The QUEST Initiative observational study into quality of life of patients accessing medicinal cannabis (“the Study”) is funded by Little Green Pharma Ltd (ABN 44 615 586 215)(“LGP”, “we” or “us”). LGP is responsible for recruiting patients to the Study and engaging healthcare professionals to identify and register eligible patients for the Study.
In addition, LGP has engaged certain distributors, being Oxford Compounding Pty Ltd (ACN 610 162 626), Canview Pty Ltd ACN 639 650 927 and CDA Health Pty Ltd 632 054 230 and any other third party that LGP may appoint or engage, to provide pharmaceutical distribution and pharmacist consulting services in connection with the Study (“Distributors”) and Carbon Group ACN 168 673 569 and any other third party that LGP may appoint or engage, to provide payment services in connection with the Study (“Accountant”). Together, the Distributors and Accountant are the “Study Contractors”.
The Distributors are responsible for processing product orders and delivering these to patients as part of their participation in the Study, as well as providing pharmacist consulting services to patients. The Accountant is responsible for managing patient payments in connection with the Study.
- the recruitment of patients and healthcare practitioners to the Study
- the processing of product payments by the Accountant through the QUEST Initiative payment portal and the distribution of product to patients by the Distributors.
In addition, you agree that all of your personal information supplied to or collected by:
LGP respects your rights to privacy and have a legal obligation to abide by the provisions of the Privacy Act 1988 (Cth) (“the Act”). Our objective is to handle information responsibly and provide you with some control over the way information about you is handled.
In general terms, personal information 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. It may also include information about your medical history or any conditions you may have. Information which cannot be reasonably linked to your identity (e.g. IP address, browser information, favourite websites or the number of users of a website) does not constitute personal information and is not regulated by the Privacy Act 1988 (Cth). If the information we collect personally identifies you, the information will be considered personal information.
Collection of Personal Information and other data
For applicants and participants in the Study, the nature of personal information collected by LGP and the Study Contractors may comprise information such as:
- your name, email, address, location and telephone number;
- your age or date of birth;
- your treating medical practitioner name, clinic and contact details;
- your medical history and any medical conditions, or the medical history or medical conditions of your children or children in respect of which you are a guardian voluntarily provided by you;
- any additional information relating to you that you provide to us directly through our representatives, medical or allied health professionals.
For healthcare professionals, the nature of personal information collected may include any or all of the above information as well as:
- your name, email, address, location and telephone number
- your AHPRA number and profession;
- the location, scope of services offered by you or your medical practice, and cost of these services;
- information collected in the provision of any services requested; and
- your prescribing practices.
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 information about how users use the Site.
When collecting personal information from you, we may collect it in ways including:
- by you completing one of our contact us forms or through an internet portal, including the Site;
- through email in relation to enquiries from you or responses to emails sent to you or phone calls, texts or other forms of communications with any of our representatives;
- in response to product queries or engagement with our representatives; through your access and use of our websites (including the Site) and social media channels;
- by review of your medical records including clinic letters or test results from health care providers; and
- in connection with the Study or patient or doctor surveys, questionnaires or other trials or testing activities.
Generally, we endeavour to collect your personal information directly from you unless it is unreasonable or impracticable to do so. In addition, we may also collect personal information from other sources including:
- information provided on your behalf with your consent or through direct contact with your guardian, other family members or your doctor/healthcare provider;
- where permitted, from third party bodies such as your health fund, hospitals or other community health services, law enforcement agencies and other government entities, including Medicare and Department of Veterans Affairs; and
- publicly available sources including directories, listings and the internet.
Collection, Use & Disclosure of Personal Information and other data
The purposes for collecting such personal information include:
- to screen potentially eligible patients for the Study;
- to support the administration of the Study;
- to provide information about the Study to you or refer to you to healthcare practitioners where requested by you;
- to disclose to the Distributors to facilitate the distribution of products to you in connection with your participation in the Study;
- to disclose to the Distributors to provide pharmacist consultation services to you in connection with the Study;
- to disclose to the Accountant to administer payments and provide related services, including through the QUEST Initiative payment portal;
- to update your contact details;
- to process and respond to any complaint made by you;
- to share with legal and regulatory bodies, including 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 of any country, including any accreditation agencies;
- to understand community interest and attitudes towards medicinal cannabis as a form of treatment for different conditions;
- discuss with and disclose to your health practitioner(s) and Distributors or any dispensing pharmacy(ies) in connection with the Study;
- facilitate the performance of any services or functions LGP provides to you in connection with the Study;
- disclose to any Related Body Corporate or any entity which controls or holds a significant shareholding in a Group member for the purpose of carrying out any of the services, functions, activities or tasks permitted to be carried out by LGP under this Policy;
- in connection with bankruptcy or insolvency of LGP; and
- to meet obligations of notification to LGP’s medical defence organisations or insurers.
