Purpose and scope
PTM is required by the Privacy Act 1988 (“Pact”) to comply with the thirteen Australian Privacy Principles (“APPs”) (subject to the other provisions of that Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.
Personal information is information or an opinion, in any form and whether true or not, about an identified individual, or an individual who is reasonably identifiable.
This policy specifically covers the collection, storage and use of personal information during the delivery of medical orientated projects and services for PTM clients.
PTM collects and stores personal information as part of the service delivery requirements as set out by PTM’s Client.
Special provisions apply to the collection of personal information which is sensitive information. Health information is defined in the Privacy Act to relevantly include:
Information or an opinion about:
the health or a disability (at any time) of an individual; or
an individual’s expressed wishes about the future provision of health services to him or her; or
a health service provided, or to be provided, to an individual; that is also personal information; or
other personal information collected to provide, or in providing, a health service; or
other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances; or
genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual
PTM will only collect sensitive information if the individual about whom the information relates has consented to the collection of the information or if the collection is otherwise permitted under the Privacy Act.
Collection of personal information by PTM
To the extent required by the Privacy Act:
PTM will not collect personal information about you unless that information is reasonably necessary for one or more of our functions or activities;
PTM will collect personal information only by lawful and fair means;
When PTM collects personal information directly from you, we will take reasonable steps at or before the time of collection to ensure that you are aware of certain key matters, such as the purposes for which we are collecting the information, the organisations (or types of organisations) to which we would normally disclose information of that kind, the fact that you are able to access the information and how to contact us (or example, where personal information is collected on a form, we will generally include a written privacy statement on the form which sets out these details);
PTM will collect your personal information directly from you where it is reasonable and practicable to do so. Where PTM collects information about you from a third party, we will still take reasonable steps to ensure that you are made aware of the details set out above.
ANONYMITY and/or the use of a PSEUDONYM
An individual may choose to remain anonymous. In these situations PTM may not be in a possible or able to interact with an individual who chooses to remain anonymous or be identified using a pseudonym. PTM will generally provide individuals with the option of not identifying themselves, or of using a pseudonym, when entering transactions when it is lawful and practicable to do so.
Potential Consequences of not providing personal information
If individuals don’t provide personal information to PTM, PTM may not be able to:
provide the required service levels agreed with the Client;
verify an individual’s identity or protect against fraud;
unable to follow-up and verify the information
Use and disclosure of personal information by PTM
If PTM uses or discloses your personal information for a purpose (the “secondary purpose”) other than the main reason for which it was originally collected (the “primary purpose”), to the extent required by the Privacy Act, we will ensure that:
the secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that PTM would use or disclose your information in that way; or
you have consented to the use or disclosure of your personal information for the secondary purpose; or
the use or disclosure is required or authorised by or under law; or
the use or disclosure is otherwise permitted by the Privacy Act (for example, as a necessary part of an investigation of suspected unlawful activity).
Our corporate site at www.pharmatomarket.com allow a user to submit requests to us (including personal information) via email and webforms. We will use that personal information to respond to the user’s requests. We will not use a user’s personal information for any other purpose.
In accordance with commonly accepted business practices, we collect and use the contact details of individuals who are employees and contractors of our corporate and other organisational customers. We use this information to advise those individuals of products and services that may be of interest to our corporate and other organisational customers and to maintain our relationship with those customers.
PTM offers a product enquiry line. If you call this line we will collect personal information from you to answer your enquiry and to contact you later if that is necessary. We will not disclose personal information about you to any other person except where required by law.
Collection and use if unsolicited personal information
Individuals may choose to share personal information that has not been requested by PTM during an interaction (referred to as ‘unsolicited information’).
When PTM receives Personal Information directly from an individual, PTM will take reasonable steps to notify the individual how and why their information has been collected; who it may be disclosed to; along with providing details regarding how the individual can access the information in the future, request a change to the information or make a complaint.
Sometimes PTM will collect personal information from individuals other than those of which the information relates (e.g. a Health Care Professional or carer). In these cases, PTM will attempt to verify if consent has been provided before retaining any personal information.
If PTM cannot verify if consent has been provided or in those cases where consent has not been provided, PTM will ensure that the personal information is de-identified.
Data quality and security
To the extent required by the Privacy Act, PTM will take reasonable steps to:
make sure that the personal information that we collect, use and disclose is accurate, complete and up to date;
protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act.
Transfer of personal information overseas
If PTM transfers your personal information outside Australia, we will comply with requirements of the Privacy Act that relate to transborder data flows.
The corporate and product websites administered by PTM for Australia use servers that are hosted in Australia that are controlled by one or more related bodies corporate of PTM. Those related bodies corporate provide information technology assistance to PTM and will not use any personal information stored on those servers for any other purpose of their own.
Storage of personal information
PTM stores personal information in hard copy and in electronic format.
PTM will take reasonable steps to protect Personal information from unauthorised access or disclosure, misuse, interference, modification or loss.
PTM requires all staff to sign confidentiality agreements, has specific document storage security policies and employs a range of physical and electronic security systems to protect personal information.
In some cases PTM uses third party data storage providers. In these cases PTM requires that contractual arrangements are in place with the providers to ensure that the provider takes or has taken appropriate measures to protect that information.
What happens when we no longer need The Information?
PTM only stores Personal information for as long as it is required in order to meet contractual obligations or to meet obligation in relation regulatory guidelines or legislation. At the conclusion of the service all person information is returned to the client or if requested by the client, destroyed using a secure destruction procedure.
PTM is required by health legislation to retain some personal information for a specified time period (e.g. Health Records Act). At the conclusion of this time period the personal information is returned to the client or destroyed using a secure destruction procedure.
Access and correction of your personal information
Please contact PTM if you would like to access or correct the personal information that we hold about you. PTM will generally provide you with access to your personal information if practicable, and will take reasonable steps to amend any personal information that is incorrect. In some circumstances, PTM may not permit access to your personal information (Retrieval fee may apply), or may refuse to correct your personal information, in accordance with law.
PTM Clients may not provide access to Personal Information of projects when:
there is perceived threat to life or public safety
access would be deemed unlawful
the information wouldn’t be ordinarily accessible because of legal proceedings
there is an unreasonable impact on other individuals
it would be likely to harm the activities of an enforcement body (e.g. the police)
the request is frivolous or
it would harm the confidentiality of PTM’s commercial information.
Please contact PTM if you have any queries about the personal information that PTM holds about you or the way we handle that personal information:
Pharma To Market Pty Ltd
Level 1, 7 Clunies Ross Ct, Brisbane Technology Park, Queensland 4113, Australia P: +61 (0)7 3122 9979
Further information about the APPs and the application of the Privacy Act to the private sector generally can be found at the website of the Office of the Australian Information Commissioner, at http://www.oaic.gov.au.
Please contact PTM using the above details if you have any concerns or complaints about the manner in which your personal information has been collected or handled by PTM.