Last Updated
June, 2020

RxMx Privacy Policies

Clinical Services Privacy Policy

Medical Safety Systems Corporate Pty Ltd ABN 89 608 630 931 and its related entities trading as RxMx Australia recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information.We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Privacy Act’s requirements in respect of the collection, management and disclosure of your personal information.

What is your personal information?
When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What is your sensitive information?
When used in this privacy policy, the term “sensitive information” has the meaning given to it in the Privacy Act. In general terms, it includes information or opinions concerning the health or disability of an individual, an individual’s expressed wishes about the future provision of health services, or a health service that is, or will be, provided to an individual. Sensitive information is a sub-category of personal information.

What personal information do we collect and hold?
We may collect the following types of personal information identification information, such as your name, mailing or street address, age or date of birth, telephone contact numbers, your email address, Medicare numbers, individual healthcare identifiers issued under the Healthcare Identifiers Act 2010 (Cth), your referring doctor and your profession or occupation if you are a health practitioner, we may collect your Australian Health Practitioner Regulation Agency (AHPRA) number, sensitive information, which will include health information including your attendance for treatment or assessment, your diagnosis, results of your medical tests and details of your treatment, the results of surveys that collect information about your health, well-being and beliefs and attitudes, as well as such information as is necessary to provide health-related notification services and other services to you including your medical history and your ethnic origins, details of our products and services you have enquired about, together with any other additional information necessary to respond to your enquiries; and any additional information relating to you that you provide to us directly in person or indirectly through use of our website or our products and services or otherwise.We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated and de-identified information (which means that it does not identify you or anyone else) about how users use our website or our products and services.

Dealing with us anonymously or using a pseudonym
You may interact with us by using a pseudonym if you wish. If you wish to interact with us in this way, we require that you use a Medicare Pseudonym Individual Healthcare Identifier and that you ensure that the details of this pseudonym are known to all appropriate persons such as your health service providers.

How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:through your access and use of our services during conversations between you and our representatives; or when you complete an enrolment application.We may also collect personal information from other people including medical professionals, health service providers, such as your specialist physician, referring doctor, hospitals, nurses, clinics and medical specialists in order to assist us in our provision of services to you.When you enrol in a service provided by us, we ask you to give your consent for your personal information to be collected in these ways.

Cookies
In some cases, we may also collect your personal information through the use of cookies. When you access our website or our online products and services, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer.  RxMx uses session-based cookies to help secure data in transit and ensure optimal online performance. RxMx websites and online services also use persistent cookies for other purposes, like retaining user preferences across sessions. Both RxMx and third-party (Google Analytics) cookies are used for analytics purposes, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Embedded third-party tools like Google Maps will also often utilise cookies.If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. Cookies can also easily be deleted.We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:we may not be able to provide our products and services to you, either to the same standard or at all; and we may not be able to provide you with information about our products or services that you may be interested in.In addition:if you are a patient and you provide inaccurate or incomplete information in connection with our services, we and your treating healthcare professional may not have all the information that is required to properly provide you with medical services; or if you are a health care professional or nurse and you provide inaccurate or incomplete information in connection with our services, you may not have all the information you require to accurately provide your patient with medical services.

For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service.We collect, hold, use and disclose your personal information (including sensitive information) for the following purposes:to provide services requested by you to answer enquiries and provide information or advice about our products and services to conduct business processing functions including providing personal information to our contractors, healthcare service providers or other organisations in order for us to provide you with our services to process and respond to any complaint made by you; and to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.We may also collect hold, use and disclose your personal information (but generally not sensitive information) for the following purposes:for administrative, service development, quality control and our research purposes to update our records and keep your contact details up to date; and to assess the performance of our website and to improve the operation of our website.We may sometimes use your personal information in an aggregated or de-identified form, which means that we will modify the information so that it does not identify you or anyone else. We may create, use and disclose aggregated and de-identified information for the purposes of quality assurance, and reporting.Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

To whom may we disclose your information?
We may disclose your personal information to our employees, contractors or service providers for the operation of our website or our business, fulfilling requests by you and to otherwise provide services to you including, without limitation, web hosting providers, IT systems administrators, couriers, and professional advisors such as accountants, solicitors, business advisors and consultants; and any organisation for any authorised purpose with your express consent.In addition, if you are a patient, we may disclose your personal information (such as your contact or health information) to referring doctor or other healthcare provider along with their nurses or support staff if you have agreed to us making such a disclosure in conjunction with our services. It is your responsibility to advise us if there is any change to your health care service provider.If you are a health care provider or nurse, we may disclose your personal information to people and organisations in conjunction with our services only if you give us your prior consent.We may also disclose your personal information without your consent when required or authorised to by law. For example, we may disclose your personal information if we reasonably believe that such disclosure is necessary to lessen or prevent a serious threat to your life, health or safety or the life, health or safety of any other individual or to public health or safety, or under compulsion of law including a court order (including a subpoena).When you enrol in one of our services, we ask you to give your consent for your personal information to be used and disclosed in these ways.

