PRIVACY POLICY

1.1 Objective

N of One recognises the importance of privacy and is committed to the management and handling of Personal Information in an open and transparent way. N of One is required to comply with the Australian Privacy Act 1988 (Cth) (Privacy Act) and this policy creates a framework to ensure that any Personal Information N of One holds is collected, used, stored and disclosed in accordance with the Australian Privacy Principles in the Privacy Act.

 

1.2 Scope

This Privacy Policy documents the handling of Personal Information by N of One Pty Limited (N of One). This policy does not apply to the handling of Personal Information about N of One employees.

 

1.3 Regulatory Environment

As a healthcare company which deals with Personal Information and Sensitive Information, N of One has an obligation to respect the privacy of individuals and to follow the Australian privacy laws, which include:

• the Privacy Act 1988 (Cth) (as amended from time to time);

• the National Privacy Principles contained in Schedule 3 to the Privacy Act or wher applicable, the Australian Privacy Principles contained in Schedule 1 of the Privacy Act;

and

• all other applicable laws that require a person to observe privacy or confidentiality obligations in respect of Personal Information;​​

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Section 1:

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1.1 Personal Information Collected and Held by N of One

 

N of One may collect and hold information about individuals who may be customers, members of

the general public, job applicants, business contacts, healthcare professionals and others.

The information N of One typically collects and holds includes:

 

General Public

Much of the information collected and held by N of One about you will be de-identified.

Information held by N of One about members of the public could include:

• Your name, relevant address, telephone number(s) and email address

• Any dealings you may with N of One, including product enquiries or complaints, Adverse

• Event reporting, and enquiries to N of One’s 1800#s

• Information relevant to your participation in medication access and support programs managed by N of One, including information collected via MedAx platform

• Information relevant to your participation in N of One run conferences or other educational events, including information collected via Virtual Patient in Practice platform

• Information obtained when you access N of One ’s website

• Job Applicants

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The types of Personal Information N of One collects from job applicants, including contractors, may include:

• Employment history

• Education and Qualifications

• Information relating to credentialing of health professionals

• Opinions about suitability for employment from referees and previous employers

• Taxation, superannuation and banking details

• Information from public domain and social media websites

• Information obtained when you access N of One ’s website

• Residential address

• Copies of Identification documents – drivers licence and/or passport

• Name and contact information for next of kin

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Applicants for employment and/or contract roles have the right to not disclose Personal Information, however N of One may not be able to assess a candidate’s suitability for employment when it does not receive all necessary information.  N of One will only disclose the Personal Information of job applicants to third parties with the consent of the job applicant, or as otherwise permitted in limited circumstances by law.

Once a position has been filled, all applications received by N of One are filed and kept by the recruitment manager in the human resources team.

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Business Contacts

• Your name, business address, business telephone number(s) and email address

• Dealings with N of One in respect of general business relationships

• Work, professional and employment references, reports and assessments

• Information from public domain websites

• Information obtained when you access N of One ’s website

 

Healthcare Professionals

• Your name, practice location, business telephone number(s) and email address

• Professional credentials and other details, including AHPRA numbers and College CPD number, years in practice

• Practice specialty including areas of interest

• Treatment site affiliation (hospital) and contact information

• Membership of professional associations

• Practice and/or business information including, where applicable, interest in N of One products

• Information relating to your patients, following Adverse Event reporting, product complaints or Medical Information line enquiries

• Information relating your participation in N of One-sponsored or supported clinical trials, conferences or other educational events

• Information from public domain websites

• Information obtained when you access N of One ’s website

• Survey and demographic information

• Survey and aggregate clinical practice information (e.g. number and type of patients

• treated)

• • Standard sales call information - who we connected with, date of the call, the call

• outcome, call duration and call notes

• • Sales data from IMS, wholesalers, or a Pharmacy point-of-sale system.

 

Patients

Data collected will vary by programme, but can include:

• Name

• Home address

• Mobile phone number

• Email address

• Age

• Gender

• Diagnosis

• Treatment information (drug, date of initiation, dose, duration/discontinuation)

 

Adverse Event Reporting

N of One is required to report Adverse Events to its clients relating to client medicines. In some

cases, this information may then be transmitted in a de-identified manner to regulatory authorities

and to client affiliates based outside of Australia. The following information is collected and used

to fulfil these reporting requirements:

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• Identifiable patient information is required for an Adverse Event report to be validated, however only patient initials OR age OR gender is required.