At any time, you may opt-out of receiving communications from us by contacting LGP or by using opt-out facilities provided in the communications and we will then ensure that your name is removed from LGP’s mailing list.
LGP may aggregate personal information so that it is not personally identifiable and disclose such aggregate or de-identified data to third parties. LGP will not sell your personal information to third parties.
On some occasions, your personal information and other data may be transferred to or processed by service providers in overseas countries including but not limited to the US, or even in ‘the cloud’ (which may involve processing in more than one country) in order for such service providers to perform services on LGP’s behalf. We will not be accountable under the Privacy Act 1988 for any breach of your privacy by the cloud storage provider nor will you be able to seek redress under the Privacy Act 1988 for any breach of your privacy by the cloud storage. Like most business organisations, LGP and the Contract Suppliers perform some of their functions under licence and also contracts out some functions and relies on third party suppliers to conduct specialised activities such as website management, IT systems administrators, mail out services, couriers, electronic network administrators, and professional advisors such as accountants, solicitors, business advisors and consultants. Personal information may be provided to these licensors (where contractually required) and to these suppliers to enable them to perform the agreed tasks.
In relation to transactions that may potentially involve the transmission of personal information, we seek to require that third parties who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with the Act.
Some companies that LGP and the Study Contractors are associated with have their own privacy policies and where they collect personal information from you for their own business, your personal information will be handled in accordance with their privacy policies.
Access and correct your personal information
LGP wishes to ensure all personal information collected is accurate, complete and up-to-date. To assist LGP in achieving its objective, please contact the Privacy Officer if any of your details change. Further, if you believe that the information LGP holds is not accurate, complete or up-to-date, please contact the Privacy Officer on email@example.com in order to have the information corrected.
You may request access to any personal information LGP hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be as advised from time to time. We will not charge for simply making the request and will not charge for making any corrections or deletions to your personal information.
For corrections or changes to information held by the Study Contractors, please contact their Privacy Officers as indicated in their Privacy terms and conditions above.
There may be instances where LGP or the Study Contractors cannot grant you access to the personal information we hold; however, we will only do so in accordance with our rights and obligations under the Act. 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.
Personal Information Security
LGP takes reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure in accordance with the sensitivity of that information. Your personal information and other data may be stored in hard copy documents but is generally stored electronically on our software or systems or on those of our third-party service providers.
As our website is linked to the internet, and the internet is essentially insecure, LGP cannot provide any assurance regarding the security of transmission of information you communicate to us online. LGP and the Study Contractors also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please also refer to the Australian Federal Police’s website at http://www.afp.gov.au/policing for information about how to protect yourself against identity theft.
Additionally, you acknowledge that the collection and use of your personal information by third-parties may be subject to separate privacy policies and/or the laws of other jurisdictions.
If you believe that your privacy has been breached, please contact us at firstname.lastname@example.org in accordance with the arrangements set out below and provide details of the incident so that we can investigate it. All complaints should initially be in writing and directed to the LGP Privacy Officer.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Our Site may contain links to other websites operated by third parties. LGP make no representations or warranties in relation to the privacy practices of any third-party website and 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.
IP addresses, cookies and web beacons
We may also collect and receive certain types of information whenever you interact with us on our websites (including the Site) and through e-mails or other communications we may send each other. These technologies we use may include, for example, Web server logs, cookies and Web beacons.
- Web server logs / IP addresses: We may collect web server logs and IP addresses to conduct system administration and report aggregate information to affiliates, business partners and/or vendors to conduct site analysis and web-site performance reviews.
- Web Beacons. On certain webpages or e-mails, we may utilize a common Internet technology called a “web beacon (also known as an “action tag” or “clear GIF technology”). Web beacons help analyse the effectiveness of websites by measuring, for example, the number of visitors to a site or how many visitors clicked on key elements of a site.
We may also collect information from your browser or device when you visit our websites (including the Site) in addition to your IP, including device ID and type, your browser type and language, access times, your mobile device’s geographic location and referring website address.
Privacy Officer’s Contact Details
Please address all written correspondence to:
LGP Privacy Officer
Little Green Pharma
PO Box 690
West Perth, WA 6872