How can you access and correct your personal information?
We take reasonable steps to make sure the personal information we hold is accurate and complete.  You have a right to request access to your personal information and that it be updated or corrected if necessary. You may request access to any personal information we hold about you at any time by contacting us (see the details below). When you request access to information we hold about you, we will usually provide it to you in an electronic form. In order to protect your privacy, we will ask you to verify your identity before giving you access to the information.We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and we will not charge for making any corrections to your personal information.There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We may also need to verify your identity in order to resolve your complaint. 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. If the circumstances of your complaint are complex and we need additional information or time to provide you with a formal response, we will contact you to let you know.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.

Do we disclose your personal information to anyone outside Australia?
We hold your personal information on secure computer systems located within Australia. Due to the nature of our business, the personal information that we collect may be transferred to or accessed from a location outside of Australia by a third party authorised by us. In any event, we take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

Security
We store your personal information on electronic systems and take reasonable steps (including technological measures such as encryption and authentication, and administrative procedures and physical security) to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Personal information is destroyed or de-identified when no longer needed.As our website and our products and services are linked to the internet, and the internet is inherently insecure, we take reasonable steps to protect data in transit, but we cannot guarantee the secure transmission of information you communicate to us online. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

Privacy Officer
Medical Safety Systems Corporate Pty Ltd t/a RxPx
Post: Level 1/94 Mallett St
Camperdown NSW 2050
Tel: 02 8004 6877
Email: privacy@rxmxcorp.com

Changes to our privacy policy
We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. Please review it regularly.

This privacy policy was last updated in June 2020.

Clinical Research Privacy Policy
Medical Safety Systems Corporate Pty Ltd ABN 89 608 630 931 and its related entities trading as RxMx Australia recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information.We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Privacy Act’s requirements in respect of the collection, management and disclosure of your personal information.

What is your personal information?
When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address and other contact details, date of birth, and may also include information about your health. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold?
We may collect the following types of personal information:identification information, such as your name, mailing or street address, age or date of birth, telephone contact numbers, your email address, your referring doctor and your profession or occupation-sensitive information, which will include health information including your attendance for treatment or assessment, your medical history and diagnosis, results of your medical tests and details of your treatment, the results of surveys that collect information about your health, well-being and beliefs and attitudes, and information about your participation in a clinical trial; and any additional information relating to you that you provide to us directly in person or indirectly through use of our website or our products and services or otherwise.Where we are required to collect identifying information such as your name, email address or phone number for the purpose of conducting a clinical trial, we will do so only with your consent. In this circumstance, this personal information will be used only for the purpose of conducting the clinical trial and will never be disclosed to a third party unless we are compelled by law to do so.In most cases we collect and hold information in a manner that is not linked to your name or other information that is likely to identify you. We identify participants in clinical trials by codes and do not use names. This is one of the ways we protect your privacy because the information we collect and link to a code does not identify you or anyone else. We also take other steps to ensure that the information cannot be linked to you or any other identifiable person. We may do this by aggregating the information of multiple individuals so that the resulting information identifies a group of individuals rather than anyone in particular.We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated and de-identified information (which means that it does not identify you or anyone else) about how users use our website or our products and services.

How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:through your access and use of our electronic platform during conversations between you and our representatives; or when you complete an application to enrol in the clinical study.We may also collect personal information from other people including medical professionals, health service providers, such as your referring doctor, hospitals, nurses, clinics and medical specialists in order to assist us in our provision of services to you.When you enrol in a clinical study provided by us, we ask you to give your consent for your personal information to be collected and managed as described in this privacy policy.  We may sometimes obtain your consent indirectly when you provide your consent to the investigator who assists you to enrol in the clinical trial and to other parties such as us who are assisting with the clinical trial.

