Privacy at AstraZeneca
AstraZeneca is bound by the Australian Privacy Principles contained in the Australian Privacy Act 1988 (Cth) and the New Zealand Privacy Principles contained in the Privacy Act 1993 (NZ) (“the Principles”) as applicable. The Privacy Acts define personal information as information or an opinion about an identified individual or an individual who is reasonably identifiable (such as name, address, telephone number, email address). In New Zealand to the extent that personal information is health information, AstraZeneca is also bound by the New Zealand Health Information Privacy Code 1994 (“Health Code”).
What personal information does AstraZeneca collect?
In the course of our business, AstraZeneca may collect personal information about you that is necessary for us to perform our functions. The personal information collected by AstraZeneca may vary depending on the type of our interaction with you and may include:
- identifying and contact information such as name, address, employment details, email address and mobile phone number;
- information about attendance at events or programs organised or supported by AstraZeneca such as meetings, symposia, conferences, expert panels and other research, disease awareness or similar programs;
- educational and professional membership information;
- bank account details if required for payments; and
- details about complaints and adverse events.
Depending on your interaction with us, AstraZeneca may also collect sensitive information such as professional association memberships and, in limited circumstances, health information and medical history.
AstraZeneca may collect personal information about:
- Healthcare professionals (including doctors, pharmacists, nurses) in the course of:
- Maintaining a record of inquiries, complaints and adverse event reports relating to AstraZeneca products;
- Interaction with sales representatives;
- Administering AstraZeneca programs such as meetings, symposia, conferences, expert panels, clinical trials and other research, disease awareness or similar programs;
- Complying with our legal and regulatory obligations, e.g. product recalls, product safety notifications.
- Members of the general public, in the course of their:
- Use of information services;
- Participation in AstraZeneca activities such as education and disease management programs.
- Third parties providing a service to AstraZeneca.
How does AstraZeneca collect personal information?
AstraZeneca may collect your personal information directly from you in a number of ways including over the telephone, through a form or online portal, or by email.
AstraZeneca may also collect your personal information from third parties such as organisations engaged by AstraZeneca to carry out functions on behalf of AstraZeneca including administrators of patient support/supply programs, event management organisations and recruitment agencies. If you are a healthcare professional, AstraZeneca may also collect your personal information from online directories which we subscribe to.
In certain circumstances, AstraZeneca is required to collect and hold certain types of personal information by law. For example, we are required to collect and hold records of sample medicines provided to healthcare professionals under the Medicines Australia Code of Conduct and applicable Australian State and Territory legislation and the Medsafe NZ Regulatory Guidelines for Medicines and applicable New Zealand legislation.
If you choose not to provide the personal information requested of you to AstraZeneca, we may be unable to provide you with the products and services you require or contact you to perform the functions and activities described below.
For what purposes does AstraZeneca collect, hold, use and disclose personal information?
The Principles generally require AstraZeneca to use personal information only for the primary purpose for which it is collected, or for secondary purposes which are related (or directly related in the case of sensitive information) to the primary purpose.
In general, AstraZeneca collects, holds, uses and discloses personal information for the following purposes:
- as indicated to you at the time your personal information was collected;
- general sales and marketing, including to contact you to provide you with information about, and to discuss, AstraZeneca products;
- to invite you to attend educational events and conferences, including any associated logistics;
- to provide health products or services (including advice) that have been requested;
- to provide educational materials;
- to manage patient support programs and patient supply programs that are administered via third parties or AstraZeneca;
- to assist in providing you with medical information relevant to AstraZeneca products;
- to conduct market research;
- to identify investigators for, establish and conduct clinical trials (including clinical trials run by a related body corporate of AstraZeneca);
- to invite you to provide services to AstraZeneca including, for example, speaking engagement, participation on advisory boards/steering committees, or to provide general opinions on medical and/or patient related issues and the development of materials;
- to process, monitor and screen any fees payable, or expenses reimbursable, by AstraZeneca to you;
- adverse event reporting;
- to recruit AstraZeneca personnel;
- to comply with legal or regulatory obligations or transparency requirements including those that apply to AstraZeneca's activities globally; and
- for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.
Our range of products and services and our functions and activities may change from time to time.
