DR FALK may amend this policy from time to time, and the amended policy will be published on our website. Please review DR FALK ‘s website periodically for changes to this policy.
What is personal information?
Personal information is any information that can be used to identify you. This includes any information or opinion about you, whether true or not.
Sensitive information is a special category of personal information and includes information about your health, race or ethnic origin, political or religious beliefs, membership of a trade union or association, or criminal record. We will not disclose your sensitive information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act or to comply with any other relevant legislation.
Why do we collect personal information?
DR FALK is a pharmaceutical company which markets and sells pharmaceutical products. In connection with sourcing and supplying therapeutic drugs, DR FALK collects personal information from various individuals, including, but not limited to:
(a) patients experiencing adverse events;
(b) health care professionals and customers including doctors, pharmacists and nurses who prescribe, sell or educate on DR FALK products;
(c) business contacts, including government regulators and external service providers; and
(d) suppliers such as wholesalers.
DR FALK collects personal information for the following purposes:
(a) to provide health products or services (including advice) that has been requested;
(b) to monitor the quality, safety and efficacy of our products and to comply with legal obligations;
(c) to better inform any adverse events and/or product recalls or product complaints; and
(d) to market and promote our products and services to you where we are able to do so.
Collection of personal information
DR FALK collects personal information necessary to lawfully and ethically carry on its business. If you would like to access any of our services on an anonymous basis, please contact the Privacy Officer (see below). If this is possible and lawful, we will take all reasonable steps to comply with your request. However, we may not be able to provide the services or supply the product in question if we are not provided with the personal information requested.
What personal information do we collect and use?
The nature and extent of personal information collected by DR FALK varies depending on your particular interaction with DR FALK. We will only collect personal information that is reasonably necessary for one or more of our functions or activities.
The personal information that we collect and hold usually falls into one of the following categories:
(a) personal information and health information about patients experiencing adverse events. Examples of such information includes your name, address, telephone numbers, medical history, current and previous medication use, details of treating doctors, date of birth, details of an adverse event (see also Health Information, below);
(b) personal information about health care professionals (such as doctors, pharmacists and nurses) who prescribe, sell or educate on DR FALK’s products and services. Examples of such information includes your name, position, business contact details, areas of professional expertise and specialty, records of previous dealings with you and details of your practice, pharmacy or clinic. Additional information may be collected in circumstances of product recalls or where a complaint is made, and DR FALK is responding and/or reporting to the relevant regulatory bodies;
(c) personal information relating to our current and prospective customers or their officers or employees, and/or suppliers in the course of conducting our business;
(d) personal information, including name and contact information of persons consenting to receive marketing and other promotional material on their or their employer’s behalf
As a pharmaceutical company, DR FALK collects some health information, for example when reporting adverse events (AEs) known or suspected to be related to DR FALK products. When collecting health information from you or a health care professional such as a doctor, nurse or pharmacist regarding an AE you have experienced, we will follow the Australian Therapeutic Goods Administration (TGA) guidance as to what information needs to be collected to fulfil their requirements for a complete and fillable report to them. Specifically, this includes an identifiable reporter of the AE(s), an identifiable patient; the suspected DR FALK product and the suspected drug reaction(s). At all times your information will be de-identified, with only your initials, age, age-group and/or gender recorded. The same information will be provided to other regulatory authorities outside Australia, if requested. Furthermore, this information will be held on a secure database overseas and will be used to report global safety trends for DR FALK products for regulatory authorities internationally, including the TGA.
Any information recorded on you by DR FALK in the reporting of any AEs beyond what is detailed above will require specific consent from you, unless your further consent is obtained or in accordance with one of the exceptions under the Privacy Act or in compliance with another law. If DR FALK uses your health information for management, research or statistical purposes, it will be de-identified unless we have your consent to identify you.
How do we collect personal information?
Where possible, we collect your personal information directly from you. We collect information through various means, including over the telephone, through this website, appointments and via emails. If you consider 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.
In some situations 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. For example, we my collect information about you from a health care professional, such as your doctor.
A person may use our website anonymously, but any information which a person chooses to submit to us will be treated in accordance with this Policy.
Our internet service provider may record details of visits to our site and when visiting our site your visit will/may be logged and the following information collected:
(a) the visitor’s server address, domain name and browser type;
(b) the date and time of the visit to the site;
(c) the pages accessed and the documents downloaded;
(d) the previous website visited;
(e) the user’s operating system; and
(f) the links followed from other sites to get to the current site.
The information listed above is collected for statistical and research purposes only and will only be utilised internally by DR FALK.
When do we use and disclose your personal information?
We will use and disclose your personal information for the purpose for which it was collected. We may also use and disclose it for related or ancillary purposes, such as for the development and marketing of our services where permitted under the Privacy Act. We guarantee that we will not sell your personal information to any third party.
For the purposes referred to in this Policy, we may disclose your personal information to external organisations including:
(a) outsource service providers, who manage some of the services we offer to you;
(b) doctors and other health care professionals, who assist us to deliver our services;
(c) regulatory bodies, such as the TGA (unless we can provide the required information in a de-identified form, as will be the case for AE reporting);
(d) our external service providers; and
(e) our related bodies corporate.
Sometimes we may use external service providers to perform certain necessary functions and, in performing such functions, these service providers may have access to some of the personal information which we collect. The service providers are bound by obligations of confidentiality and may only have access to the information to the extent to which they require it for the proper and due performance of their obligations as service providers.
Generally, we will obtain consent from you before we disclose any personal information other than as specified in this policy.
Do we send information overseas?
We do not generally send personal information out of Australia. However, in some circumstances, it may be necessary to send personal information overseas, as is the case when reporting AEs known or suspected to related to DR FALK products, although this information will be de-identified as previously stated. If we are required to send information overseas, we will either obtain your consent and/or take measures to protect your personal information in accordance with the Privacy Act.
Security of your information
We will take all reasonable steps to secure your personal information. Electronic information is protected by various security measures (including password protection) and physical paper files are stored in a secure location. Access to information and databases is restricted to staff of DR FALK or its outsourced service providers that need access to the information, in order to perform their duties. All our staff are bound by obligations of confidentiality.
Access to and correction of your personal information
You have a right to access and copy your personal information, subject to certain exceptions provided for in the Act. If you would like to access your personal information, please follow the procedures set out in our Access Policy. Our Access Policy can be accessed by contacting our Privacy Officer (details below). For security reasons, you will be required to put your request in writing and provide proof of your identity. If you are able to establish that personal information we hold about you is not accurate, complete, or up to date we will take all reasonable steps to correct our records. We may charge a reasonable fee for the time and resources required to provide any information requested by you.
Any person that has a complaint about the way their personal information is collected, used, disclosed, stored and administered by DR FALK may lodge a complaint. All complaints will be treated seriously and dealt with promptly and confidentially. Complaints should be sent to the attention of the Privacy Officer. Our Privacy Officer will investigate your complaint and determine what steps we need to take to resolve your complaint. We will contact you if we require further information from you and will notify you in writing of the outcome of our investigation. If you are not satisfied with the outcome, you may contact us to discuss the matter further, or you may make a complaint to the Information Commissioner, using the details below:
Office of the Australian Information Commissioner:
GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992
Fax: 02 9284 9666
Policy No: POL003. Effective Date: April 2020.