Cookies
In some cases, we may also collect your personal information through the use of cookies. When you access our website or our online products and services, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. RxMx uses session-based cookies to help secure data in transit and ensure optimal online performance. RxMx websites and online services also use persistent cookies for other purposes, like retaining user preferences across sessions. Both RxMx and third-party (Google Analytics) cookies are used for analytics purposes, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Embedded third-party tools like Google Maps will also often utilise cookies.If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. Cookies can also easily be deleted.We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, you may not be able to participate in the clinical trial. In addition, if you provide inaccurate or incomplete information in connection with the clinical trial, we and your treating healthcare professional may not have all the information that is required to properly provide you with medical or clinical trial services.

For what purposes do we collect, hold, use and disclose your personal information? We collect, hold, use and disclose your personal information for the following purposes:to assist you and facilitate your participation in a clinical trial to enable us to conduct a clinical trial and to conduct research and analysis and prepare reports on the results of a clinical trial to answer enquiries and provide information about a clinical trial to conduct business processing functions including providing personal information to our contractors, healthcare service providers or other organisations in order for us to conduct a clinical trial to process and respond to any complaint made by you; and to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.We generally use your personal information in a de-identified or aggregated form, which means that we will modify the information so that it does not identify you or anyone else. Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

To whom may we disclose your information?
We will never disclose any information that identifies you (such as your phone number or email address which we need for the clinical trials) to any third party.  If you experience technical difficulties with the electronic platform that we use for the clinical trial, we may disclose your phone number or email (but never your name) to our relevant employees so that they can help you and us to resolve those difficulties.  In this case, our employees will have your contact details but will not have your name.We may disclose information that does not identify you (for example, we may aggregate or code the information so that it does not identify anyone) to third parties for the purposes of conducting the clinical trial. Those third parties include our employees, contractors or service providers for the operation of our electronic platforms or our business, fulfilling requests by you and to otherwise provide services to you including, without limitation, statistical advisors, web hosting providers, IT systems administrators, couriers, and professional advisors.We never disclose your personal information relating to a clinical trial to a third party sponsor of a clinical trial, such as a pharmaceutical company. Any information released to a third party sponsor of the clinical trial is aggregated so that it does not identify you or anyone else.In addition, if you are a patient, we may disclose your personal information (such as your contact or health information) to your referring doctor or other healthcare provider along with their nurses or support staff if you have agreed to us making such a disclosure in conjunction with our services. It is your responsibility to advise us if there is any change to your health care service provider.We may also disclose your personal information without your consent when required or authorised to by law. For example, we may disclose your personal information if we reasonably believe that such disclosure is necessary to lessen or prevent a serious threat to your life, health or safety or the life, health or safety of any other individual or to public health or safety, or under compulsion of law including a court order (including a subpoena).When you enrol in one of our services, we ask you to give your consent for your personal information to be used and disclosed in these ways.

How can you access and correct your personal information?
We take reasonable steps to make sure the personal information we hold is accurate and complete.  You have a right to request access to your personal information and that it be updated or corrected if necessary. You may request access to any personal information we hold about you at any time by contacting us (see the details below). When you request access to information we hold about you, we will usually provide it to you in an electronic form. In order to protect your privacy, we will ask you to verify your identity before giving you access to the information.We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and we will not charge for making any corrections to your personal information.There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We may also need to verify your identity in order to resolve your complaint. 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. If the circumstances of your complaint are complex and we need additional information or time to provide you with a formal response, we will contact you to let you know.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.

Do we disclose your personal information to anyone outside Australia?
We hold your personal information on secure computer systems located within Australia. Due to the nature of our business, the personal information that we collect may be transferred to or accessed from a location outside of Australia by a third party authorised by us. In any event, we take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

Security
We store your personal information on electronic systems and take reasonable steps (including technological measures such as encryption and authentication, and administrative procedures and physical security) to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Personal information is destroyed or de-identified when no longer needed.As our website is linked to the internet, and the internet is inherently insecure, we take reasonable steps to protect data in transit, but we cannot guarantee the secure transmission of information you communicate to us online. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third party websites are responsible for informing you about their own privacy practices.

Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

Privacy Officer
Medical Safety Systems Corporate Pty Ltd t/a RxPx
Post: Level 1/94 Mallett St
Camperdown NSW 2050
Tel: 02 8004 6877
Email:  privacy@rxmxcorp.com

Changes to our privacy policy
We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. Please review it regularly.

This privacy policy was last updated in June 2020.

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