• Where Adverse Event reports require submission to local regulatory health authorities or to an in-licensed partner/distributor, a de-identified CIOMS-I form is used to collect and transmit the information (refer to section 2.4 for additional information).

• Suspect Drug Information (name, strength, dosage, route of administration, therapy start and end date, indications for use).

• Adverse Event details (date started/ended, outcome, causality).

• Concomitant medications (if any)

• Medical conditions (if available)

• Name, profession, institution name and contact details of person reporting the Adverse Event. If the Adverse Event is reported by a patient, personal details are de-identified and contact details are withheld unless authorised to complete a follow-up, in which case the contact details are retained until they are no longer needed, at which time they are permanently deleted.

 

1.2 How Will N of One Collect Your Personal Information

Wherever possible, N of One will collect Personal Information about you directly from you.

Nevertheless, on some occasions N of One may collect your Personal Information from other

sources, such as:

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• Third party agents or service providers such as data providers and customer relationship management service providers

• Public domain websites on the Internet

• Electronic communications such as articles and information pieces in which you feature such as a health information site or a medical professional site

• Publicly available directories and listings such as telephone directories or AHPRA records

• Newspapers, magazines, professional journals and the electronic media

• The date, time and domain from which you access N of One ’s website

• Personal interactions and/or communications with N of One employees and/or contractors

• Databases purchased from an external provider

• Healthcare professionals reporting submitting an adverse event report

 

Personal information about you which N of One collects and holds may vary depending on your

particular interaction with N of One and will be for a legitimate business purpose. N of One will

not collect Sensitive Information about you, such as information about your health or ethnicity

without your consent.

 

1.3 Collection of Your Personal Information Through N of

One ’s Website

N of One ’s website provides for direct input of Personal Information under some circumstances.

In addition, N of One ’s website makes use of ‘cookies’ which are small text files that are stored

in the visitor's local browser cache. This enables recognition of the visitor's browser to optimise

the website and simplify its use. Most browsers are set up to accept these cookies automatically,

however you can deactivate the storing of cookies or adjust your browser to inform you before

the cookie is stored on your computer. Data collected via cookies will not be used to determine

the personal identity of the website visitor.

N of One expects to increasingly makes use of web analytics, including analysis by third party

service providers, which may use IP addresses. While this may in some circumstances be

‘Personal Information’ neither N of One nor the service providers have any interest in an

individual’s browser activities and will not use the information to take any action targeted to

individuals without having obtained that person’s consent.

 

1.4 How Will N of One Hold and Use Your Personal Information Customer Relationship Management (CRM) Software

 

• Information relating to healthcare professionals and third parties with which N of One conducts business will be held on N of One ’s customer relationship management (CRM) software platform. This information will be accessed and used in the ordinary course of conducting business, including but not limited to communicating with you, order processing and fulfilment, accounting, responding to enquiries or complaints.

• Information relating to third parties with which N of One conducts business will be used to facilitate the provision of products and services to N of One.

• Where healthcare professionals or other N of One customers have opted in via completion of a consent form, or request via email, N of One may use your information to communicate with you in the future about programmes or events which may be of interest to you.

• N of One may also use this information to contact HCPs on behalf of N of One customers, including to send them product specific information.

• Information will also be aggregated and used on a de-identified basis for business intelligence/market insights.

• Medical Information/Adverse Event Reporting Database Information relating to adverse events is initially documented on N of One ’s platform and is then transcribed into a form for communication to the relevant N of One customer.

• N of One maintains a hard copy of all source documents relating to Medical Information/Adverse Events.

 

Patient Data

Patient data is used to administer patient programmes, including Patient Support Pogrammes

and Product Familiarisation Programmes, which may involve:

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• Direct communication with the patient via phone or email to provide information related to the programme

• Direct shipment of drug to the patient’s home (as directed by a patient’s medical practitioner)

• Home visits by nurses to provide education or initiation training to patients.

• In the course of administering these programmes, N of One may share patient information on a need-to-know basis with:

• N of One contract nurse teams who provide in-home/phone-based support

• Pharmacy responsible for dispensing or shipping treatment

• Other third parties (with patient consent). By way of example, N of One may be managing

• a Product Familiarisation Programme and the patient enrolment form includes an opt-in

• for a Patient Support Programme managed by another service provider.

