Privacy Policy

---

 

Privacy Introduction

 

The Pharmacy Guild of Australia (ABN 84 519 669 143) (the Guild) is committed to best practice in managing
and protecting the privacy of personal information gathered from members and non-members in the course of
your dealings with us and ensuring the security of personal information maintained within the organisation.
We collect information from members and non-members so that we can manage our relationship with you,
communicate with you effectively and identify which of our functions and activities will best suit your
needs.

The Guild is bound by the Privacy Act 1988 (Cth) (Privacy Act) and obligations of confidentiality in
managing the collection, use, storage, and disclosure of your personal information (including any sensitive
information), as well as in managing how individuals may access and seek to correct their information,
including any personal information, which is held by us.

This Privacy Policy provides details about how the Guild collects, uses, stores, discloses and otherwise
handles your personal information. By engaging with us, visiting our website, or providing us with your
personal information, you agree to your information being collected, used, stored and disclosed on the terms
set out in this Privacy Policy.

This Privacy Policy also seeks to explain how you can access or correct the personal information we hold
about you or raise a complaint about our handling of your personal.

 

Policy Introduction: Our obligations under the Privacy Act

 

This Privacy Policy sets out how the Guild complies with its obligations under the Privacy Act. We may also
provide more specific information relating to particular products or services in our privacy collection
notices.

The Guild’s Privacy Policy has been developed to follow a ‘layered policy’ format, which means that it
offers layers of greater or lesser detail so you can read as much or little as you wish and find what you
need fast. The Privacy Policy is broken down into a number of layers, which together constitute the Privacy
Policy:

As an ‘APP entity’, the Guild is bound by the Australian Privacy Principles (APPs) in the Privacy Act which
regulate how APP entities manage personal information throughout its lifecycle, from collection, use,
storage, disclosure and disposal of your personal information, and how individuals may access and correct
personal information held about them.

In this Privacy Policy, ‘personal information’ has the same meaning as defined by section 6 of the Privacy
Act:

Information or an opinion (including information or an opinion forming part of a database), whether
true or
not, and whether recorded in a material form or not, about an individual whose identity is apparent, or
can
reasonably be ascertained, from the information or opinion.

This Privacy Policy is intended to:

• communicate the personal information handling practices of the Guild;
• enhance the transparency of the Guild’s operations; and
• give individuals a complete understanding of the types of personal information or sensitive information
  that the Guild holds, the purposes for which that personal information or sensitive information is
  collected
  and the way the Guild handles and stores that information in accordance with the Privacy Act.

In this Privacy Policy:

• “the Guild”, “we” and “us” refers to The Pharmacy
  Guild of Australia (ABN 84 519 669 143) and includes the
  National Secretariat and each of the State and Territory Branches of the Guild; and
• ‘You’ and ’your’
  refers to
  anyone (including members to whom we provide services, and non-members) who provide us with personal
  information
  in their interactions with us.

 

Information we collect

The types of personal information that we collect

The types of personal information that the Guild collects about you will ultimately depend on the types of
interactions that you have with us. The Guild typically collects some or all of the following information
which may include personal information:

• General information about you including your name, address, contact phone number, gender, date of birth,
  email address;
• Your employment details;
• Details of your professional qualifications and registration details with AHPRA;
• Your pharmacy PBS Approval Number;
• Name and registered address details for any business entity (including sole trader) that owns the
  pharmacy with which you are associated;
• Details around the size, setup, and scope of services of your pharmacy;
• Email address of each of the pharmacy owners;
• Name, email address, and pharmacist registration number (where applicable) of any authorised person for
  the pharmacy if that person is not also a pharmacy owner;
• Your training records;
• Your payment details;
• Your dietary requirements;
• Details about our interactions with you – such as your membership details, any feedback, complaints,
  responses to surveys, records of correspondence and interactions with our staff (including in person,
  online, by telephone, email and via social media).

