Script Approval Management (SAM) Privacy Policy

This Privacy Policy describes how personal information is handled by Seekwell Pty Limited (ABN 91 624 401 618) and The Seekwell Unit Trust (ABN 59 739 246 428) (“Seekwell”) as the operator of the Script Approval Manager (“SAM”) website and application.

Purpose

Seekwell recognises the importance of your privacy and understands that securing your personal information is important to you. We are committed to protecting the personal information that you entrust to us.

Seekwell has obligations to comply with the Australian Privacy Act 1988 (Cth) ("Privacy Act"). This Privacy Policy sets out how Seekwell seeks to ensure that any personal information we hold about you is collected, used, stored, safeguarded and disclosed in accordance with the Australian Privacy Principles in the Privacy Act. In this Policy, ‘personal information’ and ‘sensitive information’ have the same meaning as in the Privacy Act.

What personal information does Seekwell collect on SAM End Users?

SAM End User personal information collected by Seekwell may include (but is not limited to):

• First and last name

• Job title

• Professional title where applicable

• Clinic name

• Clinic contact details, including address and telephone number

• Clinic email address

• Mobile phone number

• Prescriber number where applicable

• PRODA (RA) number

• Log on credentials (username, password)

How does Seekwell collect and hold your personal information?

Seekwell collects and holds your personal information when you are granted a licence to use SAM as an authorised SAM End User.

For what purposes does Seekwell collect, hold, use and disclose SAM End User personal information collected in SAM?

Seekwell collects, holds, uses and discloses personal information in SAM for the following purposes:

• To verify your identity.

• To provide a platform for the purposes of submitting immediate authority requests for continuing script approvals from Services Australia. (Please note that Immediate authority script approvals for initial prescriptions are not currently supported by SAM or the PBS/Services Australia).

• To provide you with technical customer support.

• For general administrative purposes, including training provision and account administration.

• For other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.

In addition, Seekwell may use and disclose de-identified information:

• To conduct research and analysis.

• For auditing and reporting purposes.

Unsolicited Personal Information

If we receive personal information in error and we do not require it for a business purpose, we will securely destroy it, or ensure the information is de-identified if we are permitted by law and where is practical to do so.

Do you have to provide your personal information to Seekwell?

For the purposes of providing immediate authority script approvals for continuing script approvals from Services Australia, you are required to provide your personal information. This is an essential feature of the interaction that SAM requires with the Services Australia department within the Australian Government.

Seekwell is required by law to collect your personal information to fulfil or process authority script approval requests.

Disclosure of your personal information

Seekwell may be required to disclose your personal information to duly authorised governmental authorities or as required by Australian law.

Seekwell may provide your personal information to a third party in connection with the sale, assignment, or other transfer of the business of Seekwell to which the information relates, in which case Seekwell will require any such buyer to agree to manage your personal information in accordance with this Privacy Policy.

Seekwell may share your personal information with agents, contractors, partners or related bodies corporate of Seekwell (collectively “external parties”) in connection with the services that these external parties perform for, or with, Seekwell.

Any disclosure of your personal information to an external party will only be to the extent necessary to fulfil a business purpose. Seekwell will ensure that any external party who receives your personal information complies with the Australian Privacy Principles and protects your personal information to at least the same standard as Seekwell. These external parties are restricted from using your personal information in any way other than to provide services for Seekwell.

Sharing personal information outside of Australia

Seekwell does not routinely share personal information with people or organisations outside Australia. Seekwell may share de-identified information with organisations outside Australia, from time to time.

Security of your Personal Information

Seekwell and its external parties will store your personal information securely. Furthermore, Seekwell and its external parties will take all reasonable steps to keep secure any personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure. Access to personal information is only provided to those with a business need and their access is reviewed on a regular basis and removed when it is no longer required.

Personal information is kept for a number of years to comply with legal requirements. Any personal information that is no longer needed is securely destroyed after specific retention periods are met.

Areas of the SAM application that collect and store personal information use industry standard secure socket layer (SSL) encryption.

Access and correction

You have a right to request access to or correction of the personal information held by us. You can exercise your right to access and correct your personal information by contacting our Privacy Officer via the contact details provided below. To protect your personal information, you are required to verify your identity as part of fulfilling an access or correction request.

Complaints

If you feel that we have breached the terms of our Privacy Policy or otherwise not complied with the Australian Privacy Principles in the management of your personal information, you can lodge a written complaint to our Privacy Officer via the contact details provided below. Where our Privacy Officer receives a privacy complaint, we will respond to you within ten business days Where you are unsatisfied with the outcome, you may escalate your complaint to the Office of the Australian Information Commissioner.

Currency of this Privacy Policy

We may update this Privacy Policy from time to time.

Contact Us

You may contact us via email at info@seekwell.com.au