1 July 2024.
Privacy at Involution Healthcare
Involution Healthcare Pty Ltd (“IHC”, “us”, “we”, “our”) recognise the importance of your privacy and understand that the security of your personal information is important to you. We are committed to protecting the personal information you provide to us or that we otherwise hold about you.
This privacy policy (“Policy”) outlines how we manage your personal information and protect your privacy. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) of Australia and the New Zealand Privacy Principles contained in the Privacy Act 2020 (NZ) of New Zealand (together, the “Principles”) and (together, “the Privacy Acts”) as applicable. To the extent that personal information is health information, IHC is also bound by the Health Records Act 2001 (Vic), the Health Records (Privacy and Access) Act 1997 (ACT) and the Health Records and Information Privacy Act 2002 (NSW) in Australia and the New Zealand Health Information Privacy Code 1994 in New Zealand.
By providing us with your personal information, you consent to our collection, use and disclosure of your personal information in accordance with this Policy and any other arrangements that apply between us. From time to time, it may be necessary for IHC to review and revise this Policy. IHC encourages you to periodically check our website to ensure you are aware of the most up-to-date version of this Policy.
Personal information includes information or an opinion about an identified individual or an individual who is reasonably identifiable (such as names or email addresses). Within this Policy unless indicated otherwise, references to personal information also include sensitive information, such as information or an opinion about your health, or health services provided to you.
What personal information does IHC collect?
We only collect personal information for purposes which are directly related to our services, functions or activities and only when necessary for, or directly related to those purposes. If you do not provide your personal information, we may not be able to provide some or all of our services or products to you or contact you in order to perform the functions and activities set out in this Policy.
Who does IHC collect personal information about?
IHC generally collects personal information about the following individuals:
- healthcare professionals (including doctors, pharmacists, nurses);
- members of the public (in their interactions with IHC);
- third parties who provide a service to IHC; and
- prospective employees and contractors.
Types of personal information collected
The personal information IHC collects about you may include:
- ID information:
- o identifying information such as your name, age or date of birth and gender;
- o contact information such as your address, employment details, email address and mobile phone number; and
- o educational and professional membership information;
- financial information such as bank account details, if required for payments;
- information provided in connection with assessing, recording and reporting adverse events related to our products;
- information required by law:
- if you are a healthcare professional, information necessary to provide product recalls and product safety notifications; and
- information required to be collected by Australian Federal, State and Territory or New Zealand law, including in relation to adverse event reports and safety issues under the Therapeutic Goods Act 1989 (Cth) and the Medicines Act 1981 (NZ), and records of sample medicines provided to healthcare professionals under the Medicines Australia Code of Conduct or the Medicines New Zealand Code of Practice;
- enquiry or attendance information:
- if you are a healthcare professional, information about your attendance at programs organised or supported by IHC (including meetings, conferences, expert panels, clinical trials and research or disease awareness programs);
- information about your attendance at educational or disease awareness events;
- if you are a healthcare professional, your interactions with sales representatives;
- information you provide through surveys or that you provide to us directly or indirectly through the website or to our representatives;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those services and respond to your enquiries; and
- details in relation to complaints that you have made; and
- any other personal information that may be required in order to facilitate your interaction with us.
Anonymity
Where possible, we will allow you to interact with us anonymously (for example, when you contact our enquiries line with a general question). However, for the majority of our functions, we usually require your name and contact information and enough information to allow us to efficiently handle our interaction with you.
How does IHC collect personal information?
We may collect these types of personal information either directly from you, if you are a patient, from your healthcare professional, or from third parties. We may collect this information:
- directly from you, including when:
- you communicate with us over the telephone, in person, through a form or online portal or by email;
- you make an inquiry, complaint or report an actual or suspected adverse event;
- you use our information services, such as the support phone line;
- from organisations engaged by IHC to carry out functions on our behalf including:
- administrators of patient support or supply programs;
- event management organisations; and
- recruitment agencies, in respect of prospective employees;
- in respect of patients (including information in connection with actual or suspected adverse events), from your healthcare professionals; and
- in respect of healthcare professionals, from online directories which we subscribe to.
Why does IHC collect, hold, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- as indicated to you at the time we collected your personal information;
- to provide educational or health products or services (including advice or product medical information) that you or your healthcare professional have requested);
- to assess, record and report actual or suspected adverse events and safety issues, including (if applicable) to seek additional information in connection with such adverse events or safety issues;
- General business
- to maintain a record of enquiries and complaints in relation to IHC products and services;
- to assist us in responding to, and following up on, your queries and providing you with information, including where you provide us with personal or sensitive information through our support phone line;
- for general sales, marketing and medical activities, including to contact you to provide you with information about, and discuss, IHC products (in accordance with the Marketing section below);
- to conduct market research;
- to process, monitor and screen any fees payable, or expenses reimbursable, by IHC to you; and
- to consider employment applications and recruit IHC personnel; and
- As required or authorised by law
- to comply with legal or regulatory obligations or transparency requirements including those that apply to IHC’s activities globally; and
- for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.
We may use or disclose information about you in order to combine the information that we hold about you with information about you collected from or held by other trusted partners or from public sources. We do this so that we can serve you better and can improve our services.
We may use de-identified, aggregated data derived from your personal information for internal purposes, such as improving the functionality of our website or services. We may also use such de-identified, aggregated information for analytical purposes, such as to develop analytical insights about the use our website and services (including monitoring website traffic) and participation in patient programs administered by us or third parties.
