Privacy Policy

Meda Pharmaceuticals Pty Ltd Privacy Policy

Scope

Meda Pharmaceuticals Pty Ltd ACN 155 308 679 (also referred to in this Privacy Policy "we", "our" or "us") is committed to protecting the privacy of your Personal Information. This Privacy Policy explains how we manage the Personal Information that we collect, use and disclose in connection with this product website and how to contact us if you have any further queries about our management of your Personal Information, or if you wish to seek access to or correction of your Personal Information or make a complaint. This Privacy Policy does not cover Personal Information that we collect or hold about our employees. If you have any questions relating to this Privacy Policy, please contact our Privacy Officer using the contact details provided below.

Background

We are bound by the Privacy Act 1988 (Cth) (the “Privacy Act”), the Australian Privacy Principles ("APPs"), and applicable State and Territory based health records legislation. 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.

Definitions

Health Information includes information or an opinion about:

(i) the health or a disability (at any time) of an individual; or
(ii) an individual's expressed wishes about the future provision of health services to him or her; or
(iii) a health service provided, or to be provided, to an individual;

that is also Personal Information.

An example of health information is information contained in a patient's hospital records or information about a person's allergy or vitamin deficiency.

Personal information means any information or an opinion, in any form and whether true or not, about an identified individual, or an individual who is reasonably identifiable to us.

Privacy Officer means the person whose details are set out below, and who can be contacted in relation to any enquiries, complaints, or access and correction requests in connection with this policy.

Sensitive Information is a subset of Personal Information that is given a higher level of protection by law because of its sensitive nature and includes Health Information and information about a persons' race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual orientation and criminal history.

We will only collect Sensitive Information if the individual has consented to its collection or if the collection is otherwise permitted under the Privacy Act.

Collection of your personal information

The types of Personal Information we may collect about you through the website or when you contact us via email or telephone, including through the product enquiry line we offer, includes your name, gender, date of birth, email address(es), residential, business/profession and postal address(es), contact telephone numbers and facsimile numbers, health information (for example any medical condition or adverse events you tell us about, or your use of our products), government related identifiers, any comments or suggestions about our products and other information that may be relevant in our dealings with you.

More specifically, depending on the type of relationship we have with you, we may collect the following:

From a doctor or pharmacist:

  • Name, profession, business address and other contact information;
  • Any comments or suggestions regarding our products;
  • Details gathered during calls made by our sales representatives to ensure we provide a personalised service;
  • Statistical details regarding prescriptions given or filled;
  • Details of samples requested from us; and
  • (For pharmacists) financial information required for purchases of our products.

From an individual consumer:

  • Name and contact details; and
  • Any Personal Information provided to us which is relevant to a query or complaint. This may include health information provided pursuant to an individual’s express consent.

We only collect information that is reasonably necessary for our activities listed below. We will usually collect Personal Information direct from you, unless it is not reasonable or practical to do so, or you have consented to us obtaining the information from a third party, such as a doctor or pharmacist.

Use and disclosure of personal information

Generally

We use Personal Information to:

  • Efficiently administer, manage and deliver our products and/or services including through our website;
  • Provide information about other products and/or services that may be of benefit;
  • Respond to any queries, complaints or adverse event reports made through this website or via a product enquiry line;
  • Statistically analyse the distribution of our products;
  • Facilitate our internal business operations, including fulfilment of any legal requirements (for example, submitting suspected Adverse Drug Reaction(s) to the Office of Product Review (“OPR”) in compliance with the Therapeutic Goods Administration requirements or where legally required by law enforcement agencies or government auditors;
  • Conduct research in a de-identified manner relevant to public health and/or safety, to compile and analyse statistics relevant to public health, all in a manner permitted by Australian law, where the information provided is health information.

We may disclose your Personal Information:

  • To our related entities;
  • To our agents, contractors or third party service providers that provide financial, legal, administrative or other services in connection with the operation of our business, for example mailing houses, software developers, IT maintenance providers and solicitors, or together with the sale or transfer of one of our products or services to another person or entity (to enable continuity of supply of that product or service);
  • Where acting in good faith, we believe that the law requires or permits us to do so (e.g., to law enforcement agencies, OPR or government auditors); or
  • With your consent, including to an authorised person or their health service provider.

Overseas disclosures

This website uses servers that are hosted in Sweden that are controlled by one or more of our related entities who provide information technology assistance to us and may not use any Personal Information stored on those servers for any other purpose of their own.

