GlaxoSmithKline Australia Pty Ltd (‘GSKA’) (ABN 47 100 162 481) and GlaxoSmithKline Consumer Healthcare Australia Pty Ltd (‘GSKCHA’) (ABN 68 603 310 292) (“we”, “ours” or “us”) respects and upholds your rights to privacy in accordance with the Australian Privacy Principles contained in the Privacy Act 1988. The Australian Privacy Principles apply to us from their introduction in March 2014.
This policy describes how GSKA and GSKCHA manages any personal information we have about you.
1. What personal information will we collect from you?
We may hold information on individuals who fall into one of three main groups: health professionals, members of the general public and others. The personal information held about you if you are a member of the various groups may include:
- Your name, business address, business telephone number(s) and email address;
- Professional details;
- Details included in curriculum vitae;
- Practice specialty including areas of interest;
- Membership of professional associations;
- Practice and/or business details including GSKA and GSKCHA product usage;
- Dealings with us: For example: details of medical enquiries, adverse event reporting, clinical trial involvement, your web activity in accessing GSK websites
- Details of sales representative appointments and pharmaceutical company sponsored programs such as seminars and meetings.
Consumers and the General Public:
- Your name, relevant address, telephone number(s) and email address;
- Dealings with us such as: medical enquiries, adverse event reporting, patient support scheme participation, clinical trial participation and your web activity in accessing GSK websites.
Other persons such as third party contractors and job applicants:
- Your name, business address, business telephone number(s) and email address.
- Dealings with us: work and employment references, reports and assessments.
We will not collect other sensitive information about you without your consent, such as personal information about your health, race, political opinion etc.
2. How do we collect your personal information?
We will collect information about you directly from you, if it is possible to do so, but it may on some occasions be collected from other sources, some of which you may be unaware, including:
- Publicly available directories and listings such as telephone directories;
- Newspapers, magazines, professional journals and the electronic media;
- Databases supplied by third parties;
- The internet and other electronic communications such as: Articles and information pieces in which you feature on a website such as a health information site or a medical professional site;
- The date, time and domain from which you access our websites and your web activity;
- Personal communications with our staff.
3. How do we manage your personal information?
We will store information collected about you securely and access will only be allowed to those authorised. Your personal information will only be used for the purpose for which it was collected, other related purposes or as permitted or required by law. In the case of sensitive information, such information will only be used for the purpose for which you have provided consent or as permitted or required by law. We will delete from our records personal information no longer required or in use for the purposes identified, other than information which we are required to retain. If possible, such information will be retained in a way that you cannot be identified.
4. The purposes for which we collect, hold and use your personal information
We collect personal information at different times, which may be used for one or more of a variety of purposes, to allow us to perform our business activities and functions and to provide the best possible quality of customer service. These purposes include:
- Maintaining a record of medical queries, complaints and adverse event reports relating to our products and reporting these to relevant regulatory bodies, related companies or other companies which market the same product as may be required or prudent;
- Administering disease awareness/management programs or other similar programs organised by us;
- Notifying you of matters that we may be required by law to notify you of (e.g. product recalls);
- Generating customer lists for the purposes of our own market research;
- Responding to your requests and improving our level of service to you.
In the case of Health Professionals:
- Sending you direct marketing and other material on and contacting you regarding our activities and products or developments in pharmaceutical treatments which may be of interest to you and tailoring marketing services to suit your needs;
- Notifying you of our products and services and seeking your views on our products and services;
- Supplying you with clinical samples of our products;
- Administering clinical trials or other research organised by us and which you agree to participate in or be involved with;
- Administering conferences, symposia, expert panels, seminars or other meetings or events organised by us;
- Managing, planning and arranging meetings between you and our sales representatives;
- Monitoring and reviewing our compliance with relevant regulations and codes of conduct in its dealings with you.
We will not disclose personal information about you to any person except in accordance with the Privacy Act, and only where necessary. The circumstances in which we may disclose that information include:
- Where we notified you at the time of supply of the information to us or it is expressly permitted under any agreement with you;
- Where it is necessary to provide you with a service or goods which you have requested;
- Where required for the ordinary operation of our business (for example, to send you information about our goods and services);
- Where it is necessary for support services to be provided in relation to our business activities (please note that such disclosures will only be to people and entities required to meet the same standards of data protection and are prevented from using the information for their own marketing purposes);
- Where we consider the law requires it, or in response to any demand by law enforcement authorities;
- Regulatory authorities (such as the Therapeutic Goods Administration and State and Territory drug and health authorities) where we are required to provide your personal information to the particular authority;
- Third parties that we use in the ordinary operation of our business, such as for conference organising, marketing, data processing and associated printing and mailing. For example, it may also be provided to Clinical Research Organisations for the purposes of medical research. We will only provide your personal information to reputable third parties and then only on a confidential basis where we are satisfied that those third parties will similarly comply with the Australian Privacy Principles and the Privacy Act. These activities may involve the transfer of your personal information overseas as described above;
- Companies related to us for the same kinds of purposes as listed above. Subsequent use and disclosure by the related company will be in compliance with the Australian Privacy Principles and the Privacy Act;
- Another company for the purpose of ensuring continuity of product supply and/or service if the supply of the product or service has been transferred to that company; and
- Such third parties otherwise permitted or required by law.
Unless otherwise specified in the website or mobile application, we will not sell or rent personal information to other third parties, except where your personal information may be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred.
At any time you may opt out of receiving any communications from us (other than as required for the operation of our business, e.g. regarding account payment if you have one with us), although we may then be unable to provide you with all of the information regarding our programs, events, services or products which may be of benefit to you. If you decline to provide us with your personal information (or subsequently opt-out) it will likely preclude the provision of relevant services to you by us.
6. Link to other websites
Please ensure you check the legal and privacy statements posted on each website or mobile application you access before entering any personal information.
7. Access, correction and contacting us
You may request access to personal information we hold about you by contacting “The Privacy Officer” as detailed in section 8 below.
Your request should detail your name, contact details, your former name or alias, if any, and the information you believe we may hold on you. You do not have to provide a reason for requesting access. Where we hold information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you may access it (e.g. emailing or mailing it to you). In any event we will acknowledge receipt of request within 10 working days and endeavour to respond to your request within 30 days.
If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, then you may request we 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 we hold stating that you disagree with it.
To make a complaint regarding our treatment of your personal information, you should write to “The Privacy Officer” via the address below.
We will attempt to confirm, as appropriate with you, your understanding of the conduct relevant to the complaint and what you expect as an outcome. An investigating officer will contact you to inform you of whether or not we will conduct an investigation as well as an estimated completion date for the investigation process.
Upon completion of our investigation (if any), we will contact you in writing to advise you of the outcome and invite a response to our conclusions about your complaint. We will assess any comments provided by you and advise you of our findings accordingly.
If you are unsatisfied with the outcome of our internal investigation further action may be taken by contacting the Office of the Australian Information Commissioner.
To make a direct complaint to GSK, please write to:
The Privacy Officer
Level 3, 436 Johnston Street
Abbotsford VIC 3067
In this policy “personal information” and “sensitive information” have the same meaning as under the Privacy Act.
We may change this policy from time to time. The amended policy will be effective immediately. We encourage you to periodically review this policy to stay informed about how we are helping to protect the personal information we collect. Your continued use of our websites and mobile applications constitutes your agreement to the policy and any updates.