Privacy Policy

Privacy Policy

The Australian Psychological Society Limited (APS)

The Australian Psychological Society Limited ABN 23 000 543 788 (APS, we, us, our) is committed to protecting your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Act).

This Policy sets out how we collect, use, disclose and store your personal information. This Policy does not regulate personal information exempted by law, for example, employee records.

If you are a European Union resident, please refer to paragraph 10.

1. What is personal information?

1.1 ‘Personal information’ is defined in the Act, and means information or an opinion about you (whether true or not) where you are identified or reasonably identifiable and may also include sensitive information.

1.2 ‘Sensitive information’ is any information about your racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional, or trade association, membership of a trade union, sexual preferences or practices, criminal record or health, genetic or biometric information. We will not ask you to disclose sensitive information unless it is necessary for providing our services to you. However, if you elect to provide unsolicited sensitive information it may be captured and stored.

2. What personal information do we collect?

2.1 The kinds of personal information that we collect, or may hold include your:

• Name;
• Contact details (including postal address, email address and telephone numbers);
• Date of birth;
• Payment information (including credit card details).

2.2 For members or applicants for membership, the personal information held by us may also include:

• Gender;
• Employment information such as CVs, work histories, and references;
• Training records and competency assessments;
• Cultural heritage, languages spoken;
• Demographic information;
• Health practitioner registration details;
• Academic and professional qualifications;
• Participation in continuing professional development (CPD);
• Journal articles published;
• Journals subscribed to;
• Membership grade;
• Special interests;
• Membership of or desire to join any APS Branch, College or Interest Group;
• Information about any disciplinary action, ethical notifications, professional misconduct investigations and criminal charges and convictions;
• Requests for special consideration in relation to membership and/or professional development requirements, which may involve information concerning your financial details or health;
• Information for the purpose of developing membership programmes and initiatives;
• Photos and/or videos taken at APS events or by closed-circuit television cameras (CCTV);
• Browsing history accessing the APS website or resources.

2.3 For persons holding or applying for a position with us (for example, as an employee, a contractor or a volunteer) or undertaking or applying for a student placement, we may also hold health information (for example, relating to a disability or condition relevant to the performance of your role, or relating to an injury sustained in the course of our activities).

3. How we collect personal information

3.1 We collect personal information in a number of ways, including:

• In the course of conducting our services;
• Correspondence and telephone calls;
• Conference and other event registration forms;
• From our website using various technologies, including ‘cookies’;
• If you provide us with your business card at a function or event;
• Order forms for APS products;
• Applications for assessment of overseas qualifications;
• Applications to be included in the "Find a Psychologist" service;
• When you place an advertisement with the "PsychXchange" service;
• When you participate in the PsychEngage platform;
• When you use other APS online services, apps or tools;
• Membership application forms (online and offline);
• Annual subscription forms (online and offline);
• Responses to calls for nominations for awards or positions;
• Applications for membership of member groups;
• When you participate in APS member services and benefits or privileges programs;
• If you contact us in person or through social media (such as LinkedIn and Facebook);
• When you purchase a product through the online "APS Shop";
• From medical forms, incident reports, documents about occupational health and safety requirements (including capacity to work certificates);
• When you apply for a position with us (for example, as an employee, a contractor or a volunteer) or a student placement and from other parties such as recruiters or referees;
• When taking photographs, video or other recordings;
• From publicly available sources of information such as social media.

4. Purposes of collection, use and disclosure

4.1 We collect, use and disclose personal information for the purpose of conducting, planning, improving and evaluating our operations and our services, which include:

• Processing registration of members;
• To contact members as required by law for the operation of APS;
• Identifying, creating and providing membership services and benefits;
• Maintaining membership and service/benefit records;
• To contact members and former members in relation to renewal and reapplying for membership;
• Identifying, creating and providing services to psychologists or entities involved in the practice of psychology;
• Establishing, operating and marketing of continuing professional development programs;
• Establishing user/customer accounts for psychologists accessing and/or using services, directories or information provided by us through our website or programs operated or managed by us for the promotion of psychological services;
• In the case of potential staff, volunteers and students, assessing a person's application for employment or engagement by or placement with us;
• Resolving disputes and responding to queries;
• Verifying your identity when you deal with us;
• Obtaining goods or services from you;
• Publishing your journal or article contributions;
• Conducting surveys of members and others;
• In response to requests by regulators or under the Corporations Act 2001 (Cth);
• Direct marketing to promote our or third parties' goods or services to you, including by mail, telephone, email, SMS or targeted digital marketing and you may direct us at any time to opt out from direct marketing.

