This document sets out the policy of ProVision Eyecare Pty Ltd (“ProVision”) in relation to the collection and handling of personal information. It applies to all members, staff and other individuals. Further information about our information handling processes may be available on request.
The term “personal information” refers to information from which an individual’s identity can be reasonably ascertained. It includes information such as an individual’s name, address, telephone numbers, email addresses, date of birth, credit and banking details and if and where applicable includes “sensitive information” such as health information.
In this policy the term “member” means optometrists who are members of ProVision and “personal information” in the context of a member means personal information about the individuals within that practice.
ProVision treats all personal information it collects in accordance with the Privacy Act 1988 and the Australian Privacy Principles.
Collection and use of personal information
ProVision collects and uses personal information (such as name, email address, contact details) of individuals who make enquiries through its website, over the telephone, face to face, through email or in other written communications. ProVision uses these types of personal information for the purposes of responding to such enquiries and otherwise for the purpose for which the contact is made or information is provided. ProVision also may collect use and display information provided by individuals through social media in circumstances where it can be inferred that the individual consents.
ProVision collects and uses personal information of members to represent the individual interests of members, to provide them with the business services and products needed to keep them competitive and profitable. and to the extent necessary (and with the consent of the individuals concerned) the independent full scope optometry profession.
Information ProVision collects about members includes:
- The member’s name
- Contact address(es), phone number(s) and contact email address(es). Contact addresses may include practice or work addresses, home address where supplied by the member, and postal address.
- Date of birth
- Date of joining ProVision
- Optometry Australia membership details
- Membership category or type
- Payments for purchases
- Member’s key staff names, positions, phone number(s) and contact email address(es).
- Information about a member’s Continuing Professional Development (CPD) completed with ProVision to provide to Optometry Australia.
- Purchases through ProVision preferred suppliers including laboratories, contact lens and frame suppliers(to the extent personal information is involved)
- Traffic and purchases within ProSupply, ProVision’s B2B frame ordering website (to the extent personal information is involved)
- Monthly retail data for members of ProVision’s comprehensive membership program (to the extent personal information is involved)
- Marketing orders through My Local Marketing, ProVision’s web to print marketing site (to the extent personal information is involved)
- Contact history including notes on all ProVision services/programs provided/attended and related business results (to the extent personal information is involved)
We may collect additional personal information where this is provided or supplied by a member, including:
- Optometry professional interest areas
- Endorsements (such as Scheduled Medicines Endorsement)
- Memberships/fellowships of optometric organisations
- Hours worked
- A member’s practice position
- Information for benchmarking purposes including salaries, hours worked, leasing, sales, profitability with the member’s permission
- Information in relation to the sale or refit of a member’s existing practice or purchase of a new practice
- Personal testimonials and prospective member referrals
A member may elect to provide, or not provide, any of this additional information.
The specific uses to which ProVision puts members’ personal information includes to develop, coordinate and implement ProVision’s business services and products, to communicate, provide and inform members of services that are available from ProVision, to support the business needs of members, to manage member monthly accounts, as a source of information for both the members and the public.
ProVision obtains a member’s personal information primarily from the member themselves, although ProVision also obtains personal information about members from preferred suppliers and other publicly available sources where it is reasonably necessary to do so and it is permitted under the Privacy Act.
Use and Disclosure of Personal Information
ProVision may use and disclose personal information of individuals for purposes such as for responding to enquiries, conducting financial transactions and sending marketing materials in circumstances where the individual has asked for or reasonably expects to receive marketing materials (and where opt-out mechanisms exist).
ProVision may use and disclose personal information about members to third parties for the purpose for which that information was collected and also for related purposes that could reasonably be expected by the member. For example, ProVision may disclose the personal information of members to third parties in the following circumstances:
- to advise ProVision membership status with preferred suppliers of laboratories, contact lenses and frames so that members receive preferential discounts and terms negotiated between ProVision and preferred suppliers.
- to publish an online directory of ProVision optometrists to enable members of the public to obtain information about ProVision optometrists in Australia and the ability to make direct contact or process an appointment request.
- to provide access to other ProVision online assets including an intranet, B2B frame ordering (ProSupply) and web to print marketing (MLM)
- to conduct benchmarking studies from time to time for the purpose of identifying business opportunities for participating members eg. financial benchmarking.
- to enable a supplier to determine whether to continue to supply products to a particular member.
Members may opt out of having those details published in ProVision’s website by notifying ProVision in writing.
Other possible use and disclosure of personal information by ProVision includesthe supply of member information to a third party, for the purposes of providing members with information on membership benefits available to them through direct marketing activities. This will be done under a signed agreement to be entered into between ProVision and that third party prior to the disclosure of any member information, restricting the use of personal information to that specific purpose.
Data quality and security
ProVision will take reasonable steps to ensure that the personal information it collects is accurate, complete, up-to-date and secure. (It requests individuals (including members) to contact ProVision directly if they have any concerns or require changes to or corrections of their personal information.)
The personal information of members is stored on servers that are protected in controlled facilities locally and a secure cloud server based in Singapore. Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. Although ProVision strives to protect such information, ProVision does not warrant the security of any information transmitted to it over the internet and members do so at their own risk.
ProVision takes all reasonable steps to ensure that access to personal information is restricted to those within the organisation who have a need to know.
Access to and correction of personal information
Members and other individuals may request access to, and ask ProVision to make corrections to the personal information that ProVision holds about them.
This can be done:
- In writing (e.g. by email)
- In person
- By telephone (in this case, ProVision’s staff will ask relevant questions to confirm the identity of the caller)
ProVision will, on request, provide a member with access to the information it holds about that member, unless there is an exception which applies under relevant privacy laws. If ProVision refuses to provide access to the information, it will provide reasons for the refusal and inform the member of any exceptions relied upon.
If the personal information ProVision holds about a member is inaccurate, incomplete or out of date and the member asks ProVision to correct this information, ProVision will take reasonable steps to either correct this information or if necessary discuss alternative actions with the member.
ProVision will not adopt, use or disclose any identifier assigned to an individual or member by a government agency, except where required by law.
It is an individual’s right to be dealt with anonymously, provided that it is lawful and practicable. ProVision will try to accommodate this wherever possible. However, it may not be possible for ProVision to fully comply with any request for service or information that the individual may request, without access to that individual’s personal information.
Transborder data disclosure
ProVision does not disclose personal information outside Australia.
ProVision does not normally collect sensitive information (as defined under the Privacy Act), such as information about the health status of members or other individuals. If it is necessary to collect sensitive information, it will be done in accordance with applicable laws. Further, in accordance with the Australian Privacy Principles, ProVision will not collect sensitive information about an individual (including a member) unless that person consents to the collection of the information and the information is reasonably necessary for one or more of ProVision’s functions or activities.
Requests, Complaints or Questions about privacy and personal information
If a person (including a member) wishes to gain access to his or her personal information, has a complaint about a breach of privacy or has any questions on how their personal information is collected or used, they can forward a request, complaint or question to the address below:
ProVision Eye Care Pty Ltd
Attention: National Privacy Officer
PO Box 1226
CLAYTON VIC 3169
Or (03) 8544 3900
Or by email: firstname.lastname@example.org and marked attention National Privacy Officer.
ProVision will assess each such request, complaint or question in relation to , and respond to a member’s request, complaint or question within 14 days.