ABN: 32 003 520 072

The Royal College of Pathologists of Australasia Quality Assurance Programs Pty Ltd, referred to here after, as QAP respects the rights of individuals to privacy and the confidentiality of information about individuals it deals with.

QAP is bound by the National Privacy Principles ("Principles") contained in the Privacy Amendment Act 2000 ("Privacy Act"). The Principles are designed to protect the confidentiality of personal information and the privacy of individuals by regulating the way personal information is managed by certain private sector organisations, including QAP.

In summary, the Principles define "personal information" as information or an opinion relating to an individual, which can be used to identify that individual.

If you have questions about QAP and privacy, wish to provide feedback about this policy, would like to update your personal details held by QAP or wish to access personal information held by QAP about you, please contact the Privacy Officer using the contact details below.

QAP Services

The QAP is a stand-alone independent company that:

• Provides External Quality Assurance Programs to pathology laboratories in each pathology speciality in order to help raise the quality of the participating diagnostic laboratories.
• Provides competency- based training and education via seminars, web-based programs and virtual microscopy.
• Provides advice on quality assurance issues.
• Collaborates with NATA - Australia’s national laboratory accreditation body, Department of Health and Ageing and various medical/scientific professional associations in establishing policy and documentation for the quality provision of pathology services.

Why Does QAP Collect Personal Information?

As a matter of conducting its routine business, QAP may collect personal information from the following individuals:

• Authorised representatives.
• Laboratory/facility contacts enrolling in programs.
• Provides advice on quality assurance issues.
• Laboratory/facility personnel enrolling in programs.
• Donors (patients with specific pathological diagnoses) of tissue and body fluids
• QAP advisory and committee members/technical advisers.
• Board members and company directors
• NATA, DOHA and professional body members.
• Third party agents or distributors of QAP services and products.
• Training course and seminar registrants.
• Suppliers of services and products to QAP.
• QAP employees and contractors.
• General members of the public who voluntarily give such information.

If you choose not to provide personal information we may not be able to provide you with the services you require or we may not be able to appoint you to a position (e.g. committee member) for which you have been nominated.

Types of Personal Information

The personal information held by QAP will vary depending on your relationship with QAP.

For clients and external collaborators, it may include the following:

• Name; position; professional qualifications
• Business address and contact details (including phone, fax, mobile, email)
• Business ABN
• Memberships of professional associations
• Sales history
• Credit references
• Survey/questionnaire results
• Records of complaints and enquiries
• Key performance indicator metrics

For Donors of body tissues and body fluids it may include the following:

• Treating clinician’s name
• Name
• Address/phone number
• DOB
• Hospital accession (UR) number
• Test results
• Limited medical notes
• Donor’s consent Form

For employees, Board members, contractors, directors, advisory/ technical committee members and providers of quality assurance materials, it may include the following:

• Name
• Address / phone number
• Date of birth
• Educational/employment history
• Job performance metrics
• Bank details and rates of pay
• Tax file number
• Next of kin
• Signature
• Curricula Vitae
• Confidentiality agreements
• OHS, workers compensation and vaccination status
• NATA accreditation status

This information is required to assist in the selection process for job suitability, for payment of wages, superannuation and taxes, and for workers compensation claims. Employee data may also be disclosed to third party certification bodies during audits for the purpose of validation of the quality management system.

Collection of Personal information

QAP may collect personal information in a number of ways including:

• Directly when information is provided in person or in documents such as an enrolment or application forms. Questionnaires/surveys.
• When you use the QAP website for enrolment, results entry and for general information content.
• From publicly available sources of information.

The information that QAP will collect about you when you use the QAP website will depend on how you use the facilities offered by the QAP website.

If you visit an unsecure area of the website (that is, an area where you are not required to log on) to read, browse or download information, the system will record the date and time of your visit to our site, the pages viewed and any information downloaded. However, our systems will not record any personally identifiable information.

If you need to access any secure area of the QAP website, you will be required to apply for access using appropriate request forms. The information you provide using these forms is only used by QAP to check your identity and eligibility for access to the secure areas and is not used for any other purpose.

The QAP website offers a number of interactive facilities including search engines, enrolment, result entry as well as online enquiry forms. Other than from enrolment and enquiry forms, QAP generally does not capture any personal information that you may enter when using these tools. If you complete an online enrolment or enquiry form, we will only collect the information that you enter into the online form.

The QAP may collect IP addresses for the purposes of systems administration and to audit the use of our site. We do not ordinarily link a user’s IP address to personally identifiable information of that user. However, we may use IP addresses to identify users of our site when we feel it necessary to enforce compliance with the site’s terms of use, or to protect our service, site or other users.

How does QAP use personal information?

QAP is bound by the National Privacy Principles and as such uses information for the following primary purposes for which it was collected, including:

• To conduct and provide the services described above.
• To administer and manage those services including charging, billing, collecting debts and monitoring performance.
• To seek feedback from you on ways to improve our services and products through surveys and questionnaires.
• To respond to your queries or feedback.
• To comply with legal and regulatory obligations.
• To provide you with information on QAP’s activities and services.
• To select and monitor performance of its employees.

Who is the personal information disclosed to?

Personal information may be disclosed to third party organisations outside QAP.

Generally, we require that organisations outside QAP who handle or obtain personal information as service providers to QAP acknowledge the confidentiality of this information; undertake to respect an individual’s right to privacy and comply with the National Privacy Principles and this Policy. QAP does not, however, accept responsibility for the misuse of any personal information by third party providers.

In summary information may be disclosed to:

• Related companies (including agents) or subsidiaries of QAP for the same purposes listed above.
• Government and regulatory authorities and other organisations, as required or authorised by law
• Government and regulatory authorities and other organisations with which QAP has a formal agreement or obligation.
• Professional advisers including accountants, auditors and lawyers.
• Credit providers.
• Contractors engaged by QAP to provide services in connection with the purposes described above
• The Taxation Department

QAP does not sell or licence your personal information.

Management and Security of Personal information

QAP senior management oversees QAP’s management of personal information in accordance with this Policy and the relevant Privacy Act and regulations.

All data that is collected is held electronically on password-protected systems or in paper-based files.

These facilities and records are located on site at our premises or archived off-site in a secure location. Security is a high priority and our sites are well secured and alarmed. Personal information is only accessible by persons that require access to that information to carry out their work. QAP has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure from unauthorised access or disclosure.

QAP takes steps to preserve the security of personal information collected when you use our website. Unfortunately, no data transmission over the Internet can be guaranteed as totally secure. Accordingly, although QAP aims to protect such information, QAP cannot ensure or warrant the security of any information you transmit to us or from our online products or services and you do so at your own risk.

Updating Personal Information that QAP holds about you

QAP endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. Please contact the privacy Officer if you believe that the information QAP holds about you requires changing or becomes out of date.

Accessing Personal Information that QAP holds about you

You can, in most cases, access the personal information QAP holds about you. You can also indicate that you wish QAP NOT to collect any particular information about you or NOT to use it for any particular purpose. You may also be removed from any electronic databases or email lists if you wish.

If you wish to do any of the above, please contact the Privacy Officer as set out below. Written requests are preferred.

Complaints or Enquiries

If you have a complaint, general enquiry about our information handling procedures or wish to offer suggestions about them,

You can do this by contacting QAP’s Privacy Officer:
Paul Cohen
Ph: +612 9045 6004
Fax: +612 9356 2003
E-mail: paul.cohen@rcpaqap.com.au
Website: www.rcpaqap.com.au