1. PERSONAL INFORMATION WE COLLECT, HOW IS IT COLLECTED AND FOR WHAT PURPOSE IS IT USED.
The types of personal information we collect varies depending on our relationship with you:
1.1 Pharmacy Customers
Juno may collect your personal information where you are an individual that owns a pharmacy or an employee of a pharmacy business. The personal information collected may include your name, contact details, how you wish to be contacted, notes of our calls and communications with you, areas of your interest (including your professional interests), details of your business (including your purchasing and (deidentified) dispensing patterns), bank account and credit card details), survey information and feedback provided by you.
This personal information is generally collected directly from you when we first make contact and during the course of our business relationship with you. The information is used for the purpose of facilitating and improving our business relationship with you as a customer, including providing you with the benefit under any contracts we have with you (or your employer). Failure by you to provide personal information may hamper our ability to provide you with optimum services and benefits.
1.2 Health professionals
Where you are a health professional (such as a doctor or pharmacist) your contact details are collected when you provide us with queries or feedback in relation to products or pharmacovigilance information (ie the monitoring of medicines and other therapeutic goods). This type of personal information is generally collected directly from you when you contact us. Your contact information is used for follow-up activities, including those that are part of standard Pharmacovigilance activities. With respect to pharmacovigilance activities, if you fail to provide us with such personal information or to consent to the disclosure of this information to our suppliers and distributors (see below), this may result in the failure to properly investigate and follow-up on such pharmacovigilance reports.
If you are a health professional and provide Juno with health information of your patients, Juno expects that you obtain the consent of your patient before disclosing their health information to us. The details of your patient may be deidentified where we are not satisfied that you have obtained that consent.
Following receipt of any enquiries, healthcare professionals may also be asked for permission to be contacted by us in future about our products. You are entitled to refuse, or withdraw, such permission, at any time.
If you are a patient, your health information is collected when pharmacovigilance reports or product complaints are reported to Juno directly by you or through your health professional. Your information will also be collected if you choose to enrol in a patient support program related to our products. The specific types of health information collected may include your name, contact details, medical status and background, any medications taken, any treatment received, the contact details of your treating health professional and any recommendations arising out of such clinic or services.
Health information of patients is collected for the purpose of investigating and following up product complaints and pharmacovigilance reports, or providing you with professional services (as the case may be). Failure to provide us with all the information sought may result in our inability to provide those services or investigate the pharmacovigilance report or product complaint.
1.4 Business associates and contractors
Juno collects your personal information if you own, or work for, a business associate or contractor of Juno. This information generally consists of contact information and is generally collected directly from you or from your employer. Your personal information is used for the purposes of facilitating the business relationship (including as contemplated under any contract). Failure to collect such information may hamper our ability to communicate with you.
2. HOW WE MANAGE AND DISCLOSE PERSONAL INFORMATION
2.1 Where you provide us with personal information about someone else
2.2 Holding personal information
Juno holds personal information in hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example, security passes to enter our offices) and technology (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates) security measures. We also have document retention policies and processes. In some cases, Juno engages third parties to host electronic data (including data in relation to the services we provide) on our behalf.
2.3 Disclosure of personal information
The types of third parties to whom we may disclose your personal information include:
- our service providers, including service providers that may assist with patient support programs
- our professional advisers
- other affiliated companies within the Juno group, including our parent company, Juno Pharmaceuticals Pty Ltd
- as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including Juno’s business) or to enter into an alliance, joint venture or referral arrangement, or
- government or regulatory bodies or agencies, as part of an engagement or otherwise, (for example, the Australian Taxation Office).
Some organisations that we use to store and manage your personal information, or that we disclose your personal information to, may be located in a country or countries outside Australia. We may also use cloud-based service providers who use assets located in other countries to manage our data. We will not disclose your personal information to an overseas recipient, including our service providers, without taking reasonable steps to ensure that the overseas recipient will not breach local privacy legislation.
We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non personal, de-identified or aggregated information to them for research or promotional purposes.
We may also disclose your personal information in circumstances permitted by the Privacy Act.
3. GAINING ACCESS TO PERSONAL INFORMATION WE HOLD
You can request access to your personal information at any time, subject to some limited exceptions permitted or required by law. Such request must be made in writing to the Juno Privacy Officer.
4. KEEPING PERSONAL INFORMATION CURRENT
If you believe that any personal information Juno has collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request correction. To do so, please contact the Juno Privacy Officer and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.
5. LINKS TO OTHER WEBSITES
6. PROTECTION OF PERSONAL INFORMATION
Juno is committed to keeping your personal and sensitive information secure.
We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. We also use every effort to ensure that third parties who work with us also protect your personal information. Where we no longer require the personal information for the purpose for which it was obtained, we will take reasonable steps to delete the information and or ensure it is de-identified (as reasonable in the circumstances).
7. CONTACT DETAILS
If you wish to contact or make a complaint to Juno about our handling of your personal information, you can contact the Juno Privacy Officer, on the contact details below. You will be asked to set out the details of your complaint in writing in a form provided. Juno will endeavour to reply to you within 30 days of receipt of the completed complaint form and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, the Juno Privacy Officer may decline to investigate the complaint, for example if the complaint relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner.
Juno PC Holdings Pty Ltd
42 Kelso St,
Cremorne. Vic 3121,
By email to: firstname.lastname@example.org