Doherty Clinical Trials Ltd (ABN77 659 153 018) and its related companies (together we, us, our and other similar expressions) are committed to protecting your personal privacy.
This Privacy Policy tells you how we collect, store, use and disclose your personal information. Information is your ‘personal information’ if it is about you as an identified or identifiable individual. We encourage you to read this policy carefully so that you understand how we deal with that information.
Our Privacy Principles
When dealing with personal information, we are required to comply with privacy laws, including:
- the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). We have adopted internal policies and procedures to ensure that personal information that we collect, store, use and disclose is dealt with in accordance with the APPs. You can see the full text of the APPs online at www.privacy.gov.au.
- the Privacy and Data Protection Act 2014 (Vic), to the extent it governs our handling of personal information on behalf of Victorian public sector organisations.
- the Health Privacy Principles (HPPs) in the Health Records Act 2001 (Vic) and Health Records Regulations 2023 (Vic) which require the protection of health, disability, and aged care information by organisations in Victoria, including (amongst others) universities and research institutions.
Information we collect
In order to provide our customers with our services, we may collect and use personal information. If we are not provided with all the personal information we request, we may not be able to supply our services to you, and you or your organisation may not be able to participate in future offers of services which we supply.
We collect the following types of personal information:
General information – names, addresses, email addresses and other contact details. We may also collect details of your age, sex, occupation, hobbies and other personal information about you which is not sensitive in nature.
Sensitive information – as defined under the Privacy Act, this includes information or an opinion about your racial or ethnic origin, political opinions or memberships, religious or philosophical beliefs, criminal record and health information. For example, if you sign up to participate in one of our research studies or clinical trials, we may collect information about your medical history, family history of disease, biometric information and other sensitive information about your lifestyle and behaviour.
Where we are required to and able to do so, we will ask for your consent before collecting your sensitive information and let you know the purpose at the same time.
How we collect personal information
Generally, we collect your personal information from you. For example, we may collect information from you when you complete our online registration forms, or when you otherwise provide us with information, whether in person, by telephone, online or in writing. However, we may also collect personal information about you from someone other than you (for example from our service providers, from other research organisations or from publicly maintained records.
How we store personal information
We take all reasonable steps to keep secure any personal information which we hold about you and to protect your personal information from loss, misuse or unauthorised alteration.
Any personal information you provide to us is stored on secure servers. Access to personal information is limited to our employees who specifically need it to carry out their business responsibilities.
We also maintain physical security procedures to manage and protect the use and storage of records containing personal information.
Purpose of collection
We collect, hold, use and disclose personal information so we can:
- meet our legal obligations;
- conduct clinical research studies;
- identify our research participants, potential participants and their representatives;
- communicate with you;
- inform you of any initiatives we think may be of interest to you;
- inform you about our research activities and the benefits of participating;
- provide you with information about offers or other benefits that may become available;
- seek your opinion or comments about our activities;
- carry out billing and debt recovery activities;
- carry out our management, administrative, quality assurance and complaint handling activities in a professional and efficient manner; and
- develop and implement initiatives to improve our clinical research and other activities,
and for other secondary purposes.
Disclosure
We usually disclose the personal information we collect to our related entities, service providers and contractors that help us supply our services. For example, we may disclose the personal information we collect to our information technology providers, providers of marketing and promotional services, professional advisers such as legal practitioners and accountants, debt collectors and insurers.
Except as indicated above, we will not disclose your personal information to a third party unless:
- you have consented to the disclosure;
- we have obligations to disclose information to specific people or entities, such as your general practitioner or a health department, for example, this could be in the event of a notifiable disease, where mandatory reporting is required;
- the third party is our service provider or contractor, in which case we will require them to use and disclose the personal information only for the purpose for which it was provided to them;
- the third party is a person involved in a dealing or proposed dealing (including a sale) of all or part of our assets and business;
- the disclosure is to a related entity; or
- the disclosure is permitted, required or authorised by or under law.
Disclosure to overseas recipients
We are likely to disclose personal information, including health information, to recipients located outside Victoria and overseas. These recipients may include other research organisations who we engage with and our IT service providers.
The location of the overseas recipients may change from time to time, depending on the particular research activities we are engaged in.
In any case, we will take reasonable steps where required to ensure that any overseas recipients are subject to:
- sufficient privacy laws which protect personal information in a way that is at least substantially similar to protection under the APPs; or
- a binding agreement with us which requires them to protect the information we disclose in a way that is substantially similar to our obligations under relevant privacy laws.
Marketing
We may use personal information to advise you of new services and marketing initiatives that we think may be of interest to you. This may include product or service offerings, newsletters and general information about us.
If you prefer not to receive information about our services, you can ask to be removed from the relevant circulation list by contacting us at the contact details listed below.
We never disclose personal information to a third party for the purpose of allowing them to direct market their products or services to you, unless you have expressly consented to that disclosure.
We also use third party service providers which provide us with insights and analytics to help us improve our services and our engagement (for example, Google Analytics which helps us to understand how the public engages with our websites and other online services).
Access
If at any time you want to know what personal information we hold about you, you are welcome to request access to that information by contacting us at the contact details listed below.
If we deny your request for access, we will let you know why.
Quality and correction
We always try to make sure that the information we hold about you is accurate, complete and up-to-date. If at any time you believe the personal information that we hold about you is incomplete or inaccurate, please let us know. We will use all reasonable efforts to correct the information.
Changes to this policy
As our business evolves, our business processes and policies will be reviewed and may be amended. We may change this policy at any time. We will notify you of any change by posting an updated version of the policy on our website. Please be aware that it is your responsibility to check our website and make sure you keep up-to-date with any changes to this policy.
Complaints
We are committed to constantly improving our procedures so that your personal information is treated appropriately. If you feel that we have failed to deal with your personal information in accordance with this policy, the APPs or the HPPs, contact us at the contact details listed below so we have an opportunity to resolve the issue to your satisfaction.
Our privacy officer will:
- listen to your concerns and grievances;
- discuss with you the ways in which we can remedy the situation; and
- put in place an action plan to resolve your complaint and improve our information handling procedures if appropriate.
Contact us
If you require more detailed information about how we deal with personal information or if you have any concerns about how we have dealt with your personal information, please let us know by contacting us at:
Privacy Officer
Doherty Clinical Trials Ltd
Email: info@dohertyclinicaltrials.com
792 Elizabeth Street,
Melbourne, Vic, 3004
We will aim to respond to your concerns as quickly as possible.
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