Privacy Policy

A Better Culture is an entity established by the Royal Australasian College of Medical Administrators (RACMA) and, as such, our privacy policy aligns with RACMA's.

1. Protecting your privacy

A Better Culture is committed to maintaining the highest standards of privacy protection.

This Policy outlines how A Better Culture collects, uses, discloses and handles Personal Information and describes the practices, procedures and systems it has in place for protecting privacy.

A Better Culture may be subject to the Privacy Act 1988 (Cth) and bound by the Australian Privacy Principles. Where A Better Culture conducts activities outside Australia, it or its Members may also be subject to privacy laws of the jurisdiction in which they are operating. For example, A Better Culture Members who handle Personal Information in New Zealand may be subject to the New Zealand Privacy Act 1993. However, even where A Better Culture is not bound by the privacy law of a jurisdiction, it strives to act consistently with the privacy principles and laws that apply wherever it operates.

In this Policy, unless the context indicates otherwise:

• ‘Personal Information’ means information about an identified individual, or an individual whose identity is reasonably identifiable, whether the information or opinion is true or not or recorded in a material form or not. A reference to ‘Personal Information’ includes Sensitive Information and Health Information.
• ‘Sensitive Information’ is Personal Information about an individual’s health, racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, professional or trade association/union memberships, sexual preferences and practices or criminal record.
• ‘Health Information’ includes information about an individual’s physical or psychological health, health services provided to the individual, or an individual’s expressed wishes about the future provision of health services.
• ‘A Better Culture Member’ includes a Fellow, Honorary Fellow, Associate Fellow, Candidate, Affiliate, and in this Policy also includes a trainee.
• A Better Culture Staff includes individuals who are employees or contractors of A Better Culture.

2. This Policy applies to all Members and Staff

A Better Culture Members and A Better Culture Staff must:

• at all times be aware of and support A Better Culture’s commitment to the protection of privacy;
• comply with this Policy, and with any privacy laws that apply in the relevant jurisdiction, when handling Personal Information about A Better Culture Members or A Better Culture Staff, or carrying out A Better Culture related functions or activities; and
• provide such assistance as A Better Culture may require to deal with inquiries and complaints about privacy.

3. A Better Culture’s collection of Personal Information

A Better Culture needs to collect a range of Personal Information to meet its objects and serve the needs of its Members.

A Better Culture therefore collects Personal Information about:

• A Better Culture Members and people applying to become A Better Culture Members;
• A Better Culture Staff and applicants for employment;
• service providers, contractors and other individuals who perform functions for or on behalf of A Better Culture;
• people associated with A Better Culture Members or applicants for membership (such as referees, supervisors and colleagues); and
• business partners, consumer representatives and other stakeholders.

What Personal Information does A Better Culture collect?

The types of Personal Information A Better Culture collects will depend on the type of service being provided and/or the function(s) being performed.

For example, when a person applies to or becomes:

• become a A Better Culture Reference Group Member;
• become a A Better Culture Working Group Member;
• participate in an A Better Culture program or webinar; or
• attend an A Better Culture event.

A Better Culture is likely to need to collect a range of Personal Information in order to consider the application and manage the membership, programs, and events. The information A Better Culture needs to collect may include:

• personal and business contact details;
• banking and/or credit card details;
• names and contact details of referees and/or previous employers;
• education and training history;
• qualifications, specialisations and interests;
• information about professional memberships; and
• information about Medical Board or other relevant registration.

From persons attending events or participating in programs or activities, A Better Culture may collect information about dietary requirements and travel needs.

For persons who are, or are applying to become A Better Culture Staff, or service providers or contractors, A Better Culture needs to collect Personal Information relevant to the appointment or engagement. A Better Culture will also collect information about business partners and stakeholders to the extent necessary for the purpose of its relationship or dealings with them.

Where it is practicable to do so, A Better Culture will allow individuals to deal with it anonymously or using a pseudonym. However, this will usually only be possible in the case of very general or preliminary inquiries.

