- Key definitions
- What Personal Information do we collect?
- Can you deal with us anonymously?
- How do we collect your Personal Information?
- Why do we collect, hold, use and disclose Personal Information?
- Disclosure of Personal Information overseas
- How we protect your Personal Information
- Accessing and Correcting your Personal Information
- How to make a privacy-related complaint
- Contact us
This Privacy (“Policy”) covers Dietitians Australia’s collection, holding, use and disclosure of Personal Information.
Dietitians Australia has adopted the definitions given to ‘Personal Information’ and ‘Sensitive Information’ as outlined in the Privacy Act 1988 (Cth) (“the Privacy Act”). A brief summary of these terms are:
‘Personal Information’ means the information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion
‘Sensitive Information’ is a subset of Personal Information and includes (but is not limited to) information or an opinion about an individual’s:
- Racial or ethnic origin; or
- Political opinions; or
- Membership of a political association; or
- Religious beliefs or affiliations; or
- Philosophical beliefs; or
- Membership of a professional or trade association; or
- Membership of a trade union; or
- Sexual preferences or practices; or
- Criminal record; or
- Health information about an individual; or
- Genetic or biometric information about an individual that is not otherwise health information.
What Personal Information do we collect?
The information we collect depends on the nature of your interactions with us. Dietitians Australia collects both personal information and non-personal information, from:
- our members, potential members, business associates and their personnel
- allied health professionals, government agencies and professional bodies
- our suppliers and their personnel
- our employees, partners, contractors, former employees and former members
- former prospective members, former business associates and their personnel
The personal information we may collect includes: name, postal address, email address, phone number, credit or debit card information, age, gender, username and password (if applicable), your education history and qualifications, workforce and employment related information, testimonials, feedback, documents to verify your identity (for example, driver’s licence, Medicare card, Medicare provider number), languages spoken, any accessibility requirements and other information to assist Dietitians Australia in conducting our business, providing and marketing our services and meeting our regulatory and legal obligations. Dietitians Australia may collect additional information from its employees, such as tax file numbers.
Dietitians Australia may also collect sensitive information such as health information, information about an individual’s membership of professional associations, and whether you identify as Aboriginal or Torres Strait Islander.
Dietitians Australia may also collect and process non-personal information provided by you or your browser when you visit our website. This may include the website you came from, your location information, IP address and the time and date of access.
Can you deal with us anonymously?
There may be instances where you can interact with Dietitians Australia anonymously or by using a pseudonym for example. If you do not provide us with full information, we may not be able to properly assist you with your needs.
How do we collect your Personal Information?
We will only collect personal information by lawful and fair means and where the information is reasonably necessary to one or more of our functions or activities (as identified under ‘Why do we collect, hold, use and disclose personal information’ below).
Dietitians Australia will collect personal information from or about you in several ways.
- Directly. For example, while using our website, you may need to submit personal information to register for services, order products, post content or request assistance. We may also collect information directly from you through your emails with us, telephone, virtual or face-to-face meetings, interviews, applications for membership, registration, skills recognition, complaints, or accreditation.
- Indirectly. This may be through attendance at seminars, business cards, online queries, as well as our social media channels.
- From third parties. For example:
- through your employer (where your employer is a university seeking accreditation)
- through educational institutions, other dietetic associations, regulatory agencies, or former employers – where we are verifying your qualifications to practice as a dietitian or nutritionist
- To perform regulatory functions including to verify and validate information provided to us.
We will collect sensitive information with the relevant individual’s consent and where the collection is reasonably necessary for one or more of our functions or activities. An individual’s consent is not required to collect sensitive information where the collection of that information is required or authorised by or under any Australian law or a court order, or where a permitted general situation exists.
Why do we collect, hold, use and disclose Personal Information?