Sensitive Information

Under the Privacy Act, certain categories of personal information are considered particularly sensitive and
therefore require additional protection. These categories include (among other things) information about an
individual’s racial or ethnic origin, political opinions, membership of political associations, religious
beliefs or affiliations, philosophical beliefs, membership of a professional of trade association,
membership of a trade union, sexual preferences or practices, criminal record, health information and
genetic information.
The Guild only collects sensitive information about you with your consent (unless we are otherwise
authorised or required by law to collect that sensitive information).

 

How we collect your personal information

It is the Guild’s usual practice to collect personal information directly from you or your authorised
representative.

We collect personal information in a number of ways, including:

• by email,
• over the telephone;
• through written correspondence;
• through the completion of forms;
• you access our products and services;
• in person interactions with you;
• through our website or social media;
• at seminars, events and functions; and
• from third parties, such as our service providers and suppliers.

There may be occasions where the Guild collects personal information about you from a third party (such as
our service providers) or a publicly available source, but only if you have consented to such collection or
would reasonably expect the Guild to collect your personal information in that way, or that use is permitted
by the Privacy Act or other legislation.

In limited circumstances the Guild may receive personal information about third parties from individuals who
contact the Guild and supply the Guild with the personal information of others in the documents provided to
us.

 

How we use your personal information

The Guild requires your personal information to be able to perform its core functions to provide services and
benefits to its members, and the community pharmacy sector more generally. The Guild only collects personal
information for purposes which are directly related to our functions or activities and only when it is
necessary for, or directly related to, such purposes. For example:

• If you are a sponsor of the Guild, we collect contact address details and information about the
  sponsorship;
• If you are a supplier to the Guild, we collect your contact and address details, billing information,
  and information about the goods or services you supply;
• If you apply for a job at the Guild, we collect the personal information included in your application
  and curriculum vitae; and
• If you are a member of the general public (who does not rely on anonymity or pseudonymity) and contact
  the Guild, depending on the nature of your enquiry, we may need to record details about you to respond
  to your enquiry.

We may also use your personal information for the following purposes:

Membership administration and management activities

• to fulfil administrative functions associated with membership, including:
  • informing prospective members, members and non-members about membership benefits and services;
  • processing membership applications and renewals;
  • conducting customer satisfaction, market research and pharmacy sector surveys;
  • conducting competitions;
  • managing and coordinating Guild elections, referendums and other matters outlined in the Guild’s
    Constitution including providing your personal information to the Australian Electoral Commission
    for the purpose of conducting elections and/or referendums on the Guild’s behalf;
  • investigating and resolving complaints about members; and
  • conducting business analysis, organising and managing data, and reporting statistical information
    about the Guild’s functions and activities.
• to populate and manage our customer relationship management tool, GEMM and maintain contact lists
  (including address, email and phone number) of individuals who may have an interest in community
  pharmacy, are involved in a pharmacy business and/or a media representative with an interest in the
  pharmacy sector; and
• receiving services from third party organisations.

Advocacy and Policy advice

• to liaise with members, non-members, prospective members, individuals, Australian State and Territory
  Government agencies and private sector organisations for the purpose of advocacy on behalf of our
  members or the community pharmacy sector generally;
• to compile statistics, analyse trends, undertake research, conduct consultations, provide advice and
  issue guidance;
• to correspond with persons and stakeholders who have an interest in health policy and issues affecting
  the community pharmacy sector;
• to consult with members, non-members and stakeholders who the Guild reasonably believes would want to be
  consulted about an issue relating to the community pharmacy sector;
• to research, analyse and advocate on policy issues relating to the community pharmacy sector;
• to record details of your communication and educational activities, such as contact with the media,
  speeches, event management, surveys and publication preparation.

Administration and management of community pharmacy programs and services

• Administration and management of the following:
  • Programs relating to community pharmacy authorised with the Australian Government and/or State and
    Territory Governments;
  • Vaccination programs for corporate and government clients managed by the Guild;
  • Guild Learning and Development continued professional development programs;
  • Promote and deliver training and learning and development services.

Events and Marketing

• to record events attended by Guild representatives and contacts made at such events;
• marketing and distributing member services, publications and events;
• informing you about our activities, events, facilities and services, and distributing newsletters and
  publications to your subscribed email addresses.

