1. About this policy
Clinical Genomics (‘CG’ ‘we’, ‘us’ or ‘our’) is committed to protecting the privacy of your personal information in accordance with Australian privacy laws.
Clinical Genomics includes Enterix (Australia) Pty Limited, Enterix Pty Ltd, Clinical Genomics Pty Ltd and Clinical Genomics Technologies Pty Ltd.
2. Types of personal information we collect and hold
Your personal information may be collected through our interactions with you or from a person acting or authorised to act on your behalf. Examples include personal information provided by you on the patient information form, emails, telephone conversations or face-to-face meetings. The types of information we collect and hold include:
- identifiable information such as your name, address, date of birth, telephone numbers and e-mail address;
- personal information you provide to us when you participate in a promotional activity, survey, market research, participate in the renewal system;
- de-identified demographic information, which is not unique to you, such as your postcode, age and gender; and
- if you visit our website, your website usage information such as your IP address.
3. How we may use and disclose your personal information
We may use and disclose your personal information for the primary purpose for which it was collected, or for related purposes, or as permitted or required by law or regulatory reasons including the following purposes:
- providing pathology testing services and pathology results to you and your nominated doctor;
- delivering the products and services you have requested;
- manage, train and develop our employees;
- communicating with you;
- administering and responding to your enquiry or feedback about our products and/or services, responding to your complaints, and reporting to dispute resolution bodies;
- meeting our legal and regulatory obligations;
- conducting, improving and developing a relationship with you;
- direct marketing (such as providing you with information about our products and promotional notices and offers); and
- perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries.
We may disclose personal information we collect from you to:
- our affiliates and partner organisations for the primary purposes for which it was collected;
- our external service providers and professional consultants;
- regulatory bodies and ethics committees as part of a clinical study or evaluation process; and
- Federal, State, Territory medical, health and safety authorities (as required);
We may disclose your personal information for the purposes set out above.
We may also disclose your personal information if it is required or authorised by law, where disclosure is necessary to prevent a threat to life, health or safety, or where we are otherwise permitted by the Privacy Act.
CG does not sell or license your personal information to third parties.
CG may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party.
4. How your personal information is stored and secured
We take all reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.
We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law or the relevant regulatory bodies.
5. Using our Website and Cookies
CG secures your personal information from unauthorised access, use or disclosure. CG secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
There is also information about your computer hardware and software that is automatically collected by CG. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by CG for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the CG website.
We also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website, but the website may be limited in the use of some of the features.
6. Marketing and Opting-Out
We may use your personal information for:
- promoting and marketing of our products and services which includes sending you renewal letters and kits or reminder notifications;
- informing you of upcoming events and special promotions and offers; and
- improving and developing new products and services.
We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you. We may contact you via mail, SMS, email, telephone or online about products and services you might be interested in. We will engage in marketing unless you tell us otherwise.
You will generally be given the opportunity to “opt out” from receiving marketing communications from us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request.
7. Do we transfer personal information overseas
Your personal information may also be processed by, or disclosed to employees, representatives, or other third parties operating outside of Australia who work for, or are engaged by us in other countries, including New Zealand and USA.
We take all reasonable steps to ensure that these entities do not breach the requirements of the Privacy Act 1988 (Cth).
8. Accessing and updating your personal information
You may request access to the personal information we hold about you. You can also request that corrections be made to it. We will respond to your request within a reasonable time. To contact our Privacy Officer please see contact details below in paragraph 13.
9. Anonymity when dealing with us
We may allow you the option not to identify yourself when dealing with us.
We take reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. CG invests in the following forms of security:
- limiting physical access to our premises;
- limiting access to personal information to CG personnel on a need to know basis;
- educating and training our staff on their duty to protect your privacy in accordance to this policy;
- requiring our employees to observe obligations of confidentiality in the course of their employment with all staff signing confidentiality agreements;
- requiring suppliers and contractors to sign a confidentiality agreement and have acceptable security measures in place to keep personal information secure; and
- storing hard copies of data in secure filing areas.
11. Government identifiers
We do not use government identifiers (e.g. tax file numbers or Medicare numbers) to identify individuals.
We will ensure your complaint is handled by our Privacy Officer in an appropriate and reasonable manner. A written notice of our decision regarding your complaint will be provided to you. If you are not satisfied with the outcome, then you may contact the Office of the Australian Privacy Commissioner:
Office of the Australian Information Commissioner
Phone: 1300 363 992
13. Feedback and contact for further information
Our Privacy Officer will consider your enquiries or complaints and respond to you in a reasonable timeframe.
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Last Updated on 26JUL2016