Dietitians Australia may collect, hold, use and disclose your personal information where it is reasonably necessary for, or directly related to, one or more of our purposes, functions or activities. Our purposes, functions and activities include:
- development of accreditation standards for educational programs for dietitians and nutritionists which lead to registration or endorsement in Australia of dietitians and nutritionists as Advanced Practising Dietitians (APDs) and Accredited Nutritionists
- accreditation of education providers and educational programs for dietitians and nutritionists leading to qualifications that enable registration as an Accredited Practising Dietitian (APD) or Accredited Nutritionist
- assessment of dietitians to join the APD Program and to maintain their certification, and assessment of nutritionists to join the Accredited Nutritionist program and to maintain their certification
- assessment of internationally qualified dietitians for the purposes of admission to membership, skills recognition processes and credentialing
- undertaking research, innovation, marketing, industry development and policy development to further the dietetics and nutrition industry in Australia, including evidence-based practice, and building food and nutrition knowledge
- advocacy for managing disease and improving the nutritional status and wellbeing of Australia including advocating for a safe, nutritious and sustainable food supply
- advancing and promoting dietetics and nutrition in Australia and internationally through strategic alliances, partnerships and collaborations
- reporting internally and externally on the dietetics and nutrition industry – including demographics, qualifications, workforce/employment related information
- providing individuals and organisations with services and information about Dietitians Australia’s programs and activities, including carrying out registration requests, and fulfilling your requests for products and services (including purchases)
- administering a code of professional conduct, including managing and responding to complaints about members, and non-member APDs
- communicating with our members
- customising the advertising and content you see
- improving the content and design of our website and services
- contacting users regarding changes to our website or business
- considering the suitability of prospective employees
Dietitians Australia may also retain the details of purchases and other transactions or payments made with us or affiliates of our organisation, such as PEN Global (Dietitians of Canada).
We may also use or disclose your personal information for other purposes to which you consent, or which are required or permitted by law. This may include for a secondary purpose that is related to the purpose for which we collected it, and for which you would reasonably expect us to use or disclose your personal information.
Disclosure of Personal Information
It is our policy not to disclose, sell or rent your personal information to any individual, business, government entity or third parties except:
- to provide products or services you have requested through Dietitians Australia
- to allow Dietitians Australia to engage third party service providers to assist us fulfil our functions and activities where the disclosure is reasonably necessary (for example, our lawyers, accountants or IT providers)
- in response to a validly issued subpoena, court order or other legal process
- when necessary to establish or exercise our legal rights or defend against legal action
- if you request Dietitians Australia to do so
- anytime authorisation is given to Dietitians Australia to release information about individuals including any request to view an individual’s own information
- to researchers, government, allied health industry bodies and primary health networks for statistical analysis on the industry generally, including for the formulation of policy positions
- for the purpose of providing a public list of names and states/territories of residence to allow confirmation of APD status and Accredited Nutritionist status
- if you have opted in to receive advertising and marketing material, we will disclose your email address or physical address to relevant third parties who may contact you for advertising or marketing purposes
- to perform a regulatory function
We may also disclose your name, membership details and other personal information specifically to the following parties:
- Medicare, Department of Veterans’ Affairs (DVA), National Disability Insurance Agency (NDIA) and private health funds for funding and related purposes
- Commonwealth, State and Territory agencies which receive or investigate health care complaints
- PEN Global (Dietitians of Canada) to enable you to obtain online access to the PEN website
- Healthdirect Australia so that members may be listed on the National Health Services Directory if they have voluntarily added their details to ‘Find a dietitian'
We may publish on our website the name and membership status of any member who has had an adverse finding made against them under Dietitians Australia’s By-Law Complaints and Disciplinary Procedures. We may also publish details of any sanctions imposed on a member under those procedures. Dietitians Australia maintains and publishes details of any person who has been suspended by or expelled from Dietitians Australia.
Web statistics and shared data
Dietitians Australia collects and uses web-based information to analyse trends, administer our website, track user movement and to gather broad demographic information for reporting and sponsorship purposes.
Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
Occasionally we may use the information processed by Google Analytics to share with advertising partners, sponsors and/or affiliates. For example, we may tell an advertiser that (x) number of individuals visited a certain area on our website, or that (y) number of men and (z) number of women completed our registration form. However, we will not disclose to these partners, sponsors and/or affiliates anything that could be used to personally identify those individuals.