 

Collection of information through our website

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period
of time. There are several methods and packages that the Guild uses to collect information on the web
traffic to each of our online platforms, including the following:

• Google Analytics
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting

It is the Guild’s usual practice to collect information about all visitors to our online resources, including
our websites. The information collected includes:

• server and IP address (the electronic addresses of computers connected to the Internet);
• top level domain name accessed (for example .com, .gov, .au);
• the date and time of your visit to our website;
• the duration of your visit to our website;
• the pages you accessed and documents downloaded during your visit;
• the previous site you visited;
• if you have visited our site before; and
• the type of browser used,

The Website Analytics Information is used to identify your generic behavioural patterns, analyse trends, to
customise and improve user website experience, report statistics, track user movements, gather broad
demographic information, website administration and maintenance purposes and to target and improve the
quality of the Guild’s products and services.

The Website Analytics Information collected is not personal information and the Guild does not use this
information to personally identify any individual. Cookies used on our websites do not and cannot infiltrate
a user’s hard drive to gather personal information stored on that user’s hard drive.

Information and data collected through Google Analytics is stored by Google on servers in Belgium, Chile,
Denmark, Finland, Ireland, Singapore, Taiwan and the United States of America.

You can opt out of the collection of information via Google Analytics by downloading the Google Analytics
Opt-out browser add on. You can also use the settings in your browser to control how your browser deals with
cookies. However, in doing so, you may limit the functionality of our website and be unable to access
certain pages or content on our website.

The Guild will, on occasion, use third party platforms to deliver information to Guild members, subscribers
and stakeholders. These third-party platforms are sites hosted and managed by organisations other than the
Guild. Before deciding if you want to contribute to any third-party site, please read their privacy policy
in the first instance

 

Use and disclosure of your personal information

The Guild only uses personal information for the purposes for which it was given to the Guild, or for
purposes which are related to one of the Guild’s functions or activities. The Guild does not give your
personal information to other organisations, government agencies, or anyone else without your informed
consent unless one of the following exceptions applies:

• we believe you would reasonably expect, or have been told, that information of that kind is usually
  passed to those individuals, bodies or agencies;
• the disclosure will prevent or lessen a serious and imminent threat to somebody’s life or health; or •
  the disclosure is otherwise required or authorised by law.

You acknowledge that where we disclose your personal information to a third party service provider, that
third party service provider may in turn use or disclose your personal information as is authorised or
required by law.

 

Use and disclosure of your personal information for direct marketing

We may use or disclose your personal information for the purpose of marketing, informing you about our
services, upcoming promotions, training and events, or other opportunities that may interest you. If you do
not want to receive direct marketing communications, you can opt-out any time by:

• advising us if you
  receive a marketing call that you no longer wish to receive these calls; or
• using the unsubscribe facility
  that we include in all of our marketing communications to opt-out of receiving those messages.

If you opt-out of receiving marketing material from us, we may still contact you in relation to our ongoing
relationship with you.
We will not disclose your personal information to third parties for marketing purposes without your consent.

Disclosure of your personal information to third parties

We may be required to disclose your personal information to third parties where necessary to perform our
activities and functions. Examples include disclosure to the following third-party contactors and service
providers:

• financial institutions or payment processing platforms;
• universities;
• Australian Electoral Commission;
• our member benefits partners and sponsors; and
• our third-party contractors including:
  • conference organisers;
  • information technology services and support;
  • marketing and communication agencies;
  • mailing houses, freight and courier services;
  • printers and distributors of direct marketing material; and
  • external business advisers.

We do not give your personal information to other organisations, agencies, or individuals unless:

• (a) you (or your authorised representative) have consented for us to do so;
• (b) you (or your authorised representative) have consented to, or in our assessment may reasonably
  expect, that information of the kind provided will be given to a third party as a matter of standard
  practice; or
• (c) the Guild is obligated or authorised by law to do so.

