Privacy Policy
Quality Care Pharmacy Program (QCPP) is committed to managing personal information gathered from you in the course of your dealings with QCPP, including:
- visiting our QCPP website (www.qcpp.com);
- visiting our QCPP Customer Portal; and
- relating to QCPP assessment, accreditation, reaccreditation and any re-application including any appeals and disciplinary processes.
(collectively, QCPP Services).
QCPP is bound by the Privacy Act 1988 (Cth) (Privacy Act) and obligations of confidentiality in managing the collection, use, storage, and disclosure of personal information, as well as in managing how individuals may access and seek to correct their information, including any personal information, which is held by QCPP. Details of the personal information that we collect, and how it is used, are contained in this Privacy Policy. By engaging in our QCPP Services and providing us with your personal information and confidential information, you agree to your information being collected, used, stored and disclosed on the terms set out in this Privacy Policy.
In this Privacy Policy, “QCPP”, “we” and “us” refers to Quality Care Pharmacy Program. ‘You’ and ’your’ refers to any individual who contacts us in relation to the QCPP Services.
In this Privacy Policy, ‘personal information’ has the same meaning given in section 6 of the Privacy Act:
- “information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- (a) whether the information or opinion is true or not; and
- (b) whether the information or opinion is recorded in a material form or not.”
“Confidential information” includes information concerning you and your business that is reasonably considered to be confidential, according to the common law.
Collection
QCPP collects information directly from pharmacies, individuals or their authorised representatives when performing the QCPP Services.
We may also collect your personal information from third parties, such as banner groups of which you are part or our service providers who we contract to assist us in providing the QCPP Services.
The personal information we collect is only for purposes directly related to your engagement with the QCPP Services, and only where that use is permitted by the Privacy Act or other legislation. We outline below the types of personal information collected and held by QCPP in providing the QCPP Services and the purposes for which that personal information might be used and disclosed by us.
Type of Information
QCPP typically collects the following types of information:
- pharmacy name, address, and contact details;
- pharmacy ABN;
- pharmacy PBS Approval Number;
- full name and pharmacist registration number of each of the pharmacy owner/s;
- name and contact phone number or email address details for any company that owns the pharmacy;
- email address of each of the pharmacy owner/s;
- name, email address and pharmacist registration number (where applicable) of the contact person for the pharmacy if that person is not also a pharmacy owner;
- training records of pharmacy staff responsible for providing services that are assessed as part of the accreditation process;
- any additional email addresses the pharmacy owner/s nominate to receive communications from us; and
- names and contact details (including email address) of any Banner group, Management group or accounting contacts that have authorisation from the pharmacy to communicate with us on their behalf.
We request that all employee and patient records provided to us or our service providers in performing the QCPP Services (including but not limited to offers of employment, letters of termination, position descriptions containing personal information such as staff addresses, contact details and salary and health records) (Records) are redacted by the providing party. Records containing identifiable personal information will not be accepted by us or our service providers in performing the QCPP Services.
As at the date of this Privacy Policy, we do not collect any sensitive information about you in performing the QCPP Services.
Use and Disclosure
Use of Information
QCPP collects and uses personal information only for those purposes for which it was given to QCPP, or for purposes which are directly related to the QCPP Services, and typically include:
- to fulfil administrative functions associated with the QCPP Services, including:
- (a) delivery of the QCPP assessment and associated accreditation;
- (b) providing and verifying access to the QCPP Customer Portal, which requires individuals to have their own personal login;
- (c) invoicing, accounting and debt recovery; and
- (d) conducting customer satisfaction and market research surveys.
- responding to your requests for information and other general inquiries;
- organising and managing data, and reporting statistical information about the QCPP Services;
- training and assisting in staff development;
- receiving services from third party organisations or their employees;
- providing reports to third party contracted assessment service providers responsible for delivering certain incentive payments or services to QCPP accredited pharmacies;
- complying with any legislation or regulations as required;
- for marketing purposes, such as informing you about our activities, events, facilities and services, and distributing QCPP newsletters to subscribed email addresses; and
- responding to enquiries and complaints.
Disclosure of Information to Third Parties
We may be required to disclose your personal information to third parties where necessary to perform the QCPP Services. Examples include disclosure to third party contactors and service providers we use for conducting QCPP assessments, data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance and development, printing, archiving, mail-outs and market research;
We do not give an individual’s personal information to other organisations, agencies, or individuals unless:
- the individual who has provided their personal information (or their authorised representative) has consented for us to do so;
- the individual who has provided their personal information (or their authorised representative) has consented to, or in our assessment may reasonably expect, that information of the kind they have provided will be given to a third party as a matter of standard practice; or
- QCPP is obligated or authorised by law to do so.