Member Communication and Direct Marketing - Opt-In/Out
Dietitians Australia uses SMS messaging for membership renewals and credentialing compliance. Dietitians Australia may decide to use SMS messaging for marketing purposes in the future.
You may ’opt in to/out of’ receiving newsletters, promotional offers and other information from Dietitians Australia and our partners and affiliates. To unsubscribe from external advertising, marketing materials and Dietitians Australia-driven SMS messaging, go to the ‘Settings’ tab on your Member Portal Account Profile.
As Dietitians Australia is required by law to be able to communicate with its members, it is not possible for current members to opt out of weekly emails and newsletter subscriptions. This is to ensure members don’t miss important information that needs to be communicated on occasion, including matters related to member meetings, member rights, and credentialing. Members may opt out of SMS messaging for membership renewals and credentialing compliance, but members must nominate an alternative preferred channel of communication. The default channels will be email and SMS.
Adding your details to accessible website lists
The Dietitians Australia website supports lists which are accessible either to the public (for example, Find a dietitian) or other members (for example, Share Plate). Inclusion in these lists is voluntary and members are responsible for ensuring their details are current and correct.
Disclosure of Personal Information overseas
Dietitians Australia may disclose your personal information to the following overseas recipients:
- Relevant professional associations such as PEN Global (Dietitians of Canada) to allow members online access to the PEN website (except when we are prevented from doing so due to confidentiality obligations)
- International dietetic associations where Dietitians Australia has been requested to provide a ‘Letter of Good Standing’ (or similar document)
- Other companies or individuals who provide services or perform functions on our behalf (such as third-party service providers)
- Anyone else to whom Dietitians Australia has been authorised to disclose it by you
- Anyone else where we are required or authorised by law to do so
The countries where we currently disclose personal information include Canada, New Zealand, United Kingdom, United States and those countries whose dietetic associations are members of the International Confederation of Dietetic Associations (ICDA). A full list of members of the ICDA is available at: https://internationaldietetics.org
How we protect your Personal Information
Dietitians Australia works hard to protect your personal information at all times. Personal information is encrypted and stored on secure servers. Only authorised personnel can access this database through individualised passwords. We use a database management system that contains security features such as encryption, firewall and anti-virus, to ensure the protection and integrity of our data.
Our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.
All user accounts must be accessed with usernames and passwords. You are strongly advised not to share your username and password with any other person. All online payment pages are protected with Secure Socket Layer (‘SSL‘) encryption.
Be aware that Dietitians Australia emails are not encrypted. If you are writing to us by email, you should consider whether you can provide any personal, sensitive or commercial-in-confidence material by an alternative means to protect the information. Dietitians Australia emails are notated with a disclaimer explaining the appropriate use and protection of information contained within.
Dietitians Australia will take reasonable steps to destroy or permanent de-identify personal information it holds if we consider that the information is no longer needed for our business purposes, functions or activities.
Accessing and Correcting your Personal Information
Setting up user accounts
Dietitians Australia allows users to set up personal accounts to purchase resources or publications from our online library or to participate in our online communities. You can edit your personal information at any time and can ask to have your account removed by emailing firstname.lastname@example.org
Access to and correcting your personally identifiable information
Subject to the exceptions set out in the Privacy Act, you may seek access to, and correction of, your personal information by emailing email@example.com. You will need to verify your identity and specify what you are seeking. If a fee is charged for providing access, you will be advised of the likely cost in advance.
Dietitians Australia reserves the right to amend this policy at any time. Dietitians Australia will contact registered users by email and shall also post a notice of changes on our website, when and if the terms of this policy are amended.
How to make a privacy-related complaint
If you have any questions about privacy-related issues or wish to complain about a breach of your privacy or the handling of your personal information by us, please email firstname.lastname@example.org. Any complaint will be investigated and you will be notified of the decision as soon as practicable, usually within 30 days.
If your concerns are not satisfactorily resolved, you can contact the Office of the Australian Information Commissioner:
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
Contact us at email@example.com if you have questions regarding this policy or wish to register any concerns, including potential breaches of your personal information.