A Better Culture may collect information from Members who participate in surveys or provide feedback. Some of these activities are carried out on an anonymous basis and some are not, depending on the nature of the survey.
A Better Culture tries only to collect Personal Information to the extent that it needs to do so to carry out its functions or activities. Therefore, if the Personal Information A Better Culture asks for is not provided, A Better Culture may not be able to progress an application, provide services to its Members or otherwise provide the assistance being sought.


4. How A Better Culture collects Personal Information

Most of the Personal Information A Better Culture needs to collect about Members and applicants for membership is collected directly from the individual concerned.

However, A Better Culture may also collect Personal Information from third parties, such as referees, employers or colleagues of the Member or applicant for membership. A Better Culture will only do this with consent. 

A Better Culture may also collect Personal Information about people associated with Members and applicants for membership, for example when an applicant or Member provides us with, names and contact details for referees. In this situation the applicant or Member must ensure that they only provide Personal Information about a third party with the knowledge and consent of that third party.

If A Better Culture receives a complaint or has reason to review or investigate the conduct of a Member, it may need to collect information about the conduct from other persons involved in the training or supervision of the Member. A Better Culture may be permitted by privacy law to do this without consent (for example, where it is necessary to lessen or prevent a serious threat to health or public safety, or to investigate unlawful activity or serious misconduct). Except where collection is required or authorised by the Privacy Act or another law, A Better Culture will only do so with consent.

A Better Culture may collect Personal Information in person, in writing, by email, by telephone and through its website. For Members and applicants for membership, the means by which A Better Culture collects information will depend on the circumstances. For example, Personal Information may be collected through website form or surveys, via email, through participation in programs and events and direct dealings with our staff. 

5. What do we tell people when we collect Personal Information?

If A Better Culture collects Personal Information, it is required to take reasonable steps to ensure that the individual is aware of certain details relating to the collection. This applies whether the information is collected directly or indirectly.

Most A Better Culture forms include a notice setting out that information, either printed on the form or displayed on the on-line portal through which the information is collected.

This notice will usually either include, or provide a link to, information about:

• the purposes for which we are collecting the information in the particular circumstances;
• the types of individuals or organisations to which such information may be disclosed;
• the consequences of A Better Culture not being able to collect the information;
• any law that requires the information to be collected;
• whether the information is likely to be disclosed to recipients outside Australia, and if practicable, the countries where they are located;
• obtaining access to Personal Information A Better Culture holds; and
• making a privacy complaint.

6. Use and disclosure of Personal Information

A Better Culture uses Personal Information about Members and applicants for membership for a range of purposes, including:

• processing applications for Membership to its Reference and Working Groups;
• updating, maintaining and administering our membership base;
• providing training and professional development to our staff;
• monitoring professional performance and investigating complaints;
• monitoring, evaluation and quality assurance of A Better Culture programs and services; and
• procuring funding and other forms of support for A Better Culture’s services and activities.

Personal Information about people other than A Better Culture Members (including staff, service providers and stakeholders) is used for a range of corporate purposes, such as employment and management of staff, contracting and procurement and stakeholder relations.

A Better Culture discloses Personal Information about Members and applicants to a range of external bodies, and in limited cases to the public generally, for purposes that are related to the services it provides.

A Better Culture may, with permission, publish on its website a list of Advisory Board Members, Working Group and/or Reference Group Members.

Where A Better Culture needs to contact or collect information about a member from a third party (for example referees or professional colleagues) Personal Information about the member or applicant may be disclosed to that person. We only do this with the consent of the member or applicant.

If you subscribe to A Better Culture’s mailing list, we may use your contact details to send you news and information about A Better Culture and details of services that we think may be of interest. If at any time you decide that you no longer wish to receive this sort of information, let us know and we will remove your details from the mailing list.

A Better Culture may also disclose Personal Information:

• when required or authorised to do so by court order or other legal requirement, for example; for the purpose of dealing with a risk to health or safety, to investigate suspected unlawful activity or serious misconduct and other purposes authorised by law;
• to its business partners, external service providers (including IT contractors), professional advisers and other entities who assist it in administering its membership base and providing services; and
• to Government agencies responsible for funding programs in which A Better Culture Members participate. This information is generally provided in de-identified form. A Better Culture will not provide identifying information without consent.

