1 About this Policy
1.1 The Pharmacists’ Support Service (PSS) offers a free telephone support service to Australian pharmacists, pharmacy interns and students by providing a team of volunteer pharmacists trained in peer support and telephone counselling ready to take calls 365 days of the year from 8.00am to 11pm Australian Eastern Daylight Time (Service).
1.2 The PSS believes that the support it offers the pharmacy profession is enhanced by the assurance that (except in very limited circumstances set out below), it will not seek, collect or store personal information about you and any information you disclose will be held in confidence. PSS believes that this assurance of confidentiality allows for a full and frank exchange which is required for the PSS to give callers effective support in an environment of trust and security.
1.3 PSS is committed to protecting the privacy of all individuals that provide information to it in accordance with the Australian Privacy Principles (APPs), the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
(a) when a caller expressly authorises a disclosure of personal information or implies that they have given such authorisation;
(b) where the PSS has serious concerns for the safety, health or welfare of the caller or another person;
(c) where an individual or individuals have made threats to harm third parties;
(d) where an individual or individuals have made threats against PSS personnel or volunteers; or
(e) where an individual repeatedly makes nuisance contact including calls, chats or emails.
2 What kind of personal information will be collected by PSS?
2.1 PSS will not ask for the name or address of a caller to the Service (except in certain Exceptional Circumstances). Consequently, callers may remain anonymous when accessing the Service.
2.2 PSS will only ask for and collect the information that is necessary for the provision or quality improvement of the Service. PSS discourages callers from sharing their name and personal details with the Service volunteers.
2.3 The type of information collected by PSS about a caller to the Service includes the date of the call, the gender of the caller, general reasons for the call, the source of call (self-reported or referral), the general location of caller (State of Australia and metropolitan or rural), whether the caller indicated that there was a risk to the caller or others, any actions taken to manage risk, any referrals to other organisations which were given, the outcome of the call and whether any ongoing support is required. Information which may identify the caller is not recorded.
2.4 The information collected will vary depending on an individual’s circumstances.
2.5 The PSS may also collect personal information for the purposes of responding to any enquiry or communication you make including to:
(a) receive information from the PSS or to become involved in PSS events, campaigns, fundraising or other initiatives;
(b) make a complaint about the way in which the Service has been delivered;
(c) ask for access to information that the PSS holds about you;
(d) notify the PSS about a data breach;
(e) report a matter for investigation;
(f) supply goods or services to the PSS; and
(g) apply for a job vacancy or volunteering role with the PSS.
3 Information collected for the purpose of making donations
3.2 GiveNow shares only two categories of personal information with PSS, that being the name and address of the donor. For the avoidance of doubt, no credit card details are shared with PSS.
4 How does PSS hold and store personal information?
4.1 The PSS utilises third party software to receive and make telephone calls through a mobile app (App) as part of the Service. Callers’ telephone numbers are recorded within the app and stored on servers which are located in Australia.
4.2 PSS holds and stores personal information within electronic documents called ‘Call Reports.’ These Call Reports are stored in ‘cloud-based storage’ at a data centre in Australia.
4.3 PSS also stores some paper-based ‘Call Reports.’ PSS maintains physical security measures over the documents.
4.4 All reasonable steps are taken to ensure that your personal information is stored securely and protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.
4.5 PSS takes steps to destroy information that we no longer require or to de-identify personal information that we are required to keep by law.
5 Collecting information from third parties
5.1 Wherever possible PSS will collect personal information from the individual directly via verbal communication. However, the telephone number of a caller to the Service is collected electronically through the App.
6 Use and disclosure
6.1 Personal information is gathered for the purposes of:
(a) providing the Service;
(b) managing the Service;
(c) evaluating the number and type of calls received in order to improve the Service;
(d) identifying trends in the type of support services required;
(e) developing appropriate training of PSS volunteers; and
(f) enabling strategic planning and development of the Service.
6.2 Personal information is used:
(a) to provide the best possible counselling service to the caller;
(b) for reasons related to the life and safety of the caller or a third party;
(c) to inform counsellor supervision, assessment and training;
(d) to support efficient and effective management of the Service; and
(e) to support strategic planning and service development.
6.3 The PSS may disclose a caller’s personal information if appropriate where there are Exceptional Circumstances, in which case personal information including the telephone number and (if the PSS holds this information) the address or location of a caller may be disclosed to third party organisations such as the emergency services in order to protect life and wellbeing.
6.4 PSS will not disclose your personal information for marketing purposes. PSS does not use or disclose your personal information overseas.
7 PSS Website
7.2 PSS has access to Google analytics which allows PSS to monitor the visitors to the website. PSS does not use any information gained from website analytics.
8 Third Party Websites
8.1 PSS’s website may contain links to third-party websites. PSS is not responsible for the content or privacy practices of any such websites that are linked to our website. PSS encourages individuals to read and familiarise themselves with the privacy policies of every website visited.
8.2 PSS uses Google analytics to monitor the visitors to our website. Based on your interactions with our website, Google and third party sites may elect to show you content and advertising that directs back to our website.
9 Data Quality
9.1 PSS takes reasonable steps to ensure that all information collected is accurate. All volunteers are trained and supervised in information collection practices.
9.2 Data is collected on a template contact record form with standard categories for all data in order to minimise anomalies and variations in approach.
10 Data Security
10.1 The information gathered during the telephone support session is confidential. Even though the information gathered on the contact record forms contains no identifiers they are held in a secure filing cabinet which is accessible only to authorised personnel. A computerised data base of call statistics is password protected.
11 Access and correction to personal information
11.1 Individuals may request access to personal information held by PSS. PSS will provide access and allow individuals to correct personal information and health information held about them, if they believe it is not accurate, complete or up-to-date.
11.2 PSS will respond within 30 days of a request for access to or correction of personal information.
11.3 Access to personal information will not be provided unless the person seeking access is the person to whom the information relates, or the law otherwise supports such access. In some cases, additional proof of identity information may be required, or access may be denied because ownership of a record cannot be proven.
11.4 PSS will decide on the most appropriate format and the manner in which to present the information to the caller. For example, with legitimate reason PSS may choose to provide a summary of information or discuss information with the caller, or only provide certain parts of the information.
11.5 PSS may withhold access to all or part of the health information on the record if there is a legitimate reason as enshrined as an exemption in Australian Privacy Principle 12, the Freedom of Information Act 1982 or any other law that allows or requires the request to be denied.
11.6 Requests for access to, the correction of or the deletion of personal information can be made by contacting PSS’s Privacy Officer. The details of PSS’s Privacy Officer are as follows:
12 Making a complaint
12.2 We take all complaints seriously. The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
12.3 If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
12.4 In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
12.5 If you are not satisfied with our handling of your complaint, you may contact the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992, by email email@example.com or by using the contact details on the OAIC website.
Many thanks to Meridian Lawyers.