We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Privacy Act’s requirements in respect of the collection, management and disclosure of your personal information.
What is your personal information?
What personal information do we collect and hold?
We may collect the following types of personal information:
- identification information, such as your name, mailing or street address, age or date of birth, telephone contact numbers, your email address, your referring doctor and your profession or occupation;
- sensitive information, which will include health information including your attendance for treatment or assessment, your medical history and diagnosis, results of your medical tests and details of your treatment, and information about your participation in a clinical trial; and
- any additional information relating to you that you provide to us in the course of a clinical trial.
Where we are required to collect identifying information such as your name, email address or phone number for the purpose of conducting a clinical trial, we will do so only with your consent. In this circumstance, this personal information will be used only for the purpose of conducting the clinical trial and will never be disclosed to a third party unless we are compelled by law to do so.
In most cases we collect and hold information in a manner that is not linked to your name or other information that is likely to identify you. We identify participants in clinical trials by codes and do not use names. This is one of the ways we protect your privacy because the information we collect and link to a code is not personal information because it does not identify you or anyone else. We also take other steps to ensure that the information cannot be linked to you or any other identifiable person. We may do this by aggregating the information of multiple individuals so that the resulting information identifies a group of individuals rather than anyone in particular.
How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
- through your access and use of our electronic platform;
- during conversations between you and our representatives; or
- when you complete an application to enrol in the clinical study.
We may also collect personal information from other people including medical professionals, health service providers, such as your referring doctor, hospitals, nurses, clinics and medical specialists in order to assist us in our provision of services to you.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, you may not be able to participate in the clinical trial. In addition, if you provide inaccurate or incomplete information in connection with the clinical trial, your treating healthcare professional may not have all the information they require to accurately provide you with medical or clinical trial services.
For what purposes do we collect, hold, use and disclose your personal information?
We collect, hold, use and disclose your personal information for the following purposes:
- to assist you and facilitate your participation in a clinical trial;
- to enable us to conduct a clinical trial and to conduct research and analysis and prepare reports on the results of a clinical trial;
- to answer enquiries and provide information about a clinical trial;
- to conduct business processing functions including providing personal information to our contractors, healthcare service providers or other organisations in order for us to conduct a clinical trial;
- to process and respond to any complaint made by you; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.
To whom may we disclose your information?
We will never disclose any information that identifies you (such as your phone number or email address which we need for the clinical trials) to any third party. If you experience technical difficulties with the electronic platform that we use for the clinical trial, we may disclose your phone number or email (but never your name) to our relevant employees so that they can help you and us to resolve those difficulties. In this case, our employees will have your contact details but will not have your name.
We may disclose information that does not identify you (for example, we may aggregate or code the information so that it does not identify anyone) to third parties for the purposes of conducting the clinical trial. Those third parties include our employees, contractors or service providers for the operation of our electronic platforms or our business, fulfilling requests by you and to otherwise provide services to you including, without limitation, statistical advisors, web hosting providers, IT systems administrators, couriers, and professional advisors.
We never disclose your personal information relating to a clinical trial to a third party sponsor of a clinical trial, such as a pharmaceutical company. Any information released to a third party sponsor of the clinical trial is aggregated so that it does not identify you or anyone else.
In addition, if you are a patient, we may disclose your personal information (such as your contact or health information) to your referring doctor or other healthcare provider along with their nurses or support staff if you have agreed to us making such a disclosure in conjunction with our services. It is your responsibility to advise us if there is any change to your health care service provider.
How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and we will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to 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 stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
Do we disclose your personal information to anyone outside Australia?
We hold your personal information on secure computer systems located in Australia. However, our data hosting and other IT service providers, who are located in Hong Kong, Singapore, New Zealand and the Philippines, will access those systems and your personal information for the purposes of providing us with IT services that support our services to you. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
In addition, as we provide services which are accessible through a web portal, your personal information may be accessed by entities around the world who are authorised by us but only with your prior consent. Generally, all information will be de-identified or aggregated so that you cannot be identified.
We store your personal information on electronic systems and take reasonable steps (including technological measures, administrative procedures and physical security) to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Personal information is destroyed or de-identified when no longer needed.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Please contact our Privacy Officer at:
Medical Safety Systems Corporate Pty Ltd
Post: Level 1/94 Mallett St
Camperdown NSW 2050
Tel: 02 8004 6877