Privacy Policy

Sydney Neuroimaging Analysis Centre Pty Ltd (SNAC, we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it details how we collect and manage your personal information.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Privacy Act’s requirements in respect of the collection, management and disclosure of your personal information.

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What is your sensitive information?

When used in this privacy policy, the term “sensitive information” has the meaning given to it in the Privacy Act. In general terms, it includes information or opinions concerning the health or disability of an individual, an individual’s expressed wishes about the future provision of health services, or a health service that is, or will be, provided to an individual. Sensitive information is a sub-category of personal information.

What personal information do we collect and hold?

We may collect the following types of personal information:

identification information, such as your name, mailing or street address, age or date of birth, telephone contact numbers, email address, your referring doctor and your profession or occupation;
sensitive information, which will include health information including your attendance for treatment or assessment, your medical history and diagnosis, results of your medical tests and details of your treatment, and information about your participation in a clinical trial; and
any additional information relating to you that you provide to us directly or indirectly in the course of a clinical trial in which you are a consenting participant.

Where we are required to collect identifying information such as your name, email address or phone number for the purpose of conducting a clinical trial, we will do so only with your consent. In this circumstance, this personal information will be used only for the purpose of conducting the clinical trial and will never be disclosed to a third party unless we are compelled by law to do so.

In most cases we conduct clinical trial activities (such as MRI analysis) on behalf of a trial sponsor and collect and hold information in a manner that is not linked to your name or other information that is likely to identify you. We identify participants in clinical trials by codes and do not use names. This is one of the ways we protect your privacy because the information we collect and link to a code is not personal information because it does not identify you or anyone else. We also take other steps to ensure that the information cannot be linked to you or any other identifiable person. We may do this by aggregating the information of multiple individuals so that the resulting information identifies a group of individuals rather than anyone in particular.

How do we collect your personal information?

As a central MRI reading service for clinical trials and collaborative clinical research and investigator-initiated studies, SNAC does not collect personal information directly from you. In some circumstance we may collect personal information from other people including medical professionals or other health service providers, such as a referring doctor, hospitals, nurses, clinics and medical specialists, in order to assist us in the provision of research services to a third party (such as a clinical trial sponsor) or in the provision of clinical services to a third party (such as a radiology or clinician provider).

When you enrol in a clinical study for which we provide central MRI reading services, we may sometimes obtain your consent indirectly when you provide your consent at the time of enrolment in a clinical trial, which may require your data to be sent to other parties (such as Sydney Neuroimaging Analysis Centre) who are providing services for the clinical trial. Any personal information that is collected will be collected and managed as described in this privacy policy.

What happens if your personal information is not collected?

If you do not provide your personal information described above, you may not be able to participate in a clinical trial or receive clinical services requested by your treating clinician. In addition, if you provide inaccurate or incomplete information in connection with the clinical trial, your treating healthcare professional may not have all the information they require to accurately provide you with medical or clinical trial services.

If you are a healthcare professional and you provide inaccurate or incomplete information in connection with our services, you may not have all the information you require to accurately provide your patient with medical services.

For what purposes do we collect, hold, use and disclose your personal information?

We collect, hold, use and disclose your personal information for the following purposes:

to assist you and facilitate your participation in a clinical trial
to enable us to conduct a clinical trial and to conduct research and analysis and prepare reports on the results of a clinical trial;
to answer enquiries and provide information about a clinical trial;
where relevant, to provide your treating clinicians with identified reports pertaining to your clinical management
to conduct business processing functions including providing personal information to our contractors, healthcare service providers or other organisations in order for us to conduct a clinical trial;
to process and respond to any complaint made by you; and
to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.

In general, we use your personal information in a de-identified or aggregated form, which means that we will modify the information so that it does not identify you or anyone else; and in the majority of clinical research studies for which we provide services, we only ever receive de-identified or codified data from the clinical trial site at which you are seen. When we do receive / require your personal information, this will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

To whom may we disclose your information?

In the conduct of a clinical study/trial, we will never disclose any information that identifies you (such as your phone number or email address which we need for the clinical trials) to any third party, or to a third party sponsor of a clinical trial, such as a pharmaceutical company. Any information released to a third party sponsor of the clinical trial is aggregated so that it does not identify you or anyone else.

We may disclose information that does not identify you (for example, we may aggregate or code the information so that it does not identify anyone) to third parties for the purposes of conducting the clinical trial. Those third parties include our employees, contractors or service providers for the operation of our business, fulfilling requests by you and to otherwise provide services to you including, without limitation, statistical advisors, web hosting providers, IT systems administrators, couriers, and professional advisors such as consultants.

Where we provide clinical services (and you are a patient), we may provide reports (such as a scan analysis) containing identifying information to the health provider(s) who requested the service (e.g. a physician or radiology provider) and, in general, who already hold this information.

If you are a healthcare provider, we may disclose your personal information to people and organisations in conjunction with our services only if you give us your prior consent.

We may also disclose your personal information without your consent when required or authorised to by law. For example, we may disclose your personal information if we reasonably believe that such disclosure is necessary to lessen or prevent a serious threat to your life, health or safety or the life, health or safety of any other individual or to public health or safety, or under compulsion of law including a court order (including a subpoena).

When you enrol in one of our services, we ask you to give your consent for your personal information to be used and disclosed in these ways.

How can you access and correct your personal information?

You may request access to any personal information we hold (and are able to identify) about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and we will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, our Privacy Officer can be contacted using the contact information below and details of the incident must be provided so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

Do we disclose your personal information to anyone outside Australia?

We hold your personal information on secure computer systems located in Australia.

In addition, as we provide services, which are accessible through a web portal, your personal information may be accessed by entities around the world who are authorised by us but only with your prior consent. Generally, all information will be de-identified or aggregated so that you cannot be identified.

Security

We store all personal information on electronic systems and take reasonable steps (including technological measures, administrative procedures and physical security) to ensure all personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Personal information is destroyed or de-identified when no longer needed.

As our website is linked to the Internet, and the Internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Contacting us

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, you can contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Our Privacy Officer can be contacted at:

Privacy Officer

Sydney Neuroimaging Analysis Centre Pty Ltd

Post: Level 1, 94 Mallett St

Camperdown NSW 2050

Tel: +61 2 8005 6325

Email: info@snac.com.au