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The PMCV privacy policy

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Privacy Statement

THE PMCV PRIVACY POLICY

ABOUT PMCV AND THIS POLICY

Our obligations under privacy laws

The Postgraduate Medical Council of Victoria Inc ABN 11 296 600 377, Association number A0038523M (“PMCV”) is a non-profit association established to support the education, training and career development of hospital medical officers and hospital administrative staff.

The PMCV is committed to protecting the privacy of those involved in its processes. PMCV is bound by the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles (“APPs”) in respect of personal information. PMCV has adopted these principles as part of its business procedures and operations.

Where PMCV works with Victorian public sector bodies, it may also be required to comply with the Information Privacy Act 2000 (Vic) ("IP Act") and the Information Privacy Principles ("IPPs").

Matters covered by this Allocation and Placement Service privacy policy

PMCV owns an Allocation and Placement Service system ("APS System") and provides it to assist the Victorian Department of Health & Human Services and others.  The APS System provides for online matching and assistance for candidates/applicants ("participants"), including students, graduates, health professionals, hospital administrators, hospitals and other health services to match them with relevant positions in hospitals, health services and other organisations ("health organisations"). PMCV also develops accreditation processes and standards in connection with its work and the APS System.

This policy explains how PMCV protects the personal information of the participants that PMCV assists in connection with the APS System, along with how PMCV:

  • collects, uses and discloses that personal information;
  • allows persons to access/correct their personal information; and
  • manages complaints in respect of that personal information.

In this policy:

  • personal information” means information that can be used to identify an individual, and can include a name, address, date of birth as well as sensitive information; and
  • sensitive information” means information relating to health, religion, race or ethnic origin. 

Matters covered by general privacy policy

Aside from the APS System, PMCV also provides a number of other services, including providing members, stakeholders and others with access to information, education and training materials and details of other relevant news and events. PMCV also conducts research and undertakes projects on a range of issues affecting health professionals.

This policy does not cover the protection of personal information in the course of those activities.  Please refer to PMCV’s general privacy policy, which is available for viewing at the PMCV website: http://www.pmcv.com.au 

TYPES OF PERSONAL INFORMATION COLLECTED BY PMCV

Participants

PMCV collects personal information regarding participants in the APS System, including their:

  • name, date of birth, contact details;
  • residency status;
  • placement preferences;
  • Medical Board of Australia Registration Number, Medical Intern Placement Number;
  • current and past education;
  • qualifications and employment history (along with other information included in their curriculum vitae); and
  • referees details and referee feedback.

PMCV may also collect sensitive information (in particular health information) from participants, including those who apply for special consideration. This information is kept outside of the APS system.

Referees

PMCV collects personal information of referees, including their name, phone number, email address or other contact details, current position held and employing organisation.

Website visitors who are not registered participants

For visitors to the APS System website who are not registered participants, PMCV will collect information such as the visitor’s IP address, internet service provider, the web page directing that visitor to the website and the visitor’s activity on the website.  This information is usually anonymous and PMCV does not use it to identify individuals.  However, due to the nature of internet protocols, such information might contain details that identify those visitors.

HOW PMCV COLLECTS PERSONAL INFORMATION

Generally, PMCV collects personal information directly from individuals and their representatives as part of placing participants using the APS System unless it is unreasonable or impracticable to do so.

Participants

PMCV generally collects personal information directly from participants when they register or submit information on the APS System website or from other material provided by the participant, including their Candidate Priority List or curriculum vitae. Additional information Such as Academic Transcript may be required and held outside of the APS system. We may also collect personal information directly from participants through phone calls, emails, website forms or in person enquiries, including at careers expos and similar events attended by PMCV. Where a participant applies for special consideration, PMCV may collect sensitive information about that individual from that individual. This information is kept separately to the APS system. PMCV may also collect a participant’s personal information from their referees. In some cases, PMCV collects a participant’s personal information from public sources (for example national health practitioner register, internet) or through their memberships (for example peak bodies).

Referees

PMCV initially collects personal information about referees from participants who nominate those referees, then directly from referees (including through the Referee Assessment Form completed by referees).

Website visitors who are not registered participants

PMCV collects data from our APS System website using various technologies, including cookies.  A cookie is a text file that our website sends to your browser which is stored on your computer as a tag identifying your computer to us.  You can set your browser to disable cookies.  However, some parts of the APS System website may not function properly (or at all) if cookies are disabled.

Others

In some cases, PMCV collects information about individuals:

  • through forms or agreements;
  • through phone, in person or online enquiries through the “Contact PMCV” function on the APS System website;
  • from researchers or contractors engaged by PMCV; and
  • from public sources, such as the national health practitioner register.

PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED AND USED

PMCV generally only uses personal information for the primary purpose for which it is collected, as set out under each heading below, or a secondary purpose related to the primary purpose for which you would reasonably expect PMCV to use the collected information.

PMCV will make you aware of the purpose for which it collects your information by notifying you about all the relevant matters of that collection. 

PMCV will not use your information for an unrelated secondary purpose unless PMCV obtains your written consent, is permitted to do so under the Privacy Act or another exception applies.  Examples of exceptions could include where it is impracticable to obtain your consent and PMCV believes that collecting, using or disclosing your information is necessary to lessen a serious threat to the life, health or safety of any individual.  

Participants

PMCV collects personal information about participants in order to operate the APS System and specifically to allow for applicants to be matched to available positions at health organisations in accordance with PMCV’s computer matching algorithm.

The information collected is also used by PMCV to:

  • communicate with participants, including providing confirmation of applications, notification of additional information required, confirmation of the information provided, reminders and allocation offers;
  • maintain your personal information, our participant records and other registers;
  • liaise with referees where needed;
  • improve our services, in particular the APS System, through monitoring, quality improvement activities, audits, surveys and program evaluations;
  • undertake training, education and research for the APS System; and
  • use de-identified information to model or forecast service.

Referees

PMCV collects personal information about referees for the primary purposes of verifying the participants experience and communicating with referee’s regarding the Referee Assessment Form.

Website visitors who are not registered participants

PMCV uses information regarding website visits for the purposes we collected it.

Others

PMCV may also collect and use personal information from others for our operational, human resources, research, referral or other corporate activities in connection with the APS System.

DISCLOSURE TO THIRD PARTIES

Generally, PMCV only discloses personal information:

  • for the primary purpose for which it was collected;
  • for purposes related to the primary purpose;
  • when permitted by the Privacy Act and its APPs (and IP Act and IPPs, where applicable);
  • with your consent; or
  • when needed for law enforcement.

Referees

PMCV will provide relevant details of participants to referees in order to enable the referee to comment on the participant’s experience. 

Health organisations

In the course of operating the APS System, relevant personal information is provided to health organisations, and others involved in these processes, including any providers of relevant intern training programs.

We disclose this information for the purpose of allowing those entities to:

  • make selection and ranking decisions;
  • communicate directly with participants who apply for their programs or positions, including requesting further information and providing employment contracts;
  • undertake standard employment processes in relation to participants who apply for their programs or positions.

PMCV asks health organisations participating in the matching service to undertake to use the information provided only for selection purposes and not to disseminate any personal information to any other persons not involved in the selection process.

A health organisation may retain a candidate’s curriculum vitae and Referee Assessment Forms if that candidate is matched to, or accepts, an unmatched post. Documentation submitted by candidates who were not matched or offered a post, will be destroyed after the finalisation of any appeals process in accordance with legislative requirements. Hospitals and health services will receive details of all candidates matched to all hospitals and health services participating in this process. This information may be used only to verify the status of candidates, and for no other purpose.

Regulators and audit bodies

PMCV may disclose personal information of participants or others to the Department of Health & Human Services, in accordance with our reporting obligations or in order to allow the Department to participate in the National Audit of Internship Acceptances (“National Audit”).  PMCV may also disclose personal information directly to the Data Manager or others involved in the National Audit, so that they may perform their audit and other functions, including the Late Vacancy Management Process.

PMCV (or other organisations) may disclose personal information to regulators or auditors of health organisations on a strictly confidential basis to enable the regulator or auditor to satisfy itself that the matching was done lawfully and fairly.

Researchers and others

With the participant’s consent, PMCV may share and disclose relevant information with other similar bodies both nationally and in other states and territories for the purposes of research and general information sharing in respect of data matching processes, intern arrangements, and other related purposes. PMCV will endeavour to ensure that such other bodies will receive and hold identifying information on a basis similar to that upon which PMCV holds and protects such information.

We may also disclose personal information to:

  • State or Territory databases (where an applicant is not allocated to a position in Victoria), for the purpose of creating possible allocations to unfilled positions or casual vacancies that may arise from time to time;
  • third party service providers;
  • funders or regulatory authorities, accreditation authorities or other government departments; and
  • professional advisers, and courts or tribunals where required by law.
  • De-identified and summary information may be communicated to the public.

The PMCV will under no circumstances sell or receive payment for licensing or disclosing your personal information.

Cross-border disclosure

PMCV’s technology infrastructure may make use of cloud infrastructure or servers located outside Australia.  This means that PMCV may disclose and store your personal information outside Australia, taking such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Privacy Act or the APPs in respect of your personal information.

