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Australia Privacy Policy

Australia Privacy Policy

Revised March 2014

This policy sets out how St Jude Medical Australia Pty Ltd ACN 080 212 746 (SJMA) collects, holds, uses and discloses your personal information. We respect the privacy of individuals. We collect, hold, use and disclose personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988, including the applicable guidelines under the Privacy Act related to medical research.

How do we collect, use and disclose your personal information?

We collect information in a variety of ways, including through personal contact, via our Web site, telephone, through correspondence and from public sources and, where personal information is needed to identify patients, from private sources including hospitals and medical practitioners. Where we request personal information directly from you, we will generally explain the purpose of its collection and use and to whom it may be disclosed at the time that we collect it.

Why do we collect, use and disclose personal information?

We collect, use and disclose personal information necessary for and related to our business purposes, which are generally described at www.sjm.com (Business Purposes).

Our Business Purposes include:

(a) for recording and reporting on our products and related medical conditions, including:

(i) reporting to regulatory and medical authorities; and
(ii) recording and responding to product enquiries, feedback and complaints;

(b) in complying with our regulatory and legal obligations, including recording and reporting on any adverse events relating to our products;

(c) to contact you (including by way of email), including:

(i) in response to your inquiries about our products and services;
(ii) where authorised, providing you with information that we consider that you may be interested in;

(d) if you are a health care professional (HCP) collecting personal information such as your name, address, where you practice and your areas of research and practice specialisation and using or disclosing it:

(i) in connection with research and clinical trials that you are involved with or which we consider that you may be interested in being involved with;
(ii) in providing tailored or relevant information to you about our products;
(iii) in providing evaluations and/or demonstration products to you;
(iv) in connection with conferences, symposia, expert panels or other events with which we are involved or with which we consider that you may wish to be involved; and
(v) for complying with our corporate policies for expense reimbursement that require us to record the names and affiliations of attendees at events described in paragraph (iii) above; and

(e) if you are a patient, collecting personal information including your name, address, treating hospital and medical practitioner, health status and medical condition and medical device identifiers from your hospital or medical practitioners and using or disclosing that information:

(i) in connection with our patient programs including monitoring and programming devices you have received, or research and clinical trials in which you are participating;
(ii) to register and keep track of you for safety and regulatory purposes if you have received one of our implantable devices; and
(iii) to communicate with the hospital, your medical practitioner or your health insurer in relation to your care and for payments relating to our devices; an

(f) if you are an employee or contractor, to provide personal information to our related companies, principally in the United States, European Union countries, Hong Kong and Japan, in connection with your employment and our Business Purposes. This may involve those companies providing that information to third party suppliers subject to complying with obligations of confidence and with our privacy policies;

(g) where permitted by law, to protect our rights and property;

(h) to our external service providers that we engage to assist us in the conduct of our business (these service providers will only be permitted to use that information for the purpose of assisting us and we will require them to comply with our privacy policy); and

(i) to our parent company St Jude Medical Inc., which is based in the United States and our other related companies principally in European Union countries, Hong Kong and Japan for our and their Business Purposes.

We may also use and disclose personal information as authorised by you when you provide that information to us.

How can you opt out of subscriptions or from us contacting you?

If authorised, we may from time to time send you marketing material that we consider will be useful. If you do not wish to receive information from us, please notify our Privacy Officer at 17 Orion Road, Lane Cove NSW 2066 or email us at SJMAPrivacy@sjm.com.

Please note that we may be required to send certain information to you because of a legal or regulatory requirement.

Security of your personal information and how you can access and request correction of it

We usually hold your personal information in electronic form in our data bases, including in the data bases of our related companies located overseas. We may engage third party service providers to securely hold your personal information on our behalf, such as in a cloud server. We may hold some information in paper based form that will be securely held. However paper based personal information is generally converted to electronic form and the original documents securely destroyed.

We take reasonable steps to protect personal information from loss and unauthorised access, modification, disclosure or use. Data bases are protected by passwords and firewalls and only staff with appropriate authority can access your personal information. We require third party service providers to comply with our Privacy Policy and privacy requirements.

You may request access to personal information we hold about you and we will process that request within a reasonable time as required under the Privacy Act. We may charge a fee to cover the costs of verifying the application and retrieving the information requested.

If you consider that the personal information we hold about you is inaccurate, incomplete or out of date, you may ask SJMA at any time to correct that information.

Please address all requests or questions about how we deal with your personal information or this policy, to our Privacy Officer at 17 Orion Road, Lane Cove NSW 2066 or by email at SJMAPrivacy@sjm.com.

What should I do if I have a complaint about how SJMA handles my personal information?

If you consider that any action taken by us breaches this privacy policy or the Australian Privacy Principles, you can make a complaint by contacting us by email at SJMAPrivacy@sjm.com or by mail addressed to:

The Privacy Officer
St Jude Medical Australia Pty Limited
17 Orion Road
LANE COVE NSW 2066

If you are not satisfied with our response or if you consider we have breached the privacy laws, you can also complain to the Office of the Australian Information Commissioner on 1300 363 992 or at www.oaic.gov.au.

Updates to this policy

SJMA may amend this policy from time to time. An updated version can be obtained by writing to the Policy Officer at the email or street address above.