Sanofi-Aventis Australia Pty Ltd trading as Sanofi, Sanofi Genzyme and Sanofi Pasteur, Sanofi-Aventis Healthcare Pty Ltd and Sanofi-Aventis New Zealand Limited (together referred to as “Sanofi”) are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) for Australia as well as the Privacy Principles contained in the Privacy Act 1993 for New Zealand (together referred to as the “Principles”). The Principles define personal information as information or an opinion relating to an individual which can be used to identify that individual (such as name, address, telephone number, email address), and are designed to protect the confidentiality of personal information and the privacy of individuals by regulating the way personal information is managed.
Sanofi is a leading Australian and New Zealand company operating as part of the international Sanofi Group. Sanofi is in the business of researching, developing, manufacturing and marketing pharmaceutical, consumer health care, rare disease and vaccine products. As a matter of conducting its routine business, Sanofi may collect the following types of personal (including sensitive and health) information:
a. Consumers and Patients
Sanofi obtains personal information from patients and members of the public in various ways including in writing, the internet, social media and telephone enquiries. The type of information Sanofi collects includes a person's name, address and contact details, and information relating to the enquiry. Sanofi may also collect information about the patient or consumer's current and past medical status, such as medications being taken, the names of the patient’s doctors, medical procedures undergone and other information that is reasonably required to properly respond to an enquiry.
Collecting this personal information is necessary to enable Sanofi to deal with the enquiry and may be necessary to allow us to meet any legal or regulatory obligations.
On occasions, health professionals disclose personal and health information about themselves and their patients to Sanofi when it is considered necessary in relation to the treatment of a patient.
b. Patient Support and Information Programs
c. Healthcare Professionals and their Employees
Sanofi collects personal information about healthcare professionals and their employees or assistants, such as doctors and pharmacists, who prescribe and dispense Sanofi products, to enable it to deal with those health professionals.
Sanofi may also collect personal information about healthcare professionals for the purpose of reporting any transfer of value provided to them by Sanofi (refer to Section 2 for more details about what is collected and disclosed)
When you look at a Sanofi operated website, our Internet Service Provider may log a record of your visit and collect the following information for statistical purposes:
In the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect our parent company’s Internet Service Provider's logs.
Sanofi may collect your email address if provided by you. Your e-mail address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent.
Google Analytics Demographics and Interest Reporting have been enabled on some Sanofi operated website and as a result personal information about users such as age, gender and interests may be collected. Such information will only be used or disclosed for the purpose of better understanding users and identify how experience and interaction can be improved and will not be used or disclosed for any other purpose without your consent.
e. Information Collected from Clinical Trials
At times patients participate in clinical trials of pharmaceutical or consumer products in order to further research and development of certain drugs or health services. In doing so, patients may provide personal information to the doctor or investigator conducting the clinical trial.
However, personal and health information collected by doctors and investigators conducting clinical trials is not generally provided to Sanofi. Sanofi receives the information relating to a clinical trial patient's health and pharmaceutical needs in a de-identified form. Personal information such as the patient's name and address is not provided to Sanofi.
On occasions people employed by Sanofi, or contractors working on behalf of Sanofi, may access this personal information at the source of collection for the purpose of verifying data.
Sanofi collects personal information about the doctors and investigators conducting clinical trials and people who assist them. In general, the type of information Sanofi collects includes the name, address, telephone details, field of expertise, position, role in study and qualifications and includes information provided on Curriculum Vitae and Financial Disclosure Forms. Sanofi may use such information worldwide to pursue its business. In particular, Sanofi is required to obtain comprehensive information about potential or actual investigators in order to maintain quality clinical trials and consistently meet global regulatory and compliance guidelines. Some of the information collected may be stored and used overseas.
f. Direct Marketing
Sanofi may also collect personal information to direct market to you about our products or services that may be of interest to you via telephone, email or fax. Sanofi will only direct market to you where we have your implied or express consent as required under the Principles.
You may opt-out of receiving direct marketing from Sanofi at any time by contacting the Privacy Officer using the contact details below.