Wherever reasonably practicable, PMCV will first seek your consent to such cross-border disclosure.  Please note that where you consent to such cross-border disclosure, PMCV will be exempt from the requirements of the Privacy Act in relation to such disclosed information.  Where it is not reasonably practicable for PMCV to obtain your consent PMCV will otherwise comply with the requirements of the Privacy Act.

DIRECT MARKETING

PMCV may send you direct marketing about:

  • improvements or changes to the APS System;
  • opportunities being offered through the APS System; or
  • its other projects, activities, services and health system developments.

If PMCV collected your details from you personally, PMCV will reasonably expect that you agreed to receive direct marketing.  PMCV will offer an opt-out procedure so that you can unsubscribe from all future marketing communications.

If PMCV proposes to use information about you collected indirectly to send you direct marketing, PMCV will seek your consent unless an exception applies under the Privacy Act.  If you do not wish to receive any direct marketing, please contact PMCV to opt-out at any time.

Please note that PMCV will also comply with other laws that are relevant to direct marketing, including the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

IF YOU DO NOT PROVIDE PERSONAL INFORMATION

You are not required to give PMCV all the kinds of personal information listed above.  However, if you choose not to provide the information, this may limit your ability, particularly in respect of the participants, to use the APS System.

In relation to participants and referees, the matching service cannot be provided on an anonymous basis.  If you do not provide the minimum required personal information, you will not be able to use the APS System.  If you do not provide full and complete information, this may limit your prospects of being matched to a position.

MAINTENANCE AND SECURITY OF PERSONAL INFORMATION

All personal information is securely stored by PMCV using appropriate physical and/or electronic security technology, settings and applications, and by ensuring staff dealing with personal information are trained in our privacy policies and procedures. These policies are designed to protect personal information from unauthorised access, modification or disclosure, and from misuse, interference and loss.

There are always inherent risks in transmitting information via the internet and PMCV does not have the ability to control the security of information collected and stored on third party servers.  However, in relation to PMCV’s own servers, all reasonable steps are taken to ensure data security. PMCV takes reasonable measures to destroy or permanently de-identify personal information when it is no longer required. 

ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

All registered users of the APS system can log in and update their personal information and all information regarding their registration details except for their eligibility criteria.

If there are difficulties accessing the system individuals can contact PMCV if information held about them is incorrect or has changed and request that it be updated. PMCV will respond to all requests to update details within 10 working days.

COMPLAINTS ABOUT A BREACH OF PRIVACY

If you are concerned that PMCV may have handled your personal information inappropriately or you wish to complain about a breach of your privacy, the complaint should be made in writing to PMCV’s Privacy Officer (see details below). All privacy complaints are to be taken seriously and PMCV will endeavour to deal with them promptly and in accordance with our general complaints procedures.

PMCV will acknowledge receipt of your complaint, and will endeavour to deal with your complaint and provide you a response within 30 days.  Some matters may require detailed investigation, and may accordingly take longer to resolve.  PMCV will provide you with progress updates in that case, and may seek further information from you.

PMCV may refuse to investigate or deal with a complaint if we think it is abusive, trivial or vexatious.

If you are dissatisfied with the outcome of your complaint, you may seek internal review of the decision.  Internal review will be conducted by a different person who has not previously been involved in your complaint.

If you are still dissatisfied with the outcome of your complaint after internal review, you are able to take your complaint to a privacy commissioner for resolution.

NOTIFICATION ABOUT A BREACH OF PRIVACY

Individuals registered on the APS system will be notified about data breaches if we believe they are likely to be at risk of serious harm. For example, the data breach may be likely to result in serious financial harm, or harm to their mental or physical well-being.

See https://www.oaic.gov.au/individuals/data-breach-guidance for more details on what a data breach is.

A data breach that is deemed to cause risk of serious harm will be notified by email at the earliest opportunity once identified. Information regarding the breach will also be posted on the APS system web site.

A data breach that is identified but is deemed will not be likely to cause risk of serious harm will not be notified.

UPDATES TO THIS POLICY

PMCV may change or replace this APS System privacy policy at any time.  Any changes to this policy will be published on the APS System website, as appropriate.

PRIVACY OFFICER

Attention:  Privacy Officer

Postgraduate Medical Council of Victoria Inc.

Postal address:PO Box 13330 Law Courts VIC 8010
Location address:Suite 801, Level 8 533, Little Lonsdale Street Melbourne VIC 3000
Telephone+61 3 9670 1066
Emailpmcv@pmcv.com.au

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