Privacy

1. ABOUT THIS POLICY

1.1 This Privacy Policy (Policy) applies to MS Health Pty Ltd (ACN 155 182 586) (“MS Health”, “we”, ”our” or “us”), and describes how MS Health collects, handles and protects the privacy of your personal information.

1.2 MS Health is a not-for-profit pharmaceutical company established to deliver vital reproductive health products and medicines. We are proud to be part of Marie Stopes International, delivering a global mission of children by choice, not chance.

1.3 We are committed to protecting your privacy and understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure and your rights in relation to your personal information, including how to complain and how we deal with complaints.

1.4 We will handle your personal information in accordance with this Policy, legislation including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

1.5 In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.

1.6 This Policy does not apply to the personal information of our employees.

1.7 We may change this Privacy Policy from time to time, by publishing changes on our website: www.mshealth.com.au/privacy.

 

2. TYPES OF PERSONAL INFORMATION WE COLLECT

2.1 The types of personal information we collect about you depends on the dealings you have with us, and may include your:

(a) name, title, address, email address and phone number;
(b) the name of the organisation you work for and your professional title; and
(c) information about any enquires made to us.

2.2 If you are applying to be a Certified Prescriber or Dispenser of MS-2 Step or have already registered as a Certified Prescriber or Dispenser of MS-2 Step, we will also collect information about:

(a) your qualifications;
(b) your practice or pharmacy name and contact details;
(c) your AHPRA registration number; and
(d) your Certification status and whether you have completed all Certification Tasks.

2.3 If you have suffered or are reporting a suspected adverse event in respect of one of our products, we may also collect:

(a) patient identifier information (such as initials, date of birth or age, but not the patient’s full name);
(b) details of the product involved;
(c) details of the suspected adverse event; and
(d) if you are not the patient, your relationship to the patient.

2.4 If you are applying for a job with us, we may also collect your:

(a) employment history and qualifications;
(b) academic records;
(c) references;
(d) medical information;
(e) personal alternative contact details;
(f) superannuation fund details; and
(g) criminal history record.

2.5 If you are a contractor or supplier, we may also collect:

(a) trade references, credit references or reports from third parties about you and/or your goods or services; and
(b) financial information, including payment details.

 

3. DEALING WITH US ANONYMOUSLY OR USING A PSEUDONYM

3.1 Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question we will not record your name unless we need it to adequately handle your question.

3.2 However, for many of our functions and activities we usually need your name, contact information and other details to enable us to provide our services or products to you.

 

4. WAYS WE COLLECT YOUR PERSONAL INFORMATION

4.1 We may collect personal information from or about you in different ways, including:

(a) from you directly when you interact with us, e.g. from our discussions with you, when you complete a form, your emails and your interaction with our website;
(b) through third parties with whom we interact in order to provide our services; and
(c) publicly available sources, including social media.

4.2 If you have suffered from an adverse event, we may receive personal information about you from your treating healthcare professional who is reporting the adverse event.

4.3 If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including from:

(a) recruiters;
(b) government departments to verify your entitlement to work in Australia;
(c) police agencies to obtain your criminal history record;
(d) academic institutions;
(e) your consulting healthcare professionals
(f) your superannuation fund provider;
(g) your current or previous employers; or
(h) your referees.

 

5. COLLECTION OF INFORMATION VIA OUR WEBSITE

5.1 When you visit our website, we may also use ‘cookies’ or other similar tracking technologies (such as Google Analytics and Click Stream Data) that help us track your website usage and remember your preferences. Cookies are small files that store 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 can disable cookies through your internet browser but our website may not work as intended for you if you do so.

5.2 Whilst we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your computer.

5.3 Our web pages may contain electronic images, known as web beacons. These electronic images enable us to count users who have visited certain pages on our website. Web beacons are not used by us to access your personal information, they are simply a tool we use to analyse which web pages are viewed, in an aggregate number.

 

6. PURPOSES FOR WHICH WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION

6.1 We collect your personal information for the following purposes:

(a) to provide our services;
(b) to manage and conduct our business;
(c) to provide information about our products and services, including education or training for healthcare professionals in respect of the administration and use of our products;
(d) to compile a list of Certified Dispenser and Prescribers, in order to comply with any risk management plan associated with the products we supply and which is shared with:

(i) other Certified Dispensers and Prescribers so that Certified Prescribers can refer patients to Certified Dispensers and vice-versa; and
(ii) pharmaceutical wholesalers who distribute our products so that they only supply products subject of a risk management plan to Certified Dispensers;

(e) to obtain feedback;
(f) to comply with our obligations to report suspected adverse events in respect of therapeutic goods that we sponsor and supply in Australia to the Therapeutic Goods Administration;
(g) to help us manage, develop and enhance our services, including our websites and applications;
(h) to consider your suitability for employment; and
(i) to comply with our legal obligations, resolve any disputes and enforce our agreements and rights with third parties.

 

7. DISCLOSING YOUR PERSONAL INFORMATION

7.1 In the course of providing our products and services to you and otherwise fulfilling the purposes set out in paragraph 6.1 above, we may need to disclose your personal information to:

(a) members of the MS Health Group of companies;
(b) third parties in order to provide our services, for example pharmaceutical wholesalers, and our suppliers in order to comply with our pharmacovigilance and quality assurance obligations;
(c) organisations we contract to provide services on our behalf such as software suppliers;
(d) anyone to whom part of all of our assets or businesses are transferred or sold;
(e) our professional advisers, including lawyers, accountants and auditors; and
(f) government agencies, regulatory bodies and law enforcement agencies, or other similar entities.

7.2 Some of these organisations may be located outside of Australia, including in the United States and the United Kingdom.

 

8. DIRECT MARKETING

8.1 We may use your personal information to identify a product or service that you may be interested in or to contact you about education or training courses that may be of interest to you, or to invite you to participate in our fundraising activities. We may, with your consent, use the personal information we have collected about you to contact you from time to time whether by post, email, phone, SMS or MMS to tell you about new products or services and special offers that we believe may be of interest to you.

8.2 You can withdraw your consent to receiving direct marketing communications from us at any time by unsubscribing from the mailing list by:

(a) clicking “Unsubscribe” on any email communications; or
(b) contacting our Privacy Officer.

However, if you are a Certified Dispenser or Prescriber, it is not possible to opt out of receive all communications from us and pursuant to our risk management plans in relation to the products that we supply, we will continue to provide you with important updates regarding product safety and quality matters.

 

9. SECURITY AND STORAGE

9.1 We store your personal information in hard copy and electronically. We take reasonable and appropriate steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

9.2 We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

 

10. ACCESS TO AND CORRECTION OF YOUR INFORMATION

10.1 We will endeavour to ensure that the personal information collected from you is up to date, accurate and complete.

10.2 You may request access to, or correction of, the personal information we hold about you at any time by contacting our Privacy Officer using the details set out in this Policy. We will need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, we will provide you with access to the personal information you request within a reasonable time and usually within 28 days. If we decide to refuse your request, we will tell you why in writing and how to complain.

 

11. COMPLAINTS

11.1 You can make a complaint in writing to our Privacy Officer using the details set out in this Policy. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

11.2 If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.

 

12. CONTACT US

If you have a question or comment regarding this Policy or wish to make a complaint or exercise your privacy rights, please contact our Privacy Officer via any one of the following:

Email: [email protected]
Mail: GPO Box 1635, Melbourne Vic 3001
Phone: 1300 515 883

Dated: 31 March 2021