The Principles generally require Sanofi to use personal information only for the primary purpose for which it is collected, or for secondary purposes that are related to the primary purpose. In general, Sanofi uses personal information for the following purposes:
Sanofi discloses personal information to third parties, including its associated companies, within or outside of Australia or New Zealand, including but not limited to: France, USA, Singapore and Japan to help Sanofi improve its pharmaceutical, consumer healthcare, rare disease, vaccine and health services. Information may also be disclosed to regulatory authorities and ethics committees as part of a clinical trial evaluation, monitoring or inspection process. Sanofi will also disclose personal information to its affiliate in Malaysia for the purposes of processing invoices and accounts.
Sanofi may also use your personal information to comply with its transparency obligations under the Medicines Australia Code of Conduct 18th edition (“Code”). Sanofi is required under the Code to publish a report of all transfer of values given to Australian healthcare professionals including the name of the recipient healthcare professional, the type of healthcare professional, their principle practice address, the value given and the associated activity. Sanofi will only disclose the personal information associated with transfers of value where there is express consent or a reasonable expectation to do so. For more information about what information will be disclosed and how, please visit the Medicines Australia FAQ page on transparency.
Generally, we require that third party service providers engaged by Sanofi who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with the Principles and this Policy.
In most cases, if you do not provide information about yourself which Sanofi has requested, Sanofi may not be able to provide you with the relevant service or information required.
Sanofi keeps personal information for as long as it is reasonably necessary for the purpose of collection and unless a longer retention period is required or allowed by law or to fulfil regulatory obligations. At collection, Sanofi may inform you of the intended length that we will hold your information for. If you would like to have specific information regarding the length of time your personal information is stored for, please contact the Sanofi Privacy Officer, using the contact details below.
Some personal information collected by Sanofi is considered “sensitive”. Sensitive information which Sanofi may collect includes a person’s state of health and medical history.
The Principles require that sensitive information is used and disclosed only for the purposes for which it was provided, or a directly related secondary purpose, unless you agree otherwise or for other specific reasons such as if the use or disclosure of this information is required by law or to prevent a serious and imminent threat to life or health of an individual.
Sanofi may also collect information in an aggregate or de-identified format which cannot be used to identify a particular individual. Aggregate information may include pooled information about the type of visitors accessing the website this Policy is linked to.
Sanofi’s interactions with you are also regulated by the Spam Act 2003 in Australia and the Unsolicited Electronic Messages Act 2007 in New Zealand. In compliance with these Acts, Sanofi will not send you a commercial electronic message to you unless permitted.
Sanofi has appointed a Privacy Officer to oversee Sanofi’s management of personal information in accordance with this Policy and the Principles.
All data that is collected is held electronically on password protected systems. Personal information is only accessible by persons that require access to that information to carry out their work. Sanofi has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure from unauthorised access or disclosure.
Sanofi endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. Please contact Sanofi if you believe that the information Sanofi holds about you requires changing or becomes out-of-date. Sanofi's contact details are set out below.
If you believe that Sanofi has breached the Principles you may complain in writing to our Privacy Officer (see contact details below). Sanofi will respond within thirty (30) days and will use its best endeavour to resolve the issue.
If you are unsatisfied with Sanofi’s answer, you may take your complaint to the Office of the Australian Information Commissioner as detailed on http://www.oaic.gov.au/privacy/privacy-complaints or to the Office of the Privacy Commissioner for New Zealand as detailed on http://www.privacy.org.nz/your-privacy/how-to-complain/.
As a convenience to our visitors, our sites currently contain links to a number of other (non-Sanofi) sites that we believe may offer useful information. The Policy presented here does not apply to those sites. However, Sanofi will endeavour to link to on-line resources that are known to abide by the Principles. You should contact these sites directly for information on their privacy policies and personal information collection/usage procedures.
Sanofi-Aventis Australia Pty Ltd
Talavera Corporate Centre
Building D, 12-24 Talavera Road
Macquarie Park NSW 2113
This Policy was last updated on 27 February 2016