To whom does IHC disclose your personal information?
IHC may disclose your personal information to third parties, including parties which are located overseas, such as:
- our affiliates and related bodies corporate;
- regulatory authorities and ethics committees as part of a clinical trial evaluation, monitoring or inspection process, including the Therapeutic Goods Administration in Australia;
- third party suppliers and service providers to assist IHC in carrying out the purposes set out in this Policy located globally including in the US, European Union, the UK and Asia Pacific such as healthcare professionals, clinical research organisations, patient support program administrators, our finance processing provider, travel agents, market researchers, professional conference or event management organisations, IT support providers, mail houses, recruitment agencies and professional advisors;
- our IT servers, databases and cloud based data centres, which are located globally including in Australia, the European Union, the UK, the US, India, Singapore and Japan;
- parties involved in a prospective or actual transfer of our assets or business; and
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
We will take reasonable steps to ensure that any overseas recipient will deal with your personal information in a way that is consistent with the Principles and this Policy. Generally, we require that organisations outside IHC who handle or obtain personal information as service providers to IHC acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with IHC’s commitment to privacy.
The collection and use of your information by these third parties may also be subject to separate privacy and security policies.
Marketing
IHC may use your personal information to contact you (including by telephone, text message or email) in relation to IHC products or services we think may be of interest to you. IHC will not send you a commercial electronic message unless permitted by the Spam Act 2003 (Cth) or the Unsolicited Electronic Messages Act 2007 (NZ).
We will only use or disclose your sensitive information for the purpose of direct marketing with your consent.
You may opt-out of receiving marketing information from IHC at any time by contacting the Privacy Officer using the details below or by using the opt-out facilities provided within the relevant marketing material.
Sensitive information
As mentioned previously, some personal information, which includes all health information collected by IHC is considered “sensitive”. Due to the nature of our business, we may sometimes need to collect sensitive information about you.
We will collect your sensitive information in accordance with the Principles and only where provided by you or your healthcare professional, with your consent and where necessary for or directly related to our services (including support services), functions or activities, such as:
- information about your health, including your health status or medical conditions, when you call our support phone line;
- information about your health, genetic or biometric information, health services being provided to you or your medical history, if we are providing you with a product;
- information about your health, including previous medical and medication history, and side effects, if you have, or are suspected to have, suffered an adverse event in relation to one of our products; or
- information about your professional association memberships, if such information is required for our dealings with you.
We only use and disclose sensitive information for the purposes for which it was provided, or a directly related purpose you would reasonably expect (such as following up in relation to support phone line queries or adverse event reports), unless you provide your consent or where required or authorised by or under law such as if the use or disclosure of sensitive information is required to prevent a serious and imminent threat to the life or health of an individual.
Cookies
IHC may collect personal information about you when you use or access our website, through the use of ‘cookies’. A cookie is a small file that stores information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You have the ability to accept or decline cookies and can choose to disable cookies through your internet browser. If you choose to decline cookies, some areas of IHC’s or other websites may not function properly.
IHC may use cookies to compile statistics that allow us to understand how a website is used and to facilitate your visit to a website (including remembering your preferences). We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Policy.
Management and security of personal information
IHC stores your personal information in hard copy documents or as electronic data in our software IT systems (and those of our service providers). As mentioned above, our IT servers, databases and cloud based data centres are located globally.
IHC is committed to keeping your personal and sensitive information secure and has appointed a Privacy Officer to oversee IHC’s management of personal information in accordance with this Policy and the respective Privacy Acts.
We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, IHC has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure (using a variety of security technologies and procedures) from unauthorised access or disclosure.
Accessing or correcting personal information IHC holds about you
You can access the personal information IHC holds about you, by contacting the Privacy Officer using the details below. Sometimes, we may not be able to provide you with access to some or all of your personal information and, where this is the case, we will tell you why. IHC will deal with requests for access to personal information as quickly as possible and will endeavour to respond within 10 business days of receipt of the request in writing.
IHC endeavours to ensure that the personal information it holds about you is accurate, complete and up-to-date. If you think that any personal information we hold about you is inaccurate, please contact the Privacy Officer and we will take reasonable steps to ensure that it is corrected.
What if you have a complaint?
If you have any concerns or complaints about the manner in which your personal information has been collected or handled by IHC, please contact the Privacy Officer. Your concern or complaint will be directed to the appropriate complaint manager who will consider and endeavour to respond to your complaint within 10 business days.
It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response:
In Australia you may contact the Office of the Australian Information Commissioner who may investigate your complaint further. Further information about the application of the Australian Privacy Act can be found at www.oaic.gov.au.
In New Zealand you may contact the New Zealand Privacy Commissioner who may investigate your complaint further. Further information about the application of the New Zealand Privacy Act can be found at www.privacy.org.nz.
How to contact us
If you have questions about our Policy or privacy practices, wish to provide feedback about this Policy or would like to access or correct your personal information held by IHC, please contact our Privacy Officer at:
Email: info@involutionhc.com
Phone: +61 2 8527 8788
Postal address: Involution Healthcare Pty Ltd, Level 36 Gateway, 1 Macquarie Place, Sydney NSW 2000, Australia
Changes
From time to time it may be necessary for IHC to review and revise this privacy policy. IHC encourages you to periodically check our website where IHC will post the most up-to-date version of this privacy policy.