Privacy Policy

Privacy Policy

Document Background

Juno Pharmaceuticals Pty Ltd and each of its related bodies corporate (collectively referred to as “Juno”, “we”, “us”, “our”) is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act). Personal information is defined in the Privacy Act, and as used in this Privacy Policy may include health information or other sensitive information. This Privacy Policy sets out how Juno handles personal information. This Privacy Policy does not apply to personal information collected by Juno that is exempted under the Privacy Act, for example employee records.

Juno may modify this Privacy Policy from time to time, including to reflect its current privacy practices or changes to its website, products or services. Any revised Privacy Policy will be uploaded to our website, so we recommend you check back regularly to review any changes. Changes to this Privacy Policy will apply from the date that we upload the revised policy to ourwebsite, and your continued use of our website or our services after that time constitutes your agreement to the changes.

1. PERSONAL INFORMATION WE COLLECT, HOW IS IT COLLECTED AND FOR WHAT PURPOSE IS IT USED.

The types of personal information we collect varies depending on our relationship with you:

1.1 Hospital and health service customers

Juno may collect your personal information where you are an employee of a hospital or public or private health service in connection with the procurement of our products. The personal information collected may include your name, contact details, how you wish to be contacted, notes of our calls and communications with you, areas of your interest (including your professional interests), details of the organisation you work for (including its purchasing and (deidentified) dispensing patterns), bank account and credit card details), survey information and feedback provided by you. This personal information is generally collected directly from you when we first make contact and during the course of our business relationship with you and your employer. The information is used for the purpose of facilitating and improving our business relationship with you as a customer, including providing you with the benefit under any contracts we have with your employer and marketing our products and services to you. Failure by you to provide personal information may hamper our ability to provide you and your employer with optimum services and benefits.

1.2 Retail pharmacy customers

Juno may collect your personal information where you are an individual that owns a pharmacy or an employee of a pharmacy business. The personal information collected may include your name, contact details, how you wish to be contacted, notes of our calls and communications with you, areas of your interest (including your professional interests), details of your business (including your purchasing and (deidentified) dispensing patterns), bank account and credit card details), survey information and feedback provided by you.
This personal information is generally collected directly from you when we first make contact and during the course of our business relationship with you. The information is used for the purpose of facilitating and improving our business relationship with you as a customer, including providing you with the benefit under any contracts we have with you (or your employer) and marketing our products and services to you. Failure by you to provide personal information may hamper our ability to provide you with optimum services and benefits.

1.3 Health professionals

Where you are a health professional (such as a doctor or pharmacist) your name and contact details are collected when you provide us with queries or feedback in relation to products or pharmacovigilance information (ie the monitoring of medicines and other therapeutic goods), along with your qualifications, membership of professional associations and employer details where relevant. This type of personal information is generally collected directly from you when you contact us. Your personal information is also collected where you register an account to access and use our web-based product risk management and monitoring system, Juno Connected™. Additional terms and conditions (available here) apply to your use of Juno Connected™.
Your contact information is used for follow-up activities, including those that are part of standard pharmacovigilance activities. With respect to pharmacovigilance activities, if you fail to provide us with such personal information or to consent to the disclosure of this information to our suppliers and distributors (see below), this may result in the failure to properly investigate and follow-up on such pharmacovigilance reports.
If you are a health professional and provide Juno with health information of your patients, including via Juno Connected™, Juno requires that you obtain the consent of your patient before disclosing their health information to us.
Following receipt of any enquiries, healthcare professionals may also be asked for permission to be contacted by us in future about our products. You are entitled to refuse, or withdraw, such permission, at any time.

1.4 Patients

If you are a patient, your health information is collected when pharmacovigilance reports or product complaints are reported to Juno directly by you or through your health professional. Your health information will also be collected if you choose to enrol in a patient support program related to our products, or are enrolled by your health professional in Juno Connected™ for monitoring your treatment with one of our products. The specific types of health information collected may include your name, date of birth, contact details, sex, medical status and background, any medications taken, any treatment received, the contact details of your treating health professional and any recommendations arising out of such clinic or services. Additional types of health information may also be collected as part of monitoring your treatment with specific products via Juno Connected™, as outlined in our Privacy Statement for the relevant product, which we or your health professional will provide to you.
Health information of patients is collected for the purpose of investigating and following up product complaints and pharmacovigilance reports, complying with our regulatory and pharmacovigilance reporting obligations, providing you with professional services (as the case may be), and any other purposes specified in our Privacy Statement for a specific product (where applicable). Failure to provide us with all the information sought may result in our inability to provide those services or investigate the pharmacovigilance report or product complaint.

1.5 Participants in bioequivalence studies

If you participate in bioequivalence studies,involving our products, your health information is collected by the third party conducting the study and may be made accessible to Juno by that third party. The specific types of health information accessible by Juno may include your name, date of birth, sex, medical status and background, any medications taken, and other medical screening data. Juno uses this health information for the purposes of assisting the third party conducting the study, analysing the results of the study, improving Juno’s products and services and registering the relevant product Therapeutic Goods Administration (TGA).