4.2 We may also collect, use and disclose your personal information:

• For purposes which should be reasonably expected by you and are related to the above purposes;
• For other purposes to which you have consented; and
• As otherwise authorised or required by law.

4.3 We may disclose personal information as follows for the above purposes:

• To outsourced service providers who assist us in the delivery of some of the services you receive, by providing functions such as:
  • Mailing systems;
  • Information technology services;
  • Conference organising.
• To other providers of services to us (for example, our insurers);
• To external providers of member services, benefits and privileges, in order to confirm that the member is a member;
• To our professional advisers, including auditors;
• To funders or government authorities for the purpose of publishing reports or other information about the workforce or to comply with funder accountability requirements;
• To providers of insurance or other products offered by us;
• Where you otherwise provide your consent, whether express or implied;
• Where otherwise required or permitted by law or court order, or other governmental order or process, such as where we believe in good faith that the law compels us to disclose information to:
  • Lessen or prevent a serious threat to your life, health or safety or public health or safety, where it is impractical to obtain your consent;
  • Take appropriate action in relation to suspected unlawful activity or serious misconduct;
  • To assert a legal or equitable claim.

4.4 In addition, for APS members:

• Your nominated contact telephone number will only be released to members of the public where you have provided prior written consent;
• If you are an Associate, Member, Fellow or Honorary Fellow of the APS, your title, name, membership grade, telephone number, workplace and APS member group affiliations are included in the Membership Directory on the APS website, which is accessible by APS members, to the extent that you have opted in to the release of some or all of this information;
• If requested by a regulatory body or authority, we may disclose information held about your qualifications, professional experience and practice as a psychologist, to the extent required or authorised by law;
• We may seek your consent to make the same categories of information contained in the Membership Directory available to other allied health organisations for the purpose of facilitating referrals and enhancing access to appropriately qualified professionals.

4.5 We will take all reasonable steps to ensure that third parties to whom we disclose your personal information have a compliant Privacy Policy and are committed to protecting your personal information at a standard at least equal to our commitment under the Australian privacy laws.

5. Overseas disclosure

5.1 Some of the third parties to whom we may disclose your personal information may operate globally and be located or based outside Australia (including the USA) so that they can provide us with services in connection with the operation of our business, such as marketing services, bulk email sending services, text messaging providers, survey tools and data storage.

Such third-party providers may be subject to their own internal policies and protocols as well as jurisdictional legal requirements to better ensure that your privacy is protected.

In accordance with paragraph 4.5, we will take all reasonable steps to ensure that any overseas-based third parties engaged by us are committed to protecting your personal information at a standard at least equal to our commitment under the Australian privacy laws.

6. Cookies

6.1 Cookies are pieces of information that the APS website transfers to your device's browser for record keeping purposes. Most web browsers are set to accept cookies. We use cookies to make your experience of our website and services as convenient as possible.

The information collected includes the pages viewed and the information downloaded, the IP address of the computer or mobile used to visit our website, the page from where the individual visited our website, the type of browser used, unique device identifiers and information about websites visited before the individual visited our website. 

6.2 Cookies are used to estimate the number of users and determine overall traffic patterns through our website. If you do not wish to receive any cookies, you can set your browser to refuse cookies. However, this may mean you will not be able to take full advantage of our services. Some parts of our website may not function properly (or at all) if cookies are disabled.

7. Direct marketing

7.1 You may from time-to-time receive direct marketing to promote our or third parties' goods or services to you, including by mail, telephone, email, SMS or targeted digital marketing.

7.2 If you would like to opt out of receiving marketing material, please contact our Privacy Officer (see below). There will also be a simple ‘unsubscribe’ (opt out) method in any marketing emails. If you opt out of receiving marketing material from us, we may still otherwise contact you in relation to our existing relationship with you other than for marketing.

8. Storage and security of personal information

8.1 We take all reasonable steps to ensure that the personal information we hold is secure and may only be accessed by authorised persons.

8.2 We will retain personal information of former members in accordance with law for a period of at least 7 years from the date that their membership ceased. After that time, former members may request that their personal information be de-identified.

9. Access and correction

9.1 We strive to keep accurate, complete and up-to-date records of the personal information we collect, so far as practical. Accuracy depends on the information provided to us. Members can update their personal details in the restricted access ‘Manage your membership’ section of the APS website. Any non-members who wish to query the accuracy of personal information held about them or update that information may contact the Privacy Officer as set out below.