Where reasonably practical, or where the provision of information to third parties is in our assessment
outside the scope of the purposes outlined above, we will provide you with advance notification of, and
obtain your informed consent to, the proposed disclosure.

 

Data quality and security

The security of your personal information (and sensitive information) is important to us.

The Guild’s websites are hosted in Australia. If you choose to provide us with your personal information
(and sensitive information), you are consenting to the collection, use, disclosure of personal information
in the manner outlined in this Privacy Policy and the storage of that personal information on our servers
located in Australia.

The personal information (and sensitive information) provided to us is stored in electronic databases. In
some instances, information may also be stored in physical paper-based files held in locked facilities and
in appropriate circumstances archived and stored offsite.

The Guild takes reasonable steps to ensure your personal information is stored securely and protected from
loss, unauthorised access, use, modification or disclosure, interference and misuse. These steps include:

• using login, password protection and encryption, web-filters, firewalls and anti-virus software;
• securing paper files in locked cabinets;
• secure office access;
• using secure payment gateways for the processing of payments;
• using encryption technology to protect data when it is being transferred, and also once it is stored by
  us;
• access to personal information is restricted to personnel who require that information to perform their
  assigned roles;
• personnel security and training on privacy and confidentiality;
• our GEMM customer relationship management database maintains an audit trail whenever personal
  information is amended or made inactive. The GEMM database does not allow the users to delete records.
  This allows us to maintain an ownership and membership history which is critical to our functions and
  operations.

Where we are required to retain your personal information for our historical records or for archival
purposes, we do so in accordance with legislation. In circumstances where we no longer require your personal
information for any of our purposes, and where we are not required to retain it by legislation, we will
destroy your personal information in a secure manner.

While the Guild endeavours to protect the personal information and privacy of website users, we cannot
guarantee the security of any information that you disclose online. You disclose that information at your
own risk. If you are concerned about sending your information over the internet you can contact the Guild.
If we have given you (or you have chosen) a password which enables you to access certain parts of our
websites, you are responsible for keeping this password confidential and for complying with any other
security procedures notified to you and not to disclose that password to anyone else.

 

Overseas transfer of personal information

As at the date of this Privacy Policy, we do not disclose your personal information to overseas recipients.

If in future we do propose to disclose your personal information overseas, we will do so in compliance with
the requirements of the Privacy Act. We will, where practicable, advise you of the countries in which any
overseas recipient is likely to be located.

 

Access to, and correction of, your personal information

The Guild takes reasonable steps to keep the personal information it collects accurate, up to date and
complete. These steps include maintaining and updating personal information when the Guild is advised by
individuals that their personal information has changed, and at other times as necessary.

If you request access to the personal information that we hold about you, or request that we change that
personal information, the Guild will allow access or make the requested changes unless the Guild considers
there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make
the requested change. To correct and update your personal information please contact us at the details
provided below.

If we refuse your access or correction request, we will provide you with a written notice setting out the
reasons for our refusal and how you can make a complaint to the Office of the Australian Information
Commissioner.

 

Making a complaint about the handling of your personal information

You may contact us at any time if you have any questions, concerns or complaints about this Privacy Policy,
or about the way in which your personal information is handled. Please address any complaint about privacy
to the National Secretariat Privacy Officer via:

• email to: guild.nat@guild.org.au
• phone our reception on: 02 6270 1888;
• by mail to: PO Box 310 Fyshwick ACT 2609

We take all complaints seriously, and will respond to your complaint within a reasonable time.

In addition, we have set out below contact details for each of the Guild Branches should you wish to contact
them about the handling of your personal information in accordance with the Privacy Policy.

If you are not satisfied with our handling of your complaint, you may contact the Office of the Australian
Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992, by email
enquiries@oaic.gov.au or by using the contact details on the OAIC website.

Contact details for the Guild Branches

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect our current data collection and disclosure
practices, with or without notice to you. The most recent version of our Privacy Policy is available on our
website. We recommend that you visit our website regularly to keep up to date with any changes to this
Privacy Policy.

This Privacy Policy was last updated October 2020.