GlaxoSmithKline Australia Pty Ltd

Australian Privacy Policy

1. Introduction

GlaxoSmithKline Australia Pty Ltd (ABN 47 100 162 481) (“GSKA”, “we” or “us”) respects and upholds your rights to privacy in accordance with the Australian Privacy Principles contained in the Privacy Act 1988. The Australian Privacy Principles apply to us from their introduction in March 2014.

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


2. What personal information about me may GSKA hold?

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 held about you if you are a member of the various groups may be as follows:

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 for 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 identified in this privacy policy, other than information which we are required to retain. If possible, such information will be retained in a way that you cannot be identified.

Information collected from or about you may be stored and processed in your country of residence or any other country in which GSK or its affiliates worldwide, or its or their subcontractors or agents maintain facilities. GSKA will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this privacy policy. The countries in which your personal information may be disclosed include the United States and countries within the European Union.

GSKA will collect information about you directly from you, if it is possible to do so, 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;

• Databases supplied by third parties;

• 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.


3. What does GSKA do with my personal information?

GSKA collects personal information at different times which may be used for one or more of a variety of purposes, to allow us to perform our business activities and functions and to provide best possible quality of customer service. These purposes include:

• 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;

• Responding to your requests and improving our level of service to you;

In the case of Health Professionals:

• Sending you direct marketing and other 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;

• Notifying you of GSKA products and services and seeking your views on GSKA products and services;

• 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 accordance with the Privacy Act, and only where necessary. The circumstances in which we may disclose that information include:

• where GSKA notified you at the time of supply of the information to GSKA or it is expressly permitted under any agreement with you;

• where it is necessary to provide you with a service or goods which you have requested;

• where required for the ordinary operation of our business (for example, to send you information about our goods and services);

• where it is necessary for support services to be provided in relation to our business activities (please note that such disclosures will only be to people and entities required to meet the same standards of data protection and are prevented from using the information for their own marketing purposes);

• where we consider the law requires it, or in response to any demand by law enforcement authorities;

• regulatory authorities (such as the Therapeutic Goods Administration and State and Territory drug and health authorities) where GSKA is required 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 Australian Privacy Principals and the Privacy Act These activities may involve the export of your personal information overseas as described above;

• companies related to GSKA for the same kinds of purposes as listed above. Subsequent use and disclosure by the related company will be in compliance with the Australian 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; and

• 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. If you decline to provide us with your personal information (or subsequently opt-out) it will likely preclude the provision of relevant services to you by GSKA.


4. Access, correction and contacting GSKA

You may request access to personal information GSKA holds about you by contacting “The Privacy Officer” as detailed below. Your request should 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 a reasonable period and in any event within 10 working days and endeavour to respond to your request within 30 days.

If you believe that personal information GSKA holds 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 through the contact details below.

We will attempt to confirm as appropriate with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view. If you are unsatisfied with the outcome, we will advise you about further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.

Our contact details are as follows:

The Privacy Officer
GlaxoSmithKline Australia Pty Ltd
Level 4, 436 Johnston Street, Abbotsford, 3067


5. Miscellaneous

In this policy “personal information” and “sensitive information” have the same meaning as under the Privacy Act.

GSKA may change this policy from time to time. We encourage you to periodically review this policy to stay informed about how we are helping to protect the personal information we collect.