Collection of personal information by Sun Pharma ANZ.
Personal information is defined as “information or an opinion about an identified individual, or an individual who is reasonably identifiable.”
In general the personal information which we collect from you will depend on the type of relationship we have with you and may include your name, contact details, and your general dealings with Sun Pharma ANZ including enquiries and complaints; information about attendance at events or programs organised or supported by Sun Pharma ANZ such as meetings, symposia, conferences, expert panels and other research, disease awareness, patient support programs or similar programs; educational and professional membership information; If you are a customer your bank account details if required for payments, your purchase history, your preferences regarding communication, your affiliation with buying or banner groups, your supplier preference and account number, dispensing patterns, records of any dealings with us or other information that you have provided to us as a result of any communication, dealings, transaction or negotiation with us, and details about complaints and adverse events. If you are a patient enrolled in one of our patient support programs we will collect information that enables us to carry out the administrative and supportive activities of the program and allows us to communicate with you about the program.
Depending on your interaction with us, Sun Pharma ANZ may also collect sensitive information such as professional association memberships and, in limited circumstances, health information and medical history.
- If you are a healthcare professionals (including doctors, pharmacists, nurses) we may collect information in the course of:
- Maintaining a record of inquiries, complaints and adverse event reports relating to SunPharma ANZ products;
- Interaction with sales representatives;
- Administering Sun Pharma ANZ programs such as meetings, symposia, conferences, expert panels, clinical trials and other research, disease awareness or similar programs;
- Complying with our legal and regulatory obligations, e.g. product recalls, product safety notifications.
- Conducting general business transactions
- In certain circumstances, Sun Pharma is required to collect and hold certain types of personal information by law. For example, we are required to collect and hold records of sample medicines provided to healthcare professionals under the Medicines Australia Code of Conduct and applicable Australian State and Territory legislation
- If you are a member of the general public we may collect information in the course of :
- Participation in Sun Pharma ANZ activities such as education, support and disease management programs.
Sun Pharma ANZ will usually collect your personal information directly from you through means such as, telephone calls, emails, faxes, competitions, customer surveys, online portals and our website. However, on some occasions it may be collected from other sources such as:
- From third parties such as agents or service (e.g. administrators of patient support/supply programs, event management organisations and recruitment agencies), providers, distributors and buying group or banner group head offices, where it is reasonably necessary or normal business practice, so that we can continue to provide you with our services.
- Publically available directories and listings such as telephone directories.
- The internet, newspapers, magazines, professional journals.
- Personal communication from Sun Pharma ANZ staff.
Sun Pharma ANZ will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner.
Sun Pharma ANZ will not collect personal information about you unless that information is necessary for our business purposes.
Sun Pharma ANZ will not collect sensitive information about you, such as information about your health, race, religion or political associations, without your consent.
If you choose not to provide the personal information requested of you to Sun Pharma ANZ, we may be unable to provide you with the products and services you require.
Use and disclosure of personal information
Sun Pharma ANZ may use your personal information for one or more of a variety of purposes including:
- as indicated to you at the time your personal information was collected
- general sales and marketing, including to contact you to provide you with information about, and to discuss, Sun Pharma ANZ products or to take an order or update records.
- to invite you to attend educational events and conferences, including any associated logistics;
- to provide health products or services (including advice) that have been requested;
- to provide educational materials;
- to manage patient support programs and patient supply programs that are administered via third parties or Sun Pharma ANZ;
- to assist in providing you with medical information relevant to Sun Pharma ANZ products;
- to conduct market research;
- to identify investigators for, establish and conduct clinical trials
- to invite you to provide services to Sun Pharma ANZ including, for example, speaking engagement, participation on advisory boards/steering committees, or to provide general opinions on medical and/or patient related issues and the development of materials;
- to process, monitor and screen any fees payable, or expenses reimbursable, by Sun Pharma ANZ to you;
- adverse event reporting
- To meeting legal requirements such as notifications of product withdrawals or recalls.
- Where you would reasonably expect that we might use your information for a purpose.
Where we send you direct marketing promotions we will give you the opportunity to tell us if you do not want to receive this information.
Disclosure of Information
In order to deliver the services you require we may occasionally hire other companies to provide services on our behalf, including but not limited to organisations that provide data processing, mailing services, billing services, patient support services, printing and fulfilment operations. Those companies will be permitted to obtain only the personal information they need to deliver the service. Sun Pharma ANZ takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
Disclosure of personal information to overseas entities.
Sun Pharma ANZ is part of a global organization with offices within and outside of Australia. Information held by us may, on occasion, be disclosed or stored on our databases housed in overseas locations including but not limited to India and Malaysia. We take all reasonable steps to ensure that the personal information which is transferred outside of Australia will not be used or disclosed by the recipient inconsistently with the Australian Privacy Principles.
Data quality and security
Sun Pharma ANZ 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 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.
Sun Pharma ANZ takes reasonable steps to keep your personal information secure. We cannot guarantee that your personal information will be protected against unauthorised access or misuse, and do not accept any liability for the improper actions of unauthorised third parties.
Sun Pharma ANZ does not condone “spamming”. Spamming is defined as sending unsolicited e-mails, usually of a commercial nature, in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who has declined to receive such communications. If you contact us by e-mail and Sun Pharma ANZ believes that certain information is of importance to you, we may inform you by e-mail but will give you the choice to opt out of receiving further communications of this type.
Access and correction of your personal information
You may contact The Privacy Officer at the below listed address to request access to your personal information. Access will be provided unless there is legal or administrative reason for denying or limiting access. A fee may be imposed for providing you access. You may request to have it corrected if it is inaccurate, out of date, incomplete or irrelevant. Sun Pharma ANZ will take reasonable steps to respond to your request within 30 days of receipt (or within any further time notified in writing) to amend any personal information that we agree is incorrect.
Sun Pharma ANZ may edit this policy from time to time. The most current version of this policy will be located on the Sun Pharma ANZ website (https://sunpharma.com/australia-new-zealand/) or a copy can be obtained by contacting the privacy officer at the address below.
Please contact us if you have any comments, queries or complaints about the personal information that Sun Pharma ANZ holds about you or the way we handle that personal information. Our contact details for privacy queries are set out below.
Sun Pharma ANZ Privacy Officer
Suite 2.02, Level 2,
12 Waterloo Rd,
Macquarie Park, NSW 2113
Phone 1800 726 229
This policy was last updated on 23/07/2018