GlaxoSmithKline Australia Pty Ltd (“GSKA”) respects and upholds your rights to privacy in accordance with the National Privacy Principles contained in the Privacy Act 1988. The National Privacy Principles apply to us from their introduction in late 2001.

This policy describes how GSKA manage any personal information we have about you.

GSKA may hold information on individuals who fall into one of three main groups: health professionals, members of the general public and others. The information typically held about you if you are a member of the various groups include:

Health Professionals:

• Your name, business address, business telephone number(s) and email address;
• Professional details;
• Practice specialty including areas of interest;
• Membership of professional associations;
• Practice and/or business details including GSKA product usage;
• Dealings with GSKA: For example: details of medical enquiries, adverse event reporting, clinical trial involvement,
• details of sales representative appointments and pharmaceutical company sponsored programs such as seminars and meetings.
  
  

Consumers and the General Public:

• Your name, relevant address, telephone number(s) and email address;
• Dealings with GSKA such as: medical enquiries, adverse event reporting, patient support scheme participation and clinical trial participation.

Other persons such as third party contractors and job applicants:

• Your name, business address, business telephone number(s) and email address;
• Dealings with GSKA: work and employment references, reports and assessments.
  
  

GSKA will not collect other sensitive information about you without your consent, such as personal information about your health, race, political opinion etc.

GSKA will store information collected about you securely and access will only be allowed to those authorised and then only for the purpose for which it was collected and in the case of sensitive information the purpose for which you have provided consent. GSKA will delete from its records personal information no longer required or in use for the purposes listed in paragraph 3 below other than information, which we are required to retain. If at all possible such information will be retained in a way that you can not be identified.

GSKA will, if at all possible, collect information it holds on you directly from you but it may on some occasions be collected from other sources, some of which you may be unaware, including:

• Publicly available directories and listings such as telephone directories;
• Newspapers, magazines, professional journals and the electronic media;
• The internet and other electronic communications such as:
• Articles and information pieces in which you feature on a website such as a health information site or a medical professional site;
• The date, time and domain from which you access GSKA’s website;
• Personal communications with GSKA’s staff.

GSKA collects personal information at different times which may be used for one or more of a variety of purposes depending on the circumstances. These are as follows.

• Maintaining a record of medical queries, complaints and adverse event reports relating to GSKA products and reporting these to relevant regulatory bodies, related companies or other companies which market the same product as may be required or prudent; 
• Administering disease awareness/management programs or other similar programs organised by GSKA;
• Notifying you of matters that GSKA may be required by law to notify you of (eg. product recalls);
• Generating customer lists for the purposes of GSKA’s own market research;
  

In the case of Health Professionals:

• sending you material on and contacting you regarding GSKA’s activities and products or developments in pharmaceutical treatments which may be of interest to you and tailoring marketing services to suit your needs; 
• Supplying you with clinical samples of GSKA products;
• Administering clinical trials or other research organised by GSKA and which you agree to participate in or be involved with;
• Administering conferences, symposia, expert panels, seminars or other meetings or events organised by GSKA;
• Managing, planning and arranging meetings between you and the GSKA sales representatives;
• Monitoring and reviewing GSKA’s compliance with relevant regulations and codes of conduct in its dealings with you.

GSKA will not disclose personal information about you to any person except in the following circumstances and then only that information which is necessary:

• regulatory authorities (such as the Therapeutic Goods Administration and State and Territory drug and health authorities) where GSKA is under a legal obligation to provide your personal information to the particular authority;
• third parties that we use in the ordinary operation of our business, such as for conference organising, marketing, data processing and associated printing and mailing. For example, it may also be provided to Clinical Research Organisations for the purposes of medical research. We will only provide your personal information to reputable third parties and then only on a confidential basis where we are satisfied that those third parties will similarly comply with the National Privacy Principals and the Privacy Act;
• companies related to GSKA for the same kinds of purposes as listed above. Subsequent use and disclosure by the related company will be generally in compliance with the National Privacy Principles and the Privacy Act;
• another company for the purpose of ensuring continuity of product supply and/or service if the supply of the product or service has been transferred to that company;
• such third parties otherwise permitted or required by law.
  

At any time you may opt out of receiving any communications from GSKA (other than as required for the operation of our business, eg regarding account payment if you have one with us), although GSKA may then be unable to provide you with all of the information regarding our programs, events, services or products which may be of benefit to you.

You may request access to your personal information GSKA hold about you by writing to “The Privacy Officer” at the address below. Your request must detail your name, contact details, your former name or alias if any and the information you believe GSKA may hold on you. You do not have to provide a reason for requesting access. Where GSKA holds information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you may access it (eg emailing or mailing it to you). In any event GSKA will acknowledge receipt of your request within 7 days and endeavour to respond to your request within 30 days.

If you believe that personal information GSKA hold about you is incorrect, incomplete or inaccurate, then you may request we amend it. We will consider if the information requires amendment. If GSKA does not agree that there are grounds for amendment, then we will add a note to the personal information we hold stating that you disagree with it.

Any questions about this policy, or any complaint regarding treatment of your privacy by GSKA, should be made in writing to the address below.

Our contact details are as follows:

GlaxoSmithKline
1061 Mountain Highway
BORONIA VIC 3155
Fascimile: +61 03 9729 5319
Web: Privacy Contact Form

In this policy “personal information” and “sensitive information” have the same meaning as under the Privacy Act. References to “GSKA” are to GlaxoSmithKline Australia Pty Ltd (ABN 47 100 162 481), which has issued this policy.

GSKA may change this policy from time to time. Although we intend to observe this policy at all times, it is not legally binding on GSKA in any way.