Our Privacy Obligations
Key Pharmaceuticals is governed by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). The APPs regulate how personal information is handled by Key Pharmaceuticals.
‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Key Pharmaceuticals’ Privacy Policy applies to personal information collected and/or held by Key Pharmaceuticals.
Additionally, as an organisation operating in NSW that collects, holds or uses health information, Key Pharmaceuticals is also governed by the Health Records & Information Privacy Act 2002 (NSW).
We will review this policy regularly, and we may update it from time to time.
The Types of Personal Information We Collect and Hold
We collect personal information about employees, prospective employees, clients, customers, consumers, suppliers, vendors, as part of our routine activities.
We also collect contact details of individuals who work for contractors and suppliers, and other types of professional associates and personal contacts.
How we collect personal information
Information that you specifically give us:
We collect information through various means, including interviews, phone calls, appointments, forms and questionnaires (whether in hardcopy or electronic format, including information submitted via our website or other electronic means). If you feel that the information that we are requesting, either on our forms or in our discussions with you, is not information that you wish to provide, please feel free to raise this with us.
We may ask you to provide us with certain types of personal information if you wish to report an adverse event or product or service complaint. This might happen over the telephone, through our website, by filling in a paper form, through social media platforms or meeting with us face-to-face. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.
You might also provide your personal information to us, without us directly asking for it, for example if you engage with us on social media.
Information that we collect from others:
We may also obtain personal information about you from a third-party source. If we collect information about you in this way, we will take reasonable steps to contact you and ensure that you are aware of the purposes for which we are collecting your personal information and the organisations to which we may disclose your information, subject to any exceptions under the Privacy Act. If we receive unsolicited personal information about you that we could not have collected in accordance with this Privacy Policy and the Privacy Act, we will within a reasonable period, destroy or de-identify such information received.
If you apply for a job or contract with us, we will collect personal information about you from your referees. With your consent we may also use a third party service to ensure your employment, educational and identity records are valid.
We may also check some details about our suppliers from publicly available sources, such as the Australian Business Register and ASIC databases.
Information that we generate ourselves:
We maintain records of the interactions we have with employees, prospective employees, clients, customers, consumers, suppliers, vendors, including the products we have provided to you, reported adverse events and product or service complaints.
When individuals visit our customer websites and portals, we may collect certain data for analytical and marketing purposes. This may include:
- IP addresses and device information for security and technical purposes.
- Cookies and similar technologies to track user interactions, preferences, and behaviour on our websites.
- Information voluntarily provided by users through online forms and registrations.
We use this data to improve the functionality and user experience of our websites, personalise content and advertisements, and analyse website traffic and trends.
Our Internet Service Provider, websites and online portals may collect limited information about users for diagnostic and analytic purposes We do not trace these back to individual users.
The types of personal information we collect
The types of personal information we collect about employees, prospective employees, clients, customers, consumers, suppliers, vendors may include:
- name, position, date of birth, current address, facsimile numbers, email address, telephone numbers, next of kin, tax file number, education details, Australian Business Number, bank details, business references, financial details, details about your business, drivers licence number, preferred means of contact, professional credentials, hobbies and interests.
- We also may collect data relating to suspected adverse events as follows: age, weight, medication use, allergies or sensitivities to foods and ingredients, medical condition, doctor or pharmacist details.
On our website, we may provide links to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.
How We Use Personal Information
We may use your personal information for the following purposes:
- to provide the product you have requested
- to provide technical or other support to you
- to answer your enquiry about our products, or to respond to a complaint
- to manage our employment or business relationship with you
- to promote our other products which may be of interest to you (unless you have opted out from such communications)
- to comply with legal and regulatory obligations
- if otherwise permitted or required by law, or
- for other purposes with your consent, unless you withdraw your consent.
We will keep personal information about you, to use for the above purposes, for various amounts of time depending on the circumstances in which it is collected (see section on Security of your personal information).
When We Disclose Personal Information
Our third party service providers
The personal information of employees, prospective employees, clients, customers, consumers, vendors, staff, suppliers and other contacts may be held on our behalf outside Australia, including ‘in the cloud’, by our third party service providers. We take reasonable steps to ensure that third parties handle personal information in accordance with applicable privacy laws and contractual obligations.
Other disclosures and transfers
We may also disclose your personal information to third parties for the following purposes:
- if necessary to provide the product you have requested;
- Therapeutic Goods Administration and/or overseas companies who are required by law to collect details related to suspected adverse events and product complaints;
- Trade customers in relation to suspected adverse events and product complaints;
- your referees;
- your former employers;
- credit agencies;
- our professional advisors, including our accountants, auditors and lawyers;
- our Related Entities and Related Bodies Corporate (as those terms are defined in the Corporations Act 2001 (Cth))
- our contractors and suppliers;
- if otherwise permitted or required by law; or
- for other purposes with your consent.
We will only use or disclose your personal information for the purposes of direct marketing if:
- we collected the information from you;
- it is reasonable in the circumstances to expect that we would use or disclose the information for direct marketing purposes;
- we provide you with a simple means to ‘opt-out’ of direct marketing communications from us; and
- you have not elected to ‘opt-out’ from receiving such direct marketing communications from us.
It is likely that we will disclose personal information to overseas recipients as required by law in relation to suspected adverse events.
The countries in which overseas recipients of personal information are located includes:
- United States of America
- United Kingdom
- Singapore
- Netherlands
- Thailand
If we disclose personal information to overseas recipients, we will take reasonable steps to ensure that such recipients do not breach the Privacy Act and the APPs unless:
- we believe that the overseas recipient is subject to a law that has the same effect of protecting personal information in a way that, overall, is at least substantially similar to the way in which the Privacy Act and the APPs protect personal information and there are mechanisms available for you to access to take action to enforce that protection of law; or
- we obtain your express consent to the disclosure of personal information to overseas recipients.
Security of Your Personal Information
We are committed to protecting personal information from loss, unauthorised access, use, modification or disclosure. We implement appropriate technical and organisational measures to protect and safeguard personal information, including encryption, access controls, and secure storage systems.
We will take reasonable steps to ensure personal information is stored securely and disposed of appropriately.
Personal information stored for common categories will be retained for the below periods:
- Product Complaints – 6 years
- Adverse Events – maximum is for life of medicine or device plus 10 years registration cancelled
- Payroll records – 6 years
- Training records and position descriptions – Duration of employment plus 6 years
Accessing or Correcting Your Personal Information
You have the right to request access to the personal information Key Pharmaceuticals holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense.
You also have the right to request the correction of the personal information we hold about you. We will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date. Unless an exception applies, we must update, correct, amend or delete the personal information we hold about you within a reasonable time period. We do not charge for making corrections.
To seek access to, or correction of, your personal information, please contact our Privacy Officer.
To Contact Our Privacy Officer
If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:
PRIVACY OFFICER
Telephone: +61 2 8113 6200
Australia toll-free: 1800 653 373
Email: privacy@keypharm.com.au
Mail: MQX4, Level 3, 1 Giffnock Avenue Macquarie Park, NSW 2113 Australia
While we endeavour to resolve privacy complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal privacy complaint within 10 working days.
If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by calling them on 1300 363 992, making a complaint online at www.oaic.gov.au, or writing to them at OAIC, GPO Box 5218, Sydney NSW 2001.