1. PURPOSE

Apotex Pty Limited ABN 52 096 916 148 (Apotex) offers for sale and sells pharmaceutical products and related services to wholesalers, pharmacies and hospitals. This Privacy Policy applies to the processing of personal information by Apotex in Australia.

2. SCOPE

Apotex recognises the importance of the privacy of individuals. In conducting its business, Apotex collects personal information (which may include health information and sensitive information). This Privacy Policy aims to allow individuals to make their own choices about how Apotex uses this personal information. This Privacy Policy sets out how Apotex manages personal information to meet its obligations under the Privacy Act and the National Privacy Principles and the Australian Privacy Principles (which will commence application in 2014). This Privacy Policy complies with the requirements of the Privacy Act. Some of Apotex’s actions with respect to employee records are exempt from regulation under the Privacy Act and, therefore, this Privacy Policy.

3. DEFINITIONS

Health information includes information about the health of a person, or health services provided to them. Personal Information generally means information or opinions about a person who is reasonably identifiable from that information. Personal information includes sensitive information. Sensitive Information includes information about a person’s beliefs or associations.

4. RESPONSIBILITIES

As outlined in Apotex’s Code of Conduct, the directors and employees of Apotex are bound by the laws of the country in which they operate and the security, lawful and proper use of personal information is mandatory.

5. GUIDELINES

5.1 Collecting personal information

Wherever possible and practical, Apotex will ensure personal information is de-identified, and individuals dealing with Apotex may request anonymity or the use of a pseudonym. However, there may be situations for both healthcare professionals and patients where it is impracticable for the purposes outlined above to de-identify each individual. If Apotex receives personal information that it would not ordinarily be permitted to collect under the Privacy Act, it will destroy or de-identified that information. Apotex will take reasonable steps to notify individuals of Apotex’s collection of their personal information, and will provide all relevant information prescribed under the Privacy Act. Apotex will only collect personal information by lawful and fair means.

5.2 What information is collected

Healthcare Professionals

The personal information Apotex may collect includes:

1.     a health professional’s name;

2.     general contact information such as address, telephone and fax;

3.     professional practice information, such as year of graduation;

4.     professional information which individuals provide directly to it, such as areas of their professional interest;

5.     information about their own pharmacy, such as purchase and dispensing patterns; and

6.     information about the health professional’s preferences about how they should be contacted for professional purposes.

Patients

The personal information Apotex may collect includes:

1.     a patient’s name;

2.     general contact information such as address, telephone and fax; and

3.     other information reasonably required in order to respond to the enquiry and/or comply with legal obligations, and, with the patient’s consent or as required by law;

4.     medical status and medical history;

5.     medications being taken;

6.     treatment received;

7.     contact details of treating healthcare professionals.

5.3 How Apotex uses personal information

Healthcare Professionals

The primary purpose for which Apotex collects personal information of healthcare professionals is to provide information for customers and for sales and marketing purposes by Apotex and its contractors, including sales representatives, on behalf of Apotex.

Patients

The primary purpose for which Apotex collects personal information of patients’ is to respond to enquiries and comply with legal obligations.

5.4 How Apotex discloses personal information

Other than by operation of the above databases, Apotex does not use or disclose any information about individuals without their consent, unless:

1.     required by law;

2.     Apotex believes it is necessary to provide an individual with a service which they have indicated they wish to receive, such as product updates;

3.     to protect the personal safety of any member of the public; and

4.     the assets and operations of Apotex business are transferred to another party as a going concern.

Apotex may disclose personal information to third parties within and outside of Australia, in addition to its related bodies corporate, regulatory authorities and ethics committees as required and permitted under the Privacy Act.

5.5 Apotex will not ‘spam’ you

Apotex may contact you at the email, fax or other address which you provide in order to:

1.     provide you with urgent communications regarding Apotex’s products;

2.     provide you with other information about products and services in which you may be interested; or

3.     respond to an enquiry.

Apotex will comply with its obligations under Spam Act 2003 (Cth).

5.6 Do Not Call Register

Apotex may contact you on any telephone number which you provide in order to provide you with information about its products and services or respond to an enquiry. Apotex will comply with its obligations under the Do Not Call Register Act 2006 (Cth).

5.7 You can access the personal information Apotex holds

If at any time you want to update or know what personal information Apotex holds, you are welcome to access your record by contacting Apotex using the details set out below. Your information will generally be made available to you within 14 days of receiving your request. Apotex reserves the right to not provide access to individuals if the request for access is frivolous or vexatious, or falls into another relevant exception category. Apotex may impose reasonable charges for such access.

5.8 Changing and deleting the personal information Apotex holds

Apotex will take reasonable steps to ensure personal information is accurate, up-to-date and complete and notify you of any such changes. If you wish to update your personal information, please contact Apotex to amend your record accordingly. If you wish to have your personal information deleted, please contact Apotex and Apotex will take all reasonable steps to delete it unless compelled by law to keep it.

5.9 Storage and security of your personal information

Apotex will take all reasonable steps to keep secure all personal information from misuse, interference, loss and unauthorised access. Personal information is stored on secure servers that are protected in controlled facilities, or in hardcopy paper records stored in secure access facilities. Apotex require its employees and data processors to protect the confidentiality of any personal information held by Apotex. Personal information will be kept until Apotex no longer needs the information for purposes it was collected for.

5.10 Apotex’s web site

Apotex does not collect personal information from visitors of this website. Future services or offerings available on this website may require personal information to be collected. If this is the case in the future, users will be notified of the purpose for the collection and intended use of the information. Cookies are pieces of data that a website transfers to a user’s hard drive for record-keeping purposes. Web beacons are transparent pixel images that are used in collecting information about website usage, email response and tracking. This Apotex site uses cookies and web beacons to provide enhanced functionality on the site and aggregate traffic data (e.g., what pages are the most popular). Apotex’s site also captures limited information (user-agent, last URL requested by the user) about visits in a form that does not identify individual users, Apotex may use this information to analyse general traffic patterns and to perform routine system maintenance. You have many choices with regard to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. By using this website, you consent to the use and installation of these cookies and web beacons to provide you with these services.

5.11 What to do if you have a problem or question

If Apotex becomes aware of any ongoing concerns or problems relating to other privacy practices, it will take these issues seriously and work to address these concerns. If you have any further queries relating to this Privacy Policy, you wish to receive a hard copy version of this Privacy Policy, or you have a problem or complaint, please contact Apotex. Apotex takes complaints seriously, and upon receipt will examine the complaint and instigate internal procedures to ensure Apotex continues to comply with the Privacy Act.

5.12 Future changes

Apotex’s commitment to being a leading provider of pharmaceuticals means its business will continue to evolve as new services and products are introduced. Because of this, from time to time, policies will be reviewed and may be revised. Apotex will notify you of any changes by posting an updated version of the Privacy Policy on its website.

5.13 Contact details for Apotex

You may write to Apotex at:
Managing Director
Apotex Pty Ltd.
PO Box 280
North Ryde BC NSW 1670

You may telephone Apotex on:
+61 2 8877 8333 or 1-800-APOTEX (273-839)

You may email us at: Email Apotex Pty Ltd.
Specifying in the subject line “Customer Privacy Policy”.

Should at anytime, there be a discrepancy between this Privacy Policy and the applicable legislation at the time, the applicable legislation at that time will prevail. Please note that Apotex reserves the right to amend or cancel this Privacy Policy at any time at its absolute discretion.

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