1.6 Business associates and contractors

Juno collects your personal information if you own, or work for, a business associate or contractor of Juno. This information generally consists of name and contact information and is generally collected directly from you or from your employer. Your personal information is used for the purposes of facilitating the business relationship (including as contemplated under any contract). Failure to collect such information may hamper our ability to communicate with you.

1.7 De-identified information

We may also use de-identified information derived from personal information that we have collected for analysis purposes, to inform our product development activities, improve our services and for our submissions to regulators.

2. HOW WE MANAGE AND DISCLOSE PERSONAL INFORMATION

2.1 Where you provide us with personal information about someone else

If you provide us with someone else’s personal information, you should only do so if you have their authority or consent to provide us with their personal information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy or any Privacy Statements we give you.

2.2 Holding personal information

Juno holds personal information in hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example, security passes to enter our offices) and technology (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates) security measures. We also have document retention policies and processes. In some cases, Juno engages third parties to host electronic data (including data in relation to the services we provide) on our behalf.

2.3 Disclosure of personal information

The types of third parties to whom we may disclose your personal information include:

  • our service providers, including service providers that may assist with patient support programs, pharmacovigilance reporting or the hosting or operation of Juno Connected™
  • our professional advisers
  • other affiliated companies within the Juno group
  • as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including Juno’s business) or to enter into an alliance, joint venture or referral arrangement
  • the Therapeutic Goods Administration (TGA) in accordance with pharmacovigilance reporting requirements
  • other government or regulatory bodies or agencies, as part of an engagement or otherwise, (for example, the Australian Taxation Office), or
  • other parties identified in a Privacy Statement provided to you.

Some organisations that we use to store and manage your personal information, or that we disclose your personal information to, may be located in a country or countries outside Australia. We may also use cloud-based service providers who use assets located in other countries to manage our data. We will not disclose your personal information to an overseas recipient, including our service providers, without taking reasonable steps to ensure that the overseas recipient will not breach local privacy legislation.

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non personal, de-identified or aggregated information to them for research or promotional purposes.

We may also disclose your personal information in circumstances permitted by the Privacy Actor (where applicable to our business with you) State and Territory based privacy legislation.

3. GAINING ACCESS TO PERSONAL INFORMATION WE HOLD

You can request access to your personal information at any time, subject to some limited exceptions permitted or required by law. Such request must be made in writing to the Juno Privacy Officer. We may charge a fee in accordance with law for providing access.

4. KEEPING PERSONAL INFORMATION CURRENT

If you believe that any personal information Juno has collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request correction. To do so, please contact the Juno Privacy Officer and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.

5. UNSUBSCRIBING FROM MARKETING COMMUNICATIONS

You can unsubscribe from any marketing communications from us by following the instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the details at the end of this Privacy Policy.

6. LINKS TO OTHER WEBSITES

This Privacy Policy applies only to this website, and not to websites owned by third parties. We may provide links to other websites which we believe may be of interest to our visitors. We cannot guarantee the privacy standards of websites to which we link and are not responsible for the contents of sites other than this one, and this Privacy Policy is not intended to be applicable to any linked site.

7. COOKIES

We use cookies (small pieces of information that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of our website (including Juno Connected™) and to optimise or personalise certain features of our website for you. While cookies do not normally contain personal information, if you have provided us with personal information as part of using our website then the cookies we use may be associated with that personal information to enable us to increase the personalisation of our website for you.

Most web browsers can be configured to notify you when a cookie is received, allowing you to either accept it or reject it. You may inspect cookies on your hard drive and delete them. If you disable the use of cookies or remove them, you may not be able to gain access to all of the content and facilities of our website.

8. PROTECTION OF PERSONAL INFORMATION

Juno is committed to keeping your personal and sensitive information secure. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. We also take reasonable steps to ensure that third parties who work with us also protect your personal information. Where we no longer require the personal information for the purpose for which it was obtained, we will take reasonable steps to delete the information and or ensure it is de-identified (as reasonable in the circumstances).

9. CONTACT DETAILS

If you wish to contact or make a complaint to Juno about our handling of your personal information, you can contact the Juno Privacy Officer, on the contact details below. You will be asked to set out the details of your complaint in writing in a form provided. Juno will endeavour to reply to you within 30 days of receipt of the completed complaint form and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, the Juno Privacy Officer may decline to investigate the complaint, for example if the complaint relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner or, where applicable, the relevant State or Territory Commissioner or Ombudsman.

Privacy Officer
Juno Pharmaceuticals Pty Ltd
42 Kelso St,
Cremorne. Vic 3121,
Australia.
By email to: privacyofficer@junopharm.com.au