iClinix Privacy Policy


(This Policy was last updated in October 2006)



Introduction


iClinix Pty. Ltd. believes that privacy is an important individual right and is important to our own business and the businesses of our clients and customers. In this policy we set out the standards to which the Australian company is committed in ensuring the privacy of individuals. We are also bound to comply with the National Privacy Principles as set out in the Privacy Act 1988. This document provides general information about our information handling practices. Where we directly collect information from individuals we endeavor to provide more specific privacy statements or disclosures at the point of collection, including on our web sites.

Collection of Personal Information


iClinix Pty. Ltd. only collects personal information if it is necessary for our business purposes. The information we collect will depend on the purpose for which it is collected – it may be limited to contact details where we interact with the public (e.g. in the case of a web site request or registration, or when you choose to take part in a survey), or it may include more detailed information where a client relationship exists (for instance financial details if we are engaged to perform financial services). We rarely need to collect sensitive information (such as health, ethnicity, religion) and will not do so without consent. Where information is provided to iClinix as part of the management of clinical systems, then iClinix will protect the identity of such date, notwithstanding, that de identified data is regularly exchanged between health care organisation, data management companies, pharmaceutical companies etc. Where your data is collected or provided to iClinix and iClinix for any reason, iClinix will not unlawfully release your data,. Where data is de identified then iClinix will permit data to be transferred for any viable legal, scientific, research, commercial or clinical reason as the law permits.

Use of Personal Information


We generally use personal information for the primary purpose for which it is collected. That may include supplying our services or responding to an individual's request. Depending on the purpose for which we have collected personal information (e.g. registration for an iClinix Pty. Ltd. event or a request for particular information or material), we may store some of the information in iClinix Pty. Ltd.’s CRM system. Some or all of this information may be available to partners and authorized staff of iClinix Pty. Ltd. for use in accordance with this policy. We may use personal information for business purposes which relate to the primary purpose of collection. We may also use contact information to market our related services, however, the individual always has the opportunity to elect not to receive further marketing information from us by writing to us at: The National Privacy Office, iClinix Pty. Ltd., PO Box 567 Roseville NSW 2069, or email us at privacyofficer @ iclinix.com. Internally, we have controls and procedures to ensure that personal information provided to us remains confidential. All of our staff are trained in privacy and are bound by strict duties of confidentiality to the firm and its clients. We will not collect or use personal information in ways other than as stated in this policy unless we have obtained an individual's consent. In some cases we may specifically request a consent form to be signed. In other cases consent may be implied (for instance, where an individual gives us information after being fully advised of how it will be used). De identified data will be used by iClinix for any lawful purpose as approved by the board of iClinix.

Disclosure of Personal Information


We do not sell or trade personal information, or allow third parties to use that personal information for their own purposes where the identify of a person can be recognised. Sometimes, our business needs require that external contractors or suppliers assist us with information handling. This may include such processes as off-site security storage, website hosting, electronic database management, or management of an iClinix Pty. Ltd. event. If information needs to be accessed by a third party, we attempt to limit that access to the extent necessary for the third party to provide services to us or to perform its functions. We will ensure that those suppliers and contractors are also bound by duties of confidentiality and by the same privacy obligations as iClinix Pty. Ltd. itself. In all other cases, we will only disclose personal information to a third party if the disclosure is permitted by law (including under the National Privacy Principles). We also ask our clients to confirm that they have made their own disclosures or obtained consents before they pass any personal information to us. Sometimes we may need to transfer personal information outside of Australia, for example to one of iClinix Pty. Ltd.’s international offices in order to complete or fulfill a request or for operational efficiency. We may also transfer personal information where permitted under the National Privacy Principles. Where data is de-identified, then iClinix may use such data as permitted by law and for all appropriate purposes as permitted by the board of iClinix.

Privacy on Our Web Sites


This policy applies equally to any personal information we collect via our web sites, clinical systems etc, including the site at privacyofficer @ iclinix.com. Apart from personal information you provide to us intentionally (e.g. where you make a request or complete a registration form), this section explains some other ways in which iClinix Pty. Ltd. collects information via its web sites. Cookies may be used on some areas of our web sites. A cookie is a small software application which allows a web site to recognise a previous user and to observe how a user navigates within a web site. Cookies are now used as a standard by many web sites. iClinix Pty. Ltd. uses cookies to improve the navigational experience of visitors to our web sites, and to make them easier to use. If you are concerned about cookies, most browsers now recognise when a cookie is offered and permit you to opt out of receiving it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your Internet service provider. In most cases, you can refuse a cookie and still fully navigate the iClinix Pty. Ltd. web sites. In order to properly manage our web sites, we may log certain statistics about the users of the sites, for example the users’ domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our web sites present the best possible navigational experience for visitors. Whenever a registered member (e.g. an iClinix Pty. Ltd. alumnus) logs in to our web sites, they will be identified by their user name and password. The information we collect about members’ use of our web sites is used purely for measuring site performance and in assisting to resolve any technical difficulties. Because iClinix Pty. Ltd. wants your web site experience to be as informative and resourceful as possible, we provide a number of links to web sites operated by third parties. You should be aware that we are not responsible for the privacy practices or policies of those sites. We encourage you to review each web site’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non iClinix web site is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site. iClinix data files may travel outside of Australia and may form time to time be stored outside of Australia. Where data is de-identified, then iClinix may use such data as permitted by law and for all appropriate purposes as permitted by the board of iClinix.

Security of Personal Information


iClinix Pty. Ltd. aims to achieve industry best practice in the security of personal information which it holds. It is our policy to destroy personal information once there is no longer a legal or business need for us to retain it. Where data is de-identified, then iClinix may use such data as permitted by law and for all appropriate purposes as permitted by the board of iClinix and may retain such data indefinitely.

Access to Information


We will provide access to personal information upon request by an individual, unless a request is unreasonable and the National Privacy Principles would permit us to decline that access (for instance, where granting access would infringe another person's privacy). Clients who wish to gain access to their personal information should contact their iClinix representative. Non-clients may contact us by writing to: The National Privacy Office, iClinix Pty. Ltd., PO Box 567 Roseville NSW 2069 or emailing us at privacyofficer @ iclinix.com. When you make a request to access personal information, we will require you to provide some form of identification (eg. driver’s license or passport) so we can verify that you are the person to whom the information relates. In most cases we may also request an administrative fee to cover the cost of access. This fee is set at $250.00 per hour and covers the cost of a senior member of the management team ensuring that your request is managed promptly as per procedure. The minimum search fee shall be $250 and then billed every 15 minutes at the rate of $250 per hour. You agree that by requesting iClinix to undertake a “privacy search” for you that you will cover the costs at the rate described above and that you will make such a payment prior to receipt of the report. You also agree that you will do all such things and sign all such documents that iClinix provides you with to ensure that all costs and legal matters are resolved in favour of iClinix, without exception whatsoever. iClinix may waive or discount this fee if the information is proven to be incorrect and this will be at the sole discretion of the iClinix Pty. Ltd. board.

Corrections and Concerns


If you believe that information we hold about you is incorrect, or if you have concerns about how we are handling your personal information then we ask that you contact us and we will try to resolve those concerns. If you are a client you should contact your normal iClinix representative or the consultant supervising your engagement. If you are not a client please write to us at: The National Privacy Office, iClinix Pty. Ltd., PO Box 567 Roseville NSW 2069 or email us at privacyofficer @ iclinix.com

Effect of Policy


This policy does not form a contract between an individual and iClinix Pty. Ltd.. The policy may also be subject to change. Whenever you need to refer to this policy you should contact us, or check our web sites, for the most up to date version.