AstraZeneca may disclose personal information to:
- its affiliates;
- regulatory authorities and ethics committees as part of a clinical trial evaluation, monitoring or inspection process;
- persons or organisations to assist AstraZeneca in carrying out the above purposes such as travel agents, market researchers, professional conference organisers, clinical research organisations, patient support program administrators, IT support providers, mailhouses, event management organisations, recruitment agencies and professional advisors;
- parties involved in a prospective or actual transfer of our assets or business.
Some of the persons or organisations to whom AstraZeneca may disclose your personal information may be located overseas. These include:
- our overseas related bodies corporate including in the US, European Union and Asia Pacific (a list of countries in which AstraZeneca has related bodies corporate can be found at http://www.astrazeneca.com/About-Us/Worldwide;
- our IT servers, databases and cloud based data centres located globally including in Sweden, the European Union (including the UK and Poland), the US, India, Singapore and Japan;
- some of our service providers including our finance processing provider in Malaysia and our IT service providers, international travel agents and event management organisations located globally including in the US, European Union and Asia Pacific; and
- regulatory authorities and ethics committees overseas such as the Food & Drug Administration in the US.
Generally, we require that organisations outside AstraZeneca who handle or obtain personal information as service providers to AstraZeneca acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with AstraZeneca’s global commitment to privacy. The collection and use of your information by these third parties may also be subject to separate privacy and security policies.
In most cases, if you do not provide information about yourself which AstraZeneca has requested, AstraZeneca may not be able to provide you with the relevant service or information required.
AstraZeneca may use your personal information to contact you (including by telephone call, text message or email) in relation to AstraZeneca products or services we think may be of interest to you.
You may opt-out of receiving marketing information from AstraZeneca at any time by contacting the Privacy Officer whose contact details appear below.
As mentioned previously, some personal information, which includes all health information collected by AstraZeneca is considered “sensitive”.
The Principles require that sensitive information is used and disclosed only for the purposes for which it was provided, or a directly related secondary purpose, unless you agree otherwise or for other specific reasons such as if the use or disclosure of this information is required by law or to prevent a serious and imminent threat to life or health of an individual.
AstraZeneca uses a technology call “cookies” on its websites. A cookie is a small data file that is placed on your computer when you use a particular website. Cookies act as a memory for a website, allowing that website to remember your computer on your return visits. You have the ability to accept or decline cookies. If you choose to decline cookies, some areas of AstraZeneca’s or other websites may not function properly.
AstraZeneca’s interactions with you are also regulated by the Commonwealth Spam Act or the Unsolicited Electronic Messages Act (as the case may be). In compliance with these Acts, AstraZeneca will not send you a commercial electronic message unless permitted.
Management and security of personal information
AstraZeneca stores your personal information in hard copy documents or as electronic data in our software IT systems (and those of our service providers). As mentioned above, our IT servers, databases and cloud based data centres are located globally.
Updating personal information that AstraZeneca holds about you
AstraZeneca endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. You can, in most cases, correct the personal information AstraZeneca holds about you. Please contact the Privacy Officer if you believe that the information AstraZeneca holds about you requires changing or has become out-of-date.
Accessing personal information AstraZeneca holds about you
You can, in most cases, access the personal information AstraZeneca holds about you. All requests for access to your personal information should be directed to the Privacy Officer. AstraZeneca will deal with requests for access to personal information as quickly as possible and will endeavour to respond within 14 days of receipt of the request in writing. In certain circumstances AstraZeneca is entitled to deny access. If access is denied, reasons for the denial of access will be given in writing.
What if you have a complaint?
If you have any concerns or complaints about the manner in which your personal information has been collected or handled by AstraZeneca, please contact the Privacy Officer.
Your concern or complaint will be directed to the appropriate complaint manager who will consider and respond to your complaint within 14 days.
It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response:
- In Australia you may contact the Office of the Australian Information Commissioner who may investigate your complaint further. Further information about the application of the Australian Privacy Act can be found at www.oaic.gov.au.
- In New Zealand you may contact the New Zealand Privacy Commissioner who may investigate your complaint further. Further information about the application of the New Zealand Privacy Act can be found at www.privacy.org.nz.
How to contact us
Phone: +61 2 9978 3500
Postal address: The Privacy Officer
AstraZeneca Pty Ltd
PO Box 131
North Ryde NSW 1670
Updated May 2014