Introduction
Medtronic is the world leader in medical technology providing lifelong solutions to patients with chronic disease. We offer products, therapies and services that enhance the lives of millions of people.
As an ethical supplier of medical technologies and devices, Medtronic Australasia is committed to protecting personal and health information.
Medtronic Australasia operates in all states and territories of Australia with the head office in Sydney. As such, Medtronic is bound by the Privacy Act 1988 (Cth) and the Privacy Amendment (Private Sector) Act 2000.
This Privacy Policy outlines Medtronic Australasia’ compliance with the following National Privacy Principles:
01. Collection
02. Use and Disclosure
03. Data Quality
04. Data Security
05. Openness
06. Access and Correction
07. Identifiers
08. Anonymity
09. Trans-border Data Flows
10. Sensitive Information (Health information)
Medtronic Australasia regularly monitors its’ systems and procedures to ensure compliance with this policy.
1. Collection
Medtronic Australasia collects and will continue to collect business contact details and commercial transaction data regarding the accounts, customers and related parties involved in the sale and management of its products. This forms a part of our ongoing business relationship.
Customer records include the following information:
- Name, title, workplace address, telephone(s)
- Email address (if applicable)
- Hospital and case load data
- Case/ implant history
- Sales data
- Medical specialty
- Clinical interests
2. Use and Disclosure
The personal information collected is used for the purpose of conducting commercial business transactions and for advising of clinical and product education as well as marketing activities conducted by Medtronic Australasia.
We may also use this information for the purpose of providing updated information about our products and services, complying with regulatory requirements, (such as those of the Therapeutic Goods Administration) and building and maintaining our relationship with customers.
Customers have the right to opt out of receiving certain mailings such as clinical communications and updates about our products and services. Customers should advise the originator of the communication within Medtronic Australasia if they do not wish to receive similar communications in the future.
Due to the potential serious health implications for patients, customers cannot opt out of receiving regulatory notifications about our products.
Apart from the uses above, Medtronic Australasia will not use or disclose or permit the use or disclosure of personal information that could be used to identify an individual unless required to by Australian law.
3. Data Quality
Medtronic Australasia endeavors to ensure that the personal information collected, is complete and correct at the time of collection. However, with the passage of time the details of the information may need to be updated.
Should customers find that any of the details of the personal information held by Medtronic Australasia is incorrect or out of date, Medtronic Australasia will correct the information.
4. Data Security
Medtronic Australasia Pty Ltd undertakes to take reasonable steps necessary to ensure that personal information is secure from any unauthorised access, modification or disclosure.
Medtronic uses a mainframe computer system for most of its business operations. This system is password secured and connected by secure communications. The information on the mainframe computer system is routinely backed up and the back up information is stored in a secure location.
Access to the personal information on the mainframe computer system is restricted to those personnel who require access in order to perform their job function.
5. Openness
The Medtronic Australasia Privacy Policy shall be made freely available to any one who requests it.
6. Access and Correction
Customers may request access to their personal information held by Medtronic Australasia by putting a request for the information in writing to the Manager – Regulatory Affairs, Medtronic Australasia Pty Ltd, 97 Waterloo Road North Ryde NSW 2113. Information concerning the manner such personal information is managed may also be requested by the same means.
In some cases, a fee for reasonable costs incurred may be charged in responding to these written requests; such fee will be made known to you before it is incurred.
If customers believe any of the details of their personal information is incorrect, or has changed, then Medtronic Australasia will correct the information free of charge.
6.1 Privacy Complaints or Queries
Complaints or queries about the handling of personal information should be directed in writing to Country Manager, Medtronic Australasia Pty Ltd, 97 Waterloo Road North Ryde NSW 2113.
Medtronic Australasia undertakes to respond in a reasonable timeframe to all requests and complaints.
7. Identifiers
Medtronic Australasia may collect identifiers such as Commonwealth Medicare numbers in the process of its normal business operations. However, these identifiers are only used for billing purposes and are not used as key identifiers within Medtronic Australasia.
