CSL is committed to protecting the privacy of all the individuals it deals with. This document sets out our policies on handling personal information (including health information).
For specific information about how CSL in Australia may collect and use personal information for marketing purposes, please refer to our Marketing Statement.
This Policy gives effect to our commitment to protect your personal information and has been adopted by CSL Limited and its affiliates in the CSL group of companies (collectively referred to as “CSL”, “we“, “us”, and ”our” throughout this Policy, depending upon the context).
This Policy applies to personal information regarding patients, healthcare professionals, customers, other third party business associates, employees and others and to the management of that personal information. The purpose of this Policy is to explain the types of information that CSL collects, what we do with that information, and with whom we share this information.
While this Policy is intended to establish a standard for our information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we comply with relevant local laws and regulations.
1.1 TYPES OF INFORMATION
The term “personal information” under this Policy refers to information about an identifiable individual. The types of personal information that we process (which may vary depending on your relationship with us as well as by jurisdiction based on applicable law) may include, among others, contact information (such as name, postal or e-mail address, and phone or fax number), business contact information (such as job title, medical specialty, department and name of organization), or other information (such as language preference, date of birth, gender and family status).
CSL collects personal information directly from individuals when necessary to provide our services, including as part of responding to queries from individuals, our recruitment processes, ongoing employment activities, conducting clinical trials, speaking to health and allied professionals about our products and services, conducting marketing activities and organising conferences, seminars and other meetings, and receiving medical queries and adverse drug reports.
There may be instances in which the personal information that we collect, use, and process is considered “sensitive personal information” under the privacy laws of some countries. The definition of “sensitive personal information” under these privacy laws may, for instance, include personal information from which we can determine or infer an individual’s racial or ethnic origin, religious or philosophical beliefs, or medical or judicial data. We only collect, use, and process “sensitive personal information” in your jurisdiction if and to the extent permitted or required by applicable law.
1.2 USE OF PERSONAL INFORMATION
CSL collects and uses personal information to the extent necessary to provide products and services for our patients, customers, employees, and others. Subject to applicable laws, we may collect, use, process and disclose relevant portions of your personal information in order to
- administer, operate, facilitate and manage your relationship with CSL. This may include sharing such information internally as well as disclosing it to third parties, as described in Section 1.3;
- provide you or, if applicable, your designated representative(s) with information (including marketing information) or contact you by post, telephone, electronic mail, facsimile, etc. in connection with your relationship;
- facilitate our internal business operations, including fulfilling our legal and regulatory requirements.
1.3 DISCLOSURE OF PERSONAL INFORMATION
In order to provide products and services to you, more than one entity within CSL may be given, or given access to, your personal information. When we share your personal information, we adhere to applicable legal requirements regarding the protection of personal information.
We may outsource the processing of certain functions and/or information to third parties (including, but not limited to, mail-out companies, agencies engaged to organise conferences and database managers who maintain and update contract information and who may contact you independently to verify that information or your contact preferences). When we contract with other companies to provide services to CSL and then provide or allow access to personal information to such third party service providers for that purpose, we require those companies to protect the information and adhere to applicable data privacy standards.
CSL and third parties to whom we may provide your personal information are located in countries including, but not limited to, Argentina, Australia, Austria, Belgium, Brazil, Canada, China, Czech Republic, Denmark, France, Germany, Greece, Hong Kong, Hungary, Italy, Japan, Malaysia, Mexico, Netherlands, New Zealand, Panama, Poland, Portugal, Spain, Sweden, Switzerland, the United Kingdom, the United States of America.
We reserve the right to disclose any personal information if we are compelled to do so by a court of law or requested to do so by governmental authorities or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting, tax rules and regulations and any specific record retention laws.
Circumstances may arise where, whether for strategic or other business reasons, CSL decides to sell, buy, merge or otherwise reorganize businesses. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers.
1.4 INTERNATIONAL DATA PROCESSING
Like most international businesses, certain aspects of our data processing activities will result in the transfer of your personal information from one country to another. The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information. Nevertheless, whenever your personal information is transferred within CSL, your personal information will be processed in accordance with the terms and conditions of this Policy and all applicable laws.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take an order without a name). If you provide us with your contact details (e.g., postal or email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in.
In some jurisdictions, data privacy laws may require us to obtain your consent before we, for instance, send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfill your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be of a sensitive nature under local regulations).
1.6 DATA ACCURACY; ACCESS
CSL strives to keep your personal information accurate. We provide individuals with reasonable access to their personal information so that they can review and correct it, or ask us not to use it. We do not charge for this service and will respond to reasonable requests in an appropriate timeframe. If you wish to exercise your rights of access and correction in accordance with applicable law, please contact us at the address set out in Section 1.8.
1.7 OTHER APPLICABLE TERMS; CHANGES TO THIS POLICY
This Policy provides a general statement of the ways in which CSL protects your personal information. This Policy does not modify or alter any applicable agreement you have or may have with CSL. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. To assist you, this Policy has an effective date.
1.8 If you have any questions about how we process your personal data or want to exercise one of your rights, you can contact us or our Data Protection Officer through firstname.lastname@example.org.
All requests for access to your personal information must be submitted in writing by letter or email.