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Other Use and Disclosure

• Where relevant, information will be used for Medicines Australia Code of Conduct reporting requirements.

• Where you are participating in a Patient Familiarisation Programme or Patient Support Programme, we will use your information to confirm registration with the PFP programme and/or online portal and to provide programme updates – drug dispatch, patient discontinuation, adverse event reporting follow-up.

 

N of One may disclose information about you in the course of any of the uses described above,

including to related businesses and third-party service providers for routine business purposes

such as order delivery, marketing, hosting, data processing and validation, data storage or archiving, printing and mailing. N of One will use only reputable service providers and will ensure that it enters into appropriate contractual provisions with service providers to safeguard your privacy.

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Should N of One now or in the future use a third-party Customer Database Provider to supply it with a syndicated database of healthcare professionals and their practices, N of One will be required to keep the database updated and may disclose some information about healthcare professionals and their practices to its Customer Database Provider. This information will be limited to professional information about healthcare professionals and their practices. The information is used for commercial purposes and the Customer Database Provider makes that information available to all parties who also have access to its database, including pharmaceutical companies other than N of One .

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Should N of One in the future buy or sell (or propose to buy or sell) all or part of its business, N of One may disclose your Personal Information to a third party, as customer information is generally regarded as a business asset.

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N of One will otherwise only disclose Personal Information about you to a third party where

required by law.

 

1.5 Overseas Recipients

N of One conducts business for customers who have a global presence and are headquartered

in jurisdictions outside of Australia. Information held by N of One about you may in some

circumstances be collated, de-identified and transferred to overseas partners.

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Section 2:

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2.1 Data Security

N of One uses technical and organisational security precautions to protect your data from

misuse, interference or loss and from unauthorised access, modification or disclosure.

Any Personal Information that is provided to N of One by you through N of One ’s systems will be

encrypted in transit to prevent its possible misuse by third parties. N of One ’s security

procedures are continuously revised based on new technological developments.

In the event of an actual or suspected data breach, N of One will follow the procedures outlined

in its Data Breach Response Plan, including

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• containing the data breach

• conducting a risk assessment to assess the severity rating of a suspected or known data breach

• assessing whether an Eligible Data Breach has occurred.

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If an Eligible Data Breach has occurred, N of One may report the data breach to third parties such as:

• N of One ’s financial services provider

• police or law enforcement bodies

• the Australian Securities & Investments Commission (ASIC)

• the Australian Taxation Office (ATO)

• the Australian Transaction Reports and Analysis Centre (AUSTRAC)

• the Australian Cyber Security Centre (ACSC)

• the Australian Digital Health Agency (ADHA)

• the Department of Health

• State or Territory Privacy and Information Commissioners

• professional associations and regulatory bodies

• insurance providers.

N of One will contact you if you have been personally impacted by an Eligible Data Breach.

 

2.2 Data Retention

N of One will delete from its records Personal Information which is no longer required.

If N of One is required to retain Personal Information (e.g. Adverse Event records), then

wherever practicable, it will be held in a de-identified form.

 

2.3 Data Access and Correction

 

You may request access to Personal Information N of One holds about you at any time. If you believe your Personal Information is inaccurate, out of date, incomplete, irrelevant or misleading, you may request to have it corrected.

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Requests to access or correct Personal Information should be sent to the Privacy Officer. Please provide as much detail as possible to assist in the location of information N of One may be holding about you, such as your name, contact details, any former name(s), and if possible the context, for example, your relationship with N of One . Please specify if you are seeking access to specific Personal Information. N of One will respond to your request within 30 days of receipt or within any further time notified to you in writing.

 

2.4 Deletion of Data

You may notify N of One at any time if you do not wish N of One to retain your Personal

Information. N of One will comply with all such requests wherever practicable and lawful.

 

2.5 Complaints

All complaints regarding your Personal Informational should be made in writing to N of One ’s

Privacy Officer.

 

N of One will respond to your complaint within 30 days of receipt of your correspondence or

within any further time notified to you in writing.

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If you are not satisfied with the outcome of the response you receive, we can refer you to the

Office of the Australian Information Commissioner (as applicable) for further investigation.

 

2.6 Privacy Officer contact information

All requests relating to access, correction or deletion of Personal Information, or any other

information relating to N of One ’s Privacy Policy should be made in writing to: info@nof1solutions.com.au