8. Anonymity
It is possible for a customer/person to make general enquires about Medtronic Australasia products or gain access to product information without their personal information being permanently collected and stored.
9. Trans-border Data Flows
Should it be necessary to transfer personal information to a Medtronic facility overseas, Medtronic Australasia will take reasonable steps to ensure that the information, which is transferred, will not be held, used or disclosed by the recipient of the information in a manner that is not consistent with the points outlined in this policy.
10. Sensitive Information (HEALTH INFORMATION)
10.1 Collection of Health Information
Medtronic Australasia Pty Ltd receives health information from the hospitals where a patient’s treatment involving a Medtronic product has taken place. The information is collected for the purpose of billing, product registration and on-going maintenance of the product.
At implant, only data relevant to the medical procedure and the implanted device is collected as follows:
- Name, address and telephone number(s) of the patient
- Date of birth of the patient
- Health Insurer of the patient (if applicable)
- Device details, settings and test data
- Date of implant
- Implanting Physician
- Follow up Physician (if different to implanting physician)
- Hospital where implant took place
- Reason for implant (i.e. clinical condition) where applicable
During the patient’s follow up visits, on-going information on the performance and settings of the device may also be collected and held by Medtronic Australasia.
10.2 Use and Disclosure of Health Information
Medtronic holds this health information in the event that we may need to contact the patient or the patient’s physician with new information about the implanted device and for the on-going maintenance of the device.
The on-going health care of the patient is not affected by the supply of this information. However, if all or part of the data is unavailable to us, Medtronic Australasia may not be able to contact the patient or the patient’s physician should new information about the device become available.
Information gathered on the on-going performance and settings of the device may be used for trouble-shooting and/or advising the patient’s physician on the status of the device.
Apart from the uses above; the health information held by Medtronic Australasia is not disclosed to any other organization unless required to by Australian law.
10.3 Data Quality and Health Information
Medtronic Australasia endeavors to ensure that the health information collected, is complete and correct at the time of collection. However, with the passage of time the details of the information may need to be updated.
Should any of the details of the health information held by Medtronic Australasia be found to be out of date, Medtronic Australasia will correct the information.
10.4 Data Security and Health Information
Medtronic Australasia undertakes to take reasonable steps necessary to ensure that health information is secure from any unauthorized access, modification or disclosure.
Medtronic uses a mainframe computer system to hold most of its health information. This system is password secured and connected by secure communications. The information on the mainframe computer system is routinely backed up and the back up information is stored in a secure location.
Access to the health information on the mainframe computer system is restricted to those personnel who require access in order to perform their job function.
Health information on the on-going performance and settings of the devices may also be held in other secure locations within Medtronic Australasia. Access to this information is restricted to those personnel who require the access in order to troubleshoot or monitor the status of the devices.
10.5 Openness and Health Information
Patients that are registered with Medtronic will be sent a Device Registration Card that details most of the information we hold on their medical treatment. A letter is sent with the Device Registration Card that summarizes Medtronic Australasia’ privacy policy on health information. The complete Medtronic Australasia Privacy Policy will be made available on request.
10.6. Access and Correction of Health Information
Medtronic Australasia attempts to ensure that the information collected at the time of a patient’s treatment is correct. Most of the information collected is printed on the Device Registration Card. Patients are advised to inform Medtronic Australasia if any of the details are incorrect, or have changed since the time of the treatment. Medtronic Australasia will correct the information free of charge, and a new card issued.
Any additional health information held by Medtronic Australasia will be supplied to the patient upon written request. In some cases, a fee for reasonable costs incurred may be charged in responding to these written requests; such fee will be made known to the patient before it is incurred.
10.7. Identifiers and Health Information
Medtronic Australasia may collect Commonwealth or agency identifiers such as Medicare Numbers and Department of Veteran’s Affairs Numbers during a patient’s treatment; however, these numbers are used only for billing purposes and are not used as key identifiers within Medtronic Australasia.