PRIVACY AND SECURITY POLICY
Pharmaceutical Defence Limited ABN 51 004 065 794 ("PDL", "we", "our" or "us") is a national pharmacy body, providing support to its pharmacist members through professional indemnity insurance along with advice and procedures for risk minimisation (“Services”).
PDL also operates a website under the domain name www.pdl.org.au ("Website").
We recognise the importance of maintaining the privacy of the Personal Information of our members (“you” or “PDL Member/s”), potential members (“individuals” or “users” or “you”), visitors to our Website and other individuals we deal with.
How Is Personal Information Collected By PDL?
PDL primarily collects Personal Information about individuals if and when they apply to become a member of PDL. We will also collect Personal Information from members, prospective members and other individuals if they contact us with an enquiry (such as by telephoning us or submitting an enquiry through our Website, including via reporting Notice of Incident (‘NOI’) facility and form). We will take reasonable steps to notify individuals about our collection of their Personal Information, and will provide all relevant information prescribed under the Privacy Act. We will only collect Personal Information by lawful and fair means. We will destroy or de-identify any Personal Information we receive if we would not ordinarily be permitted to collect that information under the Privacy Act.
What Kinds Of Personal Information Are Collected By PDL?
The Personal Information we collect about members and applicants for membership includes:
- Name and date of birth;
- general contact information such as address, telephone, fax and email;
- professional practice information including your place of work, your work telephone number, AHPRA registration number, State of employment;
- details of any applicable business structure and/or ownership relevant to your insurance policy in connection with your membership.
- subscription preferences;
- information relating to insurance claims; and
- NOI data including details of facts, circumstances and events reported to PDL.
Personal Information That We Collect
When you use or interact with us through the Services, we collect Personal Information, on our own behalf.
All PDL Members and Users
Information you provide to us: For all PDL Members and users, we collect Personal Information when you voluntarily provide such information relating to the Services, such as when you apply for PDL membership, during renewal of membership, when you change details in your account including profile, when you register for access to the Services and subscriptions, contact us with inquiries, respond to one of our surveys, promotions or competitions or browse or use certain parts of the Services. The Personal Information we collect includes, without limitation, your name, address, email address and other information that enables PDL Members and users to be personally identified.
Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Services ("Automatic Data"). Automatic Data, includes, without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address), characteristics about your access device and/or browser, statistics on your activities in relation to the Services, information about how you came to the Services and data collected through AdWords, Cookies, Web Storage and other similar technologies.
How We Use Your Personal Information
In accordance with your subscription contact preferences, we contact you using the details which you provide to us in order to provide you with information about products and services you may be interested in. We will comply with our obligations under Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) in relation to such direct marketing communications.
If you provide Personal Information for a certain purpose, we use the Personal Information in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
Access and Use
If you provide Personal Information in order to obtain access to, or use of, the Services or any functionality thereof, we will use your Personal Information to provide you with access to, or use of, the Services or functionality and to analyse your use of such Services or functionality. For instance, if you supply Personal Information relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
Internal Business Purposes
We use your Personal Information for internal business purposes, including, without limitation, to help us improve the content and functionality of the Services, to better understand our users, to improve the Services, to protect against identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with member (customer) service, and to generally manage the Services and our business.
PDL Marketing Communications
Where it is in accordance with your marketing and subscription preferences, we use your Personal Information to contact you in the future to provide marketing communications you have subscribed to, including PDL Practice Alerts, AJP Daily and AJP in print. Visit the "Manage Subscription Preferences" page on the website via www.pdl.org.au to opt out of PDL Marketing Communications at any time.
Aggregated Personal Information
How We Disclose and Transfer Your Personal Information
We are not in the business of selling your Personal Information. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Information to third parties, including third party advertisers. There are, however, certain circumstances in which we disclose, transfer or share your Personal Information with our subsidiary APPco or affiliates, Attvest Finance, Ecleva IT, Meridian Lawyers or Guild Insurance Limited without further notice to you, as set forth below.
We disclose Personal Information about members who take out professional indemnity insurance though PDL to the insurer through which PDL has coverage under the Master Policy so that members are covered by the Master Policy and so that claims can be processed. Only information required for the purposes of the insurance policy is disclosed to the insurer, and we do not permit them to use this information for any other purpose.
- Incident and claims support service
- Legal support and service
- Bordereau provision to underwriter
We do not disclose Personal Information to any recipients located outside Australia.
- Distribution of the Australian Journal of Pharmacy (AJP)
- Subscriptions associated with your PDL membership
Agents, Consultants and Service Providers
We share your Personal Information with our contractors and service providers who process Personal Information on behalf of PDL to perform certain business-related functions. These companies include our database service providers, backup and disaster recovery service providers, funders of the financial loan for monthly payments, email service providers and others. When we engage another company to perform such functions, we provide them with information, including Personal Information, in connection with their performance of such functions.
We will disclose your Personal Information if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (e) protect against legal liability.
How We Store Your Personal Information
How You Can Access, Update, Correct or Delete Your Personal Information
You can request access to your Personal Information being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Information that we process about you.
If you are a PDL Member, you can exercise these rights by logging in to your online member account available through www.pdl.org.au then visiting the ‘My Profile’ and Manage Subscriptions Preferences pages. Alternatively, contact us directly by:
Phone: 1300 854 838; or
Email: firstname.lastname@example.org ; or
Pharmaceutical Defence Limited
PO Box 777
Hawthorn, VIC 3122
If a PDL Member initiates a data deletion request, PDL is authorised to delete or anonymise Personal Information of the requesting member from the Services even if that means removing the member’s availability to the Services.
We will consider and respond to all requests in accordance with applicable law.
How Long We Retain Your Personal Information
We retain your Personal Information as long as you are registered to use the Services. You can cancel your membership and close your account by contacting us on the details below. However, we retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
Changes to the PDL Policy
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).
We will deal with complaints as follows:
Step 1: Let us know
- If you would like to make a complaint, you should let us know by contacting our Privacy Officer (see below for contact details).
Step 2: Investigation of complaint
- Your complaint will be investigated by our Privacy Officer.
- A response to your complaint will be provided in writing within a reasonable period.
Step 3: Contact OAIC
- We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing.
Director of Compliance
Office of the Australian
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Write to us at:
Pharmaceutical Defence Limited
PO Box 777
Hawthorn VIC 3122
Telephone us on 1300 854 838 or +613 9810 9900; or
Submit an email enquiry to us from the Website's contact page or email email@example.com.
PDL takes complaints seriously, and upon receipt will examine the complaint and instigate internal procedures to ensure compliance with the Privacy Act.