7. Disclosing information to persons outside Australia

A Better Culture does not use data centres, cloud computing providers or other IT services which would require disclosure of Personal Information to persons outside Australia.

8. How does A Better Culture hold and protect Personal Information?

A Better Culture holds Personal Information in electronic databases. A Better Culture's information systems and files are protected by a range of security measures. For example:

• Electronic systems are password protected and email systems use encryption software to limit the risk of unauthorised or accidental disclosure.
• Graduated access controls are used to limit access of A Better Culture Members and A Better Culture Staff to those areas of the network to the extent necessary for them to perform their role, with levels of access being determined by senior managers.
• A Better Culture utilises RACMA's network of secure servers, with back up services provided by a an external service provider with industry standard security measures in place.
• A Better Culture Staff must close computers when not in use.

A Better Culture makes every effort to ensure that the Personal Information it holds remains up-to-date and is used and disclosed appropriately.

A Better Culture periodically reviews its files and databases to ensure that the information it holds about Members is up-to-date and accurate. Information that is not required for operational purposes is archived. Records containing Personal Information are retained for 7 years and then culled.

A Better Culture Members, A Better Culture Staff and any other person involved in training and assessment activities must comply with the following requirements:

• Appropriate standards of confidentiality must be maintained at all times when dealing with Personal Information about trainees and candidates. Personal Information must not be accessed, used or disclosed except to the extent necessary to carry out the activity for which the information is required.
• Any issues relating to the conduct or performance of a trainee or candidate must be treated with the utmost sensitivity. Any performance issues, breaches of standards or breaches of A Better Culture policies or codes of conduct must be handled as far as practicable in a manner which ensures confidentiality.

9. Accessing and correcting Personal Information held by A Better Culture

Subject to any legal restrictions, A Better Culture will let you know what Personal Information it holds about you if you ask. If your request is particularly complex, or requires detailed searching of records, there may be a cost to you in order for us to provide this information.

If you believe there are errors in our records about you, we will investigate and correct any inaccuracies. All requests for access to Personal Information held by A Better Culture should be made to A Better Culture’s Privacy Officer (contact details below).

If you want to access Personal Information on behalf of another person, you will need to obtain the consent of that person prior to making a request.

10. Dealing with A Better Culture on-line

This Policy also applies when you use A Better Culture’s website or provide information to A Better Culture via the internet. There are inherent risks in transmitting information across the Internet. A Better Culture cannot ensure the security of Personal Information sent to it via on-line channels. However, once we receive Personal Information on-line, we take steps to protect that information in accordance with this Policy. If you are concerned about conveying Personal Information to A Better Culture over the Internet, you may prefer to contact us by telephone.

Our website may use cookies and web beacons. A cookie is a small piece of code that is placed on your computer. A web beacon is a piece of code that is placed on each page that communicates the cookie’s content once the page is visited. Cookies and web beacons may collect the information about each page of the website that you visit, your server address, the type of browser you are using, your operating system, your top level domain name and the date and time that each page is accessed. Use of cookies and web beacons does not involve the retrieval or recording of any Personal Information (such as a name or email address) by A Better Culture. To the extent that this data could make you identifiable, A Better Culture will not attempt to identify you from these records. The information is used for the purpose of website management and development only.

A Better Culture undertakes surveys from time to time using Survey Monkey or similar technologies. Some surveys are conducted anonymously. However, when you submit a survey response using this technology, a record is made of the IP address for the computer used to complete the survey. A Better Culture does not attempt to identify survey respondents from this information.

A Better Culture’s website contains links to other sites and resources. This Privacy Policy does not apply to, and A Better Culture is not responsible for, the use of, or the protection of Personal Information provided to other websites linked to our website.

11. Complaints and further information

If you believe your privacy has been interfered with and wish to make a complaint, you should contact RACMA’s Privacy Officer (contact details below). Any complaint will be investigated in accordance with A Better Culture and RACMA's complaints procedures, which are available on its website.

If the complaint indicates that there has been an interference with privacy by a person other than A Better Culture, the complaint may be referred to or discussed with that other person in an attempt to resolve it. You may also make a privacy complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).

If you would like further information or have questions or concerns about A Better Culture’s handling of Personal Information, please email info@abetterculture.org.au.