect, administer and hold your information.

As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your personal information directly from you.

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary.  If you do not provide the mandatory information or any other information which we require in order for us to provide our services to you, we may be unable to provide our service to you in an effective manner, or at all.

Collection from other sources

We may also collect personal information about you from other sources, including from third parties or publicly-available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post or New Zealand Post (as applicable), White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram etc).

Notification of collection

If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in items (a) to (c) below. Generally speaking, we will not tell you when we collect personal information about you in the following circumstances:

• where information is collected from any personal referee you have listed on any application form (including any employment application) with SCCA;
• where information is collected from publicly-available sources including but not limited to public registers such as AHPRA’s registers of practitioners, court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc); or
• as otherwise required or authorised by law.

Unsolicited personal information

In the event we collect personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and if we determine (in our sole discretion) that the personal information is not required, we will delete or destroy the information or ensure that your personal information is de-identified.

How we hold your personal information

Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us (which may be via a third party service provider who is contracted by us to ensure your personal information is protected by such security safeguards as are reasonable in the circumstances to protect against loss or misuse). We provide some more general information on our security measures later in this policy.

Cookies on our website

The SCCA website uses cookies to enhance your user experience and help us continually improve the functionality of our site. Cookies are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes, website usage statistics or to provide enhanced functionality on the site. Generally, the information obtained by cookies is de-identified and does not constitute personal information, but it may include the IP address of your computer. By using our website, you accept the use and installation of these cookies to provide you with these services. If you do not want cookies enabled on your computer you may set your browser to block them.

Use and Disclosure Details

Uses and disclosures

The table earlier in this policy sets out of some common uses and disclosures we make regarding the personal information we collect.

We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:

• when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
• if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
• if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
• if it is required or authorised by law.

Use and disclosure procedures

In the event we propose to use or disclose such personal information other than for reasons set out in the table above or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

Your personal information is disclosed to these organisations or parties only in relation to the products or services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your personal information.

Communications opt-out

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the top of this document and we will ensure the relevant communication ceases.  Any other use or disclosure we make of your personal information will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.

Sensitive information

Sensitive information generally

Sensitive information is a subset of personal information.  It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

Collection and use of sensitive information

In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you.  However, we do not collect sensitive information from you without your consent.

The type of sensitive information we may collect about you is dependent on the services which we provide to you, and will be limited to the purpose(s) for which it is collected.  Where applicable, we set out some types of sensitive information we may collect about you in the table further above.

We do not use sensitive information to send you direct marketing communications without your express consent.

Consent

We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.

Anonymity and pseudo-anonymity

Where feasible, SCCA will give you the option of de-identifying yourself when completing evaluation forms or opinion surveys. This is not always an option, particularly when it comes to claiming continuing professional development points with professional bodies such as the Royal Australian College of General Practitioners or Royal New Zealand College of General Practitioners.

Cross border disclosure

Any personal information collected and held by SCCA may be disclosed or transferred to, and held at, a destination outside Australia or New Zealand, including but not limited to the United States of America, Canada, Ireland or Germany, where we utilise third party service providers to assist SCCA with providing our services to you.  Personal information may also be processed by staff or by other third parties operating outside Australia or New Zealand who work for us or for one of our suppliers, agents, partners or related companies.

As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held.  If your information is stored in this way, disclosures may occur in countries other than those listed above.

Additionally, we may utilise overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. In such cases, we may have entered into contractual arrangements with third party service providers to assist SCCA with providing our products and services to you.

Provision of informed consent

By submitting your personal information to SCCA, you expressly agree and consent to the disclosure, transfer, storage or processing of your personal information outside of Australia or New Zealand.  In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia or New Zealand in relation to personal information.  However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

The Privacy Law requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia or New Zealand do not breach the privacy principles contained within the Privacy Law.  By providing your consent, under the Privacy Law, we are not required to take such steps as may be reasonable in the circumstances.  However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

If you do not consent

If you do not agree to the disclosure of your personal information outside Australia or New Zealand by SCCA, you should (after being informed of the cross border disclosure) tell SCCA that you do not consent. To do this, either elect not to submit the personal information to SCCA after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.

Data security and quality

We have taken steps to help secure and protect your personal information from unauthorised access, use, disclosure, alteration, or destruction.  You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where human error is involved or malicious activity by a third party.

Notwithstanding the above, SCCA will take reasonable steps to:

• ensure the personal information we collect, use or disclose is accurate, complete, up to date, and relevant to the functions we perform;
• safeguard the information we collect and store against misuse, loss, unauthorised access and modification; and
• destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.

The accuracy of personal information depends largely on the information you provide to us, so we recommend that you:

• let us know if there are any errors in your personal information; and
• keep us up-to-date with changes to your personal information (such as your name or address).

We will never store credit card details.

We provide information about how you can access and correct your information, further below.

Access and correction

Except for exceptional circumstances as provided by law (including in the Privacy Law), SCCA will ensure you have access to your information and can easily update it if it is inaccurate, incomplete, misleading or not up to date.

If you have any queries, or would like to request a change, please email .

Data storage

SCCA stores your information on secure servers (electronic records) or controlled facilities (hard copy records) and our employees and contractors are obliged to respect the confidentiality of any personal information held by us. Wherever practical we will ensure that the servers that hold your information are housed in Australia or New Zealand, however some data may be stored in other countries.

SCCA also relies on you to help keep your personal information secure. To do this keep your login and password information confidential and regularly change your password using a combination of letters (upper and lower case), numbers and special characters (!, @ etc). If you notice any unauthorized use of your account please notify SCCA immediately.

Sharing your information

All our registration and membership forms will include the option for you to specify that your information is not provided to third party organisations such as sponsors. SCCA will release your information to a third party where it is specifically requested by you.

Resolving privacy complaints

We have put in place an effective mechanism and procedure to resolve privacy complaints.  We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

If you wish to raise a complaint with us in regard to the way we have collected, used or disclosed and stored your personal information, please contact SCCA via .

In order to resolve a complaint, we:

• will liaise with you to identify and define the nature and cause of the complaint;
• may request that you provide the details of the complaint in writing;
• will keep you informed of the likely time within which we will respond to your complaint; and
• will inform you of the legislative basis (if any) of our decision in resolving such complaint.

We will keep a record of the complaint and any action taken in a Register of Complaints.

Consent, modifications and updates to this Privacy Policy

Interaction of this Policy with contracts

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract.

In such instances, we may incorporate the terms of this policy such that:

• certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto us, but do create contractual obligations on the other party to the contract; and
• the consents provided in this policy become contractual terms provided by the other party to the contract.

Acknowledgement

By using our website, becoming a member, purchasing a product or service from SCCA, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy made reasonably available to you, you acknowledge and agree to provide the consents given by you in this Privacy Policy and that you have been informed of all of the matters in this Privacy Policy.

Modifications and updates

We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website).  If you do not agree to our continued use of your personal information due to the changes in our Privacy Policy, please cease providing us with your personal information and contact us via the details set out at the top of this document.

 

Last updated 21 September 2020.