Where reasonably practical, or where the provision of information to third parties is in our assessment outside the scope of the purposes outlined above, we will provide those individuals with advance notification of, and obtain their informed consent to, the proposed disclosure.
Overseas transfer of personal information
When we disclose personal information in accordance with this Privacy Policy, it may be accessed from, transferred to, and/or stored outside of Australia. For example, we may disclose your personal information to our third party Project Management Office (PMO) contractor for the purpose of reviewing and assessing your remedial evidence. PMO personnel may be based in Australia, the Philippines and India. The data protection laws in that country may be of a lower standard than those in Australia. We will, in all circumstances, safeguard your personal information as set out in this Privacy Policy and have taken reasonable steps to ensure that any overseas recipient of your personal information will not breach the APPs in relation to your personal information. If you do not want us to disclose your information to overseas recipients, please let us know.
Data Quality and Security
The security of your information is important to us. Our QCPP website and QCPP Customer Portal are hosted in Australia. If you choose to provide us with personal information, you are consenting to the collection, use, disclosure of personal information in the manner outlined in this Privacy Policy and the storage of that personal information on our servers located in Australia.
We take reasonable steps to ensure your personal information is stored securely and protected from misuse, interference and loss and from unauthorised access, modification or disclosure. These steps include:
- the use of secure databases which require users to be licensed in order to access. Additional levels of security are adopted which restrict a user’s level of access to the database to only that information which is required to perform the user’s assigned role;
- not disclosing information regarding your QCPP accreditation or relationship with us beyond that which is already available in the public sphere or as required by law, without your express consent;
- seeking written authorisation from pharmacy owner/s before any employees of your pharmacy will be granted QCPP Customer Portal Access, including authorisation as to the level of permission granted in relation to read/write access on your account record types; and
- using encryption technology to protect data when it is being transferred to our system, and also once it is stored on our database.
The information provided to us is stored in electronic databases. In some instances, information may also be stored in physical paper-based files.
Third Party Websites
The QCPP website may contain links to third-party websites. QCPP is not responsible for the content or privacy practices of any such websites that are linked to our website. We encourage you to read and familiarise yourself with the privacy practices of each website that you visit.
QCPP uses Google analytics to monitor the visitors to our website. Based on your interactions with our website, Google and third-party sites may elect to show you content and advertising that directs back to our website.
Cookies
A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We may collect cookies from time to time to record non-personal information such as the date, time or duration of your visit to our website, or the pages accessed, for website administration, statistical and maintenance purposes. This is useful information to help us customise user website experience. Cookies used on the QCPP website do not and cannot infiltrate a user’s hard drive to gather personal information and confidential information stored on the user’s hard drive.
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
Use and disclosure of your personal information for direct marketing
We may use or disclose your personal information for the purpose of marketing, informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out any time by using the opt-out means that will accompany every communication of this kind.
If you opt-out of receiving marketing material from us, we may still contact you in relation to our ongoing relationship with you.
We will not disclose your personal information to third parties for marketing purposes without your consent.
Accessing and correcting your personal information
You are entitled to request access to your personal information that we hold about you and/or to make corrections to that information. destroy your personal information as appropriate.
Making a complaint about the handling of your personal information
QCPP regards privacy as an important part of the relationship we have with our QCPP accredited pharmacies and applicants for accreditation. You may contact us at any time if you have any questions, concerns or complaints about this Privacy Policy or about the way in which your personal information is handled. Please address any complaint about privacy to the Privacy Officer via email to help@qcpp.com or mail to:
- Privacy Officer
- PO Box 310
- Fyshwick, ACT, 2609
We take all complaints seriously and will respond to your complaint within a reasonable period.
If you are not satisfied with our handling of your complaint, you may contact the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992, by email enquiries@oaic.gov.au or by using the contact details on the OAIC website.
Changes to this Privacy Policy
We may amend this Privacy Policy from time to time to reflect our current data collection and disclosure practices, with or without notice to you. The most recent version of our Privacy Policy is available on our website. We recommend that you visit our website regularly to keep up to date with any changes to this Privacy Policy.
This Privacy Policy was last updated November 2020.