What personal information may be collected 1.1 Personal information is defined by the Act as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Examples of personal information might include an individuals name, address, phone number, email address, medical records, family details or any other information from which an individual could reasonably be identified. 1.2 AMSL may collect a variety of personal information relating to the provision of its products and services. Examples of personal information which AMSL regularly collects include an individual’s: (a) name; (b) address; (c) date of birth; (d) family details, including personal information relating to, or about, an individuals next of kin; (e) financial details for the purposes of providing products; (f) opinion about AMSL’s products; or (g) Other personal information particular to a specific individual to allow AMSL to tailor its products or services to that individual. 1.3 In addition to the above, AMSL may collect sensitive information about individuals. Sensitive information is defined in the Act and includes information about an individual’s health, amongst other information. AMSL will generally only collect sensitive information which relates to an individuals health in relation to the products and services that AMSL supplies.
Collection of Personal Information 2.1 AMSL will generally only collect personal information which relates to the provision of medical products to its clients. While this personal information will usually relate to clients themselves, it may, from time to time, be necessary for AMSL to collect personal information about individuals who are not clients, for example next of kin or a customer’s medical practitioner, to ensure that it is able to effectively provide its products. In such cases AMSL will only collect the minimum amount of personal information required to facilitate the provision of its products. 2.2 Wherever reasonable and practicable AMSL will collect personal information from the individual to whom it relates, however, in some cases this may be impracticable, or the information may be held by a third party. Common examples of these situations may include: (a) medical records held by an individual’s current or previous health care provider; (b) financial records held by an accountant or Medicare; or (c) next of kin details. In such circumstances AMSL will take reasonable steps to obtain the individual’s consent to the collection of their personal information, or failing such, will undertake to notify the individual of the collection, where it is reasonable and practicable to do so. 2.3 If an individual is required to register in order to use AMSL’s website or to otherwise complete an online application form (e.g. to obtain e-mail updates), then AMSL will collect personally identifiable information about the individual, such as their name, e-mail address, country of residence and other information which they voluntarily submit. 2.4 While an individual may choose not to provide personal information to AMSL, failure to do so may hamper the provision of products. In some case failure to provide personal information may result in AMSL being incapable of providing products to a particular individual at all.
Use and Disclosure of Personal information 3.1 AMSL uses personal information for the purpose of, or in relation to, providing medical products to individuals. Examples of uses may include, but are not limited to: (a) assessing an individual’s potential requirements for AMSL’s products; (b) corresponding with an individual regarding the products being provided, including regarding the individual’s satisfaction with the products; (c) tailoring AMSL’s products to an individual’s needs. 3.2 AMSL may also use or disclose personal information in the following circumstances: (a) where an individual has given consent; (b) where required in order to provide an individual with the products and/or services they requested (for example to a courier company); or (c) where use or disclosure is required or authorised by law. 3.2 Further to the uses above AMSL may use or disclose personal information in relation to applying for appropriate government subsidies or grants available to it. Wherever reasonable and practicable AMSL will either limit the personal information disclosed to that which is absolutely necessary or will undertake to de-identify the information prior to its disclosure. 3.3 AMSL is committed to the appropriate use of sensitive information about an individual. Wherever possible AMSL will only use sensitive information about an individual with the individual’s consent. Situations where sensitive information may be used without consent may include facilitating the provision of emergency medical treatment or where use or disclosure is required by law. 3.4 From time to time AMSL may disclose personal information to a variety of third parties in relation to the provision of products to individuals. Potential third party recipients may include: (a) AMSL’s legal and financial advisers; (b) AMSL’s Insurers; (c) Medical or dental practitioners; (d) An individual’s family or next of kin; (e) Government agencies, including as outlined in point 3.2; (f) Any third party with a lawful entitlement to the information. Whenever AMSL discloses personal information to a third party it will take steps that are reasonable and practicable in the circumstances to either: (g) limit the disclosed personal information to the minimum required to fulfil the purpose of the disclosure; or (h) de-identify the personal information prior to disclosing it to a third party. 3.5 An individual may agree to provide their personal information directly to third parties in connection with AMSL offerings, in order to access and/or use the third party’s products and/or services. If an individual agrees to provide such information to these third parties, then their personal information will be subject to the third party’s privacy policies.
Overseas Recipients 4.1.1 AMSL is a wholly owned subsidiary of New Zealand Medical and Scientific (NZMS). From time to time AMSL may provide personal information to NZMS for the purposes of product development, quality control and/or general business management. 4.3 Prior to disclosing personal information to an overseas recipient AMSL will generally either seek your consent, ensure that the recipient abides by the APP or ensure that the entity is bounds by restrictions on the use of personal information that are substantially similar to the APP. In addition wherever reasonable and practicable AMSL will either limit the personal information disclosed to that which is absolutely necessary or will undertake to de-identify the information prior to its disclosure.