9.2 You have a right to seek access to your personal information held by us and that right extends to correction of the information if it is inaccurate, out-of-date or incomplete. To seek access to your personal information, please contact the Privacy Officer as set out below.

9.3 It is our policy to provide a summary of the personal information that we hold, rather than copies of individual documents. We do not provide access to evaluative information generated within the organisation in connection with commercially sensitive decision-making processes such as recruitment or procurement.

9.4 If we are unable to provide you with access to or correction of your personal information, we will provide you with a written notice that sets out the reasons for our decision and mechanisms available to you to lodge a complaint.

9.5 All requests for access and/or correction of personal information are subject to verification of the identity of the person making the request.

9.6 In the event that copies of individual documents are requested and we agree to meet that request, the fee for provision of documents via post, fax or email is $1.00 per page (or such other reasonable fee as we specify), payable prior to delivery.

10. Overseas activities and General Data Protection Regulation

10.1 When conducting activities outside Australia such as conferences, the APS or its members may also be subject to privacy laws of the jurisdiction in which they are operating. In respect of APS members who are European Union residents, the APS may also be subject to the privacy laws of the European Union.  Even where we are not bound by the privacy law of a jurisdiction, we strive to act consistently with the privacy principles and laws that apply wherever it operates. 

10.2 Where applicable, we will comply with the principles of data protection set out in the General Data Protection Regulation (GDPR) with respect to ‘personal data’ collected from residents of the European Union. The meaning of personal data is similar to personal information as it includes any information relating to an identified or identifiable natural person. Under the GDPR principles: 

• We may process your personal data as a Processor and/or to the extent that we are a Controller as defined in the GDPR; 
• We must establish a lawful basis for processing your personal data. The legal basis for which we collect your personal data is set out at paragraph 4 of this Privacy Policy, which includes without limitation, where:
  • It is necessary for our legitimate interests or to fulfil a contractual or legal obligation;
  • It is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law;
• We will only collect your personal data with your express consent for a specific purpose, to the extent necessary and not excessive of that purpose;
• We will keep your data secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage;
• We do not collect or process any personal data from you that is considered sensitive personal information under the GDPR, such as personal data relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent or it if being collected subject to and in accordance with the GDPR; and
• You must not provide us with your personal data if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal data of children.

10.3 European residents have the right to access personal data we hold about them and to request that personal data be corrected, updated, deleted (right to be forgotten) or transferred to another organisation. European residents are also able to request that the processing of their personal data be restricted or object to their personal data being processed. To make any of these requests, please contact our Privacy Officer (details listed below).

10.4 As the APS head office is based in Melbourne, Victoria, Australia, personal data collected will be transferred out of the European Union. We have implemented appropriate safeguards in connection with the transfer of personal data from the European Union. We will also use best endeavours to ensure that any third party recipient located outside the European Union will take steps to safeguard the personal data transferred or disclosed to such a recipient.

11. Questions and complaints

11.1 If you have any questions in relation to how we handle personal information, or wish to lodge a complaint about our management of personal information or a request for access to or correction of your personal information, please call our Privacy Officer: Monday - Friday between 8:45 am – 5:15 pm Melbourne time on (03) 8662 3300 from Melbourne, or 1800 333 497 from the rest of Australia, or +61 3 8662 3300 from overseas.

Alternatively, you can write to the Privacy Officer at:

Postal address: The Australian Psychological Society Limited

PO Box 38

Flinders Lane Victoria 8009

Email: [email protected]

The Privacy Officer will coordinate the investigation of any complaint and any potential resolution of a complaint. We will aim to resolve all complaints as soon as practicable.

We reserve the right to verify the identity of the individual making the complaint and to seek further information from the complainant about the circumstances of the complaint. We reserve the right to refuse to investigate or to otherwise deal with a complaint where permitted under the Privacy Act. For example, we may refuse to investigate or to otherwise deal with a complaint if we consider the complaint to be vexatious or frivolous.

11.2 If you are not satisfied with our response to your complaint, or you consider that we may have breached the APPs or the Privacy Act, you can make a complaint to the Office of the Australian Information Commissioner (OAIC). 

Office of the Australian Information Commissioner

Postal address: GPO Box 5288 Sydney NSW 2001

Phone: 1300 363 992

Email: [email protected] 

Website: www.oaic.gov.au

12. Changes to this Policy

We may change this Privacy Policy at any time.  If we make changes to this Privacy Policy, we will notify you by publication on our website. The revised version of this Privacy Policy will be effective at the time we post it.

This Policy will be reviewed every three years, by the APS Board.