We share Personal Information with Mylan N.V. based in the Netherlands and UK and its affiliates.  These affiliates include Mylan Inc., which serves as our corporate headquarters and is based in the United States. They may be in countries which may not take steps to ensure that the Personal Information that we disclose to those countries is handled in accordance with the APPs. However, we take steps to ensure that Personal Information is transferred, stored and processed in a secure manner, and that your privacy rights are respected in a manner that is consistent with APPs.

We may transfer or disclose Personal Information to recipients outside of Australia, including, but not limited to, New Zealand, Singapore, India, United Kingdom, United States and Germany. If this happens, you will be informed of and asked to consent to such transfers and disclosures in accordance with this Privacy Policy.

Direct marketing and opting out

We may, after obtaining express prior consent or in appropriate circumstances via the contact details provided such as email, SMS or phone, inferred consent, use and disclose information, including Personal Information, to communicate with you about its current or new products and services that it considers may be useful or relevant to you. We do not rent, sell or share Personal Information about individuals with other people or non-affiliated companies for their direct marketing purposes. If you do not wish to receive direct marketing from us in the future, you may opt out of receiving such communications at any time by following the opt out instructions set out in the relevant communication or by contacting the Privacy Officer using the details set out below.

Use of cookies and IP addresses on our websites

We use session cookies on our websites. A cookie is a small information file that is transferred by the website to your computer's browser which may then store it on your system for later retrieval by this wesbite. Cookies track your movements through different websites. We do not use cookies to identify individuals (for example by linking them with an email address they may have provided). The cookies we use help your navigation of the website and personalise your experience when you visit it. We may use non-personalised statistics about the use of this website to continually improve it and improve customer service. These statistics do not comprise personal information. We also collect IP addresses. An IP address is used to identify an individual's computer on the Internet. We use the IP addresses for system administration.

Data quality and security

We take reasonable steps to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure.

Personal Information is stored securely whether in an electronic or physical form. For example, only staff needing access to the information are allowed access. Personal Information is stored in secured premises or in electronic databases requiring logins and passwords. Personal Information will be permanently de-identified or destroyed if it is no longer required for any purpose for which we collect it as described in this policy or for which we may otherwise use or disclose it, or when we are no longer required to keep it. Some information, particularly Health Information, must be kept for a number of years to comply with legal requirements, such as health records legislation.

Anonymity and pseudonymity

When dealing with us, you may choose not to identify yourself, use a pseudonym, or not provide us with some or all of your Personal Information. However, in any of these situations, such elections may affect our ability to provide the products, services, information or assistance requested. Where you elect to use a pseudonym, or to use this website anonymously, we may subsequently contact you and request details of your true identity if we need them to fulfil any legal requirements.

Access to and correction of your personal information

We try to ensure that all the Personal Information about an individual that we collect, hold, use or disclose, is relevant, accurate, complete and current. You must promptly notify us if there are any changes to your Personal Information.

You can at any time request access to your Personal Information by contacting our Privacy Officer using the details set out below. We will process such requests within a reasonable time without charge. You may also ask us to correct your Personal Information that you believe is irrelevant to the purposes set out in this Privacy Policy, inaccurate, incomplete or out-of-date.

We may need to verify your identity before giving access to or correcting your Personal Information. We will respond to such requests in a reasonable time, usually within 30 days.

We will provide you with access to your Personal Information unless an exception in the Privacy Act or applicable health records legislation applies.

If we refuse your request for access to or correction of your Personal Information in response, we will notify the you in writing of our decision and our reasons (unless it would be unreasonable to do so) and how to complain about the decision. If we refuse to correct Personal Information, you may ask us to record a statement with that Personal Information indicating what you believe is incorrect.

Questions, Concerns or Complaints

If you wish to make a complaint in relation to our handling of your Personal Information or a decision about your access or correction request or you have any other questions or concerns about your privacy, you should contact our Privacy Officer by phone, email or post using our details set out below.

We will need details about the nature of the complaint and will need to verify your identity. We will investigate any complaint and respond within a reasonable period and generally within 30 days. We may need to request more information in order to respond.

If you are not satisfied with our response to a complaint, you can contact the Office of the Australian Information Commissioner on the details below:

Our Contact Details

The Privacy Officer
Meda Pharmaceuticals Pty Ltd
c/ Head of Legal - ANZ
PO Box R1462
Royal Exchange Post Office
Tel: +61 (2) 9298 3999
Fax: +61 (2) 9566 4686
Email: privacyofficeranz@remove-this.mylan.com

OAIC contact details

Office of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001
Online form: www.oaic.gov.au (Privacy Complaint Form)

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 OAIC at http://www.oaic.gov.au.

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy at any time and without notice to reflect changes to its practices or legal obligations. Any amendments will take effect when the revised version of this Privacy Policy is posted on our product website.

Last updated: August 2017