Direct Marketing 5.1 AMSL does not sell, trade or transfer personal information to third parties for the purposes of direct marketing. 5.2 AMSL may from time to time use personal information, including sensitive information, to notify individuals of changes to products provided to that individual, or to bring to that individual’s attention new or additional products which may be beneficial to them. All such communications will include an option for the recipient to opt out of receiving any future direct marketing.
Security 6.1 AMSL is concerned with the security of your Personal Information and is committed to taking reasonable steps to protect it from unauthorized access and use. To that end, AMSL has put in place appropriate physical, electronic and managerial policies and procedures to secure personal information. These policies and procedures include, but are not limited to: (a) storing any electronic information on password protected and secure servers; (b) ensuring any physical copies of personal information are kept in a secure area which is not open to unauthorised access; (c) requiring AMSL employees to enter into confidentiality agreements requiring they ensure the security of personal information; and (d) ensuring that any access to personal information by AMSL employees is limited to those employees with a need to know that information for the provision of products to the relevant individual; 6.2 Personal information may be retained for 7 years or such other period as required by taxation or other laws.
Accuracy of Personal Information AMSL is committed to ensuring that all personal information held is accurate, complete and up-to-date. To that end AMSL may from time to time contact individuals directly for the purposes of verifying their information.
Access to and Correction of Personal information 8.1 Individuals have a right to know what of their personal information AMSL holds. Individuals may request this by contacting AMSL’s Privacy Officer by the following methods: Phone: 02 9882 3666, Email: email@example.com Mail addressed to: Privacy Officer Australasian Medical & Scientific Ltd., 2 McCabe Place, Chatswood NSW 2067 Australia 8.2 When requesting access or correction of personal information AMSL will require an individual to verify their identity by reference to their personal information. In some circumstances it may be necessary for an individual to visit AMSL’s location to properly verify their identity before access to personal information can be granted. 8.3 While AMSL will attempt to respond to a request for access to personal information in a timely manner, given the wide array of AMSL’s products provided, it may take some time to collect an individual’s personal information and make it available. Individuals can help to minimise delays by providing details of what information they require access to, how and when they have provided information to AMSL in the past and the general nature of any dealings between them. 8.4 When a request for information is received, AMSL will endeavour to provide an accurate estimate of the time it may take to comply with the request, however, compliance with this timeframe is not guaranteed. 8.5 Generally AMSL will not charge a fee to grant an individual access to their personal information, however in the case of requests for old or particularly voluminous information it may be necessary for AMSL to charge a reasonable fee, commensurate with the work required to comply with the request. However, there will be no fee charged in relation to the making of the request for access itself. 8.6 While AMSL will generally comply with an individual’s request for access to personal information about them, AMSL does have the right under the APP to refuse access in certain circumstances. In the event that access is refused AMSL will, where reasonable, provide reasons for the refusal, along with alternative methods which may allow access. 8.7 In addition to requesting access to personal information individuals may request that AMSL correct any personal information held about the individual. Once the individual’s identity has been verified AMSL will take reasonable steps to correct their personal information.
Anonymity and Pseudonymity While the APP does allow individuals to deal with an entity anonymously or by use of a pseudonym, AMSL will generally be unable to provide products to a particular individual without confirming their identity. AMSL will be able to discuss its products in a general nature, including costs and charges which it might ordinarily charge for those products, prior to obtaining an individual’s identity. Until such time as AMSL has been provided sufficient information to provide a detailed quotation or outline of products to an individual any communication will be general in nature and will not be binding upon AMSL.
Complaints 10.1 If an individual wishes to make a complaint about AMSL’s collection, use or disclosure of any personal information, or about any potential breach of an APP, the individual may contact the Privacy Officer by use of the contact details at the end of this document. 10.2 When making a complaint an individual should include as many details as possible, including the nature of the personal information concerned, how it is believed to have been misused, which APP is believed to have been breached (if relevant), the details of any AMSL employee or representative involved and any other information which may be relevant. The Privacy Officer may request additional information to enable the Privacy Officer to properly investigate the complaint and take such reparatory action as necessary. 10.3 Once a complaint is received the Privacy Officer will investigate the circumstances of the complaint and determine whether a misuse of personal information has occurred and if so how it may be rectified and whether/what action should be taken in relation to any AMSL employee or representative involved. AMSL will endeavour to keep the individual informed regarding the process of their complaint and any action taken. 10.4 Should an individual not be satisfied with AMSL’s handling of their complaint then AMSL will generally agree to the complaint being referred to mediation and/or arbitration. Should the matter remain unresolved then an individual is entitled to refer their matter to the Office of the Australian Information Commissioner.
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