Medtronic Australasia Pty Ltd and Medtronic New Zealand Ltd
1. Commitment to Privacy
Medtronic Australasia Pty Ltd and Medtronic New Zealand Limited (hereinafter referred to “we”, “us” and “Medtronic”), are bound by the Australian Privacy Principles (“APPs”), contained in the Privacy Act 1988 (Cth). We may also be bound by State and Territory privacy laws in Australia and New Zealand (ANZ Privacy Laws). The object of the ANZ Privacy Laws is to protect the confidentiality of “personal information”, and the privacy of individuals by regulating the way in which personal information is managed.
Broadly, “personal information” means information or an opinion about an identified individual or from which an individual can be reasonably identified. Personal Information includes “health information”, which refers to information regarding an individual’s physical or mental health or a health service provided to an individual. We refer to personal information and health information in this Policy collectively as “Personal Information”.
Medtronic is committed to protecting the Personal Information it collects and regularly monitors its systems and procedures to ensure compliance with the APPs and this Policy.
This Policy outlines the way in which Medtronic deals with the Personal Information it collects in Australia and New Zealand. Medtronic complies with all data privacy laws in the region.
Medtronic collects Personal Information that is reasonably necessary for or directly related to our functions and activities as a provider of medical devices. In some cases we are required by the Therapeutic Goods Act 1989 (Cth) to collect Personal Information in order to comply with our regulatory obligations such as responding to safety concerns about our products.
Medtronic may collect Personal Information about you through our interactions with you. Where Medtronic collects Personal Information from or about you, we will inform you about the purpose and use of the collected information.
The Personal Information we collect may include:
- Your name
- Your address
- Your date of birth
- Your email address
- Your phone number
If you are a healthcare professional, additional Personal Information we may collect from you includes:
- Your medical specialty
- Your clinical interests
If you are a patient, additional Personal Information we may collect includes:
- Details of your health care professional
- Your implantation details and history
- Product performance, service and reliability data
- Any specific products you want to learn about
- Product data, such as model and usage of your device
- Credit related information
Personal Information may be collected by Medtronic in the course of:
- If you are a patient, providing technical assistance about our products to you or to your healthcare professional
- Responding to product queries
- Sales calls or follow-up meetings with our sales representatives
- Participation in Medtronic sponsored programs, including educational programs and research grants
- Using our customer or product information services
3. Use and Disclosure
Medtronic will use your Personal Information for the primary purpose for which it is collected, which generally includes the following purposes:
- In the course of the sale, distribution or provision of medical devices that have been requested by you or health care providers
- In the course of supporting your healthcare professional in your ongoing care, if you are a patient
- Administering training programs, clinical trials or other similar programs in which you agree to be involved
- Compliance with regulatory requirements, such as maintaining a record of medical queries, complaints, adverse events and recalls relating to our products
We may also use your personal information to:
- Provide you with updated product or safety information with respect to Medtronic medical devices
- Send you material on our activities and products or developments in medical technology that Medtronic believes may be of interest to you, although if you are a patient we will not do so without your consent
- Manage, plan and arrange meetings between you and Medtronic representatives
- Generate customer lists for the purposes of market research
- Manage accounts and ensure that we receive payment for our products
We will only use or disclose your personal information for a purpose that was not the primary purpose for which we collected it if you would reasonably expect us to do so or if we have your permission. We may also use or disclose Personal Information if we are required or authorised by law to do so.
If you do not wish to receive information or materials about Medtronic products and updates, you may request not to receive these marketing materials. Once Medtronic receives your request, we will add your name to a no contact list for marketing purposes.
When dealing with particularly sensitive Personal Information, such as your health information for a purpose that is not directly linked to the primary purpose of collection, Medtronic will generally seek your consent before using the health information. In only very limited circumstances, such as where required by law to disclose information or in the event of a serious threat to your life or health, will we disclose your health information without your consent.
4. Cross Border Data Transfer
As part of a group of companies located in many different countries, we may disclose some Personal Information to a Medtronic company or database overseas. The countries to which we are likely to disclose Personal Information include the United States, Singapore, Switzerland and the Netherlands. In disclosing data offshore, Medtronic ensures that the use and disclosure of the personal information transferred is dealt with in accordance with this policy and the safeguards under ANZ Privacy Laws.
5. Transfer of Data to Third Parties
Medtronic will not sell your Personal Information to any third party for any purpose. Selected third parties may be used to provide Medtronic with support services in connection with our business operations; for example, database IT support. Such third parties may, from time to time, have access to your personal information to enable them to provide those services to Medtronic.
All companies providing such support services are required by Medtronic to process the Personal Information disclosed to them only for the purposes expressly authorised by Medtronic. Further, third parties are required by Medtronic to meet our standards of data protection and comply with the safeguards under ANZ Privacy Laws.
6. Data Security
Medtronic has put in place safeguards to protect the Personal Information we hold from misuse, loss, unauthorised access, modification or disclosure. Medtronic generally holds the Personal Information you provide to us in an electronic form on computer servers, which are password protected for limited access and are located in controlled facilities. However Medtronic may also hold Personal Information in physical form, such as in paper hard copies. While Medtronic cannot guarantee against any loss, misuse or alteration to data, we take reasonable steps to prevent such occurrences.
Access to the Personal Information is restricted to those employees who need to use the data, who have been trained to handle such data properly and observe strict standards of confidentiality.
Medtronic destroys or permanently de-identifies Personal Information that we no longer need, where permitted.
7. Access, Correction and Complaints
You have the right, in most cases, to access Personal Information at any time. Medtronic takes reasonable steps to ensure that any information we hold about you is up-to-date, accurate and complete. If you wish to access or correct Personal Information we hold, or you have any questions about this Policy, please contact Medtronic’s Privacy Officer at email@example.com, setting out a full description of the request.
If you have a complaint about how we have handled your personal information or consider that we may have breached our obligations under the APPs, please write to our Privacy Officer at firstname.lastname@example.org or at:
Medtronic Australasia Pty Ltd
Attention: Privacy Officer
2 Alma Road,
Macquarie Park, New South Wales, Australia, 2113.
We will respond to your complaint within a reasonable period, usually within 30 days.